Saint Thomas Law Review
Symposium Issue: Twelfth Annual Latcrit Conference
Critical Localities, Epistemic Communities, Rooted Cosmopolitans, New Hegemonies & Knowledge Processes
*710 LEGAL ASPECTS OF ANIMAL SACRIFICE WITHIN THE CONTEXT OF AFRO-CARIBBEAN RELIGIONS
Jose A. Lammoglia [FNa1]
Copyright (c) 2008 St. Thomas Law Review; Jose A. Lammoglia (reprinted with permission)
|| Introduction .. .
|| Florida ....... .
|| Texas .......... .
|| Illinois ...... .
|| Pennsylvania .. .
|| Back to Florida . .
|| Conclusion .... .
Animal sacrifices are at the core of many religious rituals within the context of Afro-Caribbean Belief Systems. [FN1]
These religions, also known as New World religions, are a mixture of Catholic and pre-Christian African beliefs, among them Cuban Santeria, Palo, and Haitian Voodoo. Cuban Santeria is also known as Yoruba, Lukumi, and Regla de Osha. [FN2]
The ritual animal sacrifices found within the context of these religions follow guidelines similar to those of Muslim [FN3]
and Kosher Jewish [FN4]
practices. Only the healthiest animals are chosen as offerings to the gods or orishas. [FN5]
The ritual sacrifice happens in a swift manner to allow for the quick draining of the animal's blood since the blood is the main part of the offering. [FN6]
Ritual animal sacrifices in Afro-Caribbean religions must be conducted by an ordained priest or priestess trained in the practice of animal sacrifice. [FN7]
In Cuban Santeria, this training culminates in a ceremony known as pinaldo. [FN8]
Pinaldo is also the name given to the sacrificial knives. [FN9]
Moreover, the sacrificial animals are obtained from two different venues. [FN10]
The larger animals are purchased from farm wholesalers. [FN11]
The smaller ones, usually doves, are obtained from botánicas, which are religious goods stores for New World religions. [FN12]
Botánicas can be found in any U.S. city with a significant Afro-Caribbean religious congregation. [FN13]
The meat of the sacrificed animals must be cooked according to strict religious rules such as the cooking utensils used to stir the meat of one sacrificed animal cannot be dipped into a pot containing the meat of a different animal. [FN14]
These rules obey a religious taboo that ordains that those initiated under the protection of a particular orisha, which is the general name for the Afro-Caribbean deities, cannot consume the meat of an animal identified with that deity; transgressions bring negative repercussions to the offender. [FN15]
Padrino and madrina de santo, which translates from Spanish to Godfather and Godmother, teach their new ahijados and ahijados, which translates from Spanish to godchildren, the *712
ways of the orishas via an oro-kinetic language. [FN16]
Not all followers of New World religions are initiated into the priesthood, [FN17]
and only those who have undergone initiation can attend and partake in ritual animal sacrifices. [FN18]
However, all others who share these belief systems can share in the consumption of meat from sacrificed animals. [FN19]
These meats contain the blessings of the individual orisha to whom the animals were offered, and as such, carry positive energy, known as ashe. [FN20]
The feast that follows is attended by initiates and followers alike. [FN21]
The communion of sacrificial animal meat takes place during a feast where drumming is offered to the African deities; each Orisha has a distinctive drum beat. [FN22]
All drumming must cease before sunset. [FN23]
Afro-Caribbean religions were practiced in secrecy in their countries of origin because these were originally the beliefs of the poor and dominated classes, such as African slaves. [FN24]
These religions were viewed by the dominant class as backwards, ignorant, and superstitious beliefs that stood in opposition to the conversion efforts of Catholic priests. [FN25]
Consequently, these religions have been associated innocently and purposefully with dark magic for centuries. [FN26]
Afro-Caribbean religions are not centralized, and they do not worship in temples erected to that effect. [FN27]
Priests and priestesses belong to what is known as a Familia de Santo, a form of familial/religious congregation. [FN28]
Worship takes place in the home of the Familia de Santo's main priest. [FN29]
Each Familia de Santo operates independently from the others. [FN30]
Pichardos, a Familia de Santo from Hialeah, Florida, and whose members were of Santeria's Priesthood class, attempted to centralize the religion in the 1980s. [FN31]
As a result, a confrontation ensued between Hialeah residents, city officials, and the Pichardos. [FN32]
In the wake of the Cuban Revolution, a significant number of Cubans migrated to the U.S. with peak migration occurring during the Mariel Boat Lift. [FN33]
Most Cubans settled in Florida, New Jersey, and New York. [FN34]
Some brought with them the faith of the orishas. [FN35]
These migrants encountered laws in the U.S. that protected their freedom of religious worship. [FN36]
These laws enabled the migrants' religion to gain visibility with respectability. [FN37]
However, a segment of Cuban migrants continued to oppose the practices of Afro-Caribbean religions, perpetuating the negative connotations adjudicated to these beliefs in their country of birth.
Most Cubans who oppose Santeria are either practicing or nominal Catholics. [FN38]
That was the case of the Hialeah residents. [FN39]
In the 1980s, this struggle gave way to a legal battle between the Church of the Lukumi Babalu Aye, Inc., and Ernesto Pichardo v. City of Hialeah. [FN40]
City residents and commissioners, mostly Cubans or Cuban-Americans, joined forces with the U.S. Conference of Catholic Bishops and the Ecclesiastical Board of Hialeah and successfully banned ritual animal sacrifices within the Church of the Lukumi's premises. [FN41]
An underlying race, language, and ethnicity issue accompanied the decision of Hialeah's City Council. Santeria and its followers have been the subject of many maligned fables since Santeria was originally a religion of an ethnic group considered inferior by Cuba's dominant class. Once in the United States, Santeria followers took their constitutional rights to heart and demanded their rightful space for their beliefs and practices within the American Society. [FN42]
Their effort met resistance from upper class Cuban *714
exiles who felt that Santeria's practices and animal sacrifices would give American society an inaccurate representation of the pre-Castro Cuban society's beliefs. American society has also attempted to deny Santeria a place within the amalgam of accepted religions, an act that can be best understood if we remember that our country is still learning to overcome racial and ethnical biases. In the words of David M. O'Brien: “The hard-fought struggles of religious minorities transformed religious freedom from a tradition of freedom from governmental endorsement of any particular religion into freedom to openly practice nonconformist religions.” [FN43]
Animal rights activists also took part in the struggle, among them the Institute for Animal Rights Law, the American Fund for Alternatives to Animal Research, Farm Sanctuary, Jews for Animal Rights, the United Animal Nations, and the United Poultry Concerns. [FN44]
The case escalated the ladders of the legal system up to the Supreme Court of the Nation. [FN45]
At the time of the Court's ruling, the U.S. Catholic Conference withdrew from the fight asserting that it did not support either the City of Hialeah or the Church of the Lukumi; the Institute for Animal Rights Law also withdrew. [FN46]
In 1993, the Court ruled in favor of Oba Pichardo and the Church of the Lukumi Babalu Aye. [FN47]
Less than fifteen years after the 1993 landmark Supreme Court ruling, a new confrontation developed between an American city and a Santeria priest, this time in Euless, Texas. [FN48]
There, on the eve of an initiation ritual in the home of Puerto Rican born Santeria priest Jose Merced (“Mr. Merced”), members of the city's police department knocked on his door to advise him of the illegality of animal sacrifices within city limits. [FN49]
Mr. Merced, priest and president of Euless based Templo Yoruba Omo Orisha Texas, explained to the officers that animal sacrifices are to Santeria what the Eucharist is to Catholicism; however, his pleas fell on deaf ears. [FN50]
short time later, Mr. Merced filed a federal discrimination lawsuit against the city of Euless. [FN51]
National religious freedom and Latino advocacy groups joined forces to fight for the right of Templo Yoruba Omo Orisha Texas to continue with its religious rituals, animal sacrifices, and celebrations. [FN52]
Oba Ernesto Pichardo of the Church of the Lukumi pronounced himself in solidarity with his Euless homolog, and a nation-wide call for donations began to cover the legal fees of the battle. [FN53]
The Euless case has gained national attention. Newspapers and television networks have brought the controversy to the foreground, arguing that New World religions continue to win followers in the U.S. and should receive the same treatment as that afforded to organized religions. For a detailed follow up of the story, consult the following: The Dallas Morning News January 6 [FN54]
and February 4, 2007 issues; [FN55]
the Free Lance-Star November 26, 2005 issue; [FN56]
Newsweek February 5, 2007 issue; [FN57]
and the Washington Times January 16, 2007 issue. [FN58]
Also, CNN interviewed Mr. Merced in February of 2007. [FN59]
Most of the media has been sympathetic toward Santeria believers and to Mr. Merced in particular. They argue that the nation's ethnic and religious landscape continues to change and, as such, so should the laws protecting the right of religious practices, even when these include animal sacrifices. But most is not necessarily all, and a negative comment repeated over time by a biased and powerful association or person can have far reaching and regretful consequences. [FN60]
The city of Euless' reacted to Mr. Merced's lawsuit by moving to dismiss the religious discrimination case, arguing that the act is unconstitutional because it amounts to an intrusion by Congress on the state's right to regulate the health and welfare of its residents. [FN61]
In addition, Euless offered Mr. Merced a settlement that would allow him to sacrifice chickens in his home as well as to hold gatherings of more than twenty five people at any given feast; however, the gathering must not be visible to the general public or occur more than five times per month. [FN62]
Mr. Merced rejected the settlement offer arguing that four legged animal sacrifices, especially goats, are also part of the religion's rites. [FN63]
Mr. Merced also noted that religious gatherings in his church-home are not conducted with the same frequency as those held by organized religions. [FN64]
Finally, he explained that drumming is a cornerstone of his faith, however, some of his neighbors had complained about the drumming as well. [FN65]
Illinois, New Jersey, and New York are some states with notable growth of congregations of New World religions. [FN66]
The environment is ripe for conflicts between Afro-Caribbean Religion practitioners and the cities where they worship. [FN67]
Chicago has been no exception. On January 14, 2007, Fox Television Network (“Fox”) aired a documentary entitled “Chicago Santeria.” [FN68]
The film provides an interview with the owner of a Chicago botánica who showed the television cameras some disturbing sights. [FN69]
A biased introduction stated, “Guess What We Found Here?” [FN70]
The documentary focused on religious ritual animal sacrifices in ways that *717
led the public to believe that Santeria priests and priestesses were animal torturers. [FN71]
A strong and angered response from the Chicago Lukumi community followed. [FN72]
Olorisha Yomi Yomi, a Santeria priestess of Irish descent and instructor of comparative religions in the city's higher education system, sent Fox a rebuttal, stating how this film was a good example of the type of harm caused by a lack of knowledge and proper documentation. She accused Fox reporters of creating a documentary about Santeria without availing themselves of the expertise of local scholars, some of whom are members of the religion's preisthood. [FN73]
Some of these scholars were members of Santeria and Voodoo priesthood. [FN74]
She also condemns the reporters' carelessness in choosing an informant who, although a botánica owner, claimed to be a priest from a different religion. [FN75]
Events like this one prove that legal action is often necessary to deal with situations that should have been put to rest a long time ago.
The Euless v. Templo Yoruba Omo Orisha Texas and Oba Jose Merced case has raised concerns in other U.S. cities regarding the legalities of animal sacrifices within their city limits. [FN76]
Such is the case in Philadelphia, where Voodoo continues to gain believers. One home-temple is run by a professional couple. [FN77]
The husband is a college art professor and the wife is an administrator at a center city architectural firm. [FN78]
Their home-sanctuary, named Le Peristyle II, also serves as a wedding chapel and guidance center for Philadelphia's Voodoo congregation. [FN79]
Le Peristyle II is located a block away from Temple University at North 15 th
Ritual animal sacrifices are performed in Le Peristyle II as part of Voodoo religious rites. [FN81]
Philadelphia has laws governing animal welfare and prohibits the storage of farm animals within city limits except in certain cases, including those to be used as food. [FN82]
But those animals must be killed within twenty four hours from their arrival in the city. [FN83]
Some four legged animals used in Philadelphia's Voodoo rites are sacrificed in a New Jersey farm. [FN84]
Thus far, there have been few complaints from neighbors related to both animal sacrifices and festivities. Nevertheless, there is no telling what the future holds if one considers that over twenty five thousand Philadelphians are followers of Voodoo or Santeria. [FN85]
VI. BACK TO FLORIDA
Recently, the case of animal sacrifices within the context of religious rituals has flared up once again in Miami, Florida. [FN86]
As noted in El Nuevo Herald on Sunday, October 21, 2007, several botánicas were visited by agents of the U.S. Department of Agriculture, and they confiscated roots and other vegetable products imported from Africa that were being used for religious rituals. [FN87]
After several interviews and some research, El Nuevo Herald determined that the consensus among the Santeria community was that the actions taken against their businesses were in retaliation to a city of Coral Gables incident that summer where concerned neighbors, worried by the screams of animals being sacrificed during a Yoruba religious rite in a private home, called the city's police department to intervene. [FN88]
When contacted, a spokesperson for the U.S. Department of Agriculture in Washington D.C. responded by stating that South Florida is a major port for the illegal entry of animal and plant species that, if go unchecked, have the possibility of introducing diseases and epidemics into the United States. [FN89]
A Santeria follower now claims that, since the Coral Gables police incident, most Lukumi congregations in Metro-Dade believe they are being watched by the government. [FN90]
In turn, this situation has triggered a *719
decrease in the number of Regla rituals throughout the city. [FN91]
Thus far, legal action on the bases of religious discrimination has not been taken, but botánica owners do not exclude the possibility of starting such action if and when religious discrimination can be proven. [FN92]
There is agreement amongst the botánica owners that this new situation resembles what their religion was subjected to during the 1980s, when the hostilities between the Hialeah City Council and the Church of the Lukumi Babalu Aye began. [FN93]
Educating the general public about the nature of animal sacrifices within the religious context of New Word religions will eradicate some general misconceptions. People who can understand New World religions will make better decisions and exercise good judgment, which in turn, will lead to more tolerant behavior from everyone. But the secret character of Afro-Caribbean rituals does not facilitate educating the public about the essence and meaning of the religious rituals. The latter tends to bread fear among those unfamiliar with the religion to the point of hostility. The situation is exacerbated when considering that in spite of the growing number of followers these religions have in the U.S., they are still considered a minority. The secrecy code for Afro-Caribbean religions allows the general public to take them as one of many religious sects that do engage in animal cruelty, thus, exacerbating generalized misconceptions.
Tolerance and understanding of the religious ritual acts of Afro-Caribbean religions can be increased by achieving a consensus among all U.S. cities and states on the subject in discussion. Nevertheless, each case must be treated on an individual basis since both city and state laws differ across the country. Many states do not want to legislate on matters of religion for fear of either setting precedent that violates the Constitutional Amendment that protects the freedom of worship or ruling in favor of one religion at the expense of insulting another. Mutual acceptance among institutionalized religions is still a rough and sensitive work in progress. [FN94]
Thus, difficulting tolerance towards the lesser known religions.
The Illinois case brings back old questions about both proper and credible research and good journalism. It also serves as a reminder of the *720
harm that can be done by carelessness in the information age. Many New World religions have their own web pages as well. Unfortunately, they must often use these electronic sites to denounce some form of religious discrimination committed against them by means of the written word, television, film industry, or all of them.
In historical terms, America's Civil Rights Movement is still a newborn child. Racial discrimination along ethnic and language lines is still pre-eminent in many parts of our country. Religious discrimination, especially toward minority religions is also very much alive today. The road to complete acceptance of the other, and to the true love of thy neighbor as we love ourselves, is infected with misunderstandings, some of which are an attempt at domination by the Christian moral majority. The perpetuation of such misunderstandings is, in my opinion, the equivalent to negating that we are all God's children with equal rights to be here.
There is a marked difference between New World religions and other Christian religions. Animal sacrifices are at the main point of departure between the two. While Christian religions think of Jesus as God's sacrificial lamb to cleanse the sins of the world, they are not willing to recognize that the same concept is at the core of New World religions' animal offerings.
The first decade of the twenty first century is seeing new legal problems at the core of Afro-Caribbean Religions, their practice of ritual animal sacrifices and the cities where some of their congregations thrive. The Euless case has not been resolved, recent developments in Metro-Dade are still ripe for conflict, and Philadelphia, though quiet so far, is a potential cradle of turmoil. States and the federal government could be forced to solve these conflicts once and for all before they begin to sprout in different areas of the country, an event that can be safely assumed if we pay attention to the Free Lance-Star's assessment of the in-progress growth in the following of Afro-Caribbean religions in the U.S. today.
[FNa1] . MA Florida International University, Latin American Studies. The author thanks Dr. Terry Rey, Professor of Religion at Temple University, who directed the MA thesis, and who has an incredible amount of faith in him, his research, and his educational goals, to the point of pushing him to participate in conferences like LatCritXII. The author extends a special thanks to the conference organizers and participants and stated it was an incredible professional and personal experience. The author also extends his gratitude to both the past and present journal editors.
[FN1] . See Leonora LaPeter & Paul de la Garza, Mercury in Rituals Raises Alarms, St. Petersburg Times, Jan. 26, 2004, at 1B.
[FN2] . See Migene González-Wippler, Santería: The Religion 2-3 (2d ed., Llewellyn Publications 2004) (1989).
[FN3] . See generally Al-Hafiz B. A. Masri, Animal Experimentation: The Muslim Viewpoint, in Animal Sacrifices: Religious Perspectives on the Uses of Animals in Science 171-98 (Tom Regan ed., 1986) (considering the Muslim viewpoint on animal sacrifices).
[FN4] . See generally Rabbi Dr. J. David Bleich, Judaism and Animal Experimentation, in Animal Sacrifices: Religious Perspectives on the Uses of Animals in Science 61-114 (Tom Regan ed., Temple University Press 1986) (explaining Judaism and its perspective on animal sacrifices).
[FN5] . Cf. Joseph M. Murphy, Santería: African Spirits in America 135-36 (2d ed. 1993) (discussing the orishas' specific requests for certain kinds of animal sacrifices and the practice of eating the meat of the sacrificed animal; thus, it is in the best interest of everyone involved to select only the healthiest animals). Moreover, orishas are defined as “[d]ivine beings of santería” or a “saint.” Id. at 181.
[FN6] . See id. at 44, 136.
[FN7] . See David M. O'Brien, Animal Sacrifice & Religious Freedom: Church of the Lukumi Babalu Aye v. City of Hialeah 28 (Peter Charles Hoffer & N. E. H. Hull eds., 2004).
[FN8] . Murphy, supra note 5, at 141.
[FN9] . Id. See also Jorge Castellanos & Isabel Castellanos, Cultura Afrocubana 3: Las Religiones Y Las Lenguas 125 (1992).
[FN10] . Jose A. Lammoglia, Botánicas: Absence in Cuba, Proliferation in the United States 14, 49 (2001) (published MA Thesis, Florida International University) (on file with author and library).
[FN11] . Id. at 49.
[FN12] . See Murphy, supra note 5, at 39-41. See also O'Brien, supra note 7, at 47 (stating that botánicas “sold small animals ... used in Santeria rites”).
[FN13] . See Murphy, supra note 5, at 39.
[FN14] . See generally González-Wippler, supra note 2, at 184-85.
[FN15] . See id. at184.
[FN16] . See Murphy, supra note 5, at 50, 55 (translating Padrino and Madrina to Godfather and Godmother); O'Brien, supra note 7, at 11 (translating ahijados and ahijadas to godchildren).
[FN17] . González-Wippler, supra note 2, at 84.
[FN18] . See Murphy, supra note 5, at viii-ix.
[FN19] . See id. at 86.
[FN20] . González-Wippler, supra note 2, at 155. Ashe is defined as “the blood of cosmic life, the power ... toward life strength, and righteousness.” Murphy, supra note 5, at 8.
[FN21] . González-Wippler, supra note 2, at 190-91.
[FN22] . Id.
[FN23] . Cf. id. at 79.
[FN24] . See generally Charles Wetli, M.D., Foreword to González-Wippler, supra note 2, at viii-ix (1989). The identity of reglas rested on ethnic ancestry up to the early 1900s when criteria for membership began to lean more on spiritual paths followed by those called to serve in the religion's priesthood. Murphy, supra note 5, at 33. It is at this point that membership became open to whites. Id.
[FN25] . O'Brien, supra note 7, at 32.
[FN26] . See id. at 36.
[FN27] . See id. at 6-7.
[FN28] . See id. at 7.
[FN29] . See id. at 28-29.
[FN30] . Id. at 29.
[FN31] . See O'Brien, supra note 7, at 19.
[FN32] . See id. at 33-36.
[FN33] . See id. at 19-20.
[FN34] . See id. at 19, 35.
[FN35] . See id. at 21.
[FN36] . See id. at 137, 149.
[FN37] . See O'Brien, supra note 7, at 35.
[FN38] . See id. at 31, 35-36.
[FN39] . See id. at 35-36.
[FN40] . See id. at 33-35.
[FN41] . See id. at 35-36.
[FN42] . See id . at 47.
[FN43] . O'Brien, supra note 7, at 50 (emphasis added).
[FN44] . Id. at 108.
[FN45] . Id. at 116, 118.
[FN46] . Id. at 109.
[FN47] . Id. at 137, 153.
[FN48] . See Michael Grabell, A Clash over Ritual Sacrifice--Santeria Leader Fights Euless Ban on Killing of Animals as Affront to Faith, The Dallas Morning News, Jan. 6, 2007, at 1A [hereinafter Grabell, A Clash over Ritual Sacrifice].
[FN49] . See id.
[FN50] . Id.
[FN51] . See id.
[FN52] . Michael Grabell, Euless Pushes Judge To Toss Santeria Suit--Priest Challenging City's Ban on Killing Animals As Affront to His Faith, The Dallas Morning News, Feb. 4, 2007, at 1B [hereinafter Grabell, Euless Pushes Judge]. Among the groups is Consejo de Latinos Unidos. Id.
[FN53] . See generally Grabell, A Clash over Ritual Sacrifice, supra note 48.
[FN54] . Id.
[FN55] . Grabell, Euless Pushes Judge, supra note 52.
[FN56] . Margaret Ramirez, Faith Based on African Rites Gaining Popularity in U.S., The Free Lance-Star (Virginia), Nov. 26, 2005.
[FN57] . Lisa Miller, BeliefWatch: Slaughter, Newsweek, Feb. 5, 2007, at 16.
[FN58] . Hugh Aynesworth, Suit Calls Sacrifice a Religious Right, The Wash. Times, Jan. 16, 2007, at A09.
[FN59] . Paul Zahn Now 13-14 (CNN television broadcast Feb. 19, 2007) (transcript available in LEXIS, News Library, CNN news file, no. 021901CN.V99).
[FN60] . To the best of my knowledge, all newspaper and television networks that covered the Euless case have at least presented it objectively and without biases. See generally Ramirez, supra note 56; Grabell, A Clash over Ritual, supra note 48; Michael Grabell, Can Euless Man Sacrifice Chicken?, The Dallas Morning News, Jan. 10, 2007, at 12A; Aynesworth, supra note 58; Grabell, Euless Pushes Judge, supra note 52; Miller, supra note 57, at 16; Paul Zahn Now, supra note 59, at 13-14; Michael Grabell, Euless Offers Settlement in Santeria Case-- But Priest Says He'll Reject It Because Ban on Goat Sacrifice Would Stay, The Dallas Morning News, Mar. 21, 2007, at 7B [hereinafter Grabell, Euless Offers Settlement]; Jessica DeLeón, Santeria Priest Rejects City Deal, Fort Worth Star-Telegram, Mar. 22, 2007, at B7.
[FN61] . See Grabell, Euless Pushes Judge, supra note 52. See also Grabell, Euless Offers Settlement, supra note 60.
[FN62] . Grabell, Euless Offers Settlement, supra note 60.
[FN63] . See id.
[FN64] . See id.
[FN65] . Id.
[FN66] . See González-Wippler, supra note 2, at 7.
[FN67] . See Frank Burgos, Landlord Ousts Santerias from Hialeah Church, The Miami Herald, Feb. 4, 1988, at 7B. See also, e.g., Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah, 508 U.S. 520 (1993).
[FN68] . Chicago Santeria (Fox Television broadcast Jan. 14, 2007).
[FN69] . The Chicago Santeria Meetup Group, http:// santeria.meetup.com/107/messages/boards/thread/2948697#8173140 (Apr. 10, 2007, 10:36 EST).
[FN70] . Id.
[FN71] . Id.
[FN72] . Id.
[FN73] . Id.
[FN74] . Id.
[FN75] . The Chicago Santeria Meetup Group, supra note 69.
[FN76] . See generally Natalie Hope McDonald, The Spirits Move Them: There Are 25,000 Practitioners of Voodoo in Philly. And Not a Single Pin., Philadelphia City Paper, Mar. 28, 2007, http:// www.citypaper.net/articles/2007/03/29/the-spirits-move-them (last visited June 4, 2008).
[FN77] . Id.
[FN78] . Id.
[FN79] . Id.
[FN80] . Id.
[FN81] . Id.
[FN82] . McDonald, supra note 76.
[FN83] . Id.
[FN84] . Id.
[FN85] . Id. See also Ramirez, supra note 56.
[FN86] . Daniel Shoer Roth, Batidas contra botánicas de Miami, El Nuevo Herald, Oct. 21, 2007, at A1.
[FN87] . See id.
[FN88] . See id.
[FN89] . See id.
[FN90] . See id.
[FN91] . See generally id.
[FN92] . Roth, supra note 86.
[FN93] . See id.
[FN94] . Madeline Korbel Albright, The Mighty and the Almighty: Reflections on America, God, and World Affairs 143 (Harper Collins 2006).