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Following '' Employment Division V. Smith '', the lower courts deemed the law to have a legitimate and rational government purpose and therefore upheld the enactment. The Supreme Court, however, held that because the law was targeted at this religion it is not subject to an undemanding Rational Basis Test : rather, it must be justified by a compelling governmental interest, and must be narrowly tailored to advance that interest. Because the ordinance did not meet this standard, it was unconstitutional.


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