Key point 13-02.1. In the Smith case (1990) the Supreme Court ruled that a neutral law of general applicability is presumably valid and need not be supported by a compelling government interest to be consistent with the First Amendment, even if it interferes with the exercise of religion.
Key point 13-02.2. Congress enacted the Religious Freedom Restoration Act to prevent the government from enacting any law or adopting any practice that substantially burdens the free exercise of religion unless the law or practice is supported by a compelling government interest. The compelling government interest requirement applies to any law, including neutral laws of general applicability. The objective of the Act was to repudiate the Supreme Court's decision in the Smith case (1990) in which the Court ruled that neutral laws of general applicability that burden the free exercise of religion do not need to be supported by a compelling government interest in order to satisfy the First Amendment. In 1997, the Supreme Court ruled that the Act was unconstitutional. However, other courts have limited this ruling to state and local legislation, and have concluded that the Act continues to apply to federal laws.
A New York court ruled that a married couple that owned a farm that was open to the public for weddings and other special events violated a state law banning discrimination based on sexual orientation by places of public accommodation when they refused, on religious grounds, to let a same-sex couple marry at the farm. A married couple owns a 100-acre farm. The farm was registered under state law as a limited liability corporation, but it is not a nonprofit or religious entity. In addition to harvesting and selling various crops to the public, the owners rent portions of the farm to the public as a venue for, among other things, wedding ceremonies and receptions. It hosts both religious and secular wedding ceremonies on the farm. When providing a venue site, the couple offers several wedding-related event services, including transportation of guests within the premises, a light beverage station, decoration and setup services, flower arrangements, and event coordination. Such services are provided primarily by the couple themselves.