Thomas v. Review Board of the Indiana Employment Security Division

Petitioner
Eddie C. Thomas
Respondent
Review Board of the Indiana Employment Security Division
Petitioner's Claim
That the Indiana Employment Security Division's refusal to grant unemploymentbenefits to Thomas, a Jehovah's Witness who quit his job for religious reasons, violated his right to free exercise of religion.
Chief Lawyer for Petitioner
Blanca Bianchi de la Torre
Chief Lawyer for Respondent
William E. Daily
Justices for the Court
Harry A. Blackmun, William J. Brennan, Jr., Warren E. Burger (writing for theCourt), Thurgood Marshall, Lewis F. Powell, Jr., John Paul Stevens, Potter Stewart, Byron R. White
Justices Dissenting
William H. Rehnquist
Place
Washington, D.C.
Date of Decision
6 April 1981
Decision
The Indiana Employment Security Division did in fact violate Thomas' constitutional right to free exercise of religion under the First Amendment.
Significance
Thomas v. Review Board of the Indiana Employment Security Division reinforced earlier decisions that required the states to have a compelling interest when denying unemployment benefits to people who leave their jobs becauseof sincere religious convictions.
Eddie C. Thomas, a Jehovah's Witness, was employed by the Blaw-Knox Foundry and Machinery Company in Indiana as a sheet metal worker. After a year on thejob, he found himself transferred to another department which produced turrets for military tanks. Since the manufacture of armaments violated his religious beliefs, Thomas asked for a second transfer. When he was told there were no other openings in departments unrelated to military production, he asked tobe laid off. When this request was likewise refused, Thomas quit his job. Thomas then applied for unemployment compensation benefits and appeared at an administrative hearing to explain his beliefs. His request for benefits was denied, on the grounds that his decision to quit was not based on "good cause arising in connection with his work." The Indiana Employment Security Divisionaffirmed this decision, which Thomas then appealed in the state court--on the grounds that the denial of benefits violated his right to the free exercisehis religion.
The Lower Court Rulings
The Indiana Court of Appeals agreed with Thomas' argument and reversed the ruling of the Employment Security Division. The Employment Security Division then appealed to the Indiana Supreme Court, which vacated the court of appeals'decision. It asserted that Thomas' decision to quit was not an exercise of religious belief but "a personal-philosophical choice." It further ruled thatwhatever burden was being imposed on Thomas' First Amendment right to religious practice was greatly outweighed by the state of Indiana's need to keep theunemployment compensation fund financially sound. It could only do this by keeping strict eligibility rules to deter people from making fraudulent or frivolous unemployment claims. Finally, the Indiana Supreme Court determined that to give financial assistance to someone who left his job on religious grounds would violate the First Amendment clause prohibiting the establishment ofa state religion. Not to be deterred, Thomas then appealed again--this time to the U.S. Supreme Court.
The Supreme Court Decides
On 6 April 1981, the Supreme Court issued its decision. By an 8-1 vote, it ruled in favor of Thomas and against the Indiana Employment Security Division.Chief Justice Burger wrote the majority opinion. The majority ruled that thedenial of unemployment benefits in this case had in fact substantially infringed upon Thomas' free exercise of religion. Moreover, in the Court's opinion,the state of Indiana had failed to justify its decision to deny benefits toan extent that would outweigh the burden placed on Thomas. Regarding the Indiana Supreme Court's conclusion that Thomas' reasons for quitting were "philosophical" rather than religious, Burger wrote:

In reaching this conclusion, the Indiana court seems to have placed considerable reliance on thefacts that Thomas was "struggling" with his beliefs and that he was not ableto "articulate" his belief precisely . . . Courts should not undertake to dissect religious beliefs because the believer admits that he is "struggling" with his position or because his beliefs are not articulated with the clarity and precision that a more sophisticated person might employ.

As to the review board's claim that forcing it to pay benefits to Thomas would violate the First Amendment's Establishment Clause, the Court rejected thenotion that "to compel benefit payments to Thomas involves the state in fostering a religious faith." In addition, the Court dismissed the contention thatthe state had a "compelling interest" in deterring people from quitting jobsfor "personal" reasons:

There is no evidence in the record to indicate that the number of people who find themselves in the predicament of choosing between benefits and religious beliefs is large enough to create "widespread unemployment."

Justice Rehnquist dissented. He believed that to force Indiana to extend benefits to Thomas would violate the Establishment Clause as the Supreme Court had interpreted it in past cases:

I believe that although a State could choose to grant exemptions to religious persons from state unemployment regulations, a state is not constitutionally compelled to do so. If Indiana were to legislate what the Court today requires--an unemployment compensation law which permitted benefits to be granted to those persons who quit their jobs for religious reasons--the statute would "plainly" violate the Establishment Clause . . . [A]lthough the unemployment statute as a whole would be enacted to serve a secular legislative purpose, the proviso would clearly serve only a religious purpose. It would grant financial benefits for the sole purposeof accommodating religious beliefs.

Thomas v. Review Board of the Indiana Employment Security Division wasan important case in the constitutional history of freedom of religion. It did not settle the matter once and for all, however. The Court would return again and again to the thorny question of where freedom of religion ends and the establishment of religion begins.
Related Cases

• Stromberg v. California, 283 U.S. 359 (1931).
  
• Cantwell v. Connecticut, 310 U.S. 296 (1940).
  
• Everson v. Board of Education, 330 U.S. 1 (1947).
  
• Walz v. Tax Commisioner, 397 U.S. 664 (1970).
  
• Wisconsin v. Yoder, 406 U.S. 205 (1972).