In "City of Boerne v. Flores, Archbishop of San Antonio," the U.S. Supreme Court struck down the 1993 Religious Freedom Restoration Act. RFRA was not intended to overrule a 1990 Supreme Court decision forbidding use of peyote in Native American religious ceremonies, but to "enforce" 14th-Amendment free-exercise rights. The "Boerne" decision gives schools little guidance with "hybrid rights." (MLH)