<P> Accommodationists, in contrast, argue along with Justice William O. Douglas that "(w) e are a religious people whose institutions presuppose a Supreme Being". This group holds that the Lemon test should be applied selectively . As such, for many conservatives, the Establishment Clause solely prevents the establishment of a state church, not public acknowledgements of God nor "developing policies that encourage general religious beliefs that do not favor a particular sect and are consistent with the secular government's goals ." </P> <P> "Freedom of religion means freedom to hold an opinion or belief, but not to take action in violation of social duties or subversive to good order ." In Reynolds v. United States (1878), the Supreme Court found that while laws cannot interfere with religious belief and opinions, laws can be made to regulate some religious practices (e.g., human sacrifices, and the Hindu practice of suttee). The Court stated that to rule otherwise, "would be to make the professed doctrines of religious belief superior to the law of the land, and in effect permit every citizen to become a law unto himself . Government would exist only in name under such circumstances ." In Cantwell v. Connecticut (1940), the Court held that the Due Process Clause of the Fourteenth Amendment applied the Free Exercise Clause to the states . While the right to have religious beliefs is absolute, the freedom to act on such beliefs is not absolute . </P> <P> In Sherbert v. Verner (1963), the Supreme Court required states to meet the "strict scrutiny" standard when refusing to accommodate religiously motivated conduct . This meant that a government needed to have a "compelling interest" regarding such a refusal . 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 need for a compelling governmental interest was narrowed in Employment Division v. Smith (1990), which held no such interest was required under the Free Exercise Clause regarding a neutral law of general applicability that happens to affect a religious practice, as opposed to a law that targets a particular religious practice (which does require a compelling governmental interest). In Church of Lukumi Babalu Aye v. City of Hialeah (1993), the Supreme Court ruled 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 . Since the ordinance was not "generally applicable", the Court ruled that it needed to have a compelling interest, which it failed to have, and so was declared unconstitutional . </P>

What does speech mean in the first amendment