y but nevertheless placing a substantial burden on the free exercise of an individual's religion (494 U.S. 872. 1990). This decision was voiced by Justice Stevens (485 U.S. 660, 1988).
The Smith majority stated: "the right to free exercise does not relieve an individual of the obligation to comply with a valid and neutral law of general applicability on the ground that the law proscribes . . . conduct that his religion prescribes" (Smith, 494 U.S. at 872). The Smith decision demonstrates the Rehnquist Court's trend toward curtailing the free exercise of religion (Boerne, No. 95 2074, 1997 U.S. LEXIS 4035).
In Jehovah's Witnesses v. King County Hospital, 348 the Supreme Court, applying Prince v. Massachusetts, affirmed a district courts ruling mandating that a child of Jehovah's Witness parents receive an emergency blood transfusion (278 F. Supp. 488 (W.D. Wash. 1967), 321 U.S. 158).
Over the parents' due process and free exercise objections, the district court found the parent's conduct not constitutionally protected (Jehovah's Witnesses, 390 U.S. 598
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