Employment Division of Oregon v. Smith case brief summary

Employment Division of Oregon v. Smith (U.S. 1990)

i.           Claimants sought review of determination that their religious use of peyote, which resulted in their dismissal from employment, was "misconduct" disqualifying them from receipt of Oregon unemployment compensation benefits. 

 

In one case, the Oregon Court of Appeals, 75 Or.App. 764, 709 P.2d 246, reversed and remanded. 

 

The Oregon Supreme Court, 301 Or. 209, 721 P.2d 445, affirmed as modified. 

 

In the second case, the Oregon Court of Appeals, 75 Or.App. 735, 707 P.2d 1274, reversed. The Oregon Supreme Court, 301 Or. 221, 721 P.2d 451, affirmed as modified and remanded. 

 

Petition for writ of certiorari was granted. 

 

The Supreme Court, Justice Steven's , vacated judgment and remanded for determination whether sacramental peyote use was proscribed by state's controlled substance law. 

 

On remand, the Oregon Supreme Court, 307 Or. 68, 763 P.2d 146, held that sacramental peyote use violated state drug laws, but concluded that prohibition was nonetheless invalid under free exercise clause. 

 

The Supreme Court, Scalia, J., held that: (1) free exercise clause did not prohibit application of Oregon drug laws to ceremonial ingestion of peyote, and (2) thus state could, consistent with free exercise clause, deny claimants unemployment compensation for work-related misconduct based on use of drug