United States v. Meyers

In United States v. Meyers (10th Cir. 1996) 95 F.3d 1475, the United States Court of Appeals for the Tenth Circuit considered a defendant's claim as follows, "It is his sincere belief that his religion commands him to use, possess, grow and distribute marijuana for the good of mankind and the planet earth." In determining whether the defendant's beliefs were religious, the Tenth Circuit panel considered the following factors paralleling traditional religions: whether fundamental questions about "life, purpose, and death" were addressed; whether a reality transcending the physical world was addressed; whether a particular manner of acting or way of life was prescribed; whether the beliefs were founded or significantly influenced by a deity, teacher, seer, or prophet; whether seminal, elemental, fundamental, or sacred writings were embraced; whether there were clergy, ministers, priests, monks, or other keepers of knowledge; the existence of ceremonies and rituals; whether holidays were observed; whether physical appearance was addressed; and whether there was any mission work or proselytizing. ( Id. at pp. 1483-1484.) The court of appeals adopted the district court's analysis: " 'Marijuana's medical, therapeutic, and social effects are secular, not religious . . . . Here, the Court cannot give Meyers' 'religious' beliefs much weight because those beliefs appear to be derived entirely from his secular beliefs. In other words, Meyers' secular and religious beliefs overlap only in the sense that Meyers holds secular beliefs which he believes so deeply that he has transformed them into a 'religion.'While Meyers may sincerely believe that his beliefs are religious, this Court cannot rely on his sincerity to conclude that his beliefs rise to the level of a 'religion' and therefore trigger the Religious Freedom Restoration Act's protections. Meyers is, of course, absolutely free to think or believe what he wants. If he thinks that his beliefs are a religion then so be it. No one can restrict his beliefs, and no one should begrudge him those beliefs. None of this, however, changes the fact that his beliefs do not constitute a 'religion' as that term is uneasily defined by law. Were the Court to recognize Meyers' beliefs as religious, it might soon find itself on a slippery slope where anyone who was cured of an ailment by a 'medicine' that had pleasant side-effects could claim that they had founded a constitutionally or statutorily protected religion based on the beneficial 'medicine.' " ( Myers, 95 F.3d at p. 1484.)