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Thomas v. Review Board of the Indiana Employment Security Division

Facts of the Case

Provided by Oyez

Eddie C. Thomas, a Jehovah's Witness and an employee of Blaw-Knox Foundry & Machinery Co., asked his company to lay him off when it transferred all of its operations to weapons manufacturing. He stated that his religious faith prohibited him from producing arms. His employer refused, so he quit instead. He applied for unemployment compensation benefits under the Indiana Employment Security Act, which the Review Board of the Indiana Employment Security Division denied. The board agreed that he quit because of his religious convictions, but claimed that this was not a "good cause [arising] in connection with [his] work" that would qualify him for benefits. The Indiana Court of Appeals reversed the decision on the ground that it burdened Thomas' First Amendment right to the free exercise of his religion. The Supreme Court of Indiana reinstated the board's initial decision, calling Thomas' decision to quit a "personal philosophical choice" that only indirectly burdened his free exercise right.

Questions

  1. Does the Free Exercise Clause require a state to provide unemployment compensation benefits to an employee who quit because of a belief that his religion prohibited him from engaging in the employer's line of work?

Conclusions

  1. Yes. In an 8-1 decision authored by Justice Burger, the Court held that the Review Board's denial of unemployment benefits to Thomas violated his First Amendment right to the free exercise of religion. The Supreme Court of Indiana wrongfully used Thomas' struggle to "articulate" his religious beliefs as grounds to call his decision merely "philosophical." The Court's decisions in _ Everson v. Board of Education_ and Sherbert v. Verner had established that "[a] person may not be compelled to choose between the exercise of a First Amendment right and participation in an otherwise available public program." In his dissent, Justice Rehnquist argued that the free exercise clause did not require a "State to provide direct financial assistance to persons solely on the basis of their religious beliefs."