United States District Court

George Eldridge was first awarded Social Security disability benefits in June 1968. In March 1972 he received a questionnaire from the state agency charged with monitoring his medical condition. He completed and returned the questionnaire, indicating that his condition had not improved and identifying recent medical sources. The state agency obtained reports from his physician and a psychiatric consultant. After reviewing those reports and other information in his file, the agency sent Eldridge a letter stating that it had made a tentative determination that his disability had ceased in May 1972. The letter included a statement of reasons for the proposed termination and advised Eldridge that he could request time to submit additional information. Eldridge responded in writing, disputing one characterization of his medical condition and asserting that the agency already possessed sufficient evidence of his disability. The state agency then made a final determination that Eldridge had ceased to be disabled in May 1972; the Social Security Administration accepted that determination. In July 1972 Eldridge received written notice that his benefits would terminate after that month and that he could seek reconsideration by the state agency within six months. Instead of requesting reconsideration, Eldridge filed suit in the United States District Court for the Western District of Virginia. He challenged the constitutionality of the Secretary's termination procedures and sought an injunction barring termination of benefits until a pretermination evidentiary hearing was provided, together with immediate reinstatement of benefits. The District Court held that the existing procedures violated the Fifth Amendment's Due Process Clause, ordered the Secretary to provide Eldridge a pretermination hearing, and directed reinstatement of benefits pending that hearing. The Court of Appeals for the Fourth Circuit affirmed. The Supreme Court noted probable jurisdiction and heard the case.

St. Peter Catholic Church was built in 1923 in Boerne, Texas. Its structure replicates the mission style of the region's earlier history. The church seats about 230 worshippers, a number too small for its growing parish. Some 40 to 60 parishioners cannot be accommodated at some Sunday masses. To meet the needs of the congregation, the Archbishop of San Antonio gave permission to the parish to plan alterations to enlarge the building. A few months later, the Boerne City Council passed an ordinance authorizing the city's Historic Landmark Commission to prepare a preservation plan with proposed historic landmarks and districts. Under the ordinance, the commission must preapprove construction affecting historic landmarks or buildings in a historic district. Soon afterwards, the Archbishop applied for a building permit so construction to enlarge the church could proceed. City authorities, relying on the ordinance and the designation of a historic district which they argued included the church, denied the application. The Archbishop brought this suit challenging the permit denial in the United States District Court for the Western District of Texas. The complaint contained multiple claims, but to this point the litigation has centered on RFRA and the question of its constitutionality. The District Court concluded that by enacting RFRA Congress exceeded the scope of its enforcement power under section 5 of the Fourteenth Amendment. The court certified its order for interlocutory appeal and the Fifth Circuit reversed, finding RFRA to be constitutional. The Supreme Court granted certiorari and now reverses. Congress enacted RFRA in direct response to the Court's decision in Employment Div., Dept. of Human Resources of Ore. v. Smith. RFRA prohibits government from substantially burdening a person's exercise of religion even if the burden results from a rule of general applicability. Unless the government can demonstrate that the burden is in furtherance of a compelling governmental interest, it must also show that the burden is the least restrictive means of furthering that interest. The Act applies to all federal and state law, and the implementation of that law, whether statutory or otherwise, and whether adopted before or after the enactment of RFRA.

On February 6, 1963, petitioner, a citizen of Ohio, filed her complaint in the District Court for the District of Massachusetts, claiming damages in excess of $10,000 for personal injuries resulting from an automobile accident in South Carolina, allegedly caused by the negligence of one Louise Plumer Osgood, a Massachusetts citizen deceased at the time of the filing of the complaint. Respondent, Mrs. Osgood's executor and also a Massachusetts citizen, was named as defendant. On February 8, service was made by leaving copies of the summons and the complaint with respondent's wife at his residence, concededly in compliance with Rule 4 (d) (1). Respondent filed his answer on February 26, alleging, inter alia, that the action could not be maintained because it had been brought contrary to and in violation of the provisions of Massachusetts General Laws Chapter 197, Section 9. On October 17, 1963, the District Court granted respondent's motion for summary judgment. On appeal, the Court of Appeals for the First Circuit affirmed. The Supreme Court granted certiorari because of the threat to the goal of uniformity of federal procedure posed by the decision below.