Most laws that are subjected to such a test – lawyers refer to this rigorous level of constitutional analysis as “strict scrutiny” – are struck down. Yet, while the Court used three loaded words in Sherbert, the judiciary applied something much less rigorous than strict scrutiny in cases involving religious objectors. A 1992 study by James E. Ryan, now the president of the University of Virginia, found that federal courts of appeals heard 97 free exercise cases applying the “compelling interest” test between 1980 and 1990, and those courts rejected 85 of these cases.