In Santeria Sanctuary v. Madison County, Tennessee, (WD TN, Dec. 2, 2021), a Tennessee federal district court applied the Younger abstention doctrine and stayed a federal civil suit while state criminal court proceedings are under way against a Santeria priestess who is under indictment on 676 counts of cruelty to animals. According to the court, plaintiffs claims under RLUIPA and the Tennessee Religious Freedom Restoration Act:
center on Defendants destruction of the Sanctuary and their forced entry into the house of worship during a religious ceremony, along with their seizure of tithes and offerings in violation of the Plaintiffs’ First Amendment right to free exercise of religion.... In addition, Plaintiffs contend the County officers raid on the property, as well as an unlawful search and seizure of money and animals, violates Plaintiffs’ Fourth Amendment rights.... Plaintiffs further maintain that such actions by Defendants imposed substantial burdens on the Plaintiffs by forcing them and the adherents of the Sanctuary to forego the practice of their religious precepts—namely, the sacrifice of live animals....
