Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah

In Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah (1993), 508 U.S. 520, 531, 113 S. Ct. 2217, 124 L. Ed. 2d 472, the court held that the traditional association of animal sacrifice and religious worship rendered the practice by members of Santeria, a hybrid African/Catholic faith mandating animal sacrifice, worthy of First Amendment protection. Likewise, given the long, historical association of Native American spirituality with the prohibition against cutting one's hair, appellant's belief is "sufficiently rooted in religion" and is not "deemed bizarre or incredible." Id. See, also, Sutton v. Rasheed (C.A. 3, 2003), 323 F.3d 236, 252 (writings of Elijah Mohammad and Nation of Islam "sufficiently rooted in religion" to warrant protection).