In the early 1990s the United States Supreme Court decided two cases that hinged upon a conflict between religious freedom and criminal activity.

The first case was Employment Division, Department of Human Resources of Oregon v. Smith. The individuals involved in this proceeding were members of the Native American Church.

This denomination was organized in Oklahoma in 1918. One of its rites, however, dated from several years earlier. That practice was the use of a hallucinogenic drug called peyote.

In the late 19th century, many Native American men used peyote to help them perform a ritual cal...