Hobbie v Unemployment Appeals Commission of Florida – 19.04

Hobbie v Unemployment Appeals Commission of Florida
Digest no. 19.04

Cite as: Hobbie v Unemployment Appeals Comm of Florida, 480 US 136 (1987).

Appeal pending: No
Claimant: Paula Hobbie
Employer: Lawton and Company
Docket no.: S.Ct. No. 85 993
Date of decision: February 25, 1987

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UNITED STATES SUPREME COURT HOLDING: When a State denies receipt of a benefit because of conduct mandated by religious belief, thereby putting substantial pressure on an adherent to modify his behavior and violate his beliefs, that denial must be subjected to strict scrutiny and can be justified only by proof of a compelling state interest. The First Amendment protects the free exercise rights of employees who adopt religious beliefs or convert from one faith to another after being hired.

FACTS: Claimant worked for the employer for 2.5 years before her religious conversion and baptism into the Seventh Day Adventist Church. At that point she informed her supervisor that she could no longer work on her sabbath – sundown Friday to sundown Saturday. Although her supervisor agreed to substitute for her whenever she was scheduled on her sabbath, the supervisors’ supervisor would not agree to that arrangement and instructed claimant to work as scheduled or resign. When claimant refused to do either she was discharged.

DECISION: Florida’s refusal to award unemployment compensation benefits to claimant violated the Free Exercise Clause of the First Amendment.

RATIONALE: The timing of claimant’s conversion in immaterial to the question of whether her free exercise rights have been burdened. Claimant was forced to choose between fidelity to her religious belief and continued employment. The forfeiture of unemployment benefits for choosing the former over the latter brings unlawful coercion to bear on the employee’s choice.

Digest Author:  Board of Review (original digest here)
Digest Updated: 12/91