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For the past 36 years, since I became a member of the Ethiopian Zion Coptic Church in 1970, I have been denied the right to use marijuana as my sacrament.  During that time, and previous to it, the courts have consistently relied on the findings of Congress supporting the prohibition of marijuana in the Controlled Substance Act of 1970 as sufficient proof that Congress intended to prohibit the sacramental use of marijuana (something which Congress did not contemplate at the time it passed the Controlled Substances Act in 1970).

In Town v. State ex rel. Reno, 377 So. 2d 648 (Fla. 1979), at page 649, the Florida Supreme Court wrote:

the trial court expressly found that: (1) the Ethiopian Zion Coptic Church represents a religion within the first amendment to the Constitution of the United States; (2) the "use of cannabis is an essential portion of the religious practice”

Further, the Ethiopian Zion Coptic Church is not a new church or religion but the record reflects it is centuries old and has regularly used cannabis as its sacrament

I was living with Jacquelyn Town and her husband Clifton Middleton, United States v. Middleton, 690 F.2d 820, 825 (11th Cir. 1982), cert. denied, 460 U.S. 1051 (1983) (Middleton hereafter), at the time that ruling was made.

There has now been a notable change in United States law to the protection of religious freedom in the ruling by the United States Supreme Court in Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal, 163 L. Ed. 2d 1017; 2006 U.S. LEXIS 1815; 74 U.S.L.W. 4119 (February 21, 2006) (UDV hereafter), which reverses the United States Supreme Court’s prior ruling in Employment Div., Dep’t of Human Services of Oregon v. Smith, 494 U.S. 872 (1990) (Smith hereafter) (that religious believers may not obtain exemptions to religion-neutral laws of general applicability that infringe on their religious practices).

In Smith, the United States Supreme Court considered the sacramental use of peyote by members of the Native American Church and concluded it would not apply the “compelling interest” test it had previous established in Sherbert v. Verner, 374 U.S. 398 (1963) and Wisconsin v. Yoder, 406 U.S. 205 (1972).

In Smith, Justice Scalia wrote:

If the "compelling interest" test is to be applied at all, then, it must be applied across the board, to all actions thought to be religiously commanded.  Moreover, if “compelling interest" really means what it says (and watering it down here would subvert its rigor in the other fields where it is applied), many laws will not meet the test.  Any society adopting such a system would be courting anarchy, but that danger increases in direct proportion to the society's diversity of religious beliefs, and its determination to coerce or suppress none of them.  Precisely because "we are a cosmopolitan nation made up of people of almost every conceivable religious preference," Braunfeld v. Brown, 366 U.S., at 606, and precisely because we value and protect that religious divergence, we cannot afford the luxury of deeming presumptively invalid, as applied to the religious objector, every regulation of conduct that does not protect an interest of the highest order.

The rule respondents favor would open the prospect of constitutionally required religious exemptions from civic obligations of almost every conceivable kind – [… other citations omitted …] drug laws, see, e. g., Olsen v. Drug Enforcement Administration, 279 U. S. App. D. C. 1, 878 F. 2d 1458 (1989) [… other citations omitted …]. The First Amendment's protection of religious liberty does not require this.

During the same week that Smith was decided, the United States Supreme Court denied certiorari to Carl Eric Olsen, an Ethiopian Zion Coptic priest appealing the denial of a DEA exemption for the sacramental use of marijuana; Olsen v. Drug Enforcement Admin., 495 U.S. 906; 110 S. Ct. 1926; 109 L. Ed. 2d 290 (1990) (Olsen hereafter).

In response to the ruling in Smith Congress enacted the Religious Freedom Restoration Act of 1993 (“RFRA”). 42 U.S.C. § 2000(b)(b)(2004). This law provides that government action that substantially burdens religious exercise is invalid unless it is justified by a compelling government interest and is the least restrictive way to achieve that interest. In City of Boerne v. Flores, 521 U.S. 507 (1997), the United States Supreme Court struck down RFRA as applied to the states on the grounds that it exceeded Congress’ power over states. RFRA continues to apply to actions by the federal government.

Congress has also enacted the Religious Land Use and Institutionalized Persons Act of 2000 (“RLUIPA”), 114 Stat. 804, which imposes, among other things, a requirement on states that in most circumstances burdens on religion through land use regulation and burdens on the religious exercise of prisoners must, as with RFRA, be justified by a compelling government interest and through the least restrictive means.

The Supreme Court upheld a constitutional challenge to the prisoner-rights portion of RLUIPA in Cutter v. Wilkinson, 125 S. Ct. 2113 (2005), finding that the law’s protection of inmate religious rights did not violate the Establishment Clause. In Cutter, the Court emphasized that there is a long tradition in the United States of accommodating religious practice through laws such as RLUIPA, and the fact that a law may provide exceptions to general rules for religious reasons but not other reasons does not render it invalid.

In Olsen at pages 1463, 1464, and 1465 (D.C. Cir. 1989) Justice Ginsburg wrote:

In sum, we conclude that the DEA cannot accommodate Olsen's religious use of marijuana without unduly burdening or disrupting enforcement of the federal marijuana laws.  We therefore hold that the free exercise clause does not compel the DEA to grant Olsen an exemption immunizing his church from prosecution for illegal use of marijuana.

We agree that the vast difference in demand for marijuana on the one hand and peyote on the other warranted the DEA's response to Olsen's petition.  Were the DEA to consider a marijuana exemption, equal protection (and/or the establishment clause, see supra note 5) would indeed appear to command that it do so evenhandedly.

While we rest our decision on the immensity of the marijuana control problem in the United States, we note some further distinctions.  The peyote exemption was accorded to the Native American Church for a traditional, precisely circumscribed ritual.  In that ritual, the peyote itself is an object of worship; for members of the Native American Church, use of peyote outside the ritual is sacrilegious.

True, for purposes of the exemption requested, Olsen narrowed the permission he sought to track the one accorded the Native American Church.  See Memorandum of Court-Appointed Amicus Curiae in Support and on Behalf of Petitioner Carl E. Olsen at 29-30 (submitted to DEA on remand).  But "narrow" use, concededly, is not his religion's tradition.

Since Smith, I have not practiced my religion because: (1) I have been repeatedly arrested and convicted of violating state and federal laws because I used marijuana as my sacrament; (2) courts have repeatedly refused to allow any defendant to show the fact finder any factual evidence about the lack of toxicity or physical impairment caused by marijuana; and (3) under UDV, RFRA and RLUIPA, the sacramental use of marijuana is now protected to the extent that the courts are compelled to allow that factual evidence, testimony and argument to the fact finder at trial.

Justice Ginsburg’s ruling in Olsen made it clear that there were no circumstances under which she would find the sacramental use of marijuana protected by law.  Justice Ginsburg predicated her ruling on the assumption that I would limit the practice of my religion in any way, and left me with only two choices: (1) practice my religion and subject myself to arrest and imprisonment for doing so; or (2) stop practicing my religion.

In OlsenJustice Ginsburg wrote:

Because the tenets of the Ethiopian Zion Coptic Church endorse marijuana use every day throughout the day, however, Olsen's proposal for confined use would not be self-enforcing.

The all or nothing approach used by the court in Olsendoes not satisfy the requirements of the Religious Freedom Restoration Act of 1993 (“RFRA”). 42 U.S.C. § 2000(b)(b)(2004) that government action that substantially burdens religious exercise is invalid unless it is justified by a compelling government interest and is the least restrictive way to achieve that interest.

Another problem with Olsenwas whether I was effectively represented by the law firm of Hogan and Hartson appointed by the court to represent me.  After reading my pro se appeal brief, the U.S. Court of Appeals hired the law firm of Hogan and Hartson to represent me on appeal.

Approximately 9 months prior to the ruling in Olsen v. Drug Enforcement Administration, 878 F.2d 1458 (D.C. Cir. 1989), the DEA’s chief administrative law judge, Francis L. Young, In the Matter of Marijuana Rescheduling Petition, DEA Docket No. 86-22, Sept. 6, 1988, pages 58-59, ruled that:

Marijuana, in its natural form, is one of the safest therapeutically active substances known to man

I was one of the petitioners in the Marijuana Rescheduling Petition, DEA Docket No. 86-22, Sept. 6, 1988.  My attorney's were aware that I was a plaintiff in that action and that the ruling had been issued at the time it was. The ruling was issued prior to the last deadline for briefing in Olsen.  Judge Young’s ruling should have been presented by the law firm of Hogan and Hartson as grounds for forcing the government to re-evaluate the prohibition of marijuana and prove it had a compelling interest in prohibiting my sacramental use of marijuana.

Under the federal drug statutes as written, the DEA Administrative Law Judge is the specific person in Government tasked with accumulating the scientifically derived evidence about a drug’s toxicity and medical utility.

The DEA Administrative Law Judge holds the hearings where the evidence is accumulated and examined; and a recommended ruling is written.  The Administrative. Law ruling is then sent to the DEA Director for final decision on the recommended scheduling.  But, whatever the final decision on rescheduling, the fact of toxicity is determined finally, under law, by that DEA Administrative Law Judge.

The first phase of the test for Compelling Interest is the examination of the evidence of the toxicity or threat to life caused by the substance or activity under examination.  For instance, ethyl alcohol is a specific chemical which has a known physical toxicity per unit of body weight in a human being.  By looking at that specific toxicity and how it manifests in human behavior, we learn about drunk driving.  Drunk driving is an example of a specific toxic behavioral effect of the drug alcohol.

The government is specifically empowered under RFRA and RLUIPA to regulate religious exercise that threatens public health and safety.

There is no doubt that reenacting the ritual of Jesus making 180 gallons of the finest wine the steward ever drank for the marriage feast at Cana could cause drunk driving.

There is no doubt that the government can prove the fact of the threat of drunk driving in a specific manner and propose regulations in a least restrictive manner to control the threat to public health and safety caused by drunk driving.

However, the government cannot bootstrap total prohibition of religious use of wine onto the threat to the public caused by drunk driving.  The government doesn’t even try to shut down bars anymore just because drunk drivers come out of them every day and kill us on the roads - and that is protection of just commerce, not protection of first amendment religious establishment and exercise.

Compelling Interest is the test under RFRA/RLUIP.  Compelling Interest is the test under Sherbert and Yoder.  Compelling Interest is the test I never got and the test I am entitled to under the statutory retroactive provisions of RFRA and RLUIPA.

And, even then, if the government could have shown a compelling interest in prohibiting my religious use, the government then must be subject to the least restrictive means of regulation prong of RFRA/RLUIPA.  So Justice Ginsberg's words above are now directly contradicted by RFRA/RLUIPA as interpreted in UDV.

Even if the government could have shown a compelling interest in prohibiting marijuana, it would still have to show a compelling interest in prohibiting me from practicing my religion (a much higher standard of proof).

The court wrote in Olsen:

And "Olsen does not dispute the government's compelling interest in controlling the distribution and drug-related use of marijuana," Brief of Court-Appointed Amicus Curiae at 18.  Indeed, "[e]very federal court that has considered the matter, so far as we are aware, has accepted the congressional determination that marijuana in fact poses a real threat to individual health and social welfare."  Rush, 738 F.2d at 512.

I was one of the defendants in United States v. Rush, 738 F.2d 497 (1st Cir. 1984), in which the court decided it did not have to re-examine the government’s compelling interest in prohibiting marijuana because Congress had already made that decision in enacting the Controlled Substances Act.  In Rush, at pages511-513, the court wrote:

The question whether the government has an overriding interest in controlling the use and distribution of marijuana by private citizens is a topic of continuing political controversy.  Much evidence has been adduced from which it might rationally be inferred that marijuana constitutes a health hazard and a threat to social welfare; on the other hand, proponents of free marijuana use have attempted to demonstrate that it is quite harmless.  See Randall v. Wyrick, 441 F. Supp. 312, 315-16 (W.D. Mo. 1977); United States v. Kuch, 288 F. Supp. 439, 446 & 448 (D.D.C. 1968).  In enacting substantial criminal penalties for possession with intent to distribute, Congress has weighed the evidence and reached a conclusion which it is not this court's task to review de novo.  Every federal court that has considered the matter, so far as we are aware, has accepted the congressional determination that marijuana in fact poses a real threat to individual health and social welfare, and has upheld the criminal sanctions for possession and distribution of marijuana even where such sanctions infringe on the free exercise of religion.  United States v. Middleton, 690 F.2d 820, 825 (11th Cir. 1982), cert. denied, 460 U.S. 1051 (1983); United States v. Spears, 443 F.2d 895 (5th Cir. 1971), cert. denied, 404 U.S. 1020 (1972); Leary v. United States, 383 F.2d 851, 859-61 (5th Cir. 1967), rev'd on other grounds 395 U.S. 6 (1969); Randall, 441 F. Supp. at 316 & n. 2; Kuch, 288 F. Supp. at 448.  Only last year, the Eleventh Circuit rejected identical claims raised by some of the very appellants before us in this case, see Middleton, 690 F.2d 820, and the United States Supreme Court denied review.  We decline to second-guess the unanimous precedent establishing an overriding governmental interest in regulating marijuana.

Finally, it has been recognized since Leary that accommodation of religious freedom is practically impossible with respect to the marijuana laws:

Congress has demonstrated beyond doubt that it believes marihuana is an evil in American society and a serious threat to its people.  It would be difficult to imagine the harm which would result if the criminal sanctions against marihuana were nullified as to those who claim the right to possess and traffic in this drug for religious purposes.  For all practical purposes the anti-marihuana laws would be meaningless, and enforcement impossible.

Leary, 383 F.2d at 861, quoted in Middleton, 690 F.2d at 825; see also Kuch, 288 F. Supp. at 447.  Although a narrow administrative exception has been carved out from the Schedule I classification of peyote for the benefit of the Native American Church, see 21 C.F.R. § 1307.31, we think this exemption is properly viewed as a government "effort toward accommodation" for a "readily identifiable, narrow catagory" which has minimal impact on the enforcement of the laws in question.  Lee, 455 U.S. at 260 n. 11 & 261.  No broad religious exemption from the marijuana laws is constitutionally required.  We therefore affirm the district court's ruling rejecting appellants' first amendment defense as a matter of law.

As Chief Justice Roberts wrote in UDV:

[T]he Government has not carried the burden expressly placed on it by Congress in the Religious Freedom Restoration Act

RFRA requires the Government to demonstrate that the compelling interest test is satisfied through application of the challenged law "to the person" -- the particular claimant whose sincere exercise of religion is being substantially burdened. 42 U.S.C. § 2000bb-1(b).

Under the more focused inquiry required by RFRA and the compelling interest test, the Government's mere invocation of the general characteristics of Schedule I substances, as set forth in the Controlled Substances Act, cannot carry the day.

The fact that the Act itself contemplates that exempting certain people from its requirements would be "consistent with the public health and safety" indicates that congressional findings with respect to Schedule I substances should not carry the determinative weight, for RFRA purposes, that the Government would ascribe to them.

We do not doubt that there may be instances in which a need for uniformity precludes the recognition of exceptions to generally applicable laws under RFRA. But it would have been surprising to find that this was such a case, given the longstanding exemption from the Controlled Substances Act for religious use of peyote, and the fact that the very reason Congress enacted RFRA was to respond to a decision denying a claimed right to sacramental use of a controlled substance. See 42 U.S.C. § 2000bb(a)(4).

The Government repeatedly invokes Congress' findings and purposes underlying the Controlled Substances Act, but Congress had a reason for enacting RFRA, too.  Congress recognized that "laws 'neutral' toward religion may burden religious exercise as surely as laws intended to interfere with religious exercise," and legislated "the compelling interest test" as the means for the courts to "strike sensible balances between religious liberty and competing prior governmental interests." 42 U.S.C. §§ 2000bb(a)(2), (5).

The government’s current ban on my religious practice is not the least restrictive means of carrying out its responsibilities under the Controlled Substances Act and the Religious Freedom Restoration Act.

UDV has now made it clear that Congress did not consider the sacramental use of marijuana when it passed the Controlled Substances Act in 1970.  UDV has now made it equally clear that a court is not prevented from its responsibility of considering my sacramental use of marijuana in the separate context of religious freedom.