<P> During the twentieth century, many major cases involving the Free Exercise Clause were related to Jehovah's Witnesses . Many communities directed laws against the Witnesses and their preaching work . From 1938 to 1955, the organization was involved in over forty cases before the Supreme Court, winning a majority of them . The first important victory came in 1938, when in Lovell v. City of Griffin, the Supreme Court held that cities could not require permits for the distribution of pamphlets . In 1939, the Supreme Court decided Schneider v. Town of Irvington, in which it struck down anti-littering laws that were enforced only against Jehovah's Witnesses who were handing out pamphlets . In 1940, the Court considered Cantwell v. Connecticut; the plaintiff, a Jehovah's Witness, was charged with soliciting donations without a certificate from the Public Welfare Council . The Council was to grant the certificate only if the organization requesting it was a charity or sponsored a religious cause . The Supreme Court ruled that any law granting a public body the function of determining if a cause is religious or not violates the First Amendment . </P> <P> In 1940, the Supreme Court would decide in Minersville School District v. Gobitis that members of the Jehovah's Witnesses in a school could be required to salute the flag . The ruling in Gobitis, however, did not stand for long . In 1943, West Virginia State Board of Education v. Barnette, the Supreme Court essentially reversed its previous opinion . Justice Frankfurter had, in the Gobitis case, suggested that the Witnesses attempt to reverse the School Board's policy by exercising their vote . In the Barnette case, however, Justice Robert H. Jackson wrote, "the very purpose of the Bill of Rights was to withdraw certain subjects from the vicissitudes of political controversy, to place them beyond the reach of majorities...One's right to life, liberty, and property, to free speech, a free press, freedom of worship and assembly, and other fundamental rights may not be submitted to vote ." The Supreme Court did not rule that the Pledge was unconstitutional; rather, they held that students may not be compelled to recite it . </P> <P> The Supreme Court under Earl Warren adopted an expansive view of the Free Exercise Clause . In, Sherbert v. Verner (1963) the Court held that states must have a "compelling interest" to refuse to accommodate religiously motivated conduct . The case involved Adele Sherbert, who was denied unemployment benefits by South Carolina because she refused to work on Saturdays, something forbidden by her Seventh - day Adventist faith . In Wisconsin v. Yoder (1972), the Court ruled that a law that "unduly burdens the practice of religion" without a compelling interest, even though it might be "neutral on its face," would be unconstitutional . </P> <P> The "compelling interest" doctrine became much narrower in 1990, when the Supreme Court held in Employment Division v. Smith that, as long as a law does not target a particular religious practice, it does not violate the Free Exercise Clause . In 1993, the Supreme Court revisited the Free Exercise Clause in Church of Lukumi Babalu Aye v. City of Hialeah . Hialeah had passed an ordinance banning ritual slaughter, a practice central to the Santería religion, while providing exceptions for some practices such as the kosher slaughter of Judaism . Since the ordinance was not "generally applicable," the Court ruled that it was subject to the compelling interest test, which it failed to meet, and was therefore declared unconstitutional . </P>

When can the free exercise of religion be limited