The fight over religious accommodation between Congress and the courts started with Employment Division v. Smith, the 1990 case in which the Supreme Court decided that if a state law prohibits a religious ritual—say, peyote smoking or animal sacrifice—the faithful have to comply with the law just like the heathens. Congress tried to respond to Smith by requiring the states and the federal government to make religious exceptions to generally applicable laws. After the Supreme Court clipped back that statute, Congress came back with the more modest law upheld in Cutter.