impose its own interpretation on states and localities. Congress can enact legislation to expand First Amendment free exercise rights through its enforcement powers in Section 5 of the Fourteenth Amendment, but to do so "there must be a congruence and proportionality between the injury to be prevented or remedied and the means adopted to that end." The decision in City of Boerne struck down the Religious Freedom Restoration Act RFRA in so far as it applied to states and other local municipalities within them., so that partly in response to it 21 states enacted State Religious Freedom Restoration Acts since 1993. According to the court's ruling in Gonzales v. UDV (2006), RFRA remains applicable to federal laws and so those laws must still have a "compelling interest." RFRA secures Congress’ view of the right to free exercise under the First Amendment, and it provides a remedy to redress violations of that right. The Supreme Court decided in light of this in Tanzin v. Tanvir (2020) that the Religious Freedom Restoration Act's express remedies provision permits litigants, when appropriate, to obtain money damages against federal officials in their individual capacities. This decision is significant "not only for the plaintiffs but also for cases involving violations of religious rights more broadly." In the 1982 U.S. Supreme Court case United States v. Lee (1982) (1982) the Court declared: "Congress and the courts have been sensitive to the needs flowing from the Free Exercise Clause, but every person cannot be shielded from all the burdens incident to exercising every aspect of the right to practice religious beliefs. When followers of a particular sect enter into commercial activity as a matter of choice, the limits they accept on their own conduct as a matter of conscience and faith are not to be superimposed on the statutory schemes which are binding on others in that activity." The Supreme Court in Estate of Thornton v. Caldor, Inc. (1985) echoed this statement by quoting Judge Learned Hand from his 1953 case Otten v. Baltimore & Ohio R. Co., 205 F.2d 58, 61 (CA2 1953): "The First Amendment ... gives no one the right to insist that, in pursuit of their own interests others must conform their conduct to his own religious necessities." In Burwell v. Hobby Lobby Stores, Inc. (2014) the Supreme Court had to decide, with a view to the First Amendment's Free Exercise Clause and the