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Conflicts continually arise between individuals and the government over religious freedom.
This conflicts with the state's interest in preserving public health. A lumber interest might want to create a road through an area that Natives consider sacred. During the 1980's, the U.S. Supreme Court considered a number of such cases. A trend appeared in which the court appeared to give less importance to religious considerations. In 1990, the Supreme Court issued a decision in the case of Employment Division vs. Smith .