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The United States Constitution provides each individual with the right to exercise freely her religion.1 There are three ways in which a law could conflict with an individual's religious liberty. First, a law could limit the ability of an individual to believe in her religion. Second, a law could limit the ability of an individual to act in accordance with her religion (or require her to act contrary to her religion). Third, a law could result in governmental action that conflicts with an individual's religion. The Supreme Court has established a different degree of protection for each of these types of situations. In the first situation, the Su-

A New Category of Free Exercise Claims: Protection for Individuals Objecting to Governmental Actions That Impede Their Religions