February 19, 1992




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No. 91-1861




ERWIN L. RUPERT, CLERGYMAN, NATIVE AMERICAN
CHURCH OF THE U.S.A.,
Plaintiff, Appellant,

v.

DIRECTOR, UNITED STATES FISH AND WILDLIFE
SERVICE,
Defendant, Appellee.


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APPEAL FROM THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MAINE

[Hon. David M. Cohen, U.S. Magistrate-Judge]
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Before

Breyer, Chief Judge,
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Selya and Cyr, Circuit Judges.
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Erwin L. Rupert on brief pro se.
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Barry M. Hartman, Acting Assistant Attorney General, Jacques
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B. Gelin, Peter Van Tuyn, Katherine W. Hazard, Attorneys,
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Department of Justice, Environment and Natural Resources
Division, Michael Mason, Office of Solicitor, U.S. Department of
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the Interior, and Robin Lepore, Office of Regional Solicitor,
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U.S. Department of the Interior, on brief for appellee.



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Per Curiam. The question in this appeal is whether the
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federal government can, without violating the Establishment

Clause of the First Amendment, (a) prohibit the possession of

eagle feathers, but (b) allow members of Native American tribes

to use eagle feathers for religious purposes, and (c) refuse to

extend that exemption to people who are not Native Americans but

who also seek to use eagle feathers for religious purposes. We

hold that, under these circumstances, the government can craft an

exemption that is limited to Native Americans because such an

exemption serves two important governmental goals.

The Eagle Protection Act, 16 U.S.C. 668 et. seq.,

prohibits the possession of bald eagles and golden eagles, or of

any parts of those eagles, such as their feathers. 16 U.S.C.

668a, however, creates an exemption to the general prohibition;

it authorizes the Secretary of the Interior to give permits for

the possession of eagles or eagle feathers for, among other

things, "the religious purposes of Indian tribes," whenever such

possession is "compatible with the preservation of the bald eagle

or the golden eagle." The Secretary has issued regulations that

describe the criteria for obtaining a permit. They require that

the applicant be "an Indian who is authorized to participate in

bona fide tribal religious ceremonies." 50 C.F.R. 22.22.
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The appellant, Erwin L. Rupert, is the pastor of an "all-

race" church which follows Native American religious customs,

including the ceremonial use of eagle feathers. (The government

does not, at least for purposes of this appeal, dispute the

sincerity of Mr. Rupert's beliefs.) Mr. Rupert has also














organized a "tribe" called the "Tribe of the Pahana," which means

the tribe of "returned white brothers and sisters." It is clear,

however, that Mr. Rupert does not descend from Native Americans

and is not a member of any officially recognized Native American

tribe. See 25 C.F.R. 83.7 (in order to obtain recognition as
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an "Indian tribe," group must show that it "has been identified

from historical times until the present on a substantially

continuous basis, as 'American Indian', or 'aboriginal'").

Mr. Rupert applied to the United States Fish and Wildlife

Service for a permit to use eagle feathers. He asked the Service

either to recognize his Tribe of Pahana as an "Indian tribe"

within the meaning of Section 668a, or to grant him dispensation

from the requirement that applicants for a permit be members of

Native American tribes. The Service refused to grant his

application, but passed it on to the Bureau of Indian Affairs as

the agency best capable of deciding whether the Tribe of Pahana

deserved recognition as a bona fide tribe. The Bureau refused to
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recognize Mr. Rupert's group as a tribe because it did "not

consist of Native American Indian descendants who are descended

from a specific historical tribe . . . ."

Mr. Rupert then sued the Director of the Fish and Wildlife

Service. He claimed that Section 668a, as the Director had

construed it, violated the Establishment Clause of the First

Amendment, which commands that Congress shall make "no law . . .

respecting an establishment of religion. . . ." The magistrate-

judge before whom the parties consented to proceed granted


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summary judgment to the defendant, and this appeal followed.

Mr. Rupert does not challenge the government's power to ban

the use of eagle feathers for all purposes, including religious
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ceremonies. See Employment Div., Dept. of Human Resources of
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Oregon v. Smith, 494 U.S. 872 (1990) (generally applicable,
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neutral criminal prohibition does not violate Free Exercise

Clause even if it proscribes conduct that litigant's religion

prescribes). But, he contends, once the government decides to

create an exemption for religious purposes, it must do so even-

handedly. An exemption for all who use eagle feathers for

religious purposes would not be an impermissible establishment of

religion, see Sherbert v. Verner, 374 U.S. 398, 409 (1963)
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(general religious exemption "reflects nothing more than the

governmental obligation of neutrality in the face of religious

differences"), but an exemption that frees one religious group

from the prohibition but leaves another bound by it offends the

principle of neutrality that is at the core of the Establishment

Clause. See Larson v. Valente, 456 U.S. 228, 244 (1982) ("The
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clearest command of the Establishment Clause is that one

religious denomination cannot be officially preferred over

another.").

Although Mr. Rupert's claim is rooted in the Establishment

Clause, "[n]eutrality in its application requires an equal

protection mode of analysis." Walz v. Tax Com. of City of New
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York, 397 U.S. 664, 696 (1970) (Harlan, J., concurring). See
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also Greenawalt, Religion as a Concept in Constitutional Law, 72
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Cal.L.Rev. 753, 797 (1984) (equal protection principles

"overarch" the tests of the religion clauses). And in fact a

number of federal appellate courts, including this court, have

used an equal protection analysis to scrutinize exemptions from

the drug laws that give some Native Americans the right to use

peyote for religious purposes. See Peyote Way Church of God,
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Inc. v. Thornburgh, 922 F.2d 1210, 1216-17 (5th Cir. 1991); Olsen
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v. Drug Enforcement Administration, 878 F.2d 1458, 1463 n.5 (D.C.
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Cir. 1989) ("in cases of this character, establishment clause and

equal protection analyses converge"); United States v. Rush, 738
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F.2d 497, 513 (1st Cir. 1984). See also Kennedy v. Bureau of
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Narcotics & Dangerous Drugs, 459 F.2d 415, 416-17 (9th Cir. 1972)
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(using a Fifth Amendment "substantive due process" analysis).

Laws that grant "denominational" preferences are generally

subject to "strict scrutiny," under which the preference "must be

invalidated unless it is justified by a compelling governmental

interest . . . and unless it is closely fitted to further that

interest. . . ." Larson v. Valente, 456 U.S. at 247. However,
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the matter is complicated here by the fact that the preference at

issue is directed toward Native Americans. Native Americans have

"unique legal status under federal law," and Congress has

"plenary power . . . based on a history of treaties and the

assumption of a 'guardian-ward' status, to legislate on behalf of

federally recognized Indian tribes." Morton v. Mancari, 417 U.S.
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535, 551-52 (1974). In a series of equal protection cases

involving laws attacked as treating Native Americans in ways that


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created racial classifications, the Supreme Court has "repeatedly
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held that the peculiar semisovereign and constitutionally

recognized status of Indians justifies special treatment on their

behalf when rationally related to the Government's 'unique
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obligation toward the Indians.'" Washington v. Washington State
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Commercial Passenger Fishing Vessel Ass'n, 443 U.S. 658, 673 n.20
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(1979) (emphasis added and citation omitted). See also United
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States v. Antelope, 430 U.S. 641, 645-46 (1977) (upholding
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federal jurisdiction over crimes committed by Native Americans on

reservations); Moe v. Confederated Salish & Kootenai Tribes of
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Flathead Reservation, 425 U.S. 463, 479-81 (1976) (striking down
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state's attempt to tax property and sales on reservation); Morton
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v. Mancari, 417 U.S. at 554 (upholding statute and regulation
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that gave preference to Native Americans in hiring and promotions

at Bureau of Indian Affairs).

The principles affirmed in these cases "point . . . broadly

to the conclusion that federal regulation of Indian affairs is

not based upon impermissible classifications", United States v.
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Antelope, 430 U.S. 641, 646 (1977), and we therefore see no
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reason not to use the "rational relationship" analysis here,

where the government has treated Native Americans differently

from others in a manner that arguably creates a religious
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classification. As we observed in United States v. Rush, such
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special treatment (in that case, an exemption from the drug laws

for religious use of peyote by members of the Native American

Church) also finds its source in Congress' historical obligation


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to respect Native American sovereignty and to protect Native

American culture, and "is uniquely supported by the legislative

history and congressional findings underlying the American Indian

Religious Freedom Act, [42 U.S.C. 1996,] which declares a

federal policy of 'protect[ing] and preserv[ing] for American

Indians their inherent right of freedom to believe, express and

exercise the[ir] traditional religions . . . , including but not

limited to access to sites, use and possession of sacred objects,

and the freedom to worship through ceremonials and traditional

rites.'" 738 F.2d at 513. See also Peyote Way Church of God,
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Inc. v. Thornburgh, 922 F.2d at 1217 ("unique guardian-ward
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relationship between the federal government and Native American

tribes precludes the degree of separation of church and state

ordinarily required by the First Amendment"); United States v.
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Warner, 595 F. Supp. 595, 600 (D.N.D. 1984) (peyote exemption
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valid given "governmental duty to preserve Indian culture and

religion"). But see Olsen v. Drug Enforcement Administration,
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878 F.2d at 1469 (Buckley, J., dissenting) (exemption for Native

American religious use of peyote not grounded in unique political

status of Native Americans but in their special culture and

religion, in which respect Native Americans cannot be treated

differently from others similarly situated without violating

Establishment Clause).

There is no question that the exemption at issue here is

"rationally related" to legitimate governmental interests. In

crafting Section 668a's religious-use exemption from the Eagle


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Protection Act (which otherwise abrogated Native American treaty

and aboriginal rights to hunt eagles), "Congress . . . considered

the special cultural and religious interests of Indians, balanced

those needs against the conservation purposes of the statute, and

provided a specific, narrow exception that delineated the extent

to which Indians would be permitted to hunt the bald and golden

eagle." United States v. Dion, 476 U.S. 734, 743-44 (1986). The
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exemption, therefore, does not merely serve the government's
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interests in (1) protecting Native American religion and culture

and (2) protecting a dwindling and precious eagle population; it

sets those interests in equipoise. Any diminution of the

exemption would adversely affect the former interest, but any

extension of it would adversely affect the latter. In equal

protection terms, the "fit" between classification and

legislative purpose is snug; indeed, given the nature of the

governmental interests at stake and the close fit between the

exemption and those interests, we would be hard put to say that

the exemption could not survive even "strict scrutiny."

Affirmed.
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