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Thomas v. Review Board of the Indiana Employment Security Division

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1981 United States Supreme Court case
Thomas v. Review Board of the Indiana Employment Security Division
Argued October 7, 1980
Decided April 6, 1981
Full case nameThomas v. Review Board of the Indiana Employment Security Division et al.
Citations450U.S.707 (more)
101 S. Ct. 1425; 67L. Ed. 2d 624; 1981U.S. LEXIS 11
ArgumentOral argument
Case history
PriorDecision of the State Employment Security Review Board reversed, 381N.E.2d 888 (Ind. Ct. App. 1978); reversed, 271 Ind. 233, 391 N.E.2d 1127 (1979);cert. granted,444 U.S. 1070 (1980).
Holding
"The State's denial of unemployment compensation benefits to petitioner violated his First Amendment right to free exercise of religion..."[1]
Court membership
Chief Justice
Warren E. Burger
Associate Justices
William J. Brennan Jr. · Potter Stewart
Byron White · Thurgood Marshall
Harry Blackmun · Lewis F. Powell Jr.
William Rehnquist · John P. Stevens
Case opinions
MajorityBurger, joined by Brennan, Stewart, White, Marshall, Powell, Stevens; Blackmun (Parts I, II, III)
ConcurrenceBlackmun (concurring in part and concurring in the result)
DissentRehnquist
Laws applied
U.S. Const. amend. I

Thomas v. Review Board of the Indiana Employment Security Division, 450 U.S. 707 (1981), was a case in which theSupreme Court of the United States held thatIndiana's denial of unemployment compensation benefits to petitioner violated hisFirst Amendment right tofree exercise of religion.[1]

Background

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Thomas, aJehovah's Witness, asked his employer to lay him off after the company transferred all of its operations to weapon manufacturing, because his religious faith prohibited him from producing weapons. His employer refused and Thomas quit. He applied for unemployment compensation benefits under the Indiana Employment Security Act, but was denied. The Review Board of the Indiana Employment Security ruled that his voluntary termination due to his religious beliefs was not a "good cause [arising] in connection with [his] work" that would qualify him for benefits under the Indiana Employment Security Act.[2]

TheIndiana Court of Appeals reversed the decision and held that the Indiana statute, as applied, improperly burdened Thomas' First Amendment right to the free exercise of his religion.[2]

TheIndiana Supreme Court reinstated the Review Board's decision and ruled that his decision to quit was a "personal philosophical choice" that only indirectly burdened his free exercise right.[2]

Opinion of the Court

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Chief JusticeWarren Burger authored the 8-1 majority decision, which held that Indiana's denial of unemployment benefits to Thomas violated his First Amendment right to the free exercise of religion.

The Court said that the Indiana Supreme Court had incorrectly characterized Thomas's decision to quit his job due to his religious beliefs as merely a "philosophical" choice.

The Court based its ruling on the precedents set inEverson v. Board of Education andSherbert v. Verner, which establish that "[a] person may not be compelled to choose between the exercise of a First Amendment right and participation in an otherwise available public program."

JusticeRehnquist dissented. He argued that theFree Exercise Clause did not require a "State to provide direct financial assistance to persons solely on the basis of their religious beliefs."[1]

Impact

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Scholars viewed the Thomas decision as significant. It establishes a well-defined test to be applied in free exercise cases, and it expanded the First Amendment protection to beliefs that are neither well-defined nor clearly articulated.[3]

In June 1981, two months after the Thomas decision, the U.S. Department of Labor issued a directive to state employment security agencies on how the Supreme Court's ruling impacted state laws regarding voluntary job resignation for religious reasons.[4]

See also

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Public Domain This article incorporatespublic domain material from websites or documents of theUnited States government.

References

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  1. ^abcThomas v. Review Bd. of Indiana Employment Sec. Div.,450 U.S.707 (1981).
  2. ^abcCovington, Jesse (January 9, 2025)."Thomas v. Review Board of Indiana Employment Security Division (1981)".firstamendment.mtsu.edu. RetrievedMarch 9, 2025.
  3. ^Gardner, Lynn McCutchen (May 15, 1983)."A New Standard of Review in Free Exercise Cases: Thomas v. Review Board of the Indiana Employment & Security Division".Pepperdine Law Review.10 (4):791–813.
  4. ^"U.S. Labor Department Directive: Unemployment Insurance Program Letter NO. 27-81". June 16, 1981. RetrievedMarch 9, 2025.

External links

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Exclusion of religion
from public benefits
Ministerial exception
Statutory religious exemptions
RFRA
RLUIPA
Others
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