Laws against cultivating the psychoactive drug peyote are problematic because of the right of religious freedom set forth in both the U.S. and the California constitutions. This is because members of the Native American Church (also known as peyotism) consume peyote as part of their religious ceremonies. Many other Native American Indian/indigenous people also make use of peyote plants, a spineless cactus, for religious use. The California Supreme Court has held that a person may not be convicted of simple possession of peyote for possessing and using peyote as part of a legitimate religious ritual. Federal law also recognizes a religious exemption for simple possession.