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Hobbie v. Unemployment Appeals Commission of Florida

Supreme Court of the United States · 1987 · Constitutional Law

Constitutional LawFree Exercise ClauseUnemployment CompensationFree Exercise Clauseunemployment benefitsreligious accommodationstrict scrutinycompelling interest

Facts

Paula Hobbie worked for a Florida jewelry company for about 2 1/2 years. During her employment, she converted to the Seventh-day Adventist Church and informed her supervisor that, for religious reasons, she could no longer work from sundown Friday to sundown Saturday, her Sabbath; a temporary scheduling arrangement accommodated this restriction. When the general manager learned of the arrangement, he told Hobbie she must work her scheduled shifts or resign, and when she refused either option, the company discharged her. Florida then denied her unemployment benefits, treating her refusal to work those shifts as misconduct connected with her work.

Issue

Whether Florida violates the Free Exercise Clause by denying unemployment compensation to an employee who was discharged after refusing, for sincerely held religious reasons adopted after she began employment, to work during her Sabbath. More specifically, the question is whether the timing of her conversion or the state's characterization of her conduct as misconduct permits the denial of benefits.

Rule

A state burdens free exercise when it conditions receipt of an important benefit on conduct prohibited by a person's religious faith, or denies that benefit because of conduct mandated by religious belief, thereby placing substantial pressure on the person to modify behavior and violate those beliefs. In the unemployment-compensation context, such a burden is subject to strict scrutiny and is permissible only if the state proves a compelling interest.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Nina Patel worked for Lakeview Packaging, a fictional company in Columbus, Ohio. After joining a faith community, she told her supervisor that her religion forbids her from working from sunset Friday to sunset Saturday; when Lakeview later scheduled her during that period and fired her for refusing, Ohio denied her unemployment claim on the ground that she violated workplace rules.

Which is the strongest constitutional argument against Ohio's denial of benefits?

Explanation. The governing rule is that a state burdens free exercise when it conditions an important benefit on conduct prohibited by religion or denies that benefit because of conduct mandated by religious belief, thereby placing substantial pressure on the claimant to modify behavior and violate those beliefs. In the unemployment-benefits context, that burden triggers strict scrutiny. The state's label of the conduct as rule-breaking or misconduct does not eliminate the constitutional problem where the denial flows from religiously mandated conduct. (Derived from Hobbie v. Unemployment Appeals Commission of Florida (1987).)