Brief Fact Summary. The Supreme Court of the United States (Supreme Court) held that South Carolina may not constitutionally apply the eligibility provisions of its unemployment compensation scheme in order to deny unemployment benefits to a Seventh-Day Adventist because she refused to work on Saturday.
Synopsis of Rule of Law. A state may not constitutionally apply the eligibility provisions of its unemployment compensation scheme so as to constrain a worker to abandon her religious convictions respecting the day of rest.
Facts. The Appellant, Sherbert (Appellant), a Seventh-Day Adventist was denied unemployment benefits by South Carolina because she refused to work on Saturdays. Specifically, her claim for unemployment benefits was denied because the state compensation law barred benefits to workers who failed, without good cause, to accept “suitable work when offered.” She refused to take a job that required her to work Saturdays. The highest state court sustained the denial of benefits.
Issue. Whether the disqualification for benefits imposes any burden on the free exercise of Appellant’s religion?
Whether some compelling state interest justifies the substantial infringement of Appellant’s First Amendment constitutional right?
Held. Yes. Judgment of the highest state court reversed and remanded for further proceedings. The consequences of such a disqualification to religious principles and practices may be only an indirect result of welfare legislation within the state’s general competence to enact. Here, not only is it apparent that Appellant’s declared ineligibility for benefits solely derives from the practice of her religion, but the pressure upon her to forego that practice is unmistakable. Governmental imposition of such a choice puts the same kind of burden upon the free exercise of religion as would a fine imposed against Appellant for her Saturday worship. Therefore, the disqualification for benefits imposes a burden on the free exercise of Appellant’s religion.
No. Judgment of the highest state court reversed and remanded for further proceedings. The state’s asserted interest is no more than a possibility of the filing of fraudulent claims by people feigning religious objections to Saturday work. Here, no justifications underlie the determination of the state court that Appellant’s religion makes her ineligible to receive benefits. South Carolina may not constitutionally apply the eligibility provisions of its unemployment compensation scheme in order to deny unemployment benefits to a Seventh-Day Adventist because she refused to work on Saturday. Therefore, there are no compelling state interests that justify the substantial infringement of Appellant’s First Amendment constitutional right.
Dissent. In no way did the state did not discriminate against the Appellant on the basis of her religious beliefs or that she was denied benefits because she was a Seventh-Day Adventist.
Concurrence. It is the Supreme Court’s duty to face up to the dilemma posed by the conflict between religion cases.
Discussion. In the wake of this holding, religious objectors to general regulations repeatedly came to the Court invoking Sherbert’s strict scrutiny in claiming constitutionally mandated exemptions. Although the Court typically adhered to the Sherbert analysis in form, it quite frequently rejected the religious objector’s claims in fact.