Animal Crushing Not Protected By RFRA

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....

Ban on Feeding Feral Animals Did Not Violate Plaintiff's Free Exercise Rights

In Barroca v. Hayward Area Recreation and Parks District, (ND CA, Feb. 23, 2026), a California federal district court dismissed all but a selective prosecution claim in a suit involving activities at a public park in Hayward, California.  Plaintiff, a lover of cats, regularly fed feral and neighborhood cats in the park in violation of an ordinance prohibiting the feeding of wild or feral animals.  He also regularly, to little avail, asked authorities to enforce against dog owners the ordinance requiring dogs in the park to be on leashes. Plaintiff sued the park district and park rangers alleging failure to perform mandatory duties under California law and violations of the Fourteenth, Fourth, and First Amendment.  

One of plaintiff's claims was that the no-feeding ordinance violated his 1st Amendment free-exercise rights. In dismissing that claim, the court said in part:

Plaintiff alleges that under his Catholic faith and the teachings of St. Francis of Assisi, he believes he has “a duty to God to take care of and love all of God’s animals.” ...  Due to these religious beliefs, Plaintiff “takes care of, feeds, shelters, provides medical needs, spay and neuters, play, love, and protect these cats and all of God’s animals.”  ... Plaintiff has alleged that this park ordinance interferes with his ability to feed cats within Meek Park, thus burdening his religious duty to take care of animals, specifically, the cats that frequent Meek Park. 

HARD Ordinance 19(b) is neutral and generally applicable.  Any burden it places on Plaintiff’s ability to exercise his religious beliefs in caring for animals is incidental.  Since the law is neutral and generally applicable, Plaintiff must show that it is not rationally related to any conceivable legitimate government purpose.  But there are many potential legitimate bases for the rule: for example, feeding wild or feral animals attracts them to the park, increasing the risk of conflict with parkgoers and their pets, and the spread of disease.  Since the rule has a conceivable legitimate basis, Plaintiff’s free exercise claim fails.

Various other claims against the park district and park rangers were also dismissed.

Court In India Says Elephant's Welfare Takes Precedence Over Its Use in Religious Rites

In  Bhattarak v. Union of India, (Bombay High Ct., July 16, 2025), a 3-judge panel of the High Court of Bombay in India upheld an order issued by Indian officials to a Trust operated by a Jain religious organization requiring the transfer of an elephant owned by the Trust to the Radhe Krishna Temple Elephant Welfare Trust, an elephant care center. Petitioner contended, among other things, that the elephant was used for Jain religious ceremonies. The court said in part:

Before we part, we deem it appropriate to record that we have considered and chosen the survival of the elephant and its right to quality life, over and above the rights of men to use the elephant for religious rites.  We have no doubt that the Petitioner-Math may have had no deliberate intent to cause injury to the elephant however, in the given circumstances of conflict between the rights of an elephant and the rights of Petitioner-Math to use the elephant in the discharge of its religious activities, priority must be given to the elephant’s welfare. The Court has duty under the doctrine parens patriae to secure the rights of the voiceless and hapless Mahadevi.  We cannot but reminisce the words of Lawrence Anthony in his book ‘The Elephant Whisperer’, 

“But perhaps the most important lesson I learned is that there are no walls between humans and the elephants except those that we put up ourselves, and that until we allow not only elephants, but all living creatures their place in the sun, we can never be whole ourselves.” 

Live Law reports on the decision.