Law School Case Brief
Hobbie v. Unemployment Appeals Com. - 480 U.S. 136, 107 S. Ct. 1046 (1987)
Where the state conditions receipt of an important benefit upon conduct proscribed by a religious faith, or where it denies such a benefit because of conduct mandated by religious belief, thereby putting substantial pressure on an adherent to modify his behavior and to violate his beliefs, a burden upon religion exists. While the compulsion may be indirect, the infringement upon free exercise is nonetheless substantial.
In 1984, pursuant to a bona fide conversion to the Seventh Day Adventist Church, Paula Hobbie, a worker for Lawton and Company (Lawton), a Florida jewelry company, informed her immediate supervisor that she would no longer be able to work on her Sabbath, from sundown on Friday to sundown on Saturday. Although the supervisor initially devised an arrangement with the worker, Lawton’s general manager eventually informed Hobbie that she could either work her scheduled shifts or resign. When Hobbie refused to do either, Lawton discharged her and contested her subsequent claim for unemployment compensation on the ground that she had been discharged for misconduct connected with her work.
Under Florida law, an employee who is discharged for misconduct connected with work (1) is disqualified from receipt of unemployment compensation benefits for the week of departure, and until the worker becomes re-employed and earns 17 times the weekly benefit amount; and (2) may receive an additional penalty of a specified number of weeks, depending on the severity of the employee's offense. A claims examiner for the Florida Bureau of Unemployment Compensation denied Hobbie’s claim for benefits. On appeal, following a hearing before a referee, the Florida Unemployment Appeals Commission affirmed the denial of benefits, expressing the view that Hobbie’s refusal to work scheduled shifts constituted misconduct connected with her work. On appeal, the District Court of Appeal of Florida, Fifth District, issued a per curiam affirmance without opinion. Under Florida law, such a per curiam affirmance could not be appealed to the state supreme court, so Hobbie sought further appeal in the United States Supreme Court.
Did Florida's refusal to award unemployment compensation benefits to Hobbie violate the Free Exercise Clause of the First Amendment?
The United States Supreme Court concluded that the Unemployment Appeals Commission's disqualification of Hobbie from receipt of benefits violated the Free Exercise Clause of the First Amendment, applicable to the states through the Fourteenth Amendment. The court noted that the accommodation of the employee's religious beliefs would not amount to a violation of the Establishment Clause.
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