Brief of Faith Leaders in Philadelphia and Beyond as Amici Curiae in Support of Defendant/Counterclaim Plaintiff Safehouse
Devin S. Sikes
SimpleOriginal

Summary

35 faith leaders say blocking Safehouse's overdose-prevention site violates their religious freedom. Their faiths command them to preserve life and show compassion to those in need.

2020 | Federal Juristiction

Brief of Faith Leaders in Philadelphia and Beyond as Amici Curiae in Support of Defendant/Counterclaim Plaintiff Safehouse

Keywords Safehouse; Religious Freedom Restoration Act (RFRA); overdose-prevention site; Philadelphia; Controlled Substances Act (CSA); religious freedom; overdose crisis; life-saving care; Judeo-Christian beliefs; preservation of human life

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.

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Summary

This amicus brief, submitted by 35 faith leaders, supports Safehouse's claim under the Religious Freedom Restoration Act (RFRA). The brief asserts that applying the Controlled Substances Act (CSA) to prevent Safehouse from operating an overdose-prevention site in Philadelphia would place a substantial burden on the deeply held religious convictions of its Judeo-Christian board members. These convictions are rooted in traditions that command the preservation of human life, the provision of life-saving care, and compassion toward individuals engaged in stigmatized or illicit conduct. The document outlines RFRA's strict-scrutiny framework, which mandates an assessment of a substantial burden, a compelling governmental interest, and the use of the least restrictive means. It posits that the government cannot challenge the religious centrality of these duties and must demonstrate that enforcing the CSA in this instance constitutes the least restrictive method to advance any compelling governmental interest, an aspect the brief contends has not been established. Drawing upon scripture, including Imago Dei, the directive to "love your neighbor," and Leviticus 19:16, as well as historical precedents such as early Christian rescue efforts, the faith-based origins of hospitals, and modern epidemic responses, the amici explain that prohibiting Safehouse's operations impedes adherents from fulfilling fundamental religious obligations to preserve lives amidst Philadelphia's critical overdose crisis. Because RFRA safeguards such religious exercise even against neutral, generally applicable laws, the brief concludes that the court should bar CSA enforcement that obstructs Safehouse's mission, thereby enabling the provision of crucial life-saving services to many Philadelphians.

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Summary

An amicus brief, submitted by 35 faith leaders, supports Safehouse’s claim under the Religious Freedom Restoration Act (RFRA). The brief asserts that using the Controlled Substances Act (CSA) to prevent Safehouse from operating an overdose-prevention site in Philadelphia would significantly interfere with the deeply held religious beliefs of Safehouse’s Judeo-Christian board members. These traditions emphasize the preservation of human life, the provision of life-saving care, and compassion for individuals involved in stigmatized or illicit activities.

The brief outlines RFRA’s strict-scrutiny framework, which requires a substantial burden on religious exercise, a compelling government interest, and the use of the least restrictive means. It argues that the government cannot question the religious importance of these duties and has not demonstrated that enforcing the CSA in this context is the least restrictive method to achieve any compelling interest. Citing both scripture, such as the concept of "Imago Dei" and the command to "love your neighbor," and historical examples, including early Christian rescue efforts and the religious origins of hospitals, the brief explains that prohibiting Safehouse’s operations prevents adherents from fulfilling fundamental religious obligations to save lives during Philadelphia’s severe overdose crisis. As RFRA protects such religious practices even from neutral laws, the court should prohibit CSA enforcement that impedes Safehouse's mission and permit it to offer vital, life-saving services to the community.

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Summary

A legal document, filed by 35 faith leaders, supports Safehouse’s claim under the Religious Freedom Restoration Act (RFRA). The filing argues that using the Controlled Substances Act (CSA) to prevent Safehouse from opening an overdose-prevention site in Philadelphia would significantly burden the sincere religious beliefs of Safehouse’s Judeo-Christian board members. Their traditions call for preserving human life, providing life-saving care, and showing compassion to those engaged in stigmatized or illegal conduct. The document outlines RFRA’s high legal standard, which requires the government to prove a religious practice is greatly burdened, that it has a compelling reason for its actions, and that it has chosen the least restrictive method. It asserts the government cannot second-guess the central role of these religious duties and must demonstrate that enforcing the CSA is the least restrictive way to achieve any compelling government interest, which it has failed to do. Citing religious texts and historical examples, the faith leaders explain that prohibiting Safehouse prevents its followers from fulfilling essential religious obligations to save lives during Philadelphia’s deadly overdose crisis. Because RFRA protects such religious exercise even against general laws, the court should block CSA enforcement that hinders Safehouse’s mission and allow it to provide crucial life-saving services for many Philadelphians.

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Summary

Thirty-five faith leaders have sent a legal paper to the court. This paper supports Safehouse’s request for religious freedom. They argue that if the government’s drug law stops Safehouse from opening a place to prevent overdoses in Philadelphia, it would greatly harm the true religious beliefs of Safehouse’s board members. These board members follow Judeo-Christian faiths. Their beliefs teach them to save human lives, give care that saves lives, and show kindness to people who are struggling or breaking rules.

The paper explains how religious freedom cases are decided. It says that the government cannot question how important these religious duties are to Safehouse's board members. The government must also show that stopping Safehouse is the only way to reach a very important goal. The faith leaders say the government has not shown this.

They use parts of their holy books and history to make their point. For example, they mention the idea that all people are valuable to God, the teaching to "love your neighbor," and how people of faith have historically helped those in need, like starting hospitals. They explain that not allowing Safehouse to open stops these leaders from doing what their faith tells them: saving lives during Philadelphia's deadly drug problem.

The paper concludes that religious freedom protects these actions, even when a law applies to everyone. So, the court should stop the government’s drug law from blocking Safehouse’s work. This would allow Safehouse to provide the life-saving help many people in Philadelphia need.

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Footnotes and Citation

Cite

Brief of Faith Leaders in Philadelphia and Beyond as Amici Curiae in Support of Defendant/Counterclaim Plaintiff Safehouse, United States v. Safehouse, 985 F.3d 225 (3d Cir. 2021) (No. 20-1422).

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