## Facts

- Paula Hobbie worked as a sales clerk at a Florida jewelry store for about two and a half years.
- During her employment, she converted to the Seventh-day Adventist Church and informed her employer she could not work from sundown Friday to sundown Saturday because of her Sabbath observance.
- After she refused to work scheduled Friday evening and Saturday shifts, the employer discharged her.
- Hobbie applied for unemployment compensation, but a claims examiner denied benefits, finding “misconduct connected with [her] work” under Florida law.
- The Florida Unemployment Appeals Commission affirmed the denial, treating her Sabbath-based refusal as disqualifying misconduct.
- The Florida Fifth District Court of Appeal affirmed, rejecting Hobbie’s First Amendment challenge.

## Issues

1. Whether disqualifying a claimant from unemployment compensation because she refused Sabbath work required by sincere religious belief violates the Free Exercise Clause.
2. Whether the State may apply a less demanding standard than strict scrutiny to justify a benefits denial that pressures religiously motivated conduct.
3. Whether providing unemployment benefits in these circumstances would violate the Establishment Clause.

## Decision

- The Supreme Court reversed the Florida court’s judgment (8–1).
- Denying unemployment benefits because the claimant would not work during her Sabbath imposed a substantial burden on religious exercise by pressuring her to modify behavior and violate beliefs.
- The Court applied strict scrutiny under the unemployment-benefits line of Free Exercise cases and held Florida did not show a compelling interest justifying the denial.
- The Court rejected Florida’s attempt to distinguish a time-limited “disqualification” from complete “ineligibility,” concluding the economic penalty was substantial in either form.
- The Court rejected the argument that conversion during employment weakens Free Exercise protection; converts are protected no less than longstanding adherents.
- The Court held that awarding benefits as an accommodation did not violate the Establishment Clause.

## Legal Principles

- When the State denies a benefit because of conduct mandated by sincere religious belief, and the denial substantially pressures the claimant to violate those beliefs, the denial is subject to strict scrutiny.
- A time-limited statutory “disqualification” from unemployment benefits can substantially burden religious exercise to the same extent as complete ineligibility.
- Free Exercise protection does not depend on whether the religious belief predated employment or arose through conversion during employment.
- Administrative interests in applying general misconduct or eligibility rules, without more, do not constitute a compelling interest sufficient to justify burdening religious exercise in this benefits context.
- Granting unemployment benefits to remove a state-imposed burden on religious practice is a permissible accommodation and does not, by itself, violate the Establishment Clause.

## Conclusion

The Court held that Florida violated the Free Exercise Clause by denying unemployment benefits to a worker discharged for refusing Sabbath work required by her sincere religious beliefs, and it further held that awarding such benefits is a permissible religious accommodation consistent with the Establishment Clause.


Hobbie v. Unemployment Appeals Comm’n of Fla., 480 U.S. 136 (1987)