## Facts

- William A. Frazee was laid off from his job with the State of Illinois.
- A temporary employment agency offered him a retail job requiring work from Wednesday through Sunday.
- Frazee refused the job because, as a Christian, he believed he should not work on Sunday.
- Illinois denied unemployment compensation on the ground that he refused “suitable work” without “good cause.”
- State decisionmakers accepted that Frazee’s belief was sincere and religious, but denied benefits because he did not claim membership in an organized sect and did not show his belief was required by an established religious body’s tenets.
- The administrative agency, an administrative review board, the Illinois Circuit Court, and the Illinois Appellate Court affirmed the denial.
- The U.S. Supreme Court noted probable jurisdiction and reviewed the state-court judgment.

## Issues

1. Whether a state may deny unemployment compensation to a claimant who refuses Sunday work for sincere religious reasons solely because the belief is not grounded in the tenets or dogma of an established religious sect.
2. Whether conditioning unemployment benefits on proof of sectarian doctrine violates the Free Exercise Clause as applied to the States through the Fourteenth Amendment.

## Decision

- The Supreme Court unanimously reversed the Illinois Appellate Court and remanded.
- The Court held that denying benefits because Frazee’s refusal was not based on the tenets or dogma of an established religious sect violated the Free Exercise Clause.
- The Court rejected the view that Free Exercise protection depends on membership in, or doctrinal commands from, an organized religious body.
- Because the State conceded the sincerity and religious nature of Frazee’s belief, the denial of benefits imposed a burden on religious exercise.
- The State offered no sufficient justification; the normalization of Sunday work was not a compelling interest on this record.

## Legal Principles

- The Free Exercise Clause protects sincere religious beliefs and practices even when they are individually held and not derived from an established sect’s formal doctrine.
- In unemployment-compensation cases, denying benefits because a claimant adheres to a sincere religious restriction can substantially burden free exercise and requires adequate state justification.
- Administrative ease in identifying sincerity may be served by sect membership, but the Constitution does not permit making such membership a prerequisite to protection.
- General assertions that a work practice (such as Sunday employment) has become common do not, without more, supply a sufficiently compelling basis to deny a legitimate free-exercise claim.

## Conclusion

The Court ruled that Illinois could not condition unemployment benefits on proof that a claimant’s sincere religious objection to Sunday work is mandated by an established religious sect, and it reversed and remanded because the State failed to justify the resulting burden on free exercise.


Frazee v. Ill. Dep’t of Emp. Sec., 489 U.S. 829 (1989)