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Notice that in ''[[City of Boerne v. Flores]]'' (1997), the [[U.S. Supreme Court]] invalidated the RFRA to the extent it applied against the states.  [[Congress]] reacted by passing the Religious Land Use and Institutionalized Persons Act (RLUIPA) in 2000.
 
Notice that in ''[[City of Boerne v. Flores]]'' (1997), the [[U.S. Supreme Court]] invalidated the RFRA to the extent it applied against the states.  [[Congress]] reacted by passing the Religious Land Use and Institutionalized Persons Act (RLUIPA) in 2000.
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Overall, the U.S. Supreme Court has issued a dozen decisions mentioning RFRA between 1994 and the end of 2015, with the most recent rank first:
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Overall, the U.S. Supreme Court has issued a dozen decisions mentioning RFRA between 1994 and the end of 2015, with the most recent ranking first:
    
*''Holt v. Hobbs'', 135 S. Ct. 853
 
*''Holt v. Hobbs'', 135 S. Ct. 853
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*''Swanner v. Anchorage Equal Rights Comm'n'', 513 U.S. 979 (1994) (in a denial of [[certiorari]], Justice Thomas mentioned RFRA in his solitary dissent "to resolve whether, under RFRA, an interest in preventing discrimination based on marital status is sufficiently 'compelling' that respondent may substantially burden petitioner's exercise of religion")
 
*''Swanner v. Anchorage Equal Rights Comm'n'', 513 U.S. 979 (1994) (in a denial of [[certiorari]], Justice Thomas mentioned RFRA in his solitary dissent "to resolve whether, under RFRA, an interest in preventing discrimination based on marital status is sufficiently 'compelling' that respondent may substantially burden petitioner's exercise of religion")
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The U.S. Court of Appeals, meanwhile, has issued close to 2000 decisions mentioning RFRA during this same two-decade period.
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The U.S. Court of Appeals, meanwhile, has issued nearly 2000 decisions mentioning RFRA during this same two-decade period.
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There are more than twice as many precedents on the [[Religious Land Use and Institutionalized Persons Act]], which applies the same compelling interest/least restrictive means test against state and local governments with respect to land use and institutional facilities such as prisons.
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== References ==
 
== References ==
 
<references/>
 
<references/>
 
[[category:First Amendment]]
 
[[category:First Amendment]]
 
[[category:RFRA]]
 
[[category:RFRA]]
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