Carey v. Dixie Inn

Carey v. Dixie Inn, 101 M.S.Ct. 112 (2020), was a decision of the United States Supreme Court on February 8, 2020, that pertained to whether the Free Exercise Clause of the invalidated a Dixie racial non-discrimination ordinance that acted to deprive a motel operator of her religious freedom to act in her religious command to uphold. A unanimous court (with Chief Justice IAMATinman and Justice NEALN not participating) overturned the decision of the Supreme Court of Dixie for the motel operator and determined instead that the First Amendment did not offer Dixie Inn a remedy against a valid and neutral law of general applicability.

However, the Supreme Court also affirmed the lower court's use of while modifying the test for free exercise purposes.

Reactions to the Ruling
The announcement of the ruling was met with swift condemnation by a variety of politicians. Attorney General Dewey Cheatem issued a Department of Justice memorandum criticizing the ruling, asserting that it was plagued by "fatal errors." Senator Prelate Zertaul (R-DX) took to Twitter to make a variety of objections to the decision including the tone, which he called "unbecoming and beneath the dignity of the Supreme Court," the lengthy delay in issuing the decision, and failure to address to the ruling of the court below. Counsel for the Respondents, BSDDC, criticized the decision for inappropriately resolving questions of state law, its "flippant and disrespectful" tone, and failure to address several of the Respondents' arguments.

Subsequent Developments
Due to lack of clarity in the Court's decision, an ongoing legal debate exists over whether the use of strict scrutiny in religious freedom cases is a binding holding or simply . Three states--Atlantic (BirackObama v. TheCloudCappedStar), Chesapeake (Singh v. Pythagoras Academies), and Dixie (In Re B.092 - End Childhood Marriage Act) have held that Dixie Inn established that strict scrutiny applies to free exercise claims. Meanwhile, Sierra (In re: San Francisco Resolution No. 190841, In Re: California Code, Penal Code PEN § 281) has refused to apply the standard to cases since Dixie Inn.

In In re: FDA Blood Donation Guidance and Related Regulations, 101 M.S.Ct. 115 (2020), the Supreme Court attempted to clarify its ruling in Dixie Inn but failed to resolve the disagreements surrounding the case. In FDA Blood Donation Guidance the Court held that it "fully reaffirm[ed] the test as articulated today regardless of any concern our decision in the Dixie Inn matter altered that analysis." The Court also stated that the Sierra court in In re: San Francisco Resolution No. 190841 was "entirely correct" but failed to specify what the Sierra court was "entirely correct" about with regard to the strict scrutiny analysis.

In a later development, the United States Congress codified its opposition to the application of strict scrutiny in civil rights cases by enacting the Robert Carey and Sharon Edwards Equality in Public Accommodations Act within the Civil Rights Act of 2020, which amended the federal to exempt the enforcement of civil rights statutes from its protections.