Fulton v. City of Philadelphia, Pa., 141 S. Ct. 1868 (2021). I. Introduction In Fulton, both the district court and court of appeals held in favor of the defendants, citing Employment Division v. Smith as controlling precedent regarding “neutral laws of general applicability.” Fulton v. City of Philadelphia, 320 F. Supp. 3d 661, 704 (E.D.…
