United States v. Timothy Anderson
2017 U.S. App. LEXIS 7333
| 8th Cir. | 2017Background
- Anderson was indicted on one count of possession with intent to distribute heroin and one count of conspiracy to distribute heroin.
- Anderson filed a pretrial motion to dismiss the indictment arguing RFRA barred prosecution under the CSA.
- The district court assumed the distribution was a sincere religious practice burdened by law, but upheld the CSA prosecution as the least restrictive means to a compelling interest.
- The district court barred Anderson from presenting RFRA as a defense to the jury.
- The jury convicted Anderson on both counts and he was sentenced to 324 months’ imprisonment.
- Anderson appeals the denial of the RFRA motion and the exclusion of RFRA from trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| RFRA applicable as defense | Anderson (RFRA) argues the government burdened religion improperly. | Government contends RFRA applies but is satisfied by least restrictive means. | RFRA defense properly rejected as matter of law. |
| Compelling interest and least restrictive means | RFRA requires government to show compelling interest and least restrictive means as applied to Anderson. | CSA enforcement to prohibit heroin distribution serves compelling interest and is least restrictive. | Court held government had compelling interest and used least restrictive means. |
| Jury presentation of RFRA defense | Anderson must be allowed to present RFRA defense to jury. | Court may foreclose RFRA defense where law is shown to be least restrictive means. | Court affirmed denial of presenting RFRA defense to jury. |
Key Cases Cited
- United States v. Ali, 682 F.3d 705 (8th Cir. 2012) (RFRA permit to raise defense where religion burdened)
- Gonzales v. O Centro Espirita Beneficiente Uniao do Vegetal, 546 U.S. 418 (S. Ct. 2006) (RFRA requires person-specific compelling interest)
- United States v. Christie, 825 F.3d 1048 (9th Cir. 2016) (compelling interest and least restrictive means in distribution context)
- Burwell v. Hobby Lobby Stores, Inc., 134 S. Ct. 2751 (Sup. Ct. 2014) (least restrictive means in RFRA analysis)
- In re Young, 82 F.3d 1407 (8th Cir. 1996) (compelling governmental interest and least restrictive means inquiries are legal questions)
- Christians v. Crystal Evangelical Free Church, 521 U.S. 1114 (1997) (RFRA-related considerations on review)
- Quaintance, 523 F.3d 1144 (8th Cir. 2008) (RFRA defense requires evidentiary showing of sincerity)