Florida Statutes

Fla. Stat. § 761.01 (2025)

Short title.

✓ 2025 Florida Statutes — current through the 2025 Regular Session

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761.01 Short title.—This act may be cited as the “Religious Freedom Restoration Act of 1998.”

History.—s. 1, ch. 98-412.

Notes of Decisions

Cited in 22 cases (2 in the last 5 years), 1999–2025 · leading case: Combs v. Homer-Ctr. Sch. Dist., 540 F.3d 231 (3rd Cir. 2008).

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Combs v. Homer-Ctr. Sch. Dist., 540 F.3d 231 (3rd Cir. 2008). · cites it 2× “§§ 110.001 to 110.012; Va.Code Ann. §§ 57-1 to 57-2.”

Warner v. City of Boca Raton, 64 F. Supp. 2d 1272 (S.D. Fla. 1999). · cites it 4× “In particular, count I alleges that the prohibition substantially burdens the plaintiffs’ exercise of religion in violation of the recently enacted Florida Religious Freedom Restoration Act of 1998 (the “Florida RFRA”), Fla. Stat. § 761.01 et seq. Count II alleges that the…”

Toca v. State, 834 So. 2d 204 (Fla. 2d DCA 2002). · cites it 3× “Free exercise of religion protected (1) The government shall not substantially burden a person's exercise of religion, even if the burden results from a rule of general applicability, except that government may substantially burden a person's exercise of religion only if it…”

First Vagabonds Church of God v. City of Orlando, 610 F.3d 1274 (11th Cir. 2010). · cites it 2× “The Church alleged that the Ordinance, as applied to them, violates the Florida Religious Freedom Restoration Act ("FRFRA"), Fla. Stat. § 761.01 et seq., and that the Ordinance, facially and as applied to them, violates the First Amendment's Free Exercise Clause.”

Warner v. City of Boca Raton, 887 So. 2d 1023 (Fla. 2004). “(codified as §§ 761.01-.05, Fla. Stat. (2003)). After a bench trial, the United States District Court for the Southern District of Florida held that the right to place vertical grave structures was not protected under the FRFRA.”

Temple B'Nai Zion, Inc. v. City of Sunny Isles Beach, Florida, 727 F.3d 1349 (11th Cir. 2013). “§§ 2000cc to 2000cc-5; the Florida Religious Freedom Restoration Act of 1998 (FRFRA), Fla. Stat. §§ 761.01 — .05; the Free Exercise- Clause of the Florida Constitution; and the Equal Protection, Free Exercise, and Substantive Due Process Clauses of the United States Constitution…”

First Vagabonds Church Of God v. City Of Orlando, 638 F.3d 756 (11th Cir. 2011). “The Church alleged that the ordinance, as applied, violated the Florida Religious Freedom Restoration Act, Fla. Stat. § 761.01 et seq.; and that the ordinance, both facially and as applied, violated the Free Exercise Clause of the First Amendment.”

Warner v. City of Boca Raton, 267 F.3d 1223 (11th Cir. 2001). “All cemetery plot decorations had to be brought into compliance by 15 January 1998. Plaintiffs later filed this lawsuit.”

Gilio v. Sch. Bd. of Hillsborough Cnty., 905 F. Supp. 2d 1262 (M.D. Fla. 2012). · cites it 4× “Constitution and *1266 Florida’s Religious Freedom Restoration Act, Fla. Stat. § 761.01 , et seq. Thereafter, Plaintiff filed a motion for a preliminary injunction seeking to enjoin the School Board from barring J.”

Yasir v. Singletary, 766 So. 2d 1197 (Fla. 5th DCA 2000). “Yasir alleged that the refusal to permit him to use his new religious name violated his right to religious freedom under Article I, Section 3, of the Florida Constitution, and his rights under Florida's Religious Freedom Restoration Act, § 761.01, et seq. The record shows that…”

Lawson v. Sec'y, Florida Dep't of Corr., 427 F. App'x 799 (11th Cir. 2011). “§ 2000cc-1, and the Florida Religious Freedom Restoration Act (“RFRA”), Fla. Stat. Ann. § 761.01 , 1 Finding that Lawson’s professed beliefs in Orthodox Judaism were insincere, the district court dismissed the action as frivolous under the Prison Litigation Reform Act (PLRA), 28…”

Open Homes Fellowship, Inc. v. Orange Cnty., Fla., 325 F. Supp. 2d 1349 (M.D. Fla. 2004). “S.C. §§ 12131-65 and the Rehabilitation Act, 29 U.”

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