How did Employment Division v. Smith influence Congress’s passage of the Religious Freedom Restoration Act?

In Employment Division v. Smith (1990), the Supreme Court held that the First Amendment’s free exercise clause does not require legislatures to grant religious exemptions from generally applicable, neutral laws. This decision effectively rejected the "compelling-interest" balancing test (also known as the Sherbert/Yoder test), which courts had previously used to determine if such laws unconstitutionally burdened religious practices.12

In direct response to Smith, Congress passed the Religious Freedom Restoration Act (RFRA) in 1993. By enacting this legislation, Congress sought to codify the compelling-interest test that the Supreme Court had abandoned. The RFRA mandated that the government could not substantially burden a person’s exercise of religion unless the action was in furtherance of a compelling governmental interest and represented the least restrictive means of achieving that interest. This statute later became the legal foundation for the Supreme Court's decision in Burwell v. Hobby Lobby Stores, Inc. (2014), which allowed certain for-profit corporations to claim religious exemptions from federal mandates.132