State v. Balzer

— The State charged Gene Balzer with two counts of unlawful possession of a controlled substance, marijuana and cocaine, and one count of unlawful possession with intent to deliver (marijuana). Balzer notified the trial court that he planned to assert an affirmative defense under the Religious Freedom Restoration Act (RFRA), specifically, that he possessed the marijuana for religious purposes. The trial court held a hearing to determine whether the defense applied, and after hearing testimony from Balzer and the arresting officer, ruled that Balzer had established a prima facie case for the…