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Frazee v. Illinois Department of Employment Security
Facts of the Case
William A. Frazee refused a temporary retail position offered him by Kelly Services because the job would have required him to work on Sundays. Mr. Frazee maintained his devout Christian beliefs precluded him from working on "the Lord's Day". Mr. Frazee applied to the Illinois Department of Employment Security for unemployment compensation benefits claiming that there was good cause for his refusal to work on Sundays. The Illinois Department of Employment Security denied him unemployment compensation, claiming his reason for not working on Sunday was invalid.An administrative review board, an Illinois Circuit Court, and the State Appellate Court affirmed the denial. Mr. Frazee appealed all the way to the United States Supreme Court and the court ruled in his favor (Bennett-Alexander & Hartman, 001, p. 68).
Rules of Law
According to the 18 Supreme Court Opinion the Illinois Department of Employment Security's Board of Review stated,
When a refusal of work is based on religious convictions, the refusal must be based upon some tenets or dogma accepted by the individual of some church, sect, or denomination, and such a refusal based solely on an individual's personal belief is personal and noncompelling and does not render the work unsuitable.
The Circuit Court of the Tenth Judicial Circuit of Illinois, Peoria County agreed. The Court found that the agency's decision was "not contrary to law nor against the manifest weight of the evidence," therefore rejecting Mr. Frazee's claim based on the Free Exercise Clause of the First Amendment (US Supreme Court, 18). The Appellate Court of Illinois also rejected Mr. Frazee's free exercise claim for the same reason as the Circuit Court.
The United States Supreme Court saw it differently.It ruled that disqualification of benefits to Mr. Frazee did violate the Free Exercise Clause of the First Amendment. The court addressed its earlier decisions in cases involving conflicts between work and religious beliefs. In 18,the Supreme Court stated,
Our judgments in those cases rested on the fact that each of the claimants had a sincere belief that religion required him or her to refrain from the work in question. Never did we suggest that unless a claimant belongs to a sect that forbids what his job requires, his belief, however sincere, must be deemed a purely personal preference rather than a religious belief.
The Court concluded that Mr. Frazee was sincere in his religious convictions and in turn, it was unlawful to deny him unemployment compensation.
Managerial Prospective
Kelly Services could have easily prevented this lawsuit by allowing Mr. Frazee to have Sundays off for religious reasons.Kelly Services should have also been more aware of Mr. Frazee's employment needs and done a better job of finding him a suitable position.Religious freedom has been a hot button issue for a long time in the working world.Employers need to take their employee's religious convictions seriously if they want to avoid lawsuits.
References
Bennett-Alexander, D. D., & Hartman, L. P. (001). EMPLOYMENT LAW for BUSINESS Third Edition Custom Edition for the University of Phoenix (rd ed.). New York McGraw-Hill Primis Custom Publishing.
United States Supreme Court. (18, March ). William A. Frazee, Appellant v. Illinois Department of Employment Security ET AL. Retrieved from http//www.findlaw.com
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