Washington v. Balzer
In Washington v. Balzer, 91 Wn. App. 44, 954 P.2d 931, 941 (Wash. App. 1998), after finding a compelling governmental interest, the court considered whether the state had met its burden of demonstrating that a total ban of marijuana was the least restrictive means of achieving its objective. 954 P.2d at 941.
Considering only the logic of the situation, the court determined that any "carving out" to accommodate the religious practices in question would effectively render the laws meaningless. Id.
The court refused to create "a constitutional safe harbor for marijuana use because there is no realistic or sensible less restrictive means to enforce or regulate the use of marijuana." Id.