Two Native Americans, Alfred Smith and Galen Black, were fired from their jobs by their employer, a private drug rehabilitation center in Oregon. The reason for their dismissal was that they took peyote, (which is a hallucigenic drug banned under the controlled substance act by both the federal government and the state of Oregon), for sacramental purposes during a religious ceremony at their Native American church. Alfred Smith and Galen Black, both later applied for unemployment compensation with the state of Oregon. Oregon's Employment Division denied them unemployment benefits on the grounds that their discharge was a result of work related misconduct. The state appellate court reversed that decision ruling that the denial unemployment benefits violated the rights of Smith and Black under the First Amendment free exercise clause. Upon appeal the Oregon Supreme Court affirmed the lower courts ruling based on the rationale that the denial of Smith and Black's benefits was because the state was trying to preserve the financial integrity of the states unemployment compensation fund and not that of enforcing the states criminal drug laws.
photograph of the justices, cropped to show Justic...
The front of the Oregon Supreme Court Building in ...
The interior of the Supreme Court of the State of ...The court ruled that burden imposed by the state on Smith and Black's religious beliefs and practice was not outweighed by states interest in preserving the states compensation fund. (O'Brien pg.804)
In 1987 the state of Oregon appealed the states supreme court decision to the U.S Supreme Court, arguing that its criminal laws against the consumption of Peyote were relevant to the states interest in denying compensation benefits and Smith and Black's first amendment claims. The U.S Supreme Court remanded the case back to the Oregon Supreme Court because the court did not rule on whether the use of peyote for sacramental use was allowed under state law. Until the state Supreme Court ruled on this matter the U.S Supreme Court...