Employment Division v. Smith

E14513

Employment Division v. Smith is a landmark 1990 U.S. Supreme Court decision that significantly narrowed protections for religious practices under the Free Exercise Clause by upholding the enforcement of neutral, generally applicable laws even when they incidentally burden religion.

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Statements (49)

Predicate Object
instanceOf United States Supreme Court case
free exercise of religion case
landmark decision
hasAreaOfLaw First Amendment to the United States Constitution
surface form: First Amendment law

constitutional law
religious liberty law
hasCategory 1990 in United States case law
United States Supreme Court cases on freedom of religion
United States Supreme Court cases on the First Amendment
hasChiefJusticeAtDecision William H. Rehnquist
hasCitation 494 U.S. 872
hasConcurrenceBy Harry A. Blackmun
surface form: Harry Blackmun

Sandra Day O’Connor
hasConstitutionalProvision First Amendment to the United States Constitution
Free Exercise Clause
hasCountry United States of America
surface form: United States
hasCourt Supreme Court of the United States
hasDecisionDate 1990
hasDecisionYear 1990
hasDissentBy Harry A. Blackmun
surface form: Harry Blackmun

Thurgood Marshall
William J. Brennan Jr.
hasFact Oregon law criminalized possession of peyote
respondents ingested peyote as part of a religious ceremony
respondents were members of the Native American Church
hasFullCitation Employment Division v. Smith self-linksurface differs
surface form: Employment Division, Department of Human Resources of Oregon v. Smith, 494 U.S. 872 (1990)
hasHolding The Free Exercise Clause does not relieve an individual of the obligation to comply with a valid and neutral law of general applicability on the ground that the law proscribes conduct that his religion prescribes.
hasImpact narrowed judicial protection for religiously motivated conduct under the Free Exercise Clause
prompted legislative responses to restore stronger protections for religious exercise
shifted Free Exercise analysis away from strict scrutiny for neutral, generally applicable laws
hasIssue whether Oregon could deny unemployment benefits to workers fired for using peyote in a religious ceremony
hasJurisdiction Oregon
hasKeyConcept compelling interest test
incidental burden on religion
neutral law of general applicability
strict scrutiny
unemployment benefits and religious conduct
hasLegalPrinciple neutral laws of general applicability that incidentally burden religion do not violate the Free Exercise Clause
strict scrutiny is not required for every neutral, generally applicable law that burdens religious practice
hasLowerCourt Oregon Supreme Court
hasMajorityAuthor Antonin Scalia
hasOutcome Oregon Employment Department
surface form: Oregon was allowed to deny unemployment benefits to the respondents
hasPetitioner Employment Division, Department of Human Resources of Oregon
hasProceduralHistory affirmed in part and reversed in part the judgment of the Oregon Supreme Court
hasRespondent Alfred Leo Smith
Galen Black
hasSubsequentLegislationInfluenced Religious Freedom Restoration Act
surface form: Religious Freedom Restoration Act of 1993

state-level Religious Freedom Restoration Acts
hasVote 6–3

Referenced by (13)

Full triples — surface form annotated when it differs from this entity's canonical label.

Fulton v. City of Philadelphia didNotOverrule Employment Division v. Smith
Employment Division v. Smith hasFullCitation Employment Division v. Smith self-linksurface differs
this entity surface form: Employment Division, Department of Human Resources of Oregon v. Smith, 494 U.S. 872 (1990)
Free Exercise Clause interpretedInCase Employment Division v. Smith
Fulton v. City of Philadelphia interpretsPrecedent Employment Division v. Smith
Sherbert v. Verner laterLimitedBy Employment Division v. Smith
Public Law 103-141 legislativeResponseTo Employment Division v. Smith
Sherbert test limitedByCase Employment Division v. Smith
Religious Freedom Restoration Act motivatedBy Employment Division v. Smith
Alfred Leo Smith partyTo Employment Division v. Smith
Public Law 103-141 relatedCase Employment Division v. Smith
this entity surface form: Employment Division v. Smith, 494 U.S. 872 (1990)