equal terms provision codifies the SmithLukumi line of precedent,” the court reasoned, so “a violation of § (b)’s equal treatment provision, consistent with the analysis employed in Lukumi, must undergo strict scrutiny.” Id. at 1232. The municipality’s proffered justification for excluding churches and synagogues from the business district — the “interests of retail synergy” — flunked the compelling-interest test. Id. at 1235. The Eleventh Circuit completed its analysis in Midrash Sephardi by considering whether the equal-terms provision was a permissible use of Congress’s § 5 enforcement power as understood in City of Boeme. The court concluded that it was, largely because the equal-terms provision codified the Supreme Court’s Free Exercise Clause jurisprudence. Id. at 1236-40 (<HOLDING>). In two subsequent cases, the Eleventh Circuit
holding that discrimination based on religion is subjected to strict scrutiny whether a claim arises under the establishment clause the free exercise clause of equal protection clause holding no violation of federal establishment clause holding that doctrine does not violate equal protection holding that  2000ccbl reflects freeexercise jurisprudence and is consistent with existing equal protection and establishment clause caselaw holding that lprs are entitled to the protection of the equal protection clause