Berkley Center

In Frazee v. Illinois Dept. of Income Security, the Supreme Court expanded its holding from Hobbie v. Unemployment Appeals Commission of Florida in which the Court held unconstitutional a state’s denial of public benefits based on conduct mandated by religious belief to include individuals who are not members of an organized church or denomination. Under Illinois law, an individual was no longer entitled to unemployment benefits if he failed to accept suitable work when offered to him. Frazee rejected a job offer that would have required him to work on Sundays, stating that to do so would violate his personal religious beliefs, and the state terminated his unemployment benefits. The state argued that Frazee’s refusal to work on Sundays did not constitute a valid free exercise claim because he was not a member of a particular religious organization that mandated its members to observe a Sunday Sabbath. The Court rejected the state’s argument, holding that the Free Exercise Clause prevents a state from denying benefits to an individual based on conduct mandated by any sincerely held religious belief, regardless of whether that belief is mandated by a recognized sect or religion, unless the government has a compelling reason. The Court found that protecting the now-commonplace practice of Sunday work was not a compelling interest sufficient enough to override Frazee’s claim, and, thus, reversed the state’s denial of benefits.