Thomas v. Review Board of the Indiana Employment Security Division

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 the denial 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 to an 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 the facts that Thomas was "struggling" with his beliefs and that he was not able to "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 the notion that "to compel benefit payments to Thomas involves the state in fostering a religious faith." In addition, the Court dismissed the contention that the state had a "compelling interest" in deterring people from quitting jobs for "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 purpose of accommodating religious beliefs.

Thomas v. Review Board of the Indiana Employment Security Division was an 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.