Fulton versus city of philadelphia. Ms. Windham. Mr. Chief justice and may it please theourt, the court below made a simple error. They failed to understand where emplment division versus sth controls and where it doesnt. Ith doesnt control when the government uses the system of individualized exemptions. Orem when it makes other exceptions that underminets rules or when it changes the rules to phibit a religious practice. Philadelphia made all threefe those errors here and the city still cant identify a neutral genelly applicable law even ter six attempts and in our knowledge is its decisions are subjective and individualized. The courts belowtill apply to smith and even said smith would be a dea letter if petitioners prevailed a that demonstrates the confusion and instability smith has csed. Respondents rather than defendansmith asked the court for a newly minted nstitutional standard that is even less protective of religious exercise and that approa has no basis in the text, history