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Thomas v. Review Board of the Indiana Employment Security Division

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Unemployment insurance


Supreme Court of the United States
Thomas v. Review Board of the Indiana Employment Securit Div.
Reference: 450 U.S. 707
Term: 1981
Important Dates
Argued: October 7, 1980
Decided: April 6, 1981
Outcome
Indiana Supreme Court reversed
Majority
Warren BurgerByron WhiteJohn StevensLewis PowellWilliam BrennanThurgood MarshallPotter Stewart
Concurring
Harry Blackmun (in part)
Dissenting
William Rehnquist

Thomas v. Review Board of the Indiana Employment Security Division was a case decided on April 6, 1981, by the United States Supreme Court, which ruled that Indiana could not deny unemployment insurance benefits to Eddie Thomas, who quit his job for religious reasons after he was transferred to a department that manufactured weapons. The United States Supreme Court reversed the Indiana Supreme Court and held that the Indiana Employment Security Act, as applied, violated Thomas' right to religious expression under the First Amendment.[1][2]

Background

Eddie Thomas was a Jehovah's Witness originally hired to fabricate sheet steel in a roll foundry for multiple industrial uses. The foundry was closed, and Thomas was transferred to a department that manufactured military tank turrets. All other departments to which Thomas could have requested transfer also directly manufactured weapons. Thomas requested to be laid off, and when his employer denied the request, he quit and applied for unemployment insurance benefits. Thomas said directly participating in the manufacturing of weapons violated his religious beliefs.[1][2]

The Indiana Employment Security Division denied his application for unemployment benefits, alleging Thomas did not quit for good cause. The division's review board upheld the initial denial of benefits. Thomas filed suit in the Indiana Court of Appeals, which reversed the review board, holding the definition of good cause unduly hindered Thomas' right to the free exercise of religion under the First Amendment. The Indiana Supreme Court reversed the lower court's ruling, denying Thomas benefits.[1][2]

Oral argument

Oral argument was held on October 7, 1980. The case was decided on April 6, 1981.[1]

Decision

The Supreme Court decided 8-1 that Indiana's denial of benefits to Thomas under the Indiana Employment Security Act violated his right to religious expression under the First Amendment. Chief Justice Warren Burger delivered the opinion of the court, joined by Byron White, John Stevens, Lewis Powell, William Brennan, Thurgood Marshall, and Potter Stewart. Justice Harry Blackmun filed an opinion concurring in part and in the result. Justice William Rehnquist delivered a dissenting opinion.[3][1]

Opinions

Opinion of the court

Justice Warren Burger, writing for the court, argued that Indiana's denial of benefits to Thomas under the Indiana Employment Security Act violated his right to religious expression under the First Amendment. Burger cited the precedent set in Sherbert v. Verner and said the state's interest was not sufficiently compelling to justify the denial of benefits:[1]

Where the state conditions receipt of an important benefit upon conduct proscribed by a religious faith, or where it denied such a benefit because of conduct mandated by religious belief, thereby putting substantial pressure on an adherent to modify his behavior and to violate his beliefs, a burden upon religion exists. While the compulsion may be indirect, the infringement upon free exercise is nonetheless substantial. ...


Neither of the interests advanced is sufficiently compelling to justify the burden upon Thomas' religious liberty. Accordingly, Thomas is entitled to receive benefits. ...

Unless we are prepared to overrule Sherbert, supra, Thomas cannot be denied the benefits due him on the basis of the findings of the referee, the Review Board, and the Indiana Court of Appeals that he terminated his employment because of his religious convictions.[4]

—Justice Warren Burger, majority opinion in Thomas v. Review Board of the Indiana Employment Security Div.[1]

Concurring opinions

Justice Harry Blackmun concurred in parts I, II, and III, and in the result of the opinion.[1]

Dissenting opinions

Justice William Rehnquist, writing the dissent, said the majority interpreted the Free Exercise Clause and the Establishment Clause too broadly. Rehnquist argued for a narrower reading of the clauses, which he said could alleviate tension between them.[1]

In sum, my difficulty with today's decision is that it reads the Free Exercise Clause too broadly and it fails to squarely acknowledge that such a reading conflicts with many of our Establishment Clause cases. As such, the decision simply exacerbates the "tension" between the two Clauses. If the Court were to construe the Free Exercise Clause as it did in Braunfeld and the Establishment Clause as JUSTICE STEWART did in Schempp, the circumstances in which there would be a conflict between the two Clauses would be few and far between. Although I heartily agree with the Court's tacit abandonment of much of our rhetoric about the Establishment Clause, I regret that the Court cannot see its way clear to restore what was surely intended to have been a greater degree of flexibility to the Federal and State Governments in legislating consistently with the Free Exercise Clause. Accordingly, I would affirm the judgment of the Indiana Supreme Court.[4]
—Justice William Rehnquist, dissenting opinion in Thomas v. Review Board of the Indiana Employment Security Div.[1]

See also

External links

Footnotes

  1. 1.0 1.1 1.2 1.3 1.4 1.5 1.6 1.7 1.8 1.9 Justia, "Thomas v. Review Bd., Ind. Empl. Sec. Div., 450 U.S. 707 (1981)," accessed November 8, 2021
  2. 2.0 2.1 2.2 Cornell Law School, "Eddie C. THOMAS, Petitioner, v. REVIEW BOARD OF the INDIANA EMPLOYMENT SECURITY DIVISION et al.," accessed August 27, 2021
  3. Cite error: Invalid <ref> tag; no text was provided for refs named oyez
  4. 4.0 4.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.