Court Rejects RFRA Defense To Charges of Illegal Importation of Animal Parts

In United States v. Manneh, 2008 U.S. Dist. LEXIS 105209 (D NY, Dec. 31, 2008), a New York federal district court refused to dismiss an indictment against Mamie Manneh who was charged with importing parts of endangered African primates without the permit required by the Convention on International Trade in Endangered Species and failing to disclose to border officials the true nature of the product she was importing. Manneh, a Liberian immigrant, argued that her prosecution violated her rights under the Religious Freedom Restoration Act. She claims that bush meat is sacred to her. The court found that Manneh's religious claim was not sincere, but instead was merely pretextual. It concluded that even if her beliefs about bush meat were sincere, there was nothing in them that prevented her from disclosing the nature of her imports or applying for the required import license. Friday's New York Daily News reported on the decision. (See prior related posting.)