the states, exceeded Congress's power under Section 5 of the Fourteenth Amendment. But the ruling did not necessarily limit RFRA's effect on interpretation of federal statutes. Using a parliamentary procedure known as unanimous consent, both the House and the Senate re-enacted RFRA's provisions in 2000, in conjunction with adding a similar statutory test to the Religious Land Use and Institutionalized Persons Act (RLUIPA). Without addressing RFRA's constitutionality, the Supreme Court has held, in Gonzales v. UDV, 546 U.S. 418 (2006), that RFRA applies to other federal statutes. In UDV, the court applied the statutory Sherbert Test created by RFRA and found that the conduct in question—use of a Schedule I drug in a religious ritual—was protected under the First Amendment. See also Free Exercise Clause of the First Amendment Strict scrutiny Lemon Test References Further reading External links First Amendment Center Findlaw's page on Free Exercise exemptions United States Supreme Court cases United States free exercise of religion case law 1963 in United States case law History of the Seventh-day Adventist Church 1963 in religion United States Supreme Court cases of the Warren Court