City of Boerne v. Flores, 521 U.S. 507 (1997), was a Supreme Court case concerning the scope of Congress's enforcement power under the fifth section of the Fourteenth Amendment. The case also had a significant impact on historic preservation.
The basis for dispute arose when the Catholic Archbishop of San Antonio, Patrick Flores, applied for a building permit to enlarge his 1923 mission-style St. Peter's Church in Boerne, Texas. The building was located in a historic district and considered a contributing property. Local zoning authorities denied the permit, citing an ordinance governing additions and new construction in a historic district. The Archbishop brought suit, challenging the ruling under the Religious Freedom Restoration Act (RFRA) of 1993. Flores argued that his congregation had outgrown the existing structure, rendering the ruling a substantial burden on the free exercise of religion without a compelling state interest.