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Hobbie v. Unemployment Appeals Commission of Florida

From Ballotpedia
Unemployment insurance


Supreme Court of the United States
Hobbie v. Unemployment Appeals Commission of Florida
Reference: 480 U.S. 136
Term: 1987
Important Dates
Argued: December 10, 1986
Decided: February 25, 1987
Outcome
Florida Fifth District Court of Appeal reversed
Majority
William BrennanByron WhiteThurgood MarshallHarry BlackmunSandra Day O'ConnorAntonin Scalia
Concurring
John StevensLewis Powell
Dissenting
William Rehnquist

Hobbie v. Unemployment Appeals Commission of Florida was a case decided on February 25, 1987, by theUnited States Supreme Court, which held that Florida's denial ofunemployment insurance benefits to claimant Paula Hobbie under the Florida Employment Security Act violated her right to religious expression under the First Amendment. The court ruled that Florida could not deny unemployment insurance benefits to Hobbie after she quit a job that required her to work on Saturday in violation of her religious beliefs.[1][2]

Background

Paula Hobbie worked for a jewelry shop called Lawton and Company. Hobbie joined the Seventh Day Adventist church and was fired after informing her employer that she could not work from sundown on Friday to sundown on Saturday. Hobbie applied for unemployment insurance benefits through the joint federal-stateunemployment insurance program, but Lawton objected to her claim, saying Hobbie’s refusal to work on Saturday because of her religious conversion constituted work-related misconduct.[1][2]

Hobbie claimed the denial of benefits violated her right to free religious exercise under theFirst Amendment. She filed suit in theFlorida Fifth District Court of Appeal, which upheld the denial of benefits.[1][2]

Oral argument

Oral argument was held on December 10, 1986. The case was decided on February 25, 1987.[1][2]

Decision

The Supreme Court decided 8-1 that Florida's denial of benefits to Hobbie under the Florida Employment Security Act violated her right to religious expression under the First Amendment. JusticeWilliam Brennan delivered the opinion of the court, joined by JusticesWilliam Brennan,Byron White,Thurgood Marshall,Harry Blackmun,Sandra Day O'Connor, andAntonin Scalia. JusticesJohn Stevens andLewis Powell delivered separate concurring opinions. Chief JusticeWilliam Rehnquist delivered a dissenting opinion.[1][2]

Opinions

Opinion of the court

JusticeWilliam Brennan argued that Florida's denial of benefits to Hobbie under the Florida Employment Security Act violated her right to religious expression under the First Amendment. Burger cited the precedent set inSherbert v. Verner andThomas v. Review Board of the Indiana Employment Security Division, arguing in part that the state’s denial of unemployment benefits to Hobbie following her religious conversion amounted to unlawful coercion by attempting to pressure Hobbie to change her behavior:[2]

In effect, the Appeals Commission asks us to single out the religious convert for different, less favorable treatment than that given an individual whose adherence to his or her faith precedes employment. We decline to do so. The First Amendment protects the free exercise rights of employees who adopt religious beliefs or convert from one faith to another after they are hired. The timing of Hobbie's conversion is immaterial to our determination that her free exercise rights have been burdened; the salient inquiry under the Free Exercise Clause is the burden involved. InSherbert,Thomas, and the present case, the employee was forced to choose between fidelity to religious belief and continued employment; the forfeiture of unemployment benefits for choosing the former over the latter brings unlawful coercion to bear on the employee's choice.[3]
—JusticeWilliam Brennan, majority opinion inHobbie v. Unemployment Appeals Commission of Florida[2]

Concurring opinions

JusticesLewis Powell andJohn Stevens concurred in the case, agreeing with the majority that it was correct to refer to the precedent set inSherbert v. Verner andThomas v. Review Board of the Indiana Employment Security Division in reversing the lower court's decision.

Dissenting opinions

JusticeWilliam Rehnquist dissented, saying he would affirm the lower court's ruling on the same lines he dissented inThomas v. Review Board of the Indiana Employment Security Division. Rehnquist argued inThomas that the majority interpreted the Free Exercise Clause and the Establishment Clause too broadly.[2]

See also

External links

Footnotes

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Unemployment insurance
Terms
Unemployment insurance programs in the states
Reform proposals
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