450 U.S. 707, 101 S.Ct. 1425, 67 L.Ed.2d 624 (1981)
Thomas, a Jehovah’s Witness, was hired by Blaw-Knox Foundry & Machinery Co. to work in its roll foundry fabricating sheet steel for industrial uses.1 On his employment application, Thomas listed his membership in the Jehovah’s Witnesses and noted his hobbies of Bible study and Bible reading, though he placed no conditions on his employment.2
Approximately one year later, the roll foundry closed and Thomas was transferred to a department fabricating turrets for military tanks.3 On his first day there, Thomas realized the work was weapons related, checked the bulletin board, and found that all remaining departments at Blaw-Knox were engaged in weapons production.4 After his request for a layoff was denied, Thomas quit his job on November 6, 1975, because he believed his religious convictions prevented him from participating in the production of armaments.5
Thomas then applied for unemployment compensation benefits under the Indiana Employment Security Act.6 At an administrative hearing, Thomas testified that he had consulted a fellow Jehovah’s Witness at the plant who advised that working on weapons parts was not unscriptural, but Thomas could not accept that view and concluded his own stricter interpretation of his faith precluded such work.7 The hearing referee found that Thomas had terminated his employment due to his religious convictions but determined that this did not constitute good cause in connection with his work.8
The Review Board adopted the referee’s findings and denied benefits.9 The Indiana Court of Appeals reversed and ordered benefits, but the Indiana Supreme Court vacated that decision and denied benefits.10 The U.S. Supreme Court granted certiorari to consider the constitutional issues presented.11
Whether the State’s denial of unemployment compensation benefits to the petitioner, a Jehovah’s Witness who terminated his job because his religious beliefs forbade participation in the production of armaments, constituted a violation of his First Amendment right to free exercise of religion?12
The Free Exercise Clause prohibits the government from conditioning receipt of an important benefit upon conduct proscribed by a religious faith.13 The Clause also prohibits denying such a benefit because of conduct mandated by religious belief, thereby putting substantial pressure on an adherent to modify his behavior and to violate his beliefs. A state may justify an inroad on religious liberty by showing that it is the least restrictive means of achieving some compelling state interest.14 Only interests of the highest order can overbalance legitimate claims to the free exercise of religion.15
Yes. The Indiana Employment Security Act placed Thomas in the difficult position of choosing between adhering to his religious convictions against working on armaments and receiving unemployment benefits after quitting his job at Blaw-Knox.16 This coercive choice is indistinguishable from the burden found unconstitutional in Sherbert v. Verner.17 The state's asserted interests in avoiding widespread unemployment and detailed inquiries into religious beliefs do not justify the burden.18
The record contains no evidence that the number of similar claims would be large or that employers would make such inquiries.19
The State’s denial of unemployment compensation benefits violated Thomas’s First Amendment right to free exercise of religion.20
Related opinions on this issue
Justice Rehnquist dissented from the majority's holding on the Free Exercise Clause.21 He argued that the Court reads the Free Exercise Clause too broadly and would instead follow Braunfeld v. Brown and the dissent in Sherbert.22 In his view, a general statute with secular goals does not require the State to conform its provisions to the dictates of any individual's religious conscience.23
Rehnquist contended that the Free Exercise Clause does not compel the State to grant exemptions from neutral unemployment regulations to accommodate religious beliefs.24 He noted that the decision exacerbates the tension between the Free Exercise and Establishment Clauses and would affirm the judgment of the Indiana Supreme Court.25
Whether the Indiana Supreme Court erred in concluding that Thomas’s belief was a personal philosophical choice rather than a religious belief?26
Religious beliefs need not be acceptable, logical, consistent, or comprehensible to others to merit First Amendment protection.27 The narrow function of a reviewing court in this context is to determine whether there was an appropriate finding that petitioner terminated his work because of an honest conviction that such work was forbidden by his religion.28 Courts are not arbiters of scriptural interpretation.29
Yes. The referee found that Thomas quit due to his religious convictions, and the Review Board adopted that finding.30 Thomas testified that he could not conscientiously continue to work with armaments as it would be against all of the religious principles that he had come to learn.31 Although Thomas was struggling with his beliefs and another Jehovah’s Witness had a different view that such work was scripturally acceptable, intrafaith differences of that kind are not uncommon among followers of a particular creed, and the judicial process is singularly ill equipped to resolve such differences.32
The Indiana Supreme Court erred in concluding that Thomas’s belief was a personal philosophical choice rather than a religious belief.33
Whether awarding unemployment compensation benefits to Thomas would violate the Establishment Clause of the First Amendment?34
Awarding unemployment compensation benefits to a person who terminates employment for religious reasons reflects nothing more than the governmental obligation of neutrality in the face of religious differences.35 It does not represent that involvement of religious with secular institutions which it is the object of the Establishment Clause to forestall. Unless prepared to overrule Sherbert, Thomas cannot be denied the benefits due him on the basis of the findings that he terminated his employment because of his religious convictions.36
No. As in Sherbert, the extension of unemployment benefits to those who quit for religious reasons in common with other workers reflects nothing more than governmental neutrality.37 It does not represent involvement of religious with secular institutions which the Establishment Clause seeks to forestall. Unless prepared to overrule Sherbert, Thomas cannot be denied the benefits due him on the basis of the findings that he terminated his employment because of his religious convictions.
Awarding unemployment compensation benefits to Thomas would not violate the Establishment Clause of the First Amendment.38
Related opinions on this issue
Justice Rehnquist also dissented on the Establishment Clause issue.39 He contended that the decision requires a State to provide direct financial assistance to persons solely on the basis of their religious beliefs.40 Rehnquist argued that if Indiana were to legislate what the Court requires, the statute would plainly violate the Establishment Clause under the Lemon test because the proviso would serve only a religious purpose, its primary effect would advance religion, and it would entangle the State in religion by requiring inquiry into whether the claimant’s belief is religious and sincerely held.41
He would have affirmed the judgment of the Indiana Supreme Court.42