In United States v. Edison, (D MN, June 5, 2026), a Minnesota federal magistrate judge recommended that motions to dismiss filed by defendant in a criminal prosecution be denied. Defendant Bryan Edison was charged with sixteen counts of "animal crushing" in violation of the federal statute 18 USC §48(a)(1). According to the court:
The Indictment alleges in relevant part that Mr. Edison created and maintained YouTube channels on which he uploaded hundreds of videos depicting animals being crushed or tortured... The videos show him placing small live animals such as birds, hamsters, mice, guinea pigs, and rabbits into enclosures that contained larger live animals such as a snapping turtle, a monitor lizard, and a dog.... The Indictment alleges that the smaller animals were crushed, impaled, suffocated, and dismembered by the larger animals....
One of plaintiff's motions asserted that his alleged conduct is protected by the Religious Freedom Restoration Act. In rejecting that contention, the court said in part:
Mr. Edison does not clearly define his sincerely held religious belief, but the Court gathers from his motion that he believes a captive predator animal should be allowed to slaughter a prey animal for the purpose of providing food for human consumption. The Court arrives at this understanding of what he claims is a sincerely held religious belief by drawing on Mr. Edison's reference in his motion to the practice of "permitting a predator animal to slaughter a prey animal for the purpose of food," Mr. Edison's citation to a passage in the Quran supposedly allowing "the consumption of animals slaughtered by captive predator pets," and Mr. Edison's reference to the human consumption of rabbits and guinea pigs as food.... Mr. Edison does not claim, however, that he or any other person consumed, intended to consume, or would consume the animals slaughtered by the captive predator animals....
Mr. Edison has not shown that the Animal Crushing statute or this prosecution significantly inhibit or constrain his religious expression, meaningfully curtail his ability to express adherence to his faith, or deny him a reasonable opportunity to engage in an activity fundamental to his religion. Therefore, he has not established a substantial burden on his free exercise of religion....
