Illinois Compiled Statutes
775 ILCS 35/15 (2026)
Free exercise of religion protected
✓ current as of May 2026
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(775 ILCS 35/15)
Sec. 15.
Free exercise of religion protected.
Government may not
substantially burden a person's exercise of religion, even if the burden
results
from a rule of general applicability, unless it demonstrates that application
of
the burden to the person (i) is in furtherance of a compelling governmental
interest and (ii) is the least restrictive means of furthering that compelling
governmental interest.
(Source: P.A. 90-806, eff. 12-2-98.)
Notes of Decisions
Cited in 25
cases (3 in the last 5 years), 2001–2024 · leading case: St. John's United Church of Christ v. City of Chicago, 502 F.3d 616 (7th Cir. 2007).
St. John's United Church of Christ v. City of Chicago, 502 F.3d 616 (7th Cir. 2007). “See 775 ILCS 35/15 ("Government may not substantially burden a person's exercise of religion, even if the burden results from a rule of general applicability, unless it demonstrates that application of the burden to the person (i) is in furtherance of a compelling governmental…”
Vineyard Christian Fellowship of Evanston, Inc. v. City of Evanston, 250 F. Supp. 2d 961 (N.D. Ill. 2003). “§ 1988 , alleging that Evans-ton’s zoning laws on their face and as applied against Vineyard violate Sections 15 and 20 of the Illinois Religious Freedom Restoration Act (“IRFRA”), 775 ILCS 35/15 and 775 ILCS 35/20 (Count I); the Equal Protection Clause (Count II), Free Exercise…”
City of Chicago Heights v. Living Word Outreach Full Gospel Church & Ministries, Inc., 749 N.E.2d 916 (Ill. 2001). “775 ILCS 35/15 (West 1998). The appellate court concluded that the City had a compelling interest to “invigorate the commercial corridor [in which Living Word was located] to regenerate declining revenues and create a strong tax base.”
Stepek v. Doe, 910 N.E.2d 655 (Ill. App. Ct. 2009). “" 775 ILCS 35/15 (West 2006). We note that this issue was not well developed by the parties on appeal and do not reach it in deciding this matter.”
Christian Assembly Rios De Agua Viva v. City of Burbank, 948 N.E.2d 251 (Ill. App. Ct. 2011). “I, §2) and the Illinois Religious Freedom Restoration Act (the Act) (775 ILCS 35/15 (West 2008)) to locate a church on the property.”
World Outreach Conf. Ctr. v. City of Chicago, 591 F.3d 531 (7th Cir. 2009). “The Act also provides that “no government shall impose or implement a land use regulation in a manner that treats a religious assembly or institution on less than equal terms with a nonreligious assembly or institution,” id.”
World Outreach Conf. Ctr. v. City of Chicago, 234 F. Supp. 3d 904 (N.D. Ill. 2017). “In discussing World Outreach’s claims in the first appeal in this case, although the Seventh Circuit discussed the redundancy of these claims, it seems to have recognized their relatedness: "The Illinois law, 775 ILCS 35/15, is, so far as relates to this case, materi *915 ally…”
Our Savior Evangelical Lutheran Church v. Saville, 922 N.E.2d 1143 (Ill. App. Ct. 2009). “Section 15 of the Act (775 ILCS 35/15 (West 2006)) provides that “[glovernment may not substantially burden a person’s exercise of religion.”
Morr-Fitz, Inc. v. Blagojevich, 867 N.E.2d 1164 (Ill. App. Ct. 2007). “" 775 ILCS 35/15 (West 2004). Section 20 allows a person to raise a claim in a judicial proceeding and seek appropriate relief if his or her "exercise of religion has been burdened in violation" of the Religious Freedom Restoration Act.”
Diggs v. Snyder, 775 N.E.2d 40 (Ill. App. Ct. 2002). “It provides that the government may not burden an individual’s free exercise of religion unless imposing that burden, first, furthers a compelling governmental interest and, second, is the least restrictive means of furthering that interest.”
Rojas v. Martell, 2020 IL App (2d) 190215 (Ill. App. Ct. 2021). “¶¶ 54-55 (citing 775 ILCS 35/15 (West 2010)). The court found the Religious Freedom Act inapplicable, reasoning, inter alia, that the Right of Conscience Act specifically addresses the issue of health care, while the Religious Freedom Act applies broadly to any governmental…”
Students & Parents for Privacy v. Sch. Dirs. of Twp. High Sch. Dist. 211, 377 F. Supp. 3d 891 (E.D. Ill. 2019). “775 ILCS 35/15 (emphasis added). The IRFRA defines "demonstrates" to mean "meets the burden of going forward with the evidence and of persuasion.”
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