Frazee v. Illinois Department of Employment Security

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Unemployment insurance


Supreme Court of the United States
Frazee v. Illinois Department of Employment Security
Reference: 489 U.S. 829
Term: 1989
Important Dates
Argued: March 1, 1989
Decided: March 29, 1989
Outcome
Illinois Third District Appellate Court reversed
Majority
Byron WhiteJohn StevensWilliam BrennanThurgood MarshallHarry BlackmunSandra Day O'ConnorAntonin ScaliaWilliam RehnquistAnthony Kennedy

Frazee v. Illinois Department of Employment Security was a case decided on March 29, 1989, by the United States Supreme Court, which held that, even though Frazee was not a member of a religious group or church, Illinois' denial of unemployment benefits benefits based on his refusal to work on Sunday violated the Free Exercise Clause of the First Amendment.[1][2]

The court ruled that Illinois could not deny benefits under the joint federal-state unemployment insurance program to William Frazee based on his refusal to accept a job requiring him to work on Sunday in violation of his religious beliefs.[1][2]

Background

William Frazee refused a temporary retail position that would have required him to work on Sundays in violation of his religious beliefs. Frazee applied for unemployment benefits. The state of Illinois denied Frazee's application claiming his refusal of work disqualified him from receiving benefits.[1][2]

An administrative review board, state circuit court, and state appellate court all affirmed the denial of benefits since Frazee was not a member of an established religious sect or church, though the sincerity of his personal beliefs was not questioned.[1][2]

Oral argument

Oral argument was held on March 1, 1989. The case was decided on March 29, 1989.[1]

Decision

The Supreme Court decided 9-0 that Illinois' denial of unemployment insurance benefits to Frazee because his refusal to work on Sunday was not based on the beliefs of an established religion violated the Free Exercise Clause of the First Amendment. Justice Byron White delivered the opinion of the court, joined by Chief Justice William Rehnquist and Justices John Stevens, William Brennan, Thurgood Marshall, Harry Blackmun, Sandra Day O'Connor, Antonin Scalia, and Anthony Kennedy.[1]

Opinions

Opinion of the court

See also: Sherbert v. Verner, Thomas v. Review Board of the Indiana Employment Security Division, Hobbie v. Unemployment Appeals Commission of Florida

Justice Byron White, writing for the court, held that Illinois' denial of unemployment insurance benefits to Frazee because his refusal to work was not based on the beliefs of an established religion violated the Free Exercise Clause of the First Amendment:[1]

Frazee asserted that he was a Christian, but did not claim to be a member of a particular Christian sect. It is also true that there are assorted Christian denominations that do not profess to be compelled by their religion to refuse Sunday work, but this does not diminish Frazee's protection flowing from the Free Exercise Clause. Thomas settled that much. Undoubtedly, membership in an organized religious denomination, especially one with a specific tenet forbidding members to work on Sunday, would simplify the problem of identifying sincerely held religious beliefs, but we reject the notion that, to claim the protection of the Free Exercise Clause, one must be responding to the commands of a particular religious organization. Here, Frazee's refusal was based on a sincerely held religious belief. Under our cases, he was entitled to invoke First Amendment protection.[3]
—Justice Byron White, majority opinion in Frazee v. Illinois Department of Employment Security[1]

See also

External links

Footnotes