The First Amendment specifies that "Congress shall make no law … prohibiting the free exercise [of religion]." This language generally is referred to as the "free exercise clause." The free exercise clause remained a dormant provision of the Bill of Rights for nearly a century and a half following its adoption. This was based largely on two factors. First, Congress seldom if ever took any action that interfered with the exercise of anyone's religion. Second, in its first decision interpreting the free exercise clause, the Supreme Court ruled in 1878 that while federal laws "cannot interfere with mere religious belief and opinions, they may with practice."[40] Reynolds v. United States, 98 U.S. 145, 166 (1878). The Court upheld the bigamy ...
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