The Volokh Conspiracy

Religious Accommodations:

My post on religious accommodations, and in particular the statement, "But requests from minority religious groups (including recent immigrant groups) for accommodation are a longstanding and respectable part of the American tradition of religious freedom," drew this response from a commenter:

Correction: It's not part of American tradition but part of a U.S. Supreme Court adventurism under the faulty disguise it has the power to dictate social religious preferences within states.

Actually:

1. None of the examples I gave are U.S.-Supreme-Court-mandated religious accommodations; all were done by the democratic process.

2. While from 1963 to 1990, the U.S. Supreme Court read the Constitution as mandating some sorts of religious accommodations, the 1990 Employment Division v. Smith decision almost entirely rejected that doctrine. The rule right now is that the Free Exercise Clause almost never mandates religious exemptions from generally applicable laws. (I have written in support of the Smith constitutional rule.)

3. Following the Smith decision, it was Congress that enacted the Religious Freedom Restoration Act, which provided that governments have to exempt religious objectors from generally applicable laws that burdened their religious practices (unless applying the law to the objector was necessary to serve a compelling government interest). Congress voted in favor of RFRA by a 97-3 vote in the Senate and by voice vote with no objection in the House.

4. It was then the Supreme Court, in 1997, that struck down RFRA as it applied to states. State legislatures in about a dozen states, and state voters in Alabama, have since enacted state-level RFRAs that do apply to state laws. (State supreme courts in about a dozen more states have also read their state constitutions as mandating some sorts of exemptions from generally applicable laws.)

So you can fault the Court for lots of things, but don't turn hostility to the Court -- or even to constitutional constraints on legislative action more broadly -- into a macro (ctrl-shift-A for "activism") that becomes a blanket response to everything. The American tradition of religious accommodation has generally been a tradition of accommodation precisely by the political branches of government.

LM (mail):

So you can fault the Court for lots of things, but don't turn hostility to the Court -- or even to constitutional constraints on legislative action more broadly -- into a macro (ctrl-shift-A for "activism") that becomes a blanket response to everything.

Imagine the bandwidth that would save.
8.6.2008 7:56pm
J. Aldridge:
What about such examples of supreme court mandates as prisoner religious accommodations?
8.6.2008 8:04pm
J. Aldridge:
The American tradition of religious accommodation has generally been a tradition of accommodation precisely by the political branches of government.

Which traditionally had little tolerance for competing doctrines or non-christian teachings (idols).
8.6.2008 8:12pm
Andrew J. Lazarus (mail):
Mr Aldridge, the person who posts as "Sarcastro" does a much wittier job. I mean, calling other people's religions "idols" is really beyond the pale.
8.6.2008 8:28pm
Arkady:

Which traditionally had little tolerance for competing doctrines or non-christian teachings (idols).


When I went to high school in Los Angeles 50 years ago, Fairfax High School on the west side essentially shut down during the Jewish holidays. I don't recall a murmur of protest.
8.6.2008 8:31pm
J. Aldridge:
Andrew J. Lazarus said: "I mean, calling other people's religions "idols" is really beyond the pale."

Never heard of idol worshiping? In some states you couldn't hold office or vote if you worshiped idols.
8.6.2008 8:45pm
Sasha Volokh (mail) (www):
Of course the Supreme Court is quite right to insist on religious accommodation in prisons. Like, say you're an observant Jew convicted of marijuana possession and get a five-year prison term -- does your local prison system get to feed you nothing but pork for five years?

But unless I'm mistaken, the Supreme Court has a fairly permissive regime for judging prison-system burdens on constitutional rights -- under Turner v. Safley (1987), all you need is something like a reasonable relationship to a legitimate penological interest. That does not put a terrible burden on prison systems.

On the other hand, it's, again, Congress that has mandated a more protective regime (at least in prisons receiving federal funds) by enacting the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA) (upheld by the Supreme Court).
8.6.2008 8:54pm
J. Aldridge:
Traditionally a jewish prisoner would have to eat whatever else everyone else was fed. If they didn't approve of the diet they best stay out of prison :-)

Nothing can justify the US Supreme Court from being an religious arbitrator. They went so far as once saying the death penality was unconsititutional in face of the fact the 5th amendment recognizes capital punishment. The court is playing way out of their league and this shows in their rulings.
8.6.2008 9:16pm
GV:

The court is playing way out of their league and this shows in their rulings.

Apparently the Supreme Court is not the only one that plays out of its league.
8.6.2008 9:18pm
Esquire:
"Of course the Supreme Court is quite right to insist on religious accommodation in prisons."

Wow, so the Framers intended to protect the freedom of prisoners more than that of Evangelical photographers (NM) or Catholic philanthropists (CA)? Not only does the Supreme Court never "insist" on religious accommodation for Christians, but as we found out in RFRA it doesn't even PERMIT Congress to intervene on their behalf!
8.6.2008 9:32pm
Andrew J. Lazarus (mail):
Mr Aldridge, in several of the original 13 states, there were persons called "slaves" and a reprehensible institution known as "slavery".

Calling non-Christian religions idol worship today is as unrefined, bigoted, and downright weird as supporting slavery today.

The good news is, who knew the Internet had penetrated the Idaho Wilderness until Mr Aldridge began to post here?
8.6.2008 9:43pm
smitty1e:
Mr. Lazarus,
>...unrefined, bigoted, and downright weird as supporting slavery today.

We certainly enjoy more refined, egalitarian, and generally accepted forms of slavery in our modern age:
Mandatory Spending Shackles
8.6.2008 10:06pm
Eugene Volokh (www):
I'm just puzzled about the "idol" point. Unless I'm mistaken, it's some Muslims who call Christians idolators (since they allow pictures of prophets, and everything). Whatever you might think about Muslims, idol worship is not one of their transgressions. You might think they follow a false prophet, kind of like what Jews think about Christians, but that's not an idol question.

Of course, if you're militantly anti-Hindu, you can work yourself up into a lather about idols -- and I imagine you'll have plenty of extremist Muslim company on that score.
8.6.2008 11:15pm
krs:
Of course the Supreme Court is quite right to insist on religious accommodation in prisons. Like, say you're an observant Jew convicted of marijuana possession and get a five-year prison term -- does your local prison system get to feed you nothing but pork for five years?

I don't think the answer's quite as uncontroversial as you suggest.
8.6.2008 11:30pm
Andrew J. Lazarus (mail):
Smitty, your link didn't work for me, but I'll make my usual offer. I'll pay your taxes and other just-like-slavery problems, and you sign a contract to be my chattel slave.
8.7.2008 12:12am
Andrew J. Lazarus (mail):
EV, looking for historical or theological accuracy in Aldridge's Dominionist viewpoint is truly missing the point.
After Boykin had led Americans in a battle against a Somalian warlord he announced: “I know my God was bigger than his. I knew that my God was a real God and his God was an idol.” Now Boykin was going about evangelical revivals preaching that America was in a holy war as “a Christian nation” battling Satan and that America’s Muslim adversaries will be defeated “only if we come against them in the name of Jesus.” For such an hour, America surely needed a godly leader. So General Boykin explained how it was that the candidate who had lost the election in 2000 nonetheless wound up in the White House. President Bush, he said, “was not elected by a majority of the voters—he was appointed by God.” Not surprising, instead of being reprimanded for evangelizing while in uniform, General Boykin is now [2005–AJL] the Deputy Undersecretary of Defense for Intelligence.
8.7.2008 1:26am
ReaderY:
The Supreme Court actually has a line of "too much accommodation" cases in which it has struck down various kinds of religious accommodation under the Establishment Clause as being too friendly to religion. In a generation, the Court went from saying that the Free Exercise Clause requires accommodation to saying that the Establishment Clause polices and limits it. It's gone from being something constitutionally required to something that can be constitutionally suspect.

Many of these cases were 4-1-4 with O'Conner as the swing vote. The replacement of O'Conner by Alito may usher in new doctrines.
8.7.2008 3:09am
Bill Harshaw (mail) (www):
Interesting to consider the extent to which religious tolerance within the bounds of society has been stimulated by conflict with outsiders (as opposed to an expression of the natural goodness of Americans). I recommend the book Our Savage Neighbors which covers colonial Pennsylvania. Prof. Silver argues that the various factions in PA (Scotch-Irish, Germans, Quakers)came to tolerate each other more because they were terrified of, and terrorized, the various tribes on the frontier.

More recently, fighting Nazis promoted tolerance of Jews and rights for blacks, fighting the cold war was a powerful argument for accepting Catholics and Jews and Eastern Europeans as full equals of the WASPs.
8.7.2008 9:35am
zippypinhead:
So General Boykin explained how it was that the candidate who had lost the election in 2000 nonetheless wound up in the White House. President Bush, he said, “was not elected by a majority of the voters—he was appointed by God.”
And I was laboring under the misimpression Bush was appointed by five Supreme Court Justices. Oh wait: Supreme Court Majority = God. I had several law professors who believed this and tried hard to enlighten their students. I was always a slow learner. Never mind...

Speaking of religious tolerance (or the lack thereof), was this a real quote by a commissioned flag-rank officer in the United States military, or was it something lifted from a bad Saturday Night Live parody skit? No, on second thought don't tell me. To paraphrase one of my favorite Jack Nicholson movie characters, I don't want the truth. I can't handle the truth...
8.7.2008 10:02am
Joe Bingham (mail):
Lazarus, I think Aldridge is referring to literal idolatry and to state laws which specifically discriminated against idolaters, not making a blanket reference to all pagan beliefs as "idolatry."
8.7.2008 10:58am
Joe Bingham (mail):
IOW, where he writes "traditionally had little tolerance for competing doctrines or non-christian teachings (idols)," he'd mean "traditionally had little tolerance for competing doctrines... such as idolatry.
8.7.2008 11:01am
Nick Occam:

Bill Harshaw
More recently, fighting Nazis promoted tolerance of Jews and rights for blacks, fighting the cold war was a powerful argument for accepting Catholics and Jews and Eastern Europeans as full equals of the WASPs.


Tolerance builds quickly, but your description is a bit generous in light of this obit of the first Jewish BigLaw lawyer in Philadelphia - circa 1960.
8.7.2008 11:34am
Arkady:

Not only does the Supreme Court never "insist" on religious accommodation for Christians, but as we found out in RFRA it doesn't even PERMIT Congress to intervene on their behalf!


Next up: Christians vs. Lions at the Super Bowl half-time show.
8.7.2008 11:52am
David M (www):
The Thunder Run has linked to this post in the - Web Reconnaissance for 08/07/2008 A short recon of what’s out there that might draw your attention, updated throughout the day...so check back often.
8.7.2008 12:52pm
scosm:
Another interesting legislative religious accommodation is the self-administered wedding in Pennsylvania, which follows Quaker beliefs. Basically, couples can marry themselves, so long as they have two witnesses. I believe that some other states have the same rule as well.

I haven't read all the comments, so sorry if this was already mentioned.
8.7.2008 2:01pm
Toby:
I have performed a wedding in California, with a "general pupose permit" that was good for one event , one time, one day, for a pre-defined couple....
8.7.2008 2:23pm
Jerry F:
Shouldn't the fact that Muslim extremists are killing Americans (and others) in various parts of the world, that the main sponsors of terrorism today are Muslims, and that the sort of organizations who would be most supportive of this decision (i.e., CAIR) have ties with all sorts of shady people, be at least of some relevance in deciding whether this kind of accomodation is acceptable? If the Muslims who work at this plant can be counted among the few people who support the war on terror and denounce the most extreme Muslim fundamentalists, I would be all in favor of giving them their holiday to show our support, but somehow I doubt this is what is going on here.
8.7.2008 2:31pm
byomtov (mail):
If the Muslims who work at this plant can be counted among the few people who support the war on terror and denounce the most extreme Muslim fundamentalists, I would be all in favor of giving them their holiday to show our support, but somehow I doubt this is what is going on here.

It's actually not up to you to give them their holiday or not.
8.7.2008 3:37pm
Jesse (mail) (www):
Jerry F:

First, I assume you meant to say "If the Muslims who work at this plant can be counted among the few people Muslims who support the war on terror and denounce the most extreme Muslim fundamentalists," and weren't making a point about the current administration's unpopularity both here and abroad. Or should the plant's non-Muslim workers have to show a certain number of yellow ribbons and American flag bumper stickers before they are allowed to take New Year's or July 4th off?

But even assuming that you are right that only a few Muslims oppose terrorism, the answer is still no, it's not relevant. This is a private arrangement between an employer and employees, and it isn't up to the rest of us to support or oppose it. Providing material support for terrorists is a crime, but "supporting" terrorism in the same way that I "support" opposition leaders in Zimbabwe (i.e., only in my head) isn't.

But why stop at refusing to let them negotiate their own holidays? If the Somalis really do hold thoughts we disapprove of, they shouldn't be allowed to hold jobs in the first place. In fact, why don't we just revoke their visas, green cards, or naturalization documents and deport them? Of course, with roughly 500 non-Somali Muslims working at the plant (according to the press release), we'll have to figure out what to do with the natural-born citizens working there, but maybe we can create some kind of camp to lock them up in.
8.7.2008 4:08pm
tarheel:
I'm with Jerry F. We all remember how Christians were forced to work on Christmas and Easter during WWII as punishment for sharing a religion with the Nazis. Same deal here. Right?
8.7.2008 4:14pm
Adam J:
tarheel- First of all, I should point out that we don't all remember, since it happened over 60 years ago. Second of all, anyone with any knowledge of history knowsthat WWII doesn't provide particularly good support for "punishing" or otherwise discriminating against religions. If employees and employer agree upon a holiday, who the hell are we to decide otherwise? Finally, I'm not sure I would characterize any work during WWII on Christmas or Easter as punishment, since it was probably the result of a desire for self-preservation, not a desire to "punish" Christians.
8.7.2008 4:45pm
tarheel:
Adam J: I was kidding. Every word of that comment was sarcastic.
8.7.2008 4:52pm
Adam J:
tarheel- oh.... um, I knew that...
8.7.2008 4:59pm
NYOPINION (mail):
what about Catholic Bishops 440US490 - political or judicial? and the line of cases interpreting RLUIPA ?
8.7.2008 7:25pm
krs:
This is a post that could easily have been concluded with an "oh, snap!"
8.7.2008 7:42pm
JosephSlater (mail):
Next up: Christians vs. Lions at the Super Bowl half-time show.

If you mean the Detroit Lions -- and I say this as a longtime fan -- I recommend taking the spread and betting the house on the Christians.
8.8.2008 11:12am
Yankev (mail):

When I went to high school in Los Angeles 50 years ago, Fairfax High School on the west side essentially shut down during the Jewish holidays. I don't recall a murmur of protest
In Skokie they kept the public schools open even though over 70% of the students were out for the holidays -- the school board said they would lose Federal aid for the day if they closed, so we got excused absences and our gentil classmates got all-day study hall. In high school the absentee rates were less but still close to 50% -- and a handful of murmurs about "special privileges" from a small contingent who would have been just as happy to have a day off.

More typical was the comment that is still my favorite, made the day after Yom Kippur senior year of high school -- "Brett, why were you out yesterday? You aren't Jewish!"
"Yeah, but I'm a sympathizer."
8.8.2008 2:42pm
vepxistqaosani (mail) (www):
All the comments beg the question, "What is a religion?" Is it enough that, like Scientologists, Satanists, and Wiccans you proclaim yourself a religion de novo? (Though note that Wiccans, especially, make up history to give themselves a patina of That Old-Time Religion.) Or do you have to have a well-accepted and time-tested (in some sense) body of doctrine like Jews, Christians, Hindus, Muslims, Buddhists, and American Indian tribes? And where does atheism fit in?

This is hardly a simple question, and I would love to see it discussed by some of the more legally educated denizens of this exalted Conspiracy.
8.10.2008 1:23am
David M. Nieporent (www):
All the comments beg the question, "What is a religion?" Is it enough that, like Scientologists, Satanists, and Wiccans you proclaim yourself a religion de novo?
I don't see how the comments beg the question, since I don't see how that question is relevant to the discussion. But the answer to your question is "Yes." The First Amendment does not allow the government to distinguish between new religions and old ones. It can inquire into whether you believe something, but not whether that belief is new or old, accepted or not.
8.10.2008 4:01am