Thomas v. Indiana Employment Security
Whether the State’s denial of unemployment compensation benefits to the petitioner, who terminated his job because his religious beliefs prohibited him from participating in the production of armaments, constituted a violation of his First Amendment right to free exercise of religion Facts: Petition Thomas was a Jehovah’s witness who worked at the Blaw-Knox Foundry & Machinery Co. He was initially hired to work in the roll foundry until he was transferred to another department that fabricated turrets for military tanks.
Since his main function was related to the production of weapons he asked that he be transferred to another department. Having found out that all of the remaining departments at Blaw-Knox were weapons related he asked for a lay-off from his company. When this was denied, he quit from his job arguing that he could not work on weapons without violating the principles of his religion. After leaving his employment he asked for unemployment compensation from the Indiana Employment Security.
During his hearing, he declared that he thought that contributing to the production of arms violated his religion. The hearing referee concluded that Thomas’ religious belief precluded him from producing or aiding directly in the manufacture of items used in warfare. The referee however denied him his benefits on the ground that his termination from employment was not based on good cause in connection with his work as required by the Indiana statute. The Board adopted the referee’s ruling and denied the benefits.
On appeal, the Indiana Court of Appeals reversed the decision of the board and ruled that the subject Indiana statute improperly burdened Thomas’ right to free exercise his religion. The Supreme Court of Indiana vacated the decision of the Court of Appeals and denied Thomas his benefits Decision: The State’s denial of unemployment compensation benefits to petitioner violated his First Amendment right to free exercise of religion Reasons/Rationale In arriving at this conclusion, the Supreme Court first had to answer the question whether Thomas indeed quit his employment due to religion.
It is well-settled that only beliefs rooted in religion are protected by the Free Exercise Clause. According to the Supreme Court, the determination however of what is a religious belief or practice is more often than not a difficult and delicate task. The Supreme Court found that Thomas resigned from employment because he thought that production of arms violated his religion. In this case, the referee had found that Thomas quit his employment due to his religious convictions. This was affirmed by the Review Board.
The Indiana Supreme Court however concluded that Thomas had merely made a personal philosophical choice rather than a religious choice. It must be stressed that religious belief is not reduced to a philosophical choice merely because there are differences among the faithful in their interpretation of their scripture. The fact therefore that a colleague did not consider production of weapons as a serious violation of their religions should not affect Thomas’ reason for quitting his employment. It is also immaterial and insignificant if the faithful is having difficulty articulating his views.
The free exercise of religion protected by the First Amendment is not limited to beliefs which are shared by all of the members. Having disposed of the first question, the second question is whether the statute violated the free exercise of religion by Thomas. According to the Supreme Court, it is well-settled that when the state requires that certain conduct is mandated by a religious faith be first complied with before a benefit is received or when it denies such a benefit because of failure to comply with such conduct, the state is in effect placing a burden upon religion.
In this case, if we are to uphold the interpretation given on the Indiana statute then we are in effect stating that the employee should not resign for religious grounds otherwise he will not be entitled to benefits. Although the compulsion exercised by the state in this case is indirect, the infringement upon free exercise is nonetheless substantial. This however does not mean that the state cannot restrict the free exercise of religion. If there are more compelling interest which could justify the state from restricting the free exercise of religion then the burden may be allowed.
The ends, however, do not justify the means. In this case, the reasons behind the enactment of the statute do not justify violation of the free exercise of religion. There is no evidence that will prove that the number of people who find themselves in the predicament of choosing between benefits and religious beliefs is large enough to create widespread unemployment or even to seriously affect unemployment which is feared by the lower courts. There is therefore no interest more important than the free exercise of religion.
Neither is there any merit on the argument that to compel the payment of benefits to Thomas will amount to fostering a religious faith. The grant of benefits given to Thomas is a mere affirmation of the obligation of the state to become neutral in matters of the religious faith of the people. Dissenting Opinion of Justice Rehnquist Justice Rehnquist declared that the conclusion of the majority that the State of Indiana is constitutionally required to provide direct financial assistance to a person solely because of his religious beliefs actually adds mud to the already muddied waters of the First Amendment.
According to him this declaration of the majority is clearly erroneous as it does not resolve the tension between the Free Exercise Clause and the Establishment Clause of the constitution. It is the contention of Justice Rehnquist that the majority read the Free Exercise Clause too broadly. Although it upheld the free exercise of religion by Thomas, it however in effect violated the requirements of the Establishment Clause by preferring religion over another.
