Employment Division, Department of Human Resources of Oregon v. Smith

Citation. 494 U.S. 872, 110 S.Ct. 1595, 108 L.Ed.2d 876 (1990).

Brief Fact Summary.

Plaintiffs challenged denial of unemployment benefits due to religious use of peyote, arguing the denial violated their rights under the Free Exercise Clause of the First Amendment.

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Synopsis of Rule of Law.

An individual’s religious beliefs do not excuse him from compliance with an otherwise valid law prohibiting conduct that the state is free to regulate.

Facts.

Plaintiffs were both members of the Native American Church. As part of their religious rituals, they ingested peyote, an illegal substance under Oregon law. Following, Plaintiffs were fired from their jobs at a private drug rehabilitation. clinic. Plaintiffs then filed for unemployment benefits and were denied because they were fire for work related misconduct. Plaintiff challenged the denials, arguing it violated the Free Exercise Clause of the First Amendment.

Issue.

Whether a law which prohibits use of peyote, even in religious contexts, and denies unemployment benefits as a result violates the Free Exercise Clause of the First Amendment.

Held.

No. A law which prohibits use of peyote, even in religious contexts, and denies unemployment benefits as a result does not violate the Free Exercise Clause of the First Amendment.

Dissent.

Justice Blackmun

The state’s asserted interest amounts only to the symbolic preservation of an unenforced prohibition. they proclaim health and safety without evidence peyote has harmed anyone. The factual findings of other courts cast doubt on the state’s assumption that peyote is harmful. As such, the state’s interest is not compelling. I dissent.

Concurrence.

Justice O’Connor

Today’s holding dramatically departs from well-settled First Amendment jurisprudence. The Court today interprets the Clause to permit the government to prohibit, without justification, conduct mandated by individual religious beliefs, so long as that prohibition is generally applicable. This is a narrow reading that is unnecessary to this case. I would reach the same result by applying precedent.

Discussion.

Can a man excuse his practices to the contrary because of his religious belief? To permit this would be to make the professed doctrines of religious belief superior to the law of the land, and in effect to permit every citizen to become a law unto himself. This contradicts both constitutional tradition and common sense.

The right of free exercise does not relieve an individual of the obligation to comply with a valid and neutral law of general applicability. We leave accommodation to the political process. As judges, we will not weigh the social importance of all laws against the centrality of all religious beliefs. Judgement reversed.