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. An ongoing legal debate exists over whether the use of strict scrutiny in religious freedom cases is a binding holding or simply . Such cases have been held to strict scrutiny in Atlantic (BirackObama v. TheCloudCappedStar) and Chesapeake (Singh v. Pythagoras Academies), while Sierra (In re: San Francisco Resolution No. 190841) has refused to apply the standard to cases since Dixie Inn.

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.