Thomas v. Review Board of the Indiana Employment Security Division, 450 U.S. 707 (1981), was a case in which the Supreme Court of the United States held that Indiana's denial of unemployment compensation benefits to petitioner violated his First Amendment right to free exercise of religion.^[1]

Thomas, a Jehovah's Witness, asked his employer to lay him off after the company transferred all of its operations to weapon manufacturing, because his religious faith prohibited him from producing weapons. His employer refused and Thomas quit. He applied for unemployment compensation benefits under the Indiana Employment Security Act, but was denied. The Review Board of the Indiana Employment Security ruled that his voluntary termination due to his religious beliefs was not a "good cause [arising] in connection with [his] work" that would qualify him for benefits under the Indiana Employment Security Act.^[2]

The Indiana Court of Appeals reversed the decision and held that the Indiana statute, as applied, improperly burdened Thomas' First Amendment right to the free exercise of his religion.^[2]

The Indiana Supreme Court reinstated the Review Board's decision and ruled that his decision to quit was a "personal philosophical choice" that only indirectly burdened his free exercise right.^[2]

Chief Justice Warren Burger authored the 8-1 majority decision, which held that Indiana's denial of unemployment benefits to Thomas violated his First Amendment right to the free exercise of religion.

The Court said that the Indiana Supreme Court had incorrectly characterized Thomas's decision to quit his job due to his religious beliefs as merely a "philosophical" choice.

The Court based its ruling on the precedents set in Everson v. Board of Education and Sherbert v. Verner, which establish that "[a] person may not be compelled to choose between the exercise of a First Amendment right and participation in an otherwise available public program."

Justice Rehnquist dissented. He argued that the Free Exercise Clause did not require a "State to provide direct financial assistance to persons solely on the basis of their religious beliefs."^[1]

Scholars viewed the Thomas decision as significant. It establishes a well-defined test to be applied in free exercise cases, and it expanded the First Amendment protection to beliefs that are neither well-defined nor clearly articulated.^[3]

In June 1981, two months after the Thomas decision, the U.S. Department of Labor issued a directive to state employment security agencies on how the Supreme Court's ruling impacted state laws regarding voluntary job resignation for religious reasons.^[4]

• List of United States Supreme Court cases, volume 450

 This article incorporates public domain material from websites or documents of the United States Government.

• Text of Thomas v. Review Board of the Indiana Employment Security Division, 450 U.S. 707 (1981) is available from: Cornell CourtListener Findlaw Google Scholar Justia Library of Congress Oyez (oral argument audio)