Paula Hobbie worked for Lawton and Company, a Florida jewelry shop. She joined the Seventh-day Adventist Church and informed her employer that she could not work from sundown on Friday to sundown on Saturday since it was her new church's Sabbath day. Lawton soon dismissed her for refusing to work Friday evening and Saturday shifts. Hobbie filed for unemployment compensation with the Florida Department of Labor and Employment Security. Lawton objected to paying benefits, claiming that she did qualify since she had been dismissed "for misconduct connected with her work." The Bureau of Unemployment Compensation agreed and denied her benefits. Hobbie claimed that this violated the Free Exercise Clause of the First Amendment. She unsuccessfully appealed the decision in the Florida Fifth District Court of Appeal.
Did the state of Florida violate the Free Exercise Clause by denying unemployment benefits to an employee who was dismissed for refusing to work certain shifts because of conflicting religious obligations?
Yes. Justice William J. Brennan Jr. delivered the opinion for an 8-1 court. Referring to its similar decisions in Sherbert v. Verner and Thomas v. Review Bd. of Indiana Employment Security Div., the Court maintained that a state cannot deny unemployment benefits to an employee dismissed for having religious conflicts with the employer. This violates the Free Exercise Clause by pressuring religious adherents to modify their religious views in order to retain work or benefits. The state cannot do this without a compelling interest. The Court did not find it relevant that Hobbie converted after she began working, and did not consider the fact that she still qualified for partial benefits a satisfactory remedy.
Decisions
Decision: 8 votes for Hobbie, 1 vote(s) against Legal provision: Free Exercise of Religion
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Full Opinion by Justice William J. Brennan, Jr.
