Employment Division, Department of Human Resources of Oregon v.
Smith case brief summary
494 U.S. 872 (1990)
CASE SYNOPSIS
Petitioners, the Employment Division, Department of Human Resources of Oregon and others, appealed the judgment of the Supreme Court of Oregon, which ruled that Or. Rev. Stat. § 475.992(4) (1987) violated the Free Exercise Clause of U.S. Constitutional Amendment I by prohibiting the religious use of peyote.
CASE FACTS
Respondent employees were fired by a drug rehabilitation organization after ingesting peyote for sacramental purposes.
PROCEDURAL HISTORY
The Employment Division denied them unemployment compensation because peyote use was criminal under Oregon law, making their discharge work-related "misconduct." The Oregon Court of Appeals reversed on U.S. Constitutional Amendment I, Free Exercise grounds. The Oregon Supreme Court affirmed, but determined that the criminality of peyote use was irrelevant to the employees' constitutional claim. The United States Supreme Court held that the criminality of peyote use was relevant, but remanded for a determination of the applicability of the law to sacramental peyote use. On remand, the Oregon Supreme Court held that the statute prohibited religious use and violated the Free Exercise Clause.
DISCUSSION
CONCLUSION
The judgment was reversed because the controlled substance law was not aimed at promoting or restricting religious beliefs and therefore did not violate the Free Exercise Clause. Because the employees' peyote use was prohibited and the prohibition was constitutional, Oregon could deny unemployment compensation.
494 U.S. 872 (1990)
CASE SYNOPSIS
Petitioners, the Employment Division, Department of Human Resources of Oregon and others, appealed the judgment of the Supreme Court of Oregon, which ruled that Or. Rev. Stat. § 475.992(4) (1987) violated the Free Exercise Clause of U.S. Constitutional Amendment I by prohibiting the religious use of peyote.
CASE FACTS
Respondent employees were fired by a drug rehabilitation organization after ingesting peyote for sacramental purposes.
PROCEDURAL HISTORY
The Employment Division denied them unemployment compensation because peyote use was criminal under Oregon law, making their discharge work-related "misconduct." The Oregon Court of Appeals reversed on U.S. Constitutional Amendment I, Free Exercise grounds. The Oregon Supreme Court affirmed, but determined that the criminality of peyote use was irrelevant to the employees' constitutional claim. The United States Supreme Court held that the criminality of peyote use was relevant, but remanded for a determination of the applicability of the law to sacramental peyote use. On remand, the Oregon Supreme Court held that the statute prohibited religious use and violated the Free Exercise Clause.
DISCUSSION
- The U.S. Supreme Court reversed. The Free Exercise Clause was inapplicable because the state law was not aimed at promoting or restricting religious beliefs.
- Because the employees' peyote use was prohibited and the prohibition was constitutional, Oregon could deny unemployment compensation.
CONCLUSION
The judgment was reversed because the controlled substance law was not aimed at promoting or restricting religious beliefs and therefore did not violate the Free Exercise Clause. Because the employees' peyote use was prohibited and the prohibition was constitutional, Oregon could deny unemployment compensation.
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