MARIJUANA AS A HOLY SACRAMENT: 
     IS THE USE OF PEYOTE CONSTITUTIONALLY DISTINGUISHABLE FROM THAT 
             OF MARIJUANA IN BONA FIDE RELIGIOUS CEREMONIES? 
                       Written By Cynthia S. Mazur*
            NOTRE DAME JOURNAL OF LAW, ETHICS & PUBLIC POLICY
                Volume 5, Issue No. 3, 1991 pages 693-727
            * L.L.M. Candidate, Appellate Advocacy, Georgetown
            University Law Center. J.D., Syracuse University 
            College of Law, M.Div, Princeton Theological 
            Seminary, B.A. Hartwick College.  


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                           TABLE OF CONTENTS

                                                                 Page

  I.   THE NATIVE AMERICAN CHURCH ENJOYS A DEA EXEMPTION FROM 
       THE FEDERAL DRUG LAWS PROHIBITING INGESTION OF PEYOTE.......2 

       A.   The Native American Church.............................2 
       B.   Peyote.................................................4 
       C.   The Controlled Substances Act..........................5 
       D.   The Native American Church Exemption...................7 

  II.  THE ETHIOPIAN ZION COPTIC CHURCH IS A BONA FIDE 
       RELIGION AND MARIJUANA IS CENTRAL TO ITS WORSHIP............11 

  III. THE ETHIOPIAN ZION COPTIC CHURCH REPEATEDLY 
       PETITIONS BUT IS DENIED A SACRAMENTAL DRUG 
       EXEMPTION SIMILAR TO THAT ACCORDED TO THE NATIVE 
       AMERICAN CHURCH.............................................15 

       A.   Olsen Proceeds Pro Se..................................15 
       B.   Amicus is Appointed to Represent Olsen.................22 
       C.   Remand to the DEA......................................23 
       D.   The DEA Denies the Exemption...........................28 
       E.   The Court of Appeals Denies the Exemption..............30 
            1.   The Majority......................................30 
            2.   Judge Buckley's Dissent...........................32 

  IV.  THE COURT OF APPEALS DECISION VIOLATES 
       THE CONSTITUTION............................................36 

       A.   Comparing The Two Exemptions...........................37 
       B.   Comparing the Law Enforcement Problems.................39 
       C.   Comparing the Churches' Rituals........................42 
       D.   Comparison of the Drugs................................46 
       E.   Comparison of Attitudes Towards the Two Churches.......48 

  V.   CONCLUSION..................................................50 


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                     MARIJUANA AS A HOLY SACRAMENT:
     IS THE USE OF PEYOTE CONSTITUTIONALLY DISTINGUISHABLE FROM THAT
             OF MARIJUANA IN BONA FIDE RELIGIOUS CEREMONIES?


"And God said, Behold, I have given you every herb bearing seed." 
Genesis 1:29 (King James). 


     This past April, within one week, the Supreme Court: 1) denied 

certiorari to Carl Eric Olsen, an Ethiopian Zion Coptic priest appealing 

the denial of a DEA exemption for the sacramental use of marijuana; 

[footnote 1] and 2) held that the State of Oregon could deny unemployment 

compensation to two Native Americans who had been fired for the 

sacramental use of peyote. [footnote 2]  Similarities between the two 

cases end there.  The Supreme Court's latter holding does not change the 

fact that Congress and the Drug Enforcement Administration ("DEA"), have 

decided to accommodate the religious practices of the Native American 

Church ("NAC"), and accord it a preferential position by establishing, 

pursuant to regulation, its right to religious drug use over against all 

other churches. {footnote 3]  Part I of this article will set forth the 

favorable treatment which the federal government extends to the NAC 

regarding its unlimited exemption to use peyote in religious ceremonies. 

[footnote 4]  Part II of this article will 
____________________

     [footnote 1]  Olsen v. Drug Enforcement Admin., 110 S. Ct. 1926 
(1990). 

     [footnote 2]  Employment Div., Dep't of Human Resources v. Smith, 
110 S. Ct. 1595 (1990).  The Court determined that the U.S. Constitution 
does not mandate a free exercise right to the sacramental use of peyote.  
Id. 

     [footnote 3]  See infra notes 36-39 and accompanying text. 

     [footnote 4]  See infra notes 8-39 and accompanying text. 

                                   1


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examine the basic tenets of the Ethiopian Zion Coptic Church ("EZCC") , 

related to the sacramental use of marijuana. [footnote 5]  Part III of 

this article will detail the responses of the DEA and the courts to the 

EZCC's requests for an exemption similar to that held by the NAC. 

[footnote 6]  Finally, Part IV of this article will analyze the 

constitutionality of the differing treatment of the two religions. 

[footnote 7] 

I.   THE NATIVE AMERICAN CHURCH ENJOYS A DEA EXEMPTION FROM THE 
     FEDERAL DRUG LAWS PROHIBITING INGESTION OF PEYOTE 

     A. The Native American Church 

     When one tries to solidify a definition of the NAC, it must be 

remembered that America has 307 Native American tribes living within its 

borders. [footnote 8]  There is no majority control of the NAC and as a 

result, the only statement "that is safe to make is that there is, in 

many places and in many ways, a concept of a Native American Church." 

[footnote 9]  How the NAC conducts its rituals and celebrates its 

sacrament is subject to myriad differences." [footnote 10] 
____________________

     [footnote 5]  See infra notes 40-60 and accompanying text. 

     [footnote 6]  See infra notes 61-140 and accompanying text. 

     [footnote 7]  See infra notes 141-201 and accompanying text. 

     [footnote 8]  This number includes in its definition federally 
recognized bands, villages, groups, and pueblos but does not include 
tribes located in Alaska.  The World Almanac & Book of Facts 1991 394 
(1990). 

     [footnote 9]  A. Marriott & C. Rachlin, Peyote at 105, 107-08 
(1971).  Marriott and Rachlin cite the two, prior definitive studies in 
this area as Weston La Barre's The Peyote Cult, and J.S. Slotkin's The 
Peyote Religion: A Study in Indian-White Relations.  A. Marriott, supra, 
at ix. 

     [footnote 10]  See id. at 105-08. 

                                   2


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     While the NAC has no recorded theology, members combine certain 

Christian teachings with the belief that peyote embodies the Holy Spirit. 

[footnote 11]  It is believed that those who partake of peyote enter into 

direct contact with God and experience a heightened sense of 

comprehension which includes a deep feeling of compassion for others. 

[footnote 12] 

     Worship in the NAC centers around the "peyote meeting" which begins 

at sundown and continues at least until day break. [footnote 13] 

Normally, the ceremony is conducted to give thanks or to receive 

guidance. [footnote 14]  Participants sit in a circle around a fire, 

[footnote 15] consume peyote during the ceremony, and may pray, sing, or 

use a drum. [footnote 16]  Other accouterments can include a fan, eagle 

bone or feather, whistle, rattle, and/or a prayer cigarette. [footnote 

17]  While the membership of the NAC is estimated to consist of between 

250,000 and 400,000 people, [footnote 18] there are no official 

prerequisites to 
____________________

     [footnote 11]  People v. Woody, 61 Cal. 2d 716, 720, 40 Cal. Rptr. 
69, 73, 394 P.2d 813, 817 (1964). 

     [footnote 12]  See id. 

     [footnote 13]  Id. at 720-21, 40 Cal. Rptr. at 73, 394 P.2d at 817. 

     [footnote 14]  Id. at 721, 40 Cal. Rptr. at 73, 394 P.2d at 817. 

     [footnote 15]  A. Marriott, supra note 9, at 121. 

     [footnote 16]  Woody, 61 Cal. 2d at 721, 40 Cal. Rptr. at 73, 394 
P.2d at 817. 

     [footnote 17]  Id. 

     [footnote 18]  Peyote Way Church of God v. Smith, 742 F.2d 193, 198 
(5th Cir. 1984). 

                                   3


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membership and no written membership rolls. [footnote 19]  In fact, there 

are wide differences of opinion within the NAC regarding what constitutes 

a member. [footnote 20] 

     B. Peyote 

     Peyote, an hallucinogenic cactus, [footnote 21] has effects similar 

to lysergic acid diethylamide ("LSD"). [footnote 22]  "The major active 

ingredient in peyote is mescaline." [footnote 23]  The precursor of the 

DEA, the Bureau of Narcotics and Dangerous Drugs ("BNDD"), [footnote 24] 

has 
____________________

     [footnote 19]  Woody, 61 Cal. 2d at 720, 40 Cal.  Rptr. at 73, 394 
P.2d at 817. 

     [footnote 20]  id. 

     [footnote 21]  Peyote, which is native to the region of the Rio 
Grande Valley and southward, is a plant classified botanically as 
Lophorphora Williamsii Lemaire.  It is a small, spineless, low growing 
cactus and is carrot or turnip-like in shape and size.  Only the fleshy, 
rounded top grows above ground.  After the pincushion top is sliced off 
and dried, it becomes a hard and brittle disk-like button, which is used 
ceremoniously to produce "profound sensory and psychic phenomena."  35 
Fed. Reg. 14789-90 (1970). 

     [footnote 22]  Id.  LSD is a "Psychedelic" which refers to a class 
of drugs including mescaline and marijuana, among others, whose primary 
effect is to expand consciousness, heighten intellectual activity, and 
increase sensory awareness.  Leary v. United States, 383 F.2d 851, 858, 
860 (5th Cir. 1967), rev'd on other grounds, 395 U.S. 6 (1969).  
Researchers have found that religious reactions in those partaking of 
psychedelic drugs are present in varying degrees from about 25% to 90% of 
all users.  United States v. Kuch, 288 F. Supp. 439, 444 (D.D.C. 1968).  
A "religious reaction" is defined as a sharpening of the senses and a 
mixed feeling of awe and fear.  There may be a sense of mystery, peace, 
and a sharpening of impressions as to all natural objects, perhaps 
something like the vision Moses had of the burning bush.  Id. 

     [footnote 23]  Peyote Way Church of God v. Smith, 742 F.2d 193, 197 
(5th Cir. 1984). 

     [footnote 24]  For a discussion of the dissolve of the BNDD and the 
creation of the DEA, see the notes to 21 U.S.C. § 881 (1988). 

                                   4


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reported that mescaline may produce an altered consciousness marked by: 

1) confused mental states and dreamlike revivals of past traumatic 

events; 2) alteration of sensory perception evidenced by visual illusions 

and distortion of space and perspective; 3) alteration of mood with 

anxiety, euphoria, or ecstacy; 4) alteration of ideation with impairment 

of concentration and intelligence; and 5) alteration of personality with 

impairment of conscious functioning and the deterioration of inhibitions. 

[footnote 25]  Indeed, ingestion of peyote may result in such severe 

reactions as psychosis and suicide. [footnote 26]  The federal drug laws 

which prohibit peyote use, however, do not apply to participants who 

ingest peyote as part of the NAC religious ritual. [footnote 27] 

     C. The Controlled Substances Act 

     The Controlled Substances Act of 1970 ("CSA"), provides a 

comprehensive system of federal drug control laws in the United States. 

[footnote 28]  The CSA establishes five schedules of controlled 
____________________

     [footnote 25]  See 35 Fed. Reg. 14,791 (1970) (in addition, 
ingestion of peyote may result in fetal abnormalities, incurable 
psychosis, and personality disintegration); 742 F.2d at 197. 

     [footnote 26]  See id.  On the other hand, some report that through 
the use of peyote: 1) euphoria and good feelings are heightened; 2) 
colors and music are more vivid and more pleasing; 3) prayers take on an 
intense philosophical and ethical quality; and 4) a state of inner peace 
takes place where the individual may experience visions or sensations of 
the supernatural.  A. Marriott, supra note 9, at 70.  Peyote is not 
thought to be addictive.  Amicus Memorandum Before DEA, July 1988, App. 
16, at 415 n.27. 

     [footnote 27]  21 U.S.C. § 812 (1988); 21 C.F.R. S 1307.31 (1990). 

     [footnote 28]  See 21 U.S.C. §§ 801-971 (1988). 

                                   5


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substances, with Schedule I containing those substances subject to the 

most restrictive control. [footnote 29]  Schedule I substances are 

defined as those which meet the following three criteria: 

     1)  "a high potential for abuse"; 

     2)  "no currently accepted medical use in treatment in 
     the United States"; and 

     3)  "a lack of accepted safety for use ... under 
     medical supervision." [footnote 30] 

Peyote is classified as a Schedule I controlled substance [footnote 31] 

of the CSA which prohibits its distribution, its possession with intent 

to distribute, and its possession without a prescription. [footnote 32] 

     Section 1307.03 of the Code of Federal Regulations allows a 

petitioner to apply for an exception to "any provision" of the 
____________________

     [footnote 29]  21 U.S.C. § 812 (1988). 

     [footnote 30]  21 U.S.C. § 812(b)(1) (1988). 

     [footnote 31]  Other Schedule I substances include marijuana, LSD, 
and heroin.  21 U.S.C. § 812(c) (1988). 

     [footnote 32]  21 U.S.C. §§ 812(c)(c)(12), 841, 844 (1988).  The 
manufacture and distribution of peyote were first prohibited by federal 
law in the Drug Abuse Control Amendments of 1965, which were superseded 
by the CSA.  21 U.S.C. § 812(c), Schedule I(c)(12) cited in Native Am.  
Church of N.Y. v. United States, 468 F. Supp. 1247, 1249 (S.D.N.Y. 1979) 
(also citing 79 Stat. 226 § 3(a)). 

          "Peyote was classified as a 'narcotic' in the Narcotic Farm Act 
of 1929, 45 Stat. 1085, to enable peyote 'addicts' to seek treatment at 
federal facilities.  The Food, Drug and Cosmetic Act of 1938 also 
classified peyote as a narcotic or hypnotic substance, 52 Stat. 1050, and 
imposed certain labeling requirements.  Neither statute prohibited the 
manufacture or distribution of peyote."  Amicus Memorandum before DEA, 
July 1988, App. 16, at 404 n.3 (Memorandum Opinion for the Chief Counsel, 
DEA, Dec. 22, 1981). 

                                   6


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drug prohibitions. [footnote 33]  Indeed, evidence may be presented to 

the Attorney General by any interested party in order to determine 

whether a particular drug should be reclassified, added, or removed from 

the schedules. [footnote 34]  The CSA also authorizes the Attorney 

General to establish registration procedures to permit persons to 

manufacture, distribute, or dispense controlled substances and confers 

broad authority to grant and waive registration requirements. [footnote 

35] 

     D.  The Native American Church Exemption 

     The language of the CSA contains no exemptions from its 

prohibitions; nonetheless, in 1965, Congress passed the Drug 
____________________

     [footnote 33]  21 C.F.R. § 1307.03 (1990).  The regulations 
implementing the CSA's provisions concerning the scheduling of controlled 
substances, registration of manufacturers, labeling of substances, 
issuance of prescriptions, record-keeping and reporting requirements, and 
similar matters are codified at 21 C.F.R. §§ 1300-1316 (1990). 

     [footnote 34]  See 21 U.S.C. § 811(a) (1988); see also National Org. 
for the Reform of Marijuana Laws v. DEA, 559 F.2d 735, 737-38 (D.C. Cir. 
1977) ("Recognizing that the results of continuing research might cast 
doubts on the wisdom of initial classification assignments, Congress 
created a procedure by which changes in scheduling could be effected.").  
Citing marijuana as an example, Congress noted the need for flexibility 
when it enacted the CSA: 
     The extent to which marihuana should be controlled is a 
     subject upon which opinions diverge widely.  There are 
     some who not only advocate its legalization but would 
     encourage its use; at the other extreme there are some 
     States which have established the death penalty for 
     distribution of marihuana to minors. 
H.R. Rep. No. 91-1444, 91st Cong., 2d Sess. 12, reprinted in 1970 U.S. 
Code Cong. and Ad. News 4566, 4577. 

     [footnote 35]  21 U.S.C. §§ 821-23 (1988).  Section 823(b), which is 
entitled "Registration requirements," sets forth the bases for granting 
registration to distribute a controlled substance under Schedule I.  
Public health and safety comprise one relevant factor.  Id. 

                                   7


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Abuse Control Amendments with the understanding that bona fide religious 

use of peyote was exempt from regulation. [footnote 36]  The 
____________________

     [footnote 36]  After the Drug Abuse Control Amendments of 1965, 79 
Stat. 226 § 3(a) ("H.R. 2"), passed the Senate and were being debated in 
the House, Congressman Harris stated the following: 
          Mr. Harris:  The last amendment of substance made 
     by the Senate deletes the provisions of the House bill 
     which provided that the term "depressant or stimulant 
     drug" does not include peyote used in connection with 
     ceremonies of a bona fide religious organization. 
          Some concern has been expressed by many of the 
     religious groups affected, and by certain civil 
     liberties organizations concerning the possible impact 
     of this amendment on religious practices protected by 
     the first amendment to the Constitution. 
          Two court decisions have been rendered in this 
     area in recent years.  One, a decision by Judge Yale 
     McFate in the case of Arizona v. Attakai, No. 4098, in 
     the superior court of Maricopa County, Phoenix, 
     Arizona, July 26, 1960; and a California decision, 
     People against Woody, decided August 24, 1964, in the 
     Supreme Court of California.  Both these cases held 
     that prosecutions for the use of peyote in connection 
     with religious ceremonies was a violation of the first 
     amendment to the Constitution. 
          In view of all this, I requested the views of the 
     Food and Drug Administration and have been assured that 
     the bill, even with [sic without] the peyote exemption 
     appearing in the House-passed bill, cannot forbid bona 
     fide religious use of peyote. 
          Mr. Speaker, I ask for unanimous consent to 
     include the letter from the Food and Drug 
     Administration at this point in my remarks. 
          Dear Mr. chairman: In response to your 
          request we are stating the position the Food 
          and Drug Administration expects to take if 
          H.R. 2 becomes law as it passed the Senate 
          with respect to the use of peyote in 
          religious ceremonies. 
          We have been advised by a representative of 
          the North [sic Native] American Church that 
          this church is a bona fide religious 
          organization and that peyote has bona fide 
          use in the sacrament of the church.  The 
          representative has agreed to document both of 
          these statements. 
          If the church is a bona fide religious 
          organization that makes sacramental use of 
          peyote, then it would be our view that H.R. 

                                   8


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Attorney General in 1966, adopted a regulation effectuating Congress' 

intent. [footnote 37]  In 1970, when Congress passed the CSA, the BNDD 

assured Congress that a peyote use exemption would be carried forward by 

regulation. [footnote 38]  After the passage of the CSA, 
____________________

          2, even without the peyote exemption which 
          appeared in the House-passed version, could 
          not forbid bona fide religious use of peyote. 
          We believe that the constitutional guarantee 
          of religious freedom fully safeguards the 
          rights of the organization and its 
          communicants. 
               Sincerely yours, 
                                   George P. Larrick, 
                         Commissioner of Food and Drugs 
     Mr. Speaker, in view of the foregoing, I recommend that 
     the House agree to the Senate amendments to H.R. 2. 
111 Cong.  Rec. 15,977-78 (1965).  Shortly after these remarks were 
concluded, the House concurred in the Senate amendments.  Amicus  
Memorandum before DEA, July 1988, App. 16 at 405-407 (Memorandum Opinion 
for the Chief Counsel, DEA, December 22, 1981) (footnote omitted).  
Responsibility for enforcing the 1965 Amendments was transferred from 
HEW, of which FDA is a part, to the BNDD, pursuant to Reorganization Plan 
No. 1 of 1968.  Government Brief, Jan. 4, 1989, at 4 n.4. 

     [footnote 37]  31 Fed. Reg. 565, 4679 (1966).  Congress' delegation 
of this authority to the Attorney General is a lawful delegation of 
legislative power.  Government Brief, Jan. 4, 1989, at 11 n.9 (citing 
United States v. Gordon, 580 F.2d 827, 837-40 (5th Cir. 1978), and United 
States v. Pastor, 557 F.2d 930, 939-41 (2d Cir. 1981)).  The Attorney 
General has delegated responsibility under the CSA to the DEA 
Administrator pursuant to 28 C.F.R. § 0.100 (1990). 

     [footnote 38]  The CSA hearings contain the following: 
     Mr. [Congressman] Satterfield.  I have one other 
     question.  I recall when we were discussing dangerous 
     drugs a few years ago, the question came up about the 
     Native American Church involving Indians in the west 
     who use and have for centuries used peyote in 
     connection with religious services.  It is my 
     understanding that they enjoy an exemption under the 
     current law. 
     My question is whether in any of the bills we have 
     before us, if passed, would in any way affect this 
     present exemption? 
     Mr. Sonnenreich.  [Deputy Chief Counsel of BNDD]. 

                                   9


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the BNDD promulgated the current regulation which provides: 

          SPECIAL EXEMPT PERSONS 
          § 1307.31 Native American Church. 
          The listing of peyote as a controlled 
          substance in Schedule I does not apply to the 
          nondrug use of peyote in bona fide religious 
          ceremonies of the Native American Church, and 
          members of the Native American Church so 
          using peyote are exempt from registration. 
          Any person who manufactures peyote for or 
          distributes peyote to the Native American 
          Church, however, is required to obtain 
          registration annually and to comply with all 
          other requirements of law. [footnote 39] 
____________________

     In the first instance, Mr. Satterfield, the Native 
     American Church did ask us by letter as to whether or 
     not the regulation, exempting them by regulation, would 
     be continued and we assured them that it would because 
     of the history of the church.  We presently are 
     involved in another hearing regarding another church 
     that is a non-Indian church that is seeking the 
     exemption and the order is going to be published, I 
     believe, either today or tomorrow denying them the same 
     exemption as the Native American Church. 
     We consider the Native American Church to be sui generis. 
     The history and tradition of the church is such that there 
     is no question but that they regard peyote as a deity as it 
     were, and we'll continue the exemption. 
     Mr. Satterfield.  You do not see anything in the Senate 
     bill that would make this impossible? 
     Mr. Sonnenreich.  No.  Under the existing law 
     originally the Congress was going to write in a 
     specific exemption but it was then decided that it 
     would be handled by regulation and we intend to do it 
     the same way under this law. 
     Mr. Satterfield.  Thank you.  I have no other 
     questions. 
Drug Abuse Control Amendments of 1970 Hearings before the Subcommittee on 
Public Health & Welfare of the House of Representatives, 91st Cong. 2d 
Sess. 117-18 (1970). 

     [footnote 39]  21 C.F.R. § 1307.31 (1990).  For further discussion 
of the legislative history of the peyote exemption, see Toledo v. Nobel-
Sysco, Inc., 651 F. Supp. 483, 490 (D.N.M. 1986), and Native Am. Church 
of New York v. United States, 468 F. Supp. 1247, 1249-51 (S.D.N.Y. 1979). 
          In addition to the federal regulation, several states exempt 
the non-drug use of peyote from criminal prohibition.  See Whitehorn v. 
State, 561 P.2d 539 (Okla. 1977); State v. 

                                   10 

 
II.  THE ETHIOPIAN ZION COPTIC CHURCH IS A BONA FIDE RELIGION 
     AND MARIJUANA IS CENTRAL TO ITS WORSHIP 

     The EZCC, which traces its origins back 6,000 years, is 

headquartered in Jamaica. [footnote 40]  By the end of the Sixties, the 

Church had received a number of visitors from the U.S. and began allowing 

Caucasians to join the Church. [fotnote 41]  As a result, priests and 

members of the Church began to travel back and forth between the U.S. and 

Jamaica, and a number of U.S. citizens became members and priests in the 

Church. [footnote 42]  The Church was incorporated in 1976 and purchased 

a 1,000 acre farm in White Horse, St Thomas parish, Jamaica. [footnote 

43]  In addition, the Church purchased a residence for its members at 

Star Island in Miami, Florida. [footnote 44] 

     Church members consider themselves the historical and spiritual 

descendants of the Israelites of the Old Testament. [footnote 45] 
____________________ 

Whittingham, 19 Ariz. App. 27, 504 P.2d 950 (1973), cert. denied, 417 
U.S. 946 (1974); Peoiple v. Woody, 61 Cal. 2d 716, 40 Cal. Rptr. 69, 394 
P.2d 813 (1964); Colo. Rev. Stat. Ann. § 12-22-317 (West 1990); Iowa Code 
Ann. § 204.204(8) (West 1987); Kan. Stat. Ann. § 65-4116(8) (Supp. 1989); 
Minn. Stat. § 152.02 (West 1989); Nev. Rev. Stat. Ann. § 453.541 (Michie 
1986); N.M. Stat. Ann. 30-31-6(D) (Michie 1989); S.D. Codified Laws § 34-
20B-14(17) (Michie Supp. 1990); Tex. Rev. Civ. Stat. Ann. art. 4476-15 
(Vernon Supp. 1991); Wis. Stat. Ann. § 161.115 (West 1989); Wyo. Stat.  
Ann. § 35-7-1044 (1988). 

     [footnote 40]  Amicus Memorandum Before DEA, July 1988, at 6-7. 

     [footnote 41] Id. at 11. 

     [footnote 42] Id. 

     [footnote 43] Id. at 10. 

     [footnote 44] Id. 

     [footnote 45] Id. at 7. The EZCC distinguishes itself from the 
Rastafarian sect because the EZCC does not revere the late Emperor of 
Ethiopia, Haile Selassie, as a deity.  Id. at 10. 

                                   11


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Because of the constraints of slavery, however, the Church's written 

history did not evolve and does not compare with the organizational 

identity enjoyed by some Caucasian religions. [footnote 46]  Nonetheless, 

the Church is understood to be a Christian religion with Jesus as its 

primary prophet. [footnote 47]  The Church reveres the Bible as its holy 

book, and members adhere to traditions set forth in the Old Testament 

regarding diet, dress, grooming, sexual conduct, and so forth. [footnote 

48] 

     "The Church historically has been extremely restrictive in its 

membership practices, limiting membership to those men and women who 

demonstrate an acceptance and adherence to the Church's tenets over a 

significant period of time." [footnote 49]  If members fail to follow the 

Church's rules of conduct, they are subject to harsh 
____________________ 

     [footnote 46]  Id. at 8. 

     [footnote 47]  Id. at 7-8.  Marcus Garvey is considered one of the 
Church's great prophets.  Id.  His work in the 1920s and 30s advocating 
spirituality and black empowerment related to the general movement called 
"Ethiopianism ... is premised on a belief that all blacks share a common 
ancestry and are destined to return to a common homeland or Zion, 
symbolically identified as Ethiopia."  Id. at 9.  The goal of the Church 
in this regard is the "liberation of the black race and the spiritual 
renewal of black and white believers."  Id. at 7. 

     [footnote 48]  Id. at 7. 

     [footnote 49]  Id. at 11.  Membership involves a ritual called 
confession.  Id.  First, the confessor renounces the sins of the flesh 
and the material world.  Id. at 12.  Next, when the elders think that the 
individual has fully learned the tenets of the Church, the individual 
makes a public confession before the members.  After this, the members 
demonstrate their acceptance of the new member through the celebration of 
communion with marijuana.  Id. at 11-13. 

                                    12


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sanctions and sometimes expulsion. [footnote 50] 

     The EZCC traces its use of marijuana [footnote 51] to the Bible, 

citing passages regarding herbs, smoke, and clouds, [footnote 52] and 

stating that 

     "marijuana is the [e)ucharistic spiritual body and 
     blood of Christ," and "[o]nly through the sacramental 
     use of marijuana--combined with prayer and spiritual 
     reasoning among the brethren--can members of the Church 
     come to know God within themselves and within 
     others." [footnote 53] 

The non-drug use of marijuana is allowed at any point during the day, but 

is most commonly ingested during the three daily prayer 
____________________ 

     [footnote 50]  Id. 

     [footnote 51]  The EZCC's longstanding religious tradition of 
marijuana ingestion may have a history that dates back further than the 
Native American use of peyote.  Some authors postulate that many Indian 
religions did not incorporate the peyote ritual into their religious 
practices until the 1920s and 30s.  See A. Marriott, supra note 9, at 78-
79; see also Amicus Memorandum Before DEA, July 1988, at 34 (citing W. La 
Barre, The Peyote Cult 110-23 (4th ed. 1975)). 

     [footnote 52]  Id. at 14.  The EZCC has compiled works of 
scholarship and ancient references which substantiate and detail the 
religious use of marijuana from time immemorial.  See Amicus Memorandum 
Before DEA, July 1988, App. 6.  For instance, The Book of Grass 11-12 (G.  
Andrews & S. Vinkenoog ed. 1967), is cited for a passage on ancient 
Scythia and Iran by Mircea Eliade: 
     only one document appears to indicate the existence of 
     a Getic shamanism: It is Strabols account of the 
     Mysian KAPNOBATAI, a name that has been translated, by 
     analogy with Aristophanes' AEROBATES, as 'those who 
     walk in clouds', but which should be translated as 
     'those who walk in smoke'.  Presumably the smoke is 
     hemp smoke, a rudimentary means of ecstasy known to 
     both the Thracians and the Scythians...." 
Amicus Memorandum Before DEA, July 1988, App. 6 at 6-7.  The EZCC 
believes that the marriage of Cana involved cannabis not wine; "[c]ana is 
a linguistic derivation of the present day cannabis."  Id.  App. 6, at 
21. 

     [footnote 53]  Id. at 14-15. 

                                    13


--------------------------------------------------------------------------------

sessions. [footnote 54]  Members do not try to maximize the amount of 

smoke taken in or hold smoke in their lungs for long periods of time. 

[footnote 55]  Church members state that their ingestion of marijuana 

during worship does not result in any side-effects [footnote 56] or 

intoxication, nor is that a desirable goal. 

     The Church not only does not encourage but in fact 
     absolutely forbids the recreational use of marijuana 
     for the purpose of achieving intoxification.  The 
     Church believes that such intentional misuse of 
     marijuana, by members or nonmembers, constitutes 
     sacrilegious behavior.  Church members are strictly 
     prohibited from using any intoxication or addictive 
     substance--legal or illegal-- for recreational 
____________________ 

     [footnote 54]  Id. at 15. 

     [footnote 55]  Id. 

     [footnote 56]  Id.  These claims have been substantiated by several  
medical and psychiatric research studies done to determine the effects of 
marijuana on church members.  See Research Report by Brian L. Weiss, 
M.D., P.A. of Florida (1980) (EZCC members, some of whom have smoked 
marijuana in high doses for sixteen hours a day for up to fifty years, 
suffer no apparent psychological or physical harm; tolerance appears to 
have developed with no acute or chronic side effects); Research Report by 
Kenneth C. Fischer, M.D. of Florida (1980) (after doing a "complete 
intensive neurological examination on 31 members" of the EZCC, the "most 
impressive thing ... is the true paucity of neurological abnormalities I 
was able to discern"); American Association for the Advancement of 
Science, Cognition and Long-Term Use of Gania, 213 SCIENCE 465-66 (1981) 
(prolonged and heavy use of ganja have not resulted in any systematic 
decrements in mental abilities suggestive of impairment of brain or 
cerebral function; cognition I.Q. scores were high, and individuals 
appear to be healthy and highly functional); Neuropsychological 
Evaluation by Jeffrey Schaeffer, Ph.D. of California (1981) (despite 
measurable amounts of cannabinoid metabolites in his body and a history 
of very long-term use of cannabis, Carl Eric Olsen demonstrated no 
impairment of his cognitive, cerebral, intellectual, or new learning 
abilities, nor was there any suggestion of damage to the central nervous 
system or long and short-term memory ability; moreover, his ability to 
adapt to change remains at a very high level).  Amicus Memorandum Before 
DEA, July 1988, App. 7, 8, 9. 

                                    14


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     purposes. [footnote 57] 

     There has never been more than between 100 and 200 EZCC members in 

the U.S., and, presently, it is estimated that 60 members live in this 

country. [footnote 58]  Membership has been greatly diminished and 

dispersed due to numerous arrests and prosecutions. [footnote 59]  Some 

have left the Church, others have left the country, and others, like 

Olsen, have been paroled from prison on the condition that they will not 

associate with other members. [footnote 60] 

III. THE ETHIOPIAN ZION COPTIC CHURCH REPEATEDLY PETITIONS BUT IS 
     DENIED A SACRAMENTAL DRUG EXEMPTION SIMILAR TO THAT 
     ACCORDED TO THE NATIVE AMERICAN CHURCH 

     A.  Olsen Proceeds Pro Se 

     From 1983 to 1985, Carl Eric Olsen, a member and priest of the EZCC, 

had repeated unilateral communications with the DEA attempting to procure 

for his Church a drug law exemption for the sacramental ingestion of 

marijuana. [footnote 61]  It was not until the 
____________________ 

     [footnote 57]  Id. at 15. 

     [footnote 58]  Id. at 18.  Roughly, 30 members live in Florida, and 
the remaining members live throughout Iowa, Tennessee, Massachusetts, and 
several East Coast cities.  Id. 

     [footnote 59]  Id. at 17. 

     [footnote 60]  Id. at 17-18. 

     [footnote 61]  Olsen's Brief, Aug. 18, 1986, App. 13-20, 28-29, 31-
35.  Olsen proposed the following statutory language: 
     SPECIAL EXEMPT CHURCH.  Ethiopian Zion Coptic Church. 
     The listing of marijuana as a controlled substance in 
     Schedule I does not apply to the non-drug use of 
     marijuana in bona fide religious ceremonies of the 
     Ethiopian Zion Coptic Church and members of the 
     Ethiopian Zion Coptic Church so using marijuana are 
     exempt from registration.  Any person who manufactures 
     marijuana for or distributes marijuana to the Ethiopian 
     Zion Coptic Church, however, is required to obtain 

                                    15


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District of Columbia federal district court issued a show cause order to 

the DEA in response to Olsen's writ of mandamus filed in 1986, that the 

DEA finally responded. [footnote 62]  John C. Lawn, the DEA 

Administrator, answered Olsen's requests in the form of a three paragraph 

letter which stated in part: 

          In 1984, an estimated 7,800 to 9,200 metric tons 
     of marijuana were illegally consumed in the United 
     States.  It has been estimated that over 20 million 
     people in the United States use marijuana on a regular 
     basis.  Marijuana abuse is a major public health 
     problem in this country.  Accordingly, the 
     investigation and prosecution of marijuana traffickers, 
     the interdiction of marijuana smuggling and the 
     eradication of the drug at its source continue to be 
     major concerns of drug law enforcement both 
     domestically and internationally. 

          In view of the immensity of the marijuana abuse 
     problem in the United States and the magnitude of the 
     criminal activity surrounding the production and 
     trafficking in this substance, the Administrator of the 
     Drug Enforcement Administration concludes that the 
     interest of the Ethiopian Zion Coptic Church in the 
     ceremonial use of marijuana is outweighed by the 
     compelling governmental interest in controlling the use 
     and illegal distribution of marijuana in the United 
     States. [footnote 63] 

     The district court dismissed Olsen's mandamus petition as moot; 

appealing the dismissal, Olsen stated, "The DEA gave no reasons at all 

for denying the exemption, the DEA only gave 
_______________ 

     registration annually and to comply with all other 
     requirements of law. 
Id.  App. 13, 16, 18. 

     [footnote 62]  Id. App. 2-4.  Olsen also had filed a mandamus 
petition in the Eleventh Circuit.  Olsen v. DEA, 776 F.2d 267 (llth Cir. 
1985) (affirming district court's denial of olsen's request for a 
mandamus to compel DEA to respond to petitions for marijuana exemption 
because the statute authorizing exemptions does not provide for a 
religious exemption). 

     [footnote 63]  Olsen's Brief, Aug. 18, 1986, App. 11-12. 

                                    16


--------------------------------------------------------------------------------

reasons for denying marijuana use to the general public. [footnote 64] 

Olsen also appealed the DEA's denial, admitting that the DEA had a 

compelling interest in the overall enforcement of the CSA, but arguing 

that the exemption granted to the NAC had not undermined that interest 

nor would a limited exemption for the EZCC. [footnote 65]  Olsen pointed 

out that the DEA previously denied a peyote exemption to the Church of 

the Awakening ("CotA"), after finding that the CotA was not similar to 

the NAC because "peyote is essential and central to the [NAC] religion in 

that without peyote their religion would not and could not exist." 

[footnote 66]  The DEA made no such findings regarding the EZCC denial. 

[footnote 67] 

     In its response, the government set forth the three-part test from 

United States v. Lee, [footnote 68] for establishing a free exercise 

claim [footnote 69] and cited various free exercise cases. [footnote 70]   
____________________ 

     [footnote 64]  Id. at 5. 

     [footnote 65]  Olsen Brief, Sept. 3, 1986, at 2-4, 11.  The cases 
were consolidated on appeal. 

     [footnote 66]  35 Fed. Reg. 14790 (1970).  The CotA appealed this 
decision to the Ninth Circuit.  Kennedy v. BNDD, 459 F.2d 415 (9th Cir. 
1972) (ruling that statute granting the peyote exemption only to NAC was 
unconstitutional but nonetheless holding that extending the exemption to 
the CotA would not cure the defect, thus, the exemption for the CotA was 
denied), cert. denied, 409 U.S. 1115 (1973). 

     [footnote 67]  Olsen's Brief, Sept. 3, 1986, at 8. 

     [footnote 68]  455 U.S. 252 (1982). 

     [footnote 69]  Government Brief, Oct. 6, 1986, at 7.  The Lee test 
inquires: 1) whether the challenged law interferes with the free exercise 
of religion; 2) whether the challenged law is essential to accomplish an 
overriding governmental objective; and 3) whether accommodating the 
religious practice would unduly interfere with fulfillment of the 
governmental interest. 455 

                                    17


--------------------------------------------------------------------------------

____________________

U.S. at 256-59. 

     [footnote 70]  Government Brief at 8-9.  The following cases involve 
EZCC members.  Olsen v. Iowa, 808 F.2d 652 (8th Cir. 1986) (summarily 
rejecting Olsen's free exercise and equal protection claims on habeas 
because of the state's compelling interest in controlling marijuana); 
United States v. Rush, 738 F.2d 497 (lst Cir. 1984) (applying Lee 
standard, court affirmed convictions of 15 members of the EZCC including 
Olsen involving twenty tons of marijuana upon finding that marijuana 
constitutes a health hazard and a threat to social welfare; moreover, NAC 
exemption is different because it is a narrow, readily identifiable 
category with minimal impact on law enforcement), cert. denied, 471 U.S. 
1120 (1985); United States v. Middleton, 690 F.2d 820 (llth Cir. 1982) 
(rejecting free exercise defense of an EZCC member charged with 
importation and possession of marijuana because of government's clearly 
articulated and compelling interest in regulating marijuana), cert. 
denied, 460 U.S. 1051 (1983); Commonwealth v. Nissenbaum, 404 Mass. 575, 
536 NE.2d 592 (1989) (priest and member of EZCC convicted for possession 
of hashish and marijuana could not succeed on free exercise claim because 
state had overriding interest in controlling drug abuse); State v. Olsen, 
315 N.W.2d 1 (Iowa 1982) (state demonstrated compelling interest in 
controlling marijuana sufficient to override olsen's free exercise 
argument); Town v. State ex rel. Reno, 377 So.2d 648 (Fla. 1980) (state 
had compelling interest in restricting use of cannabis as religious 
practice of EZCC). 

     The following cases involve members of other religions seeking a 
marijuana exemption.  United States v. Greene, 892 F.2d 453 (6th Cir. 
1989) (Native American failed to convince court that possession and 
distribution of marijuana was constitutionally required), cert. denied, 
110 S. Ct. 2179 (1990); United States v. Spears, 443 F.2d 895 (5th Cir. 
1971) (summarily rejecting Black Muslim's first amendment defense to 
conviction for heroin, marijuana, and peyote smuggling because there is 
no constitutional privilege to use drugs), cert. denied, 404 U.S. 1020 
(1972); Randall v. Wyrick, 441 F. Supp. 312 (W.D. Mo 1977) (affirming 
conviction for marijuana and LSD possession of Aquarian Brotherhood 
Church leader because state had compelling interest in regulation of 
narcotic drug trafficking); United States v. Kuch, 288 F. Supp. 439, 445-
46 (D.D.C. 1968) (affirming conviction for drug offenses of ordained 
minister of Neo-American Church, which embraces principle that marijuana 
and LSD are the true Host, because church did not appear to be a bona 
fide religion and "under any common sense view of undisputed facts" the 
public interest is paramount); Hawaii v. Blake, 695 P.2d 336 (Haw. app. 
1985) (no free exercise defense for member of religion, Hindu Tantrism, 
convicted of possessing marijuana because members can freely practice 
their religion without marijuana); Whyte v. United States, 471 A.2d 1018 
(D.C. 1984) 

                                   18


--------------------------------------------------------------------------------

____________________

(upholding conviction for marijuana possession of Rastafarian of the 
Twelve Tribes of Israel where there were serious and compelling concerns 
of government regarding drug-related problems); State v. Rocheleau, 451 
A.2d 1144 (Vt. 1982) (no first amendment defense for Tantric Buddhist 
convicted for possession of marijuana); New Mexico v. Brashear, 92 N.M. 
622, 595 P.2d 63 (1979) (defendant's belief in the religious use of 
marijuana was derived from defendant's personal views of the Bible, and 
he failed to show that his belief was religious); Lewellyn v. State, 592 
P.2d 538 (Okla. 1979) (priest in Holy American Church could not raise 
religious defense to sale of marijuana to undercover officer who was not 
member of professed religion); People v. Mullins, 50 Cal. 3d 61, 123 Cal.  
Rptr. 201 (1975) (pastor of Universal Life Church of Christ Light failed 
to prove that marijuana was indispensable to his religion and that 
prohibition of marijuana use resulted in virtual inhibition of practice 
of his religion); People v. Crawford, 328 N.Y.S. 747, 748, 755 (1972) 
(member and minister of Church of Missionaries of the New Truth who used 
marijuana and LSD to achieve religious experience denied exemption 
because there was no evidence that defendant used drugs as part of 
religious ceremony, used drugs with other members of his Church, drugs 
were an intrinsic part of Church's dogma, or that his exercise of 
religion would inhibited without the use of drugs); People v. Werber, 
App. 3d 598, 97 Cal. Rptr. 150 (1971) (defendant's use marijuana did not 
constitute religious practice within constitutional concept of religion 
where it was not an object of worship essential to exclusively religious 
ritual); People v. Collins, 273 Cal.  App. 2d 486, 78 Cal. Rptr. 151 
(1969) (defendant did not worship marijuana but used it as an "auxiliary 
to a desired capacity for communication"); People v. Mitchell, 244 Cal.  
App. 2d 176, 52 Cal. Rptr. 884 (1966) (defendant did not offer any 
evidence that use of marijuana was a religious practice, instead he was 
expressing his own personal philosophy and way of life). 

     The following cases involve churches seeking a peyote exemption.  
Peyote Way Church of God v. Smith, 742 F.2d 193 (5th Cir. 1984) 
(reversing summary judgment which had been entered for government and 
remanding for weighing of interests involved because Texas and federal 
exemptions for NAC tended to negate compelling state interest in denying 
such exemption to Peyote Way Church); United States v. Warner, 595 F. 
Supp. 595 (D.N.D. 1984) (non-Indians who alleged that their use of peyote 
was part of their ceremonies in NAC were not entitled to exemption 
accorded to Indians); Native American Church of New York v. United 
States, 468 F. Supp. 1247 (S.D.N.Y. 1979) (interest of minister of Native 
American Church of New York seeking declaratory judgment in using drugs 
other than peyote must be subordinated to the important governmental 
purposes served by the CSA; as to peyote, group, while admittedly having 
no ties to NAC, must show it was a bona 

                                   19


--------------------------------------------------------------------------------

Admittedly, the federal and state peyote exemptions tend to negate the 

existence of a compelling government interest in prohibiting its non-drug 

use in bona fide religious worship. [footnote 71]  Thus, the government 

tried to distinguish the NAC, stating that Congressional testimony 

presented by the director of the BNDD during the CSA hearings indicated 

that the NAC was considered 

     sui generis.  The history and tradition of the church 
     is such that there is no question but that they regard 
     peyote as a deity. [footnote 72] 

By contrast, the EZCC "does not have such a Congressional recognition of 

its status." [footnote 73] 

     Olsen replied with a discussion of the key case regarding the 

sacramental use of marijuana, Leary v. United States. [footnote 74] 

Timothy Leary and his daughter were found in possession of marijuana upon 

their re-entry into this country by car from Mexico. [footnote 75] 

Raising a free exercise defense, Leary argued that he was part of the 

Hindu sect of Brahmakrishna and that "the experience [I find) through the 

use of marihuana is the essence 
____________________ 

fide religion), aff'd mem., 633 F.2d 205 (2d Cir. 1980); Birnbaum v. 
United States, 80 Civ. 1534 (RLC) (S.D.N.Y. Apr. 11, 1983) (would extend 
exemption to peyotist religions in general if group could establish that 
it was a bona fide religion) (unpublished). 

     [footnote 71]  Government Brief at 9. 

     [footnote 72]  Id. at 9.  For the full quote, see note 38. 

     [footnote 73]  Id.; see also Government Memorandum Before DEA, July 
22, 1988, at 13-16. 

     [footnote 74]  383 F.2d 851 (5th Cir. 1967), rev'd on other grounds, 
395 U.S. 6 (1969) cited in Olsen's Reply Brief, Oct. 10, 1986, at 3, 6-7. 

     [footnote 75]  383 F.2d at 855-56. 

                                   20


--------------------------------------------------------------------------------

of [my] religion." [footnote 76]  A Hindu monk testifying for Leary 

stated that he was partially able to achieve and practice his religious 

beliefs in the religious sect without the use of marijuana. [footnote 77] 

Leary admitted that if he could not use marijuana, it would not affect 

his religious beliefs. [footnote 78]  The court held that the laws 

regulating marijuana serve a compelling governmental interest in avoiding 

a "substantial threat to public safety, peace or order." [footnote 79] 

     Examining the NAC exemption, the court reviewed two California 

cases. [footnote 80]  In People v. Woody, the state court found a free 

exercise right to use peyote for NAC members who had been arrested during 

a ceremony, [footnote 81] and in In re Grady, the state court held that a 

peyote preacher could offer a first amendment defense to prosecution for 

possession of peyote. [footnote 81]  The Leary court found that unlike 

Leary's use of marijuana, peyote "played 'a central role in the ceremony 

and practice of the Native American Church, [and that the] ceremony 

marked by sacramental use of peyote, 
____________________ 

     [footnote 76]  Id. at 857, 860. 

     [footnote 77]  Id. at 857-58. 

     [footnote 78]  Id. at 857.  The court found that Leary drew no 
distinction between his religious beliefs and his scientific 
experimentation.  Id. 

     [footnote 79]  Id. at 860. 

     [footnote 80]  Id. at 861. 

     [footnote 81]  61 Cal. 2d 716, 40 Cal. Rptr. 69, 394 P.2d 813 
(1964). 

     [footnote 82]  61 Cal. 2d 887, 39 Cal. Rptr. 912, 394 P.2d 728 
(1964). 

                                   21

 
composes the cornerstone of the peyote religion.'" [footnote 83]  The 

Leary court continued: 

     The exemption accorded the use of peyote in the limited 
     bona fide religious ceremonies of the relatively small, 
     unknown Native American Church is clearly 
     distinguishable from the private and personal use of 
     marijuana by any person who claims he is using it as a 
     religious practice. [footnote 84] 

     B.  Amicus is Appointed to Represent Olsen 

     The Court of Appeals appointed amicus curiae for Olsen. [footnote 

85]  Amicus filed a brief discussing other marijuana exemptions extended 

by the federal government. [footnote 86]  Since the late 1960s, the 

government has been involved in growing, processing, and distributing 

marijuana to registered persons and entities. [footnote 87]  That program 

is administered by the National institute on Drug Abuse ("NIDA"), which 

has contracted with the University of Mississippi to grow marijuana; NIDA 

processes the marijuana and 
____________________ 

     [footnote 83]  Leary, 383 F.2d at 861.  Seventeen years later, the 
Fifth Circuit again distinguished Leary from other religious drug use 
cases.  Deciding that the Peyote Way Church of God would be entitled to 
the peyote exemption if it could establish that it was a bona fide 
religion, the court stated that Leary had not established that marijuana 
played a central role in the ceremony and practice of the church, and 
Leary sought unrestricted freedom to possess and use marijuana in any 
manner.  Peyote Way Church of God v. Smith, 742 F.2d 193, 200 (5th Cir. 
1984) (emphasis added). 

     [footnote 84]  Id. at 861 n.11 (emphasis added). 

     [footnote 85]  Judges Wald, Mikva, and Edwards issued an order 
appointing William Bradford and Steven Routh of the D.C. law firm, Hogan 
and Hartson.  Olsen v. DEA, No. 86-1442, Court Order, Feb. 11 1988. 

     [footnote 86]  Amicus Brief, Mar. 24, 1988, at 7-9, 21. 

     [footnote 87]  Id. at 7-9. 

                                   22


--------------------------------------------------------------------------------

provides it to researchers and medical treatment programs. [footnote 88] 

A number of marijuana exemptions have been issued to state governments 

which supervise local distribution of NIDA marijuana primarily for use in 

programs to lessen the negative side-effects of chemotherapy and to treat 

glaucoma. [footnote 89]  In the years between 1978 and 1987, NIDA has 

authorized and overseen the distribution of 477,507 cigarettes for human 

consumption. [footnote 90]  "(Clearly,] some limited level of marijuana 

use is not inconsistent with the government's" goals. [footnote 91] 

     C.  Remand to the DEA 

     The government petitioned the court of appeals to remand the case to 

the DEA so that it could "explain more fully the basis for its 

dDecision." [footnote 92]  The court denied the motion; then, changing 

its mind six days later, the court issued an order remanding the case to 

the DEA. [footnote 93] 

     Amicus submitted a memorandum with supporting documents to 
____________________

     [footnote 88]  Id. at 7-8. 

     [footnote 89]  Id. at 8. 

     [footnote 90]  Id. at 9. 

     [footnote 91]  Id. at 21.  Distinguishing the free exercise cases 
relied upon by the government, Amicus argued that granting broad after 
the fact exemptions once a defendant has been arrested for drug abuse is 
quite different from working to find a measured response to a prospective 
request for authorization.  Id. at 23. 

     [footnote 92]  Respondent's Motion For Remand To The Agency, Apr. 7, 
1988, at 2. 

     [footnote 93]  The panel consisted of Judges Edwards, Starr, and 
Weigel; Judge Stanley A. Weigel is a senior U.S. district judge for the 
Northern District of California.  Olsen v. DEA, No. 86-1442, Court 
Orders, Apr. 15, 1988, and Apr. 21, 1988. 

                                   23


--------------------------------------------------------------------------------

the DEA wherein Olsen withdrew the language of his prior exemption 

[footnote 94] and proposed the following exemption: 

     1.  [EZCC] members would be restricted to using 
     marijuana during their Saturday evening prayer 
     ceremony, which lasts from 8:00 p.m. until 11:00 p.m.; 

     2.  During that ceremony, and for the eight hours 
     following that ceremony, Church members would not leave 
     the place where the ceremony is conducted; they would 
     not drive automobiles or otherwise go out in public; 

     3.  Ingestion of marijuana would be limited to Church 
     members who had reached the age of majority, according 
     to the laws of the state in which the ceremony takes 
     place; and 

     4.  Ingestion of marijuana would be limited to full 
     Church members who had undergone the confession 
     ritual [footnote 95] for entering the Church's 
     community. [footnote 96] 

     Turning to the substantive arguments, Amicus stated that contrary to 

the position espoused by the government, the legislative history of the 

American Indian Religious Freedom Act of 1978 ("AIRFA"), [footnote 97] 

did not support the argument that Congress 
____________________

     [footnote 94]  See supra note 61. 

     [footnote 95]  See supra notes 49-50 and accompanying text. 

     [footnote 96]  Amicus Memo Before DEA, July 1988, at 29-30.  Olsen 
stated that he was willing to work out any details or arrangements with 
the DEA that would facilitate mutual agreement on the exemption and its 
logistics.  Id. 

     [footnote 97]  AIRFA provides in pertinent part: 
     Whereas the traditional American Indian religions, as 
     an integral part of Indian life, are indispensable and 
     irreplaceable: 

     be it 
     Resolved by the Senate and House of Representatives of 
     the United States of America in Congress assembled, 
     That henceforth it shall be the policy of the United 
     States to protect and preserve for American Indians 
     their inherent right of freedom to believe, express, 
     and exercise the traditional religions of the American 

                                   24


--------------------------------------------------------------------------------

specifically intended to limit the peyote exemption to the NAC; instead, 

Congress recognized that preferential treatment of the NAC would run 

afoul of the establishment clause. [footnote 98]  Indeed, an attorney for 

the Justice Department advised the Senate Select Committee on Indian 

Affairs that granting preferential treatment to Native American religions 

would be unconstitutional. [footnote 99]  In 
____________________

     Indian, Eskimo, Aleut, and Native Hawaiians, including 
     but not limited to access to sites, use and possession 
     of sacred objects, and the freedom to worship through 
     ceremonials and traditional rites. 
American Indian Religious Freedom Act of 1978, Pub. L. No. 95-341, 92 
Stat. 469 (1978). 

     [footnote 98]  Amicus Memo Before DEA, at 21-23.  In the Senate 
Select Committee on Indian Affairs Hearing on AIRFA the following 
statements were reported: 
     The clear intent of this section is to insure for 
     traditional native religions the same rights of free 
     exercise enjoyed by more powerful religions.  However, 
     it is in no way intended to provide Indian religions 
     with a more favorable status than other religions, only 
     to insure that the U.S. Government treats them equally. 
Id. App. 11, at 6 (Sen. Rep. No. 95-709, 95th Cong., 2d Sess. 6 (1978)).  
Other pertinent statements include: 
     [D]irect Federal interference in the religious 
     ceremonies imposes upon one religion, by Government 
     action, the values of another.  Such action is a direct 
     threat to the foundation of religious freedom in 
     America.  It comes far too close to an informal state 
     religion. 
                        * * * * 
     There is room for and great value in cultural and 
     religious diversity. 
                        * * * * 
     [B]ecause Indian religious practices are different 
     ...they somehow do not have the same status as a 'real' 
     religion. 
Id. App. 11, at 4-5 (Sen. Rep. No. 95-709, 95th Cong., 2d Sess. 4-5 
(1978)). 

     [footnote 99]  The legislative history of AIRFA indicates that the 
original Senate resolution contained language giving preferential 
treatment to Native American religions.  Id. at 23-24 & App. 11, at 10.  
The Department of Justice attorney gave the same advice regarding the 
establishment clause violation to Counsel to the 

                                   25


--------------------------------------------------------------------------------

response, the Senate redrafted its resolution to make "absolutely clear 

that AIRFA directed government agencies simply to ensure that Indian 

religions enjoyed the same guarantee of 'freedom of religion for all 

people' that is required by the First Amendment." [footnote 100]  When 

the Department of Justice informed the administration that it did not 

object to the President's signing of AIRFA, it made specific mention of 

the fact that Congress had incorporated the Department of Justice's 

position that a preference for Native American religions could not be 

extended without violating the establishment clause. [footnote 101] 

Furthermore, DEA attorneys concurred in the remarks made by the Justice 

Department, writing, in a memo commenting on the Justice Department's 

position, that "no line can be drawn between religions claiming a bona 

fide use of drugs." [footnote 102]  In 1981, the office of Legal Counsel 

("OLC"), published a memorandum opinion for the Chief Counsel of the DEA, 

stating that "Indian religion cannot be treated differently than other 

religions similarly situated without violation of the Establishment 

Clause." [footnote 97] 
____________________

President.  Id. at 24 & App. 12 (Memorandum for Hon. R.J. Lipshutz, Mar. 
10, 1978, at 3). 

     [footnote 100]  Id. at 24 (quoting Pub. L. No. 95-341 1978). 

     [footnote 101]  Id. at 24 & App. 13 (Pat Wald, Assist. Atty. Gen., 
Office of Legal Affairs, Letter to Honorable McIntyre). 

     [footnote 102]  Id. at 24 & App. 14, at 5 (Harry L. Myers, DEA  
Memorandum on the OLC's Comment on the Peyote Exemption, Feb. 28, 1979). 

     [footnote 103]  Id. at 25.  The Assistant Attorney General for the 
OLC stated in full: 
     [T]he special treatment of Indians under our law does 

                                   26


--------------------------------------------------------------------------------

     Finally, Amicus seriously questioned whether a first amendment claim 

could be denied on the basis of health concerns. [footnote 104]  The 

"agency's sanctioning of marijuana use by hundreds of persons involved in 

registered medical and research programs strongly suggests that marijuana 

use is not in all instances detrimental to an individuals health and 

psychological well-being." [footnote 105]  Nor has the NIDA program or 

the peyote exemption undermined public respect for the CSA. [footnote 

106] 
____________________

     not stem from the unique features of Indian religion or 
     culture.  With respect to these matters, Indians stand 
     on no different footing than do other minorities in our 
     pluralistic society.  Rather, the special treatment of 
     Indians is grounded in their unique status as political 
     entities, formerly sovereign nations preexisting the 
     Constitution, which still retain a measure of inherent 
     sovereignty over their peoples unless divested by 
     federal statute or by necessary implication of their 
     dependent status. 
     An exemption for Indian religious use of peyote would 
     not be grounded in the unique political status of 
     Indians.  Instead, the exemption would be based on the 
     special culture and religion of the Indians.  In this 
     respect, Indian religion cannot be treated differently 
     than other religions similarly situated without 
     violation of the Establishment Clause. 
Memorandum Opinion for the Chief Counsel, DEA, Dec. 22, 1981, at 403, 420 
(citation and footnote omitted), appended to Amicus Memo Before DEA, App. 
16. 

     [footnote 104]  Amicus Memo Before DEA at 32-33.  Amicus quoted 
Lawrence Tribe as stating that the government is in effect: 
     telling the individual that it knows what is best for 
     his body and mind.  Surely the individual may respond, 
     "I know what is best for my soul."  To allow the 
     government thus to impose the World of the Flesh upon 
     the World of the Spirit seems an overwhelming 
     abridgement of religious freedom. 
Id. at 32.  (quoting L. Tribe, American Constitutional Law 1269-70 (2d 
ed. 1988)). 

     [footnote 105]  Id. at 32. 

     [footnote 106]  Id. at 32-33. 

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     The government responded to Olsen's proposed EZCC exemption 

by stating that: 

     such restrictions could not be monitored or enforced 
     without significant intrusion by the Government into 
     the religious practices of the Church.  The monitoring 
     of such restrictions would be extremely burdensome on 
     an agency which is charged with enforcement of a very 
     comprehensive drug law. [footnote 107] 

     D.  The DEA Denies the Exemption 

     In a nine page decision, John Lawn denied the EZCC an exemption for 

the religious use of marijuana. [footnote 108]  Citing Leary, [footnote 

109] in addition to other cases, [footnote 110] the Administrator 

asserted that the EZCC had no free exercise right to use marijuana; 

moreover, it did not enjoy an "equal protection" right to an exemption 

because the EZCC "advocates the continuous use of marijuana or 'ganja', 

while the Native American Church's use of 
____________________

     [footnote 107]  Government Memorandum Before DEA, at 17.  Indeed, 
the government asserted that if the EZCC were granted its exemption, many 
of today's buyers and sellers would "find religion."  Government Brief 
Before CTA, Jan. 4, 1989, at 22.  Additionally, there would be no way to 
enforce the Saturday night exemption proposed by Olsen short of constant 
surveillance, requiring "Herculean efforts."  Id.  Amicus responded that 
it would be highly unlikely that large numbers of illegal drug users 
would come forward and identify themselves to the DEA hoping to obtain a 
religious drug exemption.  Amicus Reply Brief, Jan. 23, 1989, at 16. 

     [footnote 108]  DEA's Final Order, July 26, 1988, at 2. 

     [footnote 109]  383 F.2d 851 (5th Cir. 1971), rev'd on other 
grounds, 395 U.S. 6 (1969). 

     [footnote 110]  United States v. Spears, 443 F.2d 895 (5th Cir. 
1971), cert. denied, 404 U.S. 1020 (1972); United States v. Middleton, 
690 F.2d 820 (llth Cir. 1982), cert. denied, 460 U.S. 1051 (1983); United 
States v. Rush, 738 F.2d 497 (lst Cir. 1984), cert. denied, 471 U.S. 1120 
(1985); Olsen v. Iowa, 808 F.2d 652 (8th Cir. 1986). 

                                   28


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peyote is isolated to specific ceremonial occasions." [footnote 111]  The 

Administrator further distinguished marijuana from peyote stating that 

"the actual abuse and availability of marijuana in the United States is 

many times more pervasive in American society than that of peyote." 

[footnote 112]  Substantiating this claim, the Administrator stated that 

between 1980 and 1987, the DEA seized 19.4 pounds of peyote as compared 

to 15,302,468.7 pounds of marijuana. [footnote 113] 

     This overwhelming difference explains why an 
     accommodation can be made for a religious organization 
     which uses peyote in circumscribed ceremonies, and not 
     for a religion which espouses continual use of 
     marijuana.  The Administrator also notes that Mr. 
     Olsen's conviction in United States v. Rush involved 
     the illegal importation of 20 tons of marijuana....  If 
     Mr. Olsen's assertions that the Ethiopian Zion Coptic 
     Church in the United States has never had, "more than 
     between 100 and 200 members in this country," 20 tons 
     of marijuana would be an outrageous quantity to supply 
     their religious needs. [footnote 114] 

     Specifically addressing olsen's proposed exemption, the 

Administrator determined that the large quantity of marijuana in this 

country would make monitoring compliance very difficult and would make 

accommodation impractical. [footnote 115]  Olsen challenged the 
____________________

     [footnote 111]  DEA's Final Order, July 26, 1988, at 6-7. 

     [footnote 112]  Id. at 7-8. 

     [footnote 113]  Id. at 8. 

     [footnote 114]  Id. (citation omitted). 

     [footnote 115]  Id. at 8-9. 

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DEA's final order, requesting review by the court of appeals. [footnote 

116] 

     E.  The Court of Appeals Denies the Exemption 

     1.  The Majority 

     In June of 1989, the court of appeals, over a strongly worded 

dissent by Judge Buckley, denied Olsen both a free exercise right and an 

"equal protection-establishment clause" right to a religious-use 

exemption. [footnote 117]  Regarding Olsen's proposal, the majority found 

that because EZCC members were allowed to use marijuana "every day 

throughout the day," the proposal would not be "self-enforcing" and would 

require "burdensome and constant official supervision and management." 

[footnote 118]  Concerned with the EZCC's lack of stringent control over 

the sacramental use of marijuana in the past, the court noted that the 

"church's '[c]hecks on distribution of cannabis to 
____________________

     [footnote 116]  Olsen v. DEA, No. 86-1442, Motion To Establish 
Schedule For Briefing And Argument, Aug. 10, 1988.  Relying for the most 
part on its prior filings, Amicus argued that complete rejection of a 
marijuana exemption would violate both the establishment clause and the 
free exercise clause.  See Amicus Supplemental Brief, Dec. 1, 1988; 
Amicus Reply Brief, Jan 23, 1989. 

     [footnote 117]  Olsen v. DEA, 878 F.2d 1458 (D.C. Cir. 1989).  The 
case was argued before Circuit Judges Bader Ginsburg, Silberman, and 
Buckley.  Amicus was asked if he knew of any decisions where courts had 
held that the free exercise clause required government accommodation of 
religiously motivated conduct despite the government's position that 
accommodation posed a significant health risk.  In a subsequent letter to 
the court, counsel cited cases wherein people had been allowed to refuse 
medical treatment for religious reasons despite the state interest in 
preserving the health of	or even the life of the individual.  Amicus 
Letter to Court, Feb. 13, 1989, at 1-2.  In addition, Amicus cited the 
line of cases where state courts had found that a free exercise exemption 
for peyote was mandated despite the undisputed health risks.  Id. at 2. 

     [footnote 118]  878 F.2d at 1462. 

                                   30


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nonbelievers in the faith [were] minimal,' there was 'easy access to 

cannabis for a child who had absolutely no interest in learning the 

religion,' and '[m)embers [partook] of cannabis anywhere, not just within 

the confines of a church facility." [footnote 119]  Reviewing the 

"establishment clause-equal protection challenge," the court accorded 

great deference to the DEA and found that the EZCC is not similarly 

situated to the NAC, [footnote 120] because of the vast differences 

between peyote and marijuana regarding their demand, abuse, and 

availability. [footnote 121]  Resting its decision upon the "immensity of 

the marijuana control problem in the United States," the court refused to 

find an establishment clause violation and pointed out additional 

distinctions between the two religions: 

     1)  The peyote ritual is a traditional, precisely 
         circumscribed ritual; 

     2)  Peyote is itself an object of worship; 

     3)  Use of peyote outside of the ritual is sacrilegious 
         for the NAC; and 

     4)  The NAC, for all practical purposes other than the 
         special stylized ceremony, reinforces the state's 
____________________

     [footnote 119]  Id. at 1462 (quoting Town v. State ex rel. Reno, 377 
So.2d 648, 649, 651 (Fla. 1979)). 

     [footnote 120]  The court stated that had the government raised 
collateral estoppel in a timely fashion, it may have considered the equal 
protection-establishment clause issue precluded.  Id. at 1463 (citing 
Olsen v. Iowa, 808 F.2d 652, 653 (Sth Cir. 1986) (controlled and isolated 
NAC ceremony is different from EZCC's allowance of continuous and public 
use of sacrament regardless of age or occupation of member), and United 
States v. Rush, 738 F.2d 497, 513 (lst Cir. 1984) (NAC exemption is based 
on federal policy meant to confer a benefit on NAC which is sui 
generis)). 

     [footnote 121]  Id. at 1463-64. 

                                   31


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         prohibition. [footnote 122] 

The sharp contrast between the NAC and the EZCC was further evidenced by 

Olsen's statement that marijuana is smoked continually "through 

everything that we do." [footnote 123]  Again reviewing Olsen's proposed 

exemption, the court cryptically concluded that "'narrow' use, 

concededly, is not his religion's tradition." [footnote 124] 

     2.  Judge Buckley's Dissent 

     Judge Buckley dissented "because the majority fail[ed] to address 

the Establishment Clause implications of the Drug Enforcement Agency's 

rejection of Olsen's request for a limited religious exemption." 

[footnote 125]  The DEA's denial "creates a clear-cut denominational 

preference in favor of the Native American Church." [footnote 126] 

Application of strict scrutiny requires the DEA to show a compelling 

interest served by the denominational preference and to show that the 

different treatment was closely fitted to further that interest. 

[footnote 127]  Judge Buckley found that the 
____________________

     [footnote 122]  Id. 

     [footnote 123]  Id. (quoting State v. Olsen, 315 N.W.2d 1, 7 (Iowa 
1982)). 

     [footnote 124]  Id. 

     [footnote 125]  Id. at 1468.  Judge Buckley found it irrelevant that 
the NAC could be distinguished on the basis of the sui generis legal 
status of American Indians, stating, "[T]hat Church's status as an 
indigenous faith does not affect its religious character."  Id. at 1469. 

     [footnote 126]  Id. (quoting Larson v. Valente, 456 U.S. 228, 244 
(1982), and Everson v. Board of Educ., 330 U.S. 1, 15 (1947)). 

     [footnote 127]  Id. at 1468-69 (quoting Larson, 456 U.S. at 246-
47)).  Instead of using the Larson establishment clause analysis as urged 
by Judge Buckley which would have required strict scrutiny 

                                   32


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DEA's explanation fell "far short" of meeting the strict scrutiny 

standard. [footnote 128] 

     In fact, Judge Buckley found the DEA's reasoning to be extremely 

superficial in light of the Supreme Court decision of Larson v. Valente. 

[footnote 129]  In Larson, religious denominations in Minnesota receiving 

more than fifty percent of their funds from members and affiliated 

organizations were not required to comply with registration and reporting 

laws regarding their fund raising activities. [footnote 130]  This 

statute had the effect of granting a denominational preference to well-

established churches, and the Court applied strict scrutiny to 

Minnesota's well reasoned 
____________________

in view of the denominational preference, the majority relied on an equal 
protection analysis.  Id. at 1463-64 & n.5.  The majority cited Walz v. 
Tax Comm'n, 397 U.S. 664, 694, 696 (1970), for this proposition and Judge 
Buckley acknowledged that this analysis had been mentioned in a 
concurring opinion by Justice Frankfurter in Fowler v. Rhode Island, 345 
U.S. 67, 70 (1953).  878 F.2d at 1463 n.5, 1468.  However, both of these 
cases involved laws which applied equally to all religions.  The Walz 
Court examined the New York tax exemption law for religious, educational, 
or charitable uses, 397 U.S. at 666-67, while the Court in Fowler 
reviewed the constitutionality of a law that prohibited all religious 
meetings in any public park in Rhode Island.  345 U.S. at 67.  The Larson 
Court found this distinction critical, stating that the Lemon test 
applied to "laws affording a uniform benefit to all religions," while a 
law that discriminates among religions must "be invalidated unless it is 
justified by a compelling governmental interest and unless it is closely 
fitted to further that interest."  Larson, 456 U.S. at 246-47, 252 
(citations omitted).  Indeed, the Court in Gillette v. United States, 401 
U.S. 437 (1971), specifically stated that in the establishment clause 
cases, equal protection is not an independent argument.  Id. at 449 n.14. 

     [footnote 128]  878 F.2d at 1469. 

     [footnote 129]  456 U.S. 228 (1982). 

     [footnote 130]  Id. at 230. 

                                   33


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explanations as to how its registration and reporting exemption was 

closely fitted to furthering a compelling state interest. [footnote 131] 

While the Supreme Court agreed that Minnesota had a compelling state 

interest in protecting its citizens from abusive solicitation practices, 

it found that Minnesota had not demonstrated that the exemption was 

necessary to further that interest nor that the exemption was closely 

fitted to furthering the interest. [footnote 132]  Finding that the 

statutory exemption failed to pass a strict scrutiny analysis, the 

Supreme Court extended it to the Unification Church of Sun Myung Moon, 

holding that any bona fide religion would qualify for the exemption. 

[footnote 133] 

     Addressing the DEA's argument that the two religions warranted 

different treatment because of: 1) their differing sacramental drug use 

rituals; and 2) the different law enforcement problems vis a vis the two 

drugs, Judge Buckley asserted that Olsen's proposed exemption effectively 

eliminated the first distinction. [footnote 134]  Additionally, Judge 

Buckley challenged the DEA's argument that the abuse and availability of 

marijuana justified the disparate treatment: 
____________________

     [footnote 131]  Id. at 248-51. 

     [footnote 132]  Id. 

     [footnote 133]  See id. at 255.  The majority in Olsen had asserted 
that even if it were to find an establishment clause violation, it was 
not certain that extension rather than invalidation of the exemption was 
proper.  878 F.2d at 1464.  Judge Buckley retorted that such indecision 
could not excuse the court from properly reviewing an underinclusive 
statute.  Id. at 1471. 

     [footnote 134]  Id. at 1469-70. 

                                   34


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     The government's interest in preventing abuse of a 
     given drug is not proportional to the drug's 
     prevalence.  By classifying both marijuana and peyote 
     as Schedule I controlled substances, Congress has 
     determined that the federal government has a compelling 
     interest in preventing the illegal distribution and use 
     of both drugs. [footnote 135] 

     Noting that the DEA had no difficulty monitoring compliance of more 

than 250,000 members of the NAC, Judge Buckley questioned the DEA's lack 

of solid reasoning why monitoring compliance of one-hundred to two-

hundred EZCC members would be so impossible. [footnote 136]  Indeed, the 

exemption would place no restrictions on the DEA's normal enforcement 

operations other than at the church for a limited number of hours once a 

week. [footnote 137]  Judge Buckley stated that he would remand the case 

to the DEA so that it could more adequately review and address Olsen's 

establishment claim. [footnote 138] 

     The court of appeals denied Olsen's Petition for Rehearing and 

Suggestion For Rehearing En Banc. [footnote 139]  The Supreme Court 

denied Olsen's Certiorari Petition. [footnote 140] 
____________________

     [footnote 135]  Id. 

     [footnote 136]  Id. at 1471. 

     [footnote 137]  Id. 

     [footnote 138]  Id. at 1468. 

     [footnote 139]  Chief Judge Wald and Judge Buckley voted to grant 
the Suggestion.  Olsen v. DEA, No. 86-1442, Court Order, Sept. 15, 1989.  
Judge Buckley voted to grant the Petition For Rehearing as well.  Olsen 
v. DEA, No. 86-1442, Court Order, Sept. 15, 1989. 

     [footnote 140]  Olsen v. DEA, 110 S. Ct. 1926 (1990).  In the 
Petition For Writ Of Certiorari, Amicus argued that the D.C. Court of 
Appeals decision conflicted with the Supreme Court precedent which 
requires that strict scrutiny be applied whenever a 

                                   35

 
IV.  THE COURT OF APPEALS DECISION VIOLATES THE CONSTITUTION 

     The establishment clause prohibits both the state and federal 

government from passing laws which prefer one religion over another. 

[footnote 141]  Whether one adheres to the "broad" interpretation of the 

establishment clause or the "narrower" interpretation, all scholars agree 

that the establishment clause was meant by the framers to prevent the 

government from bestowing a preference on one religion; [footnote 142] 

and, as such, to protect the "small, new, or unpopular denominations" 

[footnote 143] from "subtle departures from neutrality, 'religious 

gerrymanders,' as well as 
____________________

"denominational preference" is conferred by governmental action.  Amicus 
Certiorari Petition, Dec. 13, 1989, at 9-14 (citing Larson v. Valente, 
456 U.S. 228 (1982)).  Moreover, Amicus argued that confusion surrounding 
the definition of "denominational preference" was arising, and courts 
needed guidance on when strict scrutiny should be applied.  Id. at 15-22. 
     In response, the government asserted that no free exercise, 
establishment, or equal protection rights had been violated because 
"DEA's exemption for religious peyote use in 21 C.F.R. § 1307.31 applies 
equally to all bona fide religious groups."  Respondent's Opposition To 
Petition For Writ Of Certiorari, Feb. 1990, at 9.  As a result, no 
denominational preference was created and the Lemon test as opposed to 
strict scrutiny was applicable.  Id. at 10.  Moreover, the government 
argued that the DEA's "considered professional judgment" concerning the 
burden of monitoring the exemption should not be questioned.  Id. at 12. 

     [footnote 141]  Everson v Board of Educ., 330 U.S. 1, 15 (1946).  
Before the fourteenth amendment was passed, some states persisted in 
discriminating against particular religions.  Id. at 13-14 & n.17. In 
North Carolina, test provisions required that officeholders believe in 
the Protestant religion, and Maryland permitted taxation for the support 
of Christian religion and limited civil office to Christians.  Id. at 14 
& n.17. 

     [footnote 142]  Thomas J. Curry, The First Freedoms 204-09 (1986).  
The church/state scholars differ as to how much government accommodation 
of religion was intended by the framers and early interpreters of the 
Constitution.  Id. 

     [footnote 143]  Larson, 456 U.S. at 244-45. 

                                   36


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obvious abuses. [footnote 144]  The EZCC is small, new to this country, 

and unpopular. [footnote 145]  As a result, the EZCC has been denied even 

the narrowest exemption for its sacrament while the NAC enjoys an 

unlimited exemption for peyote. 

     A.  Comparing The Two Exemptions 

     The majority stated that Olsen had proposed an exemption identical 

to the one accorded to the NAC. [footnote 146]  This is not true. 

Olsen's proposed exemption is very narrow, restricting the sacramental 

use of marijuana to three hours, one day per week. [footnote 147]  The 

exemption states that once the three hour worship service has finished, 

members may not leave the place where the ceremony was conducted for 

eight additional hours.  The exemption specifically prohibits members 

from driving or going out in public during that post-worship period. 

Only EZCC members who are of the age of majority may participate in the 

service and "membership" is 
____________________

     [footnote 144]  Gillette v. United States, 401 U.S. 437, 452 (1971) 
(citations omitted). 

     [footnote 145]  The total denial of an exemption to the EZCC has had 
tragic results for the members.  The EZCC has publicly stated: 
     Through ... the police force, the church has been 
     severely harassed, victimized and discriminated 
     against.  Our members have passed through several acts 
     of police brutality, our legal properties maliciously 
     destroyed, members falsely imprisoned, divine services 
     broken up, and all these atrocities performed upon the 
     Church, under the name of political laws and their 
     justice. 
1 The Coptic World, Dec. 19, 1987, at 8.  As the Court in Larson 
explained, the free exercise clause and the establishment clause work in 
close conjunction, the guarantees of one reinforcing the guarantees of 
the other.  Larson, 456 U.S. at 244-45. 

     [footnote 146]  878 F.2d at 1464. 

     [footnote 147]  See supra notes 94-96 and accompanying text. 

                                   37


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strictly construed. [footnote 148] 

     While the majority described the NAC exemption as "tightly-cabined," 

[footnote 149] nothing could be further from the truth.  The NAC 

exemption is unlimited; it states that "Schedule I does not apply to the 

nondrug use of peyote in bona fide religious ceremonies of the Native 

American Church." [footnote 150]  The only benefit strictly limited to 

"members" is a waiver of the registration requirement if the member 

manufactures or distributes peyote to the NAC. [footnote 151]  Other than 

that, the exemption does not limit participation in the peyote ceremony 

to church members or people of majority, nor does it restrict driving or 

even suggest a detoxification period.  Given the lack of any consensus on 

the meaning of "Native American Church," either among Native Americans or 

by those outside of the Church, and the widely diverging views on how the 

religious ceremony is to be conducted, [footnote 152] the peyote 

exemption is very broad, indeed. 

     The majority was quite concerned with how rigidly membership was 

enforced in the EZCC and whether membership was required before one was 

allowed to participate in the sacrament. [footnote 153]  But the majority 

failed to note that the NAC exemption is not limited 
____________________

     [footnote 148]  See supra notes 49-50, 94-96 and accompanying text. 

     [footnote 149]  878 F.2d at 1463. 

     [footnote 150]  See supra note 39 and accompanying text. 

     [footnote 151]  Id. 

     [footnote 152]  See supra notes 8-10 and accompanying text. 

     [footnote 153]  878 F.2d at 1462. 

                                   38


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