Facts
- Eddie C. Thomas, a Jehovah’s Witness, worked for Blaw-Knox Foundry & Machinery Co. in a department producing sheet steel.
- After the foundry closed, the employer transferred Thomas to a department manufacturing turrets for military tanks.
- Thomas believed that direct participation in weapons production violated his religion, though he could work on materials only indirectly connected to weapons.
- When no other available departments avoided direct weapons work, Thomas asked to be laid off; the employer refused.
- Thomas quit and applied for unemployment compensation under Indiana law.
- A referee (and later the Review Board) found Thomas quit because of religious convictions but denied benefits for lack of “good cause” connected with the work.
- The Indiana Court of Appeals reversed on Free Exercise grounds, but the Indiana Supreme Court reinstated the denial, treating Thomas’s decision as a personal choice and finding any burden on religion indirect.
Issues
- Whether the Free Exercise Clause requires a state to award unemployment benefits to a claimant who quit work based on a sincere religious belief that the work required prohibited conduct.
- Whether denying benefits in these circumstances imposes a substantial burden on religious exercise and, if so, whether the state has a compelling justification.
Decision
- The Supreme Court reversed the Indiana Supreme Court.
- The Court held that denying Thomas unemployment benefits because he quit for sincere religious reasons violated the Free Exercise Clause.
- The Court rejected the view that courts may disqualify a claim by labeling the claimant’s belief “philosophical” or by comparing it to the views of other members of the same faith.
- The Court concluded the denial imposed substantial pressure to violate religious beliefs and that Indiana failed to show a compelling state interest sufficient to justify the burden.
- The Court held that granting benefits as an accommodation did not violate the Establishment Clause.
- Justice Blackmun concurred in part and in the result.
- Justice Rehnquist dissented, arguing the Constitution does not require financial assistance based solely on religious beliefs.
Legal Principles
- A claimant’s sincerely held religious belief is protected even if it is not shared by other adherents or is difficult to articulate; courts should not judge its theological correctness or internal consistency.
- Denial of generally available unemployment benefits because a claimant acted on religious conviction can substantially burden free exercise by coercing the claimant to choose between faith and a public benefit.
- When state action substantially burdens religious exercise in the unemployment-benefits context, the state must demonstrate a compelling interest achieved through narrowly tailored means.
- Providing unemployment benefits to accommodate religious exercise is a permissible accommodation and does not, by itself, constitute an establishment of religion.
Conclusion
The Court held that Indiana could not deny unemployment compensation to a worker who quit rather than perform work he sincerely believed his religion forbade, because the denial substantially burdened free exercise and the state did not show a compelling justification.