People v. Woody

In People v. Woody (1964) 61 Cal. 2d 716, the California Supreme Court used a strict scrutiny standard of review to conclude that the application of a criminal statute to convict defendants who were Navajos using peyote in a bona fide religious practice violated their First Amendment rights because their religious practice did not frustrate a compelling state interest. ( Woody, supra, 61 Cal. 2d at pp. 717, 727.) Although the defendants also claimed the criminal statute violated their free exercise rights under the California Constitution ( id. at p. 718, fn. 1), Woody did not evaluate this state claim separately from the federal claim or determine whether strict scrutiny applies to a state claim regardless of the standard of review applied to the federal claim.