Print this Page
Case Basics
Docket No. 
Northwest Indian CPA
(Argued the cause for the respondents)
(Argued the cause for the petitioners)
Facts of the Case 

The United States Forest Service was considering building a paved roadway that would cut through the Chimney Rock area of the Six Rivers National Forest. It was also considering timber harvesting in the area. A study commissioned by the Forest Service reported that harvesting the Chimney Rock area would irreparably damage grounds that had historically been used by Native Americans to conduct religious rituals. After the Forest Service decided to construct a road, the Northwest Indian Cemetery Protective Association took action against Secretary of Agriculture Richard Lyng.


Did the First Amendment's Free Exercise Clause prohibit the government from harvesting or developing the Chimney Rock area?

Decision: 5 votes for Lyng, 3 vote(s) against
Legal provision: Free Exercise of Religion

No. In a 5-to-3 decision, the Court held that the Forest Service was free to harvest the lands. Though the government's actions would have severe adverse effects on the Indians' practice oftheir religion, those effects were only incidental and did not constitute an attempt to coerce Native Americans to act in violation of their beliefs. The Court reasoned that government could not operate "if it were required to satisfy every citizen's religious needs and desires," and that the First Amendment did not give any one group veto power over public programs that did not actually prohibit the free exercise of religion.

Cite this Page
LYNG v. NORTHWEST INDIAN CPA. The Oyez Project at IIT Chicago-Kent College of Law. 25 August 2015. <>.
LYNG v. NORTHWEST INDIAN CPA, The Oyez Project at IIT Chicago-Kent College of Law, (last visited August 25, 2015).
"LYNG v. NORTHWEST INDIAN CPA," The Oyez Project at IIT Chicago-Kent College of Law, accessed August 25, 2015,