Facts
- Adeil Sherbert, a South Carolina textile worker and Seventh-day Adventist, was discharged after refusing to work on Saturdays for religious reasons.
- She sought unemployment compensation but remained unemployed because she would not accept jobs requiring Saturday work.
- South Carolina’s unemployment law disqualified a claimant who, “without good cause,” failed to accept “available suitable work.”
- The South Carolina Employment Security Commission denied benefits, finding Sherbert had refused suitable work without good cause.
- A state trial court and the South Carolina Supreme Court affirmed, reasoning the denial resulted from a neutral benefits system and did not violate the First Amendment.
Issues
- Whether disqualifying Sherbert from unemployment benefits because she would not work on Saturdays imposed a substantial burden on her free exercise of religion.
- If so, whether the state had a compelling interest sufficient to justify that burden under the First and Fourteenth Amendments.
Decision
- The U.S. Supreme Court reversed, holding 7–2 that denying benefits violated the Free Exercise Clause as applied to the states through the Fourteenth Amendment.
- The Court found the benefits disqualification imposed substantial pressure on Sherbert to abandon Saturday Sabbath observance, functioning like a penalty on religious practice.
- The state’s asserted interest in preventing fraudulent religious claims was deemed speculative and insufficient to justify the burden.
- The Court rejected the argument that granting benefits would violate the Establishment Clause, concluding that avoiding a penalty on religious exercise did not establish religion.
- Justice Harlan, joined by Justice White, dissented, viewing the unemployment scheme as neutral and warning the ruling effectively required religious exemptions from generally applicable economic regulation.
Legal Principles
- Conditioning public benefits on conduct that conflicts with sincere religious observance can substantially burden free exercise when it forces a choice between faith and eligibility.
- When government action substantially burdens religious exercise, it must be justified by a compelling state interest; generalized or speculative concerns (such as possible fraud) are insufficient.
- Accommodating religious exercise to avoid penalizing religious adherence does not, by itself, constitute an establishment of religion.
- The decision articulated a strict-scrutiny framework for substantial burdens on religious exercise in benefits determinations, later associated with the “Sherbert test.”
Conclusion
The Court held that South Carolina could not deny unemployment compensation to a claimant who refused Saturday work for religious reasons absent a compelling justification, because the denial substantially burdened free exercise by pressuring the claimant to forgo Sabbath observance to receive benefits.