Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal

RFRA applies to sacramental use of a tea containing DMT and religious exemptions may be granted under RFRA’s compelling interest standard.

ReligiousLiberty.TV
February 26, 2026
2 min read
Year: 2006 Court: U.S. Supreme Court Outcome: Pro-Religion
Free Exercise
Holding: RFRA applies to sacramental use of a tea containing DMT and religious exemptions may be granted under RFRA's compelling interest standard.

Background

The UDV (União do Vegetal) is a Brazilian religious organization that uses hoasca (ayahuasca), a tea containing the controlled substance DMT, as a sacrament in its religious ceremonies. When the UDV sought to import and use hoasca for religious purposes in the United States, the federal government moved to prohibit this practice under the Controlled Substances Act, which classifies DMT as a Schedule I substance. The UDV challenged this prohibition, arguing that preventing their sacramental use of hoasca violated the Religious Freedom Restoration Act.

Legal Question

Whether the federal government's enforcement of the Controlled Substances Act against the UDV's sacramental use of hoasca violates the Religious Freedom Restoration Act, and whether the government can demonstrate a compelling interest that justifies substantially burdening the organization's sincere religious exercise.

Holding

The Supreme Court unanimously ruled in favor of the UDV, holding that the government failed to demonstrate a compelling interest sufficient to justify prohibiting the religious use of hoasca under RFRA's strict scrutiny standard. The Court found that the government must accommodate sincere religious exercise unless it can prove both a compelling governmental interest and that denial of the exemption is the least restrictive means of furthering that interest. The government's generalized concerns about drug enforcement and international treaty obligations were insufficient to overcome RFRA's demanding requirements.

Significance

This decision significantly strengthened religious liberty protections by demonstrating that RFRA provides robust protection for minority religious practices, even when they conflict with federal drug laws. The ruling established that the government cannot rely on broad categorical rules to deny religious exemptions but must instead demonstrate specific compelling interests on a case-by-case basis. This precedent has enabled other religious groups to successfully seek exemptions for controlled substance use in religious contexts and reinforced RFRA as a powerful tool for protecting religious minorities against government overreach.

Key Statutes & Provisions

  • Religious Freedom Restoration Act (RFRA)
  • Controlled Substances Act
  • First Amendment Free Exercise Clause
  • Compelling interest/least restrictive means standard (strict scrutiny)
  • International Single Convention on Narcotic Drugs

Official Documents

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Coverage on ReligiousLiberty.TV

📎 Document links found in our articles: 📄 opinion

Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal is a Free Exercise case decided by the U.S. Supreme Court in 2006. The court held that rFRA applies to sacramental use of a tea containing DMT and religious exemptions may be granted under RFRA's compelling interest standard. The case resulted in a Pro-Religion outcome.

## Background
The UDV (União do Vegetal) is a Brazilian religious organization that uses hoasca (ayahuasca), a tea containing the controlled substance DMT, as a sacrament in its religious ceremonies. When the UDV sought to import and use hoasca for religious purposes in the United States, the federal government moved to prohibit this practice under the Controlled Substances Act, which classifies DMT as a Schedule I substance. The UDV challenged this prohibition, arguing that preventing their sacramental use of hoasca violated the Religious Freedom Restoration Act.

## Legal Question
Whether the federal government’s enforcement of the Controlled Substances Act against the UDV’s sacramental use of hoasca violates the Religious Freedom Restoration Act, and whether the government can demonstrate a compelling interest that justifies substantially burdening the organization’s sincere religious exercise.

## Holding
The Supreme Court unanimously ruled in favor of the UDV, holding that the government failed to demonstrate a compelling interest sufficient to justify prohibiting the religious use of hoasca under RFRA’s strict scrutiny standard. The Court found that the government must accommodate sincere religious exercise unless it can prove both a compelling governmental interest and that denial of the exemption is the least restrictive means of furthering that interest. The government’s generalized concerns about drug enforcement and international treaty obligations were insufficient to overcome RFRA’s demanding requirements.

## Significance
This decision significantly strengthened religious liberty protections by demonstrating that RFRA provides robust protection for minority religious practices, even when they conflict with federal drug laws. The ruling established that the government cannot rely on broad categorical rules to deny religious exemptions but must instead demonstrate specific compelling interests on a case-by-case basis. This precedent has enabled other religious groups to successfully seek exemptions for controlled substance use in religious contexts and reinforced RFRA as a powerful tool for protecting religious minorities against government overreach.

## Key Statutes & Provisions
– Religious Freedom Restoration Act (RFRA)
– Controlled Substances Act
– First Amendment Free Exercise Clause
– Compelling interest/least restrictive means standard (strict scrutiny)
– International Single Convention on Narcotic Drugs