This amicus brief—filed by 35 faith leaders—supports Safehouse’s Religious Freedom Restoration Act (RFRA) claim, arguing that applying the Controlled Substances Act (CSA) to block Safehouse’s overdose-prevention site in Philadelphia would substantially burden the sincerely held religious beliefs of Safehouse’s Judeo-Christian board members, whose traditions command the preservation of human life, the provision of life-saving care, and compassion toward people engaged in stigmatized or illicit conduct. After outlining RFRA’s strict-scrutiny framework—substantial burden, compelling interest, and least-restrictive means—the brief contends the government may not second-guess the religious centrality of these duties and must show that enforcing the CSA here is the least restrictive way to advance any compelling interest, which it has not done. Drawing on scripture (e.g., Imago Dei, “love your neighbor,” Leviticus 19:16) and history (from early Christian rescue of abandoned infants to faith-fueled origins of hospitals and modern epidemic responses), amici explain that refusing to permit Safehouse prevents adherents from performing core religious obligations to save lives amid Philadelphia’s lethal overdose crisis. Because RFRA protects such exercise even against neutral, generally applicable laws, the court should bar CSA enforcement that impedes Safehouse’s mission and allow it to provide the life-saving services many Philadelphians need.
2020 | Federal Juristiction