Tina Goede v. AstraZeneca Pharmaceuticals, LP, et al.
FirstAmendment DueProcess EmploymentDiscrimina
Can a state deny unemployment benefits to an applicant whose religious beliefs are independently sufficient to cause her refusal to follow an employer policy?
QUESTION PRESENTED This Court held in Thomas v. Review Board of the Indiana Employment Security Division, 450 U.S. 707 (1981), that the First Amendment limits the “narrow function of a reviewing court” to determining whether an applicant lost a job “because of an honest conviction that such work was forbidden by his religion.” In so holding, this Court reversed a state-court denial of benefits premised on the applicant’s beliefs being “more ‘personal philosophical choice’ than religious belief.” Instead of following Thomas and federal courts applying it, the Minnesota Court of Appeals and the Department of Employment and Economic Development before it intensely scrutinized Petitioner Goede’s religious sincerity and denied her unemployment benefits by holding her “personal” and “philosophical” views to outweigh her “religious” beliefs, even though those religious beliefs are independently sufficient to cause her to refuse vaccination. See App. 18a—23a. The question presented is: 1. Where an unemployment applicant’s religious beliefs are independently sufficient to cause her refusal to follow an employer policy, can a state deny her unemployment benefits by holding that philosophical and personal beliefs outweigh her religious beliefs?