United States v. Lafley

A supervised release condition that prohibits the use of a controlled substance by a convicted drug felon does not violate the Religious Freedom Reformation Act because it serves a compelling government interest using the least restrictive means.

Petitioner appeals a trial court ruling that does not allow him to smoke marijuana under the terms of his post-prison supervision release, arguing that such a provision burdens his religious beliefs as a member of the Montana Cannabis Ministries. Lafley, a convicted methamphetamine dealer on supervised release, received a medical marijuana card and admitted to smoking marijuana, stating that he was "spiritually moved at the time." Petitioner appeals under the Religious Freedom Reformation Act, which provides that the government may only "substantially burden a person's exercise of religion" if doing so "(1) is in furtherance of a compelling government interest; and (2) is the least restrictive means of furthering that . . . interest." Citing Congressional mandates denying the use of a controlled substance while on supervised release, the Court determined "[t]he government has a compelling interest in denying a convicted drug felon a religious exemption that would permit him to use drugs." The Court rejected Lafley's argument that less restrictive means, including self-reporting and more specific drug tests, would serve the intended purpose or create less of a burden on the probation department.