City of Boerne v. Flores

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In City of Boerne v. Flores, 521 U.S. 507, 529-36 (1997), the U.S. Supreme Court partially struck down the previously enacted Religious Freedom Restoration Act on the grounds that it exceeded Congress' power to regulate the states under the Fourteenth Amendment. The Court held that RFRA may not be applied to purely state, as opposed to federal, action.

Congress enacted the RLUIPA in 2000 as a response to this decision.