摘要：In 1998, the Supreme Court of Hawai`i heard a Free Exercise of Religion claim for thefirst time in eleven years in Korean Buddhist Dae Won Sa Temple of Hawaii v. Sullivan1(Korean Temple). When the court had last heard arguments regarding the freedom of religion in1987, the only standard used in either in the Hawai`i or Federal courts for Free Exercise claimswas strict scrutiny. In the interim, however, the United States Supreme Court, in EmploymentDivision, Department of Human Resources of Oregon v
