Employment Division v. Smith

Employment Division v. Smith, 494 U.S. 872 (1990), is a landmark decision of the United States Supreme Court.

Alfred Smith and Galen Black were fired from their jobs at a drug rehabilitation clinic for ingesting peyote, a hallucinogen used in Native American Church religious ceremonies. They were denied unemployment benefits because they had been discharged for work-related misconduct. They argued that denying benefits violated the Free Exercise Clause.

Significance

Justice Scalia’s 5-4 opinion held that neutral, generally applicable laws that incidentally burden religious practices do not violate the Free Exercise Clause. The Court rejected the balancing test of Yoder and Sherbert v. Verner (1963), holding that the right of free exercise does not relieve individuals of the obligation to comply with valid laws prohibiting conduct that the state is free to regulate. The decision was highly controversial and led to the Religious Freedom Restoration Act of 1993, which restored the strict scrutiny standard for federal laws.

Category

US Federal Case Law