The Supreme Court’s Tanzin v. Tanvir decision is not one that is widely known.  But the potential impact of that decision is big given its holding.  (Don’t worry, we’ll cover that in a future Religion Law Quiz.)  What were the key facts of the Tanzin decision?    (Scroll down for the answer)   Answer: Here’s how the Supreme Court summarized those facts:   Respondents Muhammad Tanvir, Jameel Algibhah, and Naveed Shinwari are practicing Muslims who claim that Federal Bureau of Investigation agents placed them on the No Fly List in retaliation for their refusal to act as informants against their religious communities. Respondents sued various agents in their official capacities, seeking removal from the No Fly List. They also sued the agents in their individual capacities for money damages. According to respondents, the retaliation cost them substantial sums of money: airline tickets wasted and income from job opportunities lost. More than a year after respondents sued, the Department of Homeland Security informed them that they could now fly, thus mooting the claims for injunctive relief. The District Court then dismissed the individual-capacity claims for money damages, ruling that RFRA does not permit monetary relief. Tanzin v. Tanvir, 141 S. Ct. 486, 489, 208 L. Ed. 2d 295 (2020).  Disclaimer: The Religion Law Quizzes are provided as a service to you. They are intended only for educational purposes. Nothing in the Quizzes is intended to be legal advice and they should not be relied upon as conclusive on any issue discussed therein. HERE IS AN AI GENERATED SUMMARY OF TODAY’S PODCAST Welcome to another enlightening episode of the 'Religion Law Podcast', where your understanding of religious freedom and various religion law-related issues will be refined through an intriguing question-and-answer setup. Guiding you on this informative journey is none other than your host, Michael Fielding. This episode unravels the complexities of Religion Law Quiz number 106, where we dissect the lesser-known but highly influential Supreme Court decision, Tansin v. Tanvir. The primary focus of our discussion revolves around enumerating and understanding the key facts of this case—a feat possible only if one is familiar with the actual verdict. But worry not, for today, these facts are laid bare for your perusal, quoted verbatim from the Supreme Court records. In this riveting episode, you will learn about the implications of this case involving Muslims who were removed from the no-fly list, the district court's decision to dismiss their need for injunctive relief and monetary damages claims, further escalating this issue to appeal at the Supreme Court. This leads to the pivotal question: Can someone whose rights have been infringed under RIFRA sue for and obtain monetary relief? Join us as we gear up to explore this issue and more in our upcoming quizzes. Remember, our quizzes serve educational purposes only and should not be relied upon as legal advice. If you find our episode helpful, don’t hesitate to share it and leave a review. Till our next meeting, strive to be an influence for good!

A lot of times in life we just generically refer to certain things.  But sometimes it is important to stop and ask: What specifically is the definition of that particular thing?  That concept applies to religion law related matters.  Frequently we talk about the “government” what exactly does that mean?  More specifically, how does the Religious Freedom Restoration Act (“RFRA”) define “government”?    (Scroll down for the answer)   Answer: You’ll see the definition highlighted in yellow below from the following citation from the Supreme Court.    RFRA secures Congress’ view of the right to free exercise under the First Amendment, and it provides a remedy to redress violations of that right. Congress passed the Act in the wake of this Court's decision in Employment Div., Dept. of Human Resources of Ore. v. Smith, 494 U.S. 872, 885–890, 110 S.Ct. 1595, 108 L.Ed.2d 876 (1990), which held that the First Amendment tolerates neutral, generally applicable laws that burden or prohibit religious acts even when the laws are unsupported by a narrowly tailored, compelling governmental interest. See § 2000bb(a). RFRA sought to counter the effect of that holding and restore the pre-Smith “compelling interest test” by “provid[ing] a claim ... to persons whose religious exercise is substantially burdened by government.” §§ 2000bb(b)(1)–(2). That right of action enables a person to “obtain appropriate relief against a government.” § 2000bb–1(c). A “ ‘government’ ” is defined to include “a branch, department, agency, instrumentality, and official (or other person acting under color of law) of the United States.” § 2000bb–2(1). Tanzin v. Tanvir, 141 S. Ct. 486, 489, 208 L. Ed. 2d 295 (2020).  Disclaimer: The Religion Law Quizzes are provided as a service to you. They are intended only for educational purposes. Nothing in the Quizzes is intended to be legal advice and they should not be relied upon as conclusive on any issue discussed therein. HERE IS AN AI GENERATED SUMMARY OF TODAY’S PODCAST Welcome to another enlightening episode of the Religion Law Podcast. In this episode, we delve into understanding religious freedom and various religion law-related matters through a thought-provoking and succinct question-and-answer session. Your host, Michael Fielding, presents to you Religion Law Quiz number 105. Throughout our lives, we often casually refer to specific terms without really understanding their precise definitions. Today, we delve into a widely used term in religion law-related matters: 'Government.' Have you ever wondered how the Religious Freedom Restoration Act (RFRA) defines government? Let's find out together! The episode navigates the Supreme Court's interpretation in the 2020 Tansin v. Tanvir decision, discussing how RFRA safeguards the right to free religious exercise under the First Amendment and provides remedies for violations of this right. Understanding what 'Government' encompasses according to RFRA involves not just the federal government, but branches, departments, agencies, instrumentalities, and an official person acting under U.S. law. One crucial feature to remember is the limited jurisdiction of RFRA - it only applies to the federal government and does not extend to state and local governments. Several states, however, have enacted their own RFRA laws. This short yet profound discussion enhances our understanding of Government under RFRA, paving a clear legal path through the intricate world of religion law. Remember, these quizzes aim solely to educate. Please tune in for more insightful discussions, share the episode if you find it helpful, and leave a review. Keep influencing for good!

What did the Supreme Court hold in Employment Div., Dept. of Human Resources of Ore. v. Smith, 494 U.S. 872 (1990) and (b) what did the Religious Freedom Restoration Act (RFRA) seek to do in response to the Supreme Court’s Smith decision?    (Scroll down for the answer)   Answer:  Here is how the Supreme Court answered that decision in 2020.    RFRA secures Congress’ view of the right to free exercise under the First Amendment, and it provides a remedy to redress violations of that right. Congress passed the Act in the wake of this Court's decision in Employment Div., Dept. of Human Resources of Ore. v. Smith, 494 U.S. 872, 885–890, 110 S.Ct. 1595, 108 L.Ed.2d 876 (1990), which held that the First Amendment tolerates neutral, generally applicable laws that burden or prohibit religious acts even when the laws are unsupported by a narrowly tailored, compelling governmental interest. See § 2000bb(a). RFRA sought to counter the effect of that holding and restore the pre-Smith “compelling interest test” by “provid[ing] a claim ... to persons whose religious exercise is substantially burdened by government.” §§ 2000bb(b)(1)–(2). That right of action enables a person to “obtain appropriate relief against a government.” § 2000bb–1(c). Tanzin v. Tanvir, 141 S. Ct. 486, 489, 208 L. Ed. 2d 295 (2020)   Disclaimer: The Religion Law Quizzes are provided as a service to you. They are intended only for educational purposes. Nothing in the Quizzes is intended to be legal advice and they should not be relied upon as conclusive on any issue discussed therein.   HERE IS AN AI GENERATED SUMMARY OF TODAY’S PODCAST Welcome to another enlightening episode of the Religion Law Podcast where we delve into the depth of the Tanzan v. Tanvir 2020 Supreme Court decision, and its ties with the Religious Freedom Restoration Act (RFRA), set within the context of religious freedom and law in the United States. In this episode, hosted by Michael Fielding, you will be taken on a journey back in time to understand the landscape of federal laws on religious freedom, especially centered on the Supreme Court decision in Employment Division, Department of Human Resources of Oregon v. Smith in 1990. We investigate the role played by RFRA in response to the Smith decision within our compelling quiz format. This episode also offers you the opportunity to assess your knowledge on some past discussions related to religion law quizzes. Using direct quotes from the Supreme Court's 2020 Tanzan v. Tanvir decision, we break down Congress's view on the right to free exercise under the First Amendment, and the provided remedies to redress violations of that right. Furthermore, we'll touch upon how RFRA came into existence to counter the implications of the Smith decision by restoring the pre-Smith compelling interest test to provide a claim to persons whose religious exercise is impeded by government (substantially). To wrap it up, our quiz will leave you intrigued and informed about what forms of damages or appropriate relief are available from the federal government in case of a RFRA violation, lined up thematically for future podcasts. This episode is not just an educational tool but also a platform that prompts you to become an influence for good. We hope you find it helpful, and if you do, please share it and leave a review! Until we meet again.

How would you explain RFRA (i.e., the Religious Freedom Restoration Act) to a kindergartener?    (Scroll down for the answer)   Answer:  Here’s how the Supreme Court succinctly summarized RFRA in 2020:   The Religious Freedom Restoration Act of 1993 (RFRA) prohibits the Federal Government from imposing substantial burdens on religious exercise, absent a compelling interest pursued through the least restrictive means. 107 Stat. 1488, 42 U.S.C. § 2000bb et seq. Tanzin v. Tanvir, 141 S. Ct. 486, 489, 208 L. Ed. 2d 295 (2020)   Disclaimer: The Religion Law Quizzes are provided as a service to you. They are intended only for educational purposes. Nothing in the Quizzes is intended to be legal advice and they should not be relied upon as conclusive on any issue discussed therein.   HERE IS AN AI GENERATED SUMMARY OF TODAY’S PODCAST Welcome to another enlightening episode of the Religion Law Podcast. In this episode, your host Michael Fielding dives into the concept of the Religious Freedom Restoration Act (RFRA) through the prism of the 2020 Supreme Court's Tanzan v. Tanvir decision. The RFRA is a significant statute that has been adopted by several, but not all, states in the US. The episode revolves around a unique question: How would you explain the RFRA to a kindergartner? Break down complex, legal terms into easy-to-understand language is a valuable skill, as it suggests a deep understanding of the concept at hand. Drawing from the court's words, Fielding throws light on the act's purpose - it prohibits the federal government from imposing heavy burdens on religious practices unless there's an extremely compelling reason, and it is pursued through the least restrictive means available. In simpler words, it requires the government to minimize its interference in religious practices. Short but substantial, this episode offers valuable insights into the RFRA and its implications on the practice of religion in the US. It is designed to enhance listeners' understanding and equip them with the skill to articulate this complex concept in simple terms. Remember, sharing knowledge can make a big difference in your community.

In what year did the Supreme Court issue its decision in Tanzin v. Tanvir and what was the issue that the Supreme Court decided in that case?     (Scroll down for the answer)   Answer: The Supreme Court issued its opinion in 2020.  Here’s how the Supreme Court described the issue it was facing:   The Religious Freedom Restoration Act of 1993 (RFRA) prohibits the Federal Government from imposing substantial burdens on religious exercise, absent a compelling interest pursued through the least restrictive means. 107 Stat. 1488, 42 U.S.C. § 2000bb et seq. It also gives a person whose religious exercise has been unlawfully burdened the right to seek “appropriate relief.” The question here is whether “appropriate relief ” includes claims for money damages against Government officials in their individual capacities. Tanzin v. Tanvir, 141 S. Ct. 486, 489, 208 L. Ed. 2d 295 (2020).   Disclaimer: The Religion Law Quizzes are provided as a service to you. They are intended only for educational purposes. Nothing in the Quizzes is intended to be legal advice and they should not be relied upon as conclusive on any issue discussed therein.   HERE IS AN AI GENERATED SUMMARY OF TODAY’S PODCAST   Welcome to the Religion Law Podcast, your go-to platform for comprehending religious freedom and hot topics related to religious law. In this episode, our host Michael Fielding delves into a significant yet underreported Supreme Court decision, Tanzan v. Tanvir. This decision was executed in 2020, a period where global attention was predominantly focused on the COVID-19 pandemic. The crux of the Tanzan v. Tanvir issue pertains to the Religious Freedom Restoration Act (RFRA) of 1993, which prohibits the federal government from encumbering religious exercise without a compelling urge exercised via the least restrictive means. It also entitles an individual whose religious exercise has been unlawfully compromised to seek apt relief. However, the moot point brought forth by Tanzan v. Tanvir is the scope of "appropriate relief" under RFRA, examining the permit of individuals to sue government officials for financial damages in their personal capacity. Join us as we unfold the implications of the Tanzan v. Tanvir decision and understand its potential consequences on religious freedom. Remember, our Religion Law quizzes are designed purely for educational enlightenment and should not be considered legal advice. If this episode has enlightened you in any way, please share it and don't forget to leave a review. Let's endorse the habit of being an advocate for good. We'll see you again for Quiz number 103. Stay enlightened. Music.

True or False: An employer can satisfy Title VII’s “undue hardship” test by assessing the reasonableness of a particular accommodation and determining that such a request is unreasonable and would create an undue hardship for the employer.    (Scroll down for the answer)   Answer:  FALSE.  Title VII requires an employer to reasonably accommodate an employee’s religious practice rather than just the employer assessing the reasonableness of the requested accommodation.  Here is what the Supreme Court said:   Second, as the Solicitor General's authorities underscore, Title VII requires that an employer reasonably accommodate an employee's practice of religion, not merely that it assess the reasonableness of a particular possible accommodation or accommodations. See Adeyeye, 721 F.3d at 455; see also Brief for United States 30, 33, 39. This distinction matters. Faced with an accommodation request like Groff ’s, it would not be enough for an employer to conclude that forcing other employees to work overtime would constitute an undue hardship. Consideration of other options, such as voluntary shift swapping, would also be necessary. Groff v. DeJoy, 143 S. Ct. 2279, 2296–97, 216 L. Ed. 2d 1041 (2023) (emphasis added).    Disclaimer: The Religion Law Quizzes are provided as a service to you. They are intended only for educational purposes. Nothing in the Quizzes is intended to be legal advice and they should not be relied upon as conclusive on any issue discussed therein.   HERE IS AN AI GENERATED SUMMARY OF TODAY’S PODCAST Our latest episode of the Religion Law Podcast offers a fresh insight into the complicated world of religious freedom and the law. Hosted by Michael Fielding, this specific episode, titled "Religion Law Quiz 101: Understanding Title VII and Religious Accommodations," dives into the important Supreme Court decision Graffi DeJoy, which pertains to Title VII and the provision of religious accommodations for employees. The episode sets the stage with a true or false question about whether an employer can satisfy Title VII's undue hardship test by simply assessing the reasonableness of a particular accommodation. The Supreme Court ruling, dissected in this episode, declares the question false - Title VII requires an employer not just to assess the reasonableness of a given accommodation, but to reasonably accommodate an employee's religious practice itself. Fielding relates this Supreme Court decision to the real-world case of an evangelical Christian working for the Postal Service who requested religious accommodation for Sabbath day observance. This scenario is used to unravel the legal complexities of the 'undue hardship' concept and discuss the integral distinction Title VII enforces for employers when accommodating the practices of their employees While this podcast provides essential educational content, it does not replace legal advice. This episode encourages listeners to understand their rights and responsibilities under the law, and invites further action should a listener confront legal challenges related to religion and employment. Religion Law Podcast delivers valuable knowledge regarding religious freedoms and legal responsibilities, making it indispensable for everyone interested in the law of religious freedom.

In Religion Law Quiz #99 we learned “that ‘undue hardship’ in Title VII means what it says, and courts should resolve whether a hardship would be substantial in the context of an employer's business in the common-sense manner that it would use in applying any such test.”  Groff v. DeJoy, 143 S. Ct. 2279, 2296, 216 L. Ed. 2d 1041 (2023).  But when a court is making this determination, are there certain points that are “off-limits” to the court’s determination?  If so, what are they?    (Scroll down for the answer)   Answer:  Yes.  A hardship that is attributable to employee animosity to a particular religion, to religion in general, or to the very notion of accommodating religious practice cannot be considered “undue.”  Here is what the Supreme Court specifically said:   On this point, the Solicitor General took pains to clarify that some evidence that occasionally is used to show “impacts” on coworkers is “off the table” for consideration. Id., at 102. Specifically, a coworker's dislike of “religious practice and expression in the workplace” or “the mere fact [of] an accommodation” is not “cognizable to factor into the undue hardship inquiry.” Id., at 89–90. To the extent that this was not previously clear, we agree. An employer who fails to provide an accommodation has a defense only if the hardship is “undue,” and a hardship that is attributable to employee animosity to a particular religion, to religion in general, or to the very notion of accommodating religious practice cannot be considered “undue.” If bias or hostility to a religious practice or a religious accommodation provided a defense to a reasonable accommodation claim, Title VII would be at war with itself. See id., at 89 (argument of Solicitor General) (such an approach would be “giving effect to religious hostility”); contra, EEOC v. Sambo's of Georgia, Inc., 530 F.Supp. 86, 89 (ND Ga. 1981) (considering as hardship “[a]dverse customer reaction” from “a simple aversion to, or discomfort in dealing with, bearded people”). Groff v. DeJoy, 143 S. Ct. 2279, 2296, 216 L. Ed. 2d 1041 (2023) (emphasis added).   Disclaimer: The Religion Law Quizzes are provided as a service to you. They are intended only for educational purposes. Nothing in the Quizzes is intended to be legal advice and they should not be relied upon as conclusive on any issue discussed therein.   HERE IS AN AI GENERATED SUMMARY OF TODAY’S PODCAST     This episode of the Religion Law Podcast, hosted by Michael Fielding, is milestone number 100 in the Religion Law Quiz series. The podcast continues the discussion on the monumental Groff v. DeJoy case, focusing on the concept of 'undue hardship' as stipulated in Title VII of the Civil Rights Act. Michael poses a question for listeners to ponder: When determining what constitutes 'undue hardship' in the context of an employer's religious accommodations, are there factors that courts should not consider? As per the Supreme Court's ruling, any hardship attributed to employee animosity towards a particular religion, religion in general, or the notion of religious accommodation cannot be deemed 'undue'. The episode offers a clearer understanding of the balance required between maintaining employees' religious freedoms and the operational needs of a business. Michael explains this complex issue with an imaginary scenario in which a majority of employees harbor resentment towards a particular religion or religious practice. The Supreme Court starkly emphasizes that such employee negativity cannot justify a refusal for religious accommodation. The podcast navigates through the finer points of religion law and religious freedom with the aim of educating listeners. The discussion ends with the anticipation of the final episode on Groff v. DeJoy in the next Religion Law Quiz. The episode asserts that protecting religious freedoms in the workspace promotes an inclusive environment, hence reducing the chance of Title VII being at war with itself.

True or False: In the context of Title VII, whether a requested religious accommodation creates an “undue hardship” should be determined by the court applying a common-sense test inquiring whether the hardship is substantial in the context of the employer’s business.    (Scroll down for the answer)   Answer: True.  Here’s what the Supreme Court said in that regard.    What is most important is that “undue hardship” in Title VII means what it says, and courts should resolve whether a hardship would be substantial in the context of an employer's business in the common-sense manner that it would use in applying any such test.   Groff v. DeJoy, 143 S. Ct. 2279, 2296, 216 L. Ed. 2d 1041 (2023)    Disclaimer: The Religion Law Quizzes are provided as a service to you. They are intended only for educational purposes. Nothing in the Quizzes is intended to be legal advice and they should not be relied upon as conclusive on any issue discussed therein.   HERE IS AN AI GENERATED SUMMARY OF TODAY’S PODCAST   Welcome to this episode of Religion Law Podcast, your go-to place for understanding religious freedom and legal issues related to religion through a unique, interactive quiz-based format. In this episode, we delve into the world of religious accomodation at work. We unfold how courts understand these accommodations and what determines if such accommodations could be an undue hardship for the employers within the Title VII context, all inspired by the Supreme Court's 2023 Graf v. DeJoy decision. Your host, Michael Fielding starts with a fun trivia recalling his favorite college football player, Jason Buck, to set a lighter tone. Soon after, we move to the serious territory of Title VII - a hot topic in religion law. You'll be presented with a true or false quiz about whether a common sense test can be applied by a court to identify if a religious accommodation request involves significant hardship in correlation to an employer's business. Find out the Supreme Court's perspective on this matter and understand what this practically implies for employees seeking religious accommodation and for employers trying to balance accommodating employee rights and running their businesses effectively. Also, let Michael clear your doubts about how big of an 'undue hardship' is 'too big' and when is it considered enough to exempt the employers from providing the accommodation. However, remember this episode, though informative, doesn't substitute for legal advice as Michael is a guide through these legal waters and not an employment attorney. Stay with us till the end where Michael also suggests the possibility of diving deep into Title VII in the future episodes. Stay tuned for the next milestone episode - the 100th quiz of the series! Share this episode if you find it helpful and leave a review. Continue being an influential force!

A heuristic is a mental shortcut that we use to reach decisions.  We all use heuristics and they can be very helpful.  But sometimes our use of a heuristic can be an Achilles heel because our generation and use of the heuristic overlooks critical details which, when they are considered, helps us realize that the heuristic that we used and created is incorrect.    With that concept in mind, when you analyze the Supreme Court’s recent Groff v. DeJoy, 143 S. Ct. 2279 (2023) decision it becomes clear that several courts had previously employed a heuristic with respect to a prior Supreme Court case.  The Groff decision identified that heuristic (although the Supreme Court didn’t call it such) and then it pointed to several key aspects in its prior decision which showed that the heuristic phrase was incorrect.  For our two-part quiz today, (a) what was the heuristic phrase that was used and (b) what was the name of the prior decision from which that heuristic phrase came from?    (If you get both these answers right then you must be an L&E rockstar!)   (Scroll down for the answer)   Answer:  The heuristic phrase was “more than a de minimis cost” and it came from Trans World Airlines, Inc. v. Hardison, 432 U.S. 63, 97 S.Ct. 2264, 53 L.Ed.2d 113 (1977).  Consider what the Supreme Court said:   We hold that showing “more than a de minimis cost,” as that phrase is used in common parlance, does not suffice to establish “undue hardship” under Title VII. Hardison cannot be reduced to that one phrase. In describing an employer's “undue hardship” defense, Hardison referred repeatedly to “substantial” burdens, and that formulation better explains the decision. We therefore, like the parties, understand Hardison to mean that “undue hardship” is shown when a burden is substantial in the overall context of an employer's business. See Tr. of Oral Arg. 61–62 (argument of Solicitor General). This fact-specific inquiry comports with both Hardison and the meaning of “undue hardship” in ordinary speech. Groff v. DeJoy, 143 S. Ct. 2279, 2294 (2023).     Disclaimer: The Religion Law Quizzes are provided as a service to you. They are intended only for educational purposes. Nothing in the Quizzes is intended to be legal advice and they should not be relied upon as conclusive on any issue discussed therein.   HERE IS AN AI GENERATED SUMMARY OF TODAY’S PODCAST   Welcome to another engaging episode of the Religion Law Podcast, exploring the realm of religious freedom and other religion law-related subjects. This episode, number 98, continues with our discussion on the 2023 Graf v. DeJoy Supreme Court decision, uncovering a different perspective with a deeper insight. Hosted by Michael Fielding, this episode explores the concept of heuristic, a mental shortcut, and how it occasionally leads to overlooking crucial details that could reshape our understanding of a situation or event. Analyzing the Supreme Court's Groff v. DeJoy decision reveals how several courts regularly employed a heuristic approach to a prior Supreme Court case, resulting in the Supreme Court pointing out the overlooked aspects in its prior decision. Fielding also discusses the implications and practical takeaways from the Groff v. DeJoy decision on employers and employees. The Supreme Court held that under Title VII, employers are required to accommodate the religious practices of their employees unless doing so would pose an undue hardship on the business. It emphasizes that an employer must prove a substantial burden should they wish to deny a religious accommodation under Title VII. Misinterpretation of the heuristic phrase "more than a de minimis cost," leads courts to focus on one small phrase from the Transworld Airlines vs. Hardison decision, rather than the big picture. Through an understanding of the overarching requirement for substantial burden, the Supreme Court offered a corrected perspective. Life lesson in this episode revolves around the importance of avoiding myopic perspectives and viewing situations through a more encompassing lens. Journey with us as we dissect legal decisions, helping you become a labor and employment superstar. Enjoy the deep dives, insights, and life lessons from the world of law and religion. Discover the valuable perspectives that could reshape your understanding, not just in law, but in life too.

In June 2023 the Supreme Court issued its opinion in Groff v. DeJoy ruling on religious accommodations under Title VII.  In a nutshell, what was the main holding of the Groff decision?    (Scroll down for the answer)   Answer:  Here’s how the Supreme Court answers that question in the syllabus:   Held: Title VII requires an employer that denies a religious accommodation to show that the burden of granting an accommodation would result in substantial increased costs in relation to the conduct of its particular business. Pp. 2287 – 2297.   Groff v. DeJoy, 143 S. Ct. 2279, 2281 (2023).   Disclaimer: The Religion Law Quizzes are provided as a service to you. They are intended only for educational purposes. Nothing in the Quizzes is intended to be legal advice and they should not be relied upon as conclusive on any issue discussed therein.   HERE IS AN AI GENERATED SUMMARY OF TODAY’S PODCAST     Welcome to another insightful episode of the Religion Law Podcast, a platform where you learn about religious freedom and other religion law-related topics in a short, engaging Q&A format. In this episode, our host, Michael Fielding, breaks down the revolutionary Supreme Court Decision - Groff v. DeJoy. This case defined the parameters of how religious accommodations should be handled under Title VII. Religion Law Quiz number 97 unravels a key legal precedent - the June 2023 Supreme Court ruling in Groff v. DeJoy. Listen as Michael Fielding intricately dissects the facts of the case involving an evangelical Christian working for the Postal Service who was unwilling to work on Sundays. Despite the case being ruled against the employee in both the district court and the appellate court level, things took a turn in the Supreme Court. A particularly intriguing discussion ensues as we discuss the big reveal - the Supreme Court’s ruling drawn from the court's syllabus. It held that if an employer denies a religious accommodation, they must demonstrate that granting such an accommodation would lead to substantially increased costs related to the conduct of their particular business. This core discussion offers listeners rich insight into the nuances of handling requests for religious accommodations within the workforce. Bringing the law to life, the episode draws parallels with everyday situations, such as the host's daughter managing her work schedule alongside her Sunday church commitments. The anecdote underscores how religious accommodations can be managed without significant disruption or cost to businesses, casting a new, practical light on the Supreme Court ruling. In conclusion, this episode invites listeners to further expand their understanding of the complex interplay between religion, law, and business. Catch us on Quiz number 98, where our exploration of Graff v. DeJoy continues.

Religion Law Quiz #91 asked how you would explain “strict scrutiny” to a kindergartner.  In keeping with that theme (i.e., you only truly understand a concept when you can intelligently teach it to someone much younger and less knowledgeable than yourself), how would you, in just one sentence, describe what Title VII requires of employers for employees who seek a religious accommodation?    (Scroll down for the answer)   Answer:  Here’s how the Supreme Court did it in late June of this year.  “Title VII of the Civil Rights Act of 1964 requires employers to accommodate the religious practice of their employees unless doing so would impose an ‘undue hardship on the conduct of the employer's business.’ 78 Stat. 253, as amended, 42 U.S.C. § 2000e(j).”  Groff v. DeJoy, 143 S. Ct. 2279, 2286 (2023).    Disclaimer: The Religion Law Quizzes are provided as a service to you. They are intended only for educational purposes. Nothing in the Quizzes is intended to be legal advice and they should not be relied upon as conclusive on any issue discussed therein.   HERE IS AN AI GENERATED SUMMARY OF TODAY’S PODCAST   Welcome to yet another insightful episode of the Religion Law Podcast hosted by Michael Fielding. In this episode, we continue our journey through the Supreme Court's case, Groff v. DeJoy while revisiting and exploring the theme of religion law quiz #91 in a new light. Shining a spotlight on the Title VII of the Civil Rights Act of 1964, this podcast episode challenges listeners to comprehend its essence and communicate it in a simple sentence. The main focus is on what Title VII demands employers to do for employees seeking religious accommodations. Through an engaging narrative, the episode introduces the Supreme Court's interpretation of Title VII: employers are required to make allowances for an employee's religious practice unless it significantly disrupts the operation of the employer's business. In a practical demonstration of Title VII, the episode shares a real-life example of how a local amusement park accommodated a teenager's request not to work on Sundays owing to her religious practices. Highlighting the win-win scenario that Title VII can create, it emphasizes the ability to practice one's religion while keeping their job, given the employer can afford the accommodation without considerable burden. Designed as the second in a series of seven quizzes shedding light on the Supreme Court's Groffy DeJoy decision, the podcast educates, challenges, and prepares listeners for the subsequent episode. Tune in to experience a culturally and legally enriching discussion on the topic of religious accommodation in the workplace!

In Groff v. DeJoy, 243 S.Ct. 2279 (2023), the Supreme Court was recently asked to address Title VII in the context of a former United States Postal Service (USPS) employee who, as an evangelical Christian, Sunday should be for worship and rest (not work).  The USPS disagreed and did not make a reasonable accommodation for him.  The worker filed suit and the District Court and later the Third Circuit ruled in favor of the USPS.  The Supreme Court in June 2023 issued its ruling on the appeal from the Third Circuit.  We know that the certain Justices are sometimes described as liberal or conservative.  We also have seen various instances in the past few years when certain Justices surprised folks by joining in the positions of others who are deemed ideologically different.  So that we can properly set the table for our Groff v. DeJoy discussion, which Justices were in the majority and which Justices dissented from the Supreme Court’s holding?    (Scroll down for the answer)   Answer:  This is a bit of a trick question.  The Supreme Court unanimously reversed and ruled in favor of the former postal worker.  For the record, however, we should note that Justice Sotomayor filed a concurring opinion that was joined by Justice Jackson.  Groff v. DeJoy, 243 S.Ct. 2279 (2023) .  This unanimous ruling is important to keep in mind as we will be learning about what the Supreme Court said about Title VII and religious accommodations.    Disclaimer: The Religion Law Quizzes are provided as a service to you. They are intended only for educational purposes. Nothing in the Quizzes is intended to be legal advice and they should not be relied upon as conclusive on any issue discussed therein.   HERE IS AN AI GENERATED SUMMARY OF TODAY’S PODCAST   Join host Michael Fielding in the 95th episode of the Religion Law Podcast, where we delve into the Supreme Court's 2023 decision in the Groff v. DeJoy case. This game-changing case, which revolves around religious freedom in the workplace, impacts countless individuals across the nation and provides fertile ground for thought-provoking discussions and learning. In this interactive quiz episode, we discuss the case of a former United States Postal Service employee who, being an evangelical Christian, firmly believed that Sundays should be reserved for worship and rest, not work. When USPS did not reasonably accommodate his beliefs, he took the case to court, eventually reaching the Supreme Court. We also explore the intriguing dynamics of the Supreme Court justices involved in the case. Who took a stand and who offered their dissenting opinions? You might be surprised to learn the unanimous verdict in favor of the former postal worker. To further enhance our understanding of Groff v. DeJoy, we'll be reviewing the key facts of the case and unpacking the implications of a unanimous ruling from the Supreme Court. This remarkable unity amongst the justices underscores the weight of the verdict and sets the stage for our upcoming discussions on Title VII and religious accommodations. So, are you ready for Quiz 96? Tune in to our next episode as we continue to educate and inspire with critical insights into religion law. Tune in, learn and enjoy. Remember, these quizzes should not be used as legal advice but are meant to provoke thought and foster a deeper understanding of religious freedom and law. Don't forget to share this episode with others and leave a review if you found it helpful.

Religion Law Quiz #94   The last several Religion Law Quizzes have focused on key legal principles as articulated in Fulton v. City of Philadelphia, Pennsylvania, 141 S.C.t 1868 (2021).  Today’s Religion Law Quiz poses one final question regarding that decision.    The Fulton decision specifically recognized that “‘gay persons and gay couples cannot be treated as social outcasts or as inferior in dignity and worth.’” Id. at 1882 (citation omitted).  But nevertheless, the Supreme Court ruled for Catholic Social Services (CSS) which would not certify same-sex couples to be foster parents because of CSS’s beliefs about marriage.  Why did the Court ultimately rule this way?    (Scroll down for the answer)   Answer: Because the city had created a system of exemptions from its non-discrimination policies and the city did not provide any compelling reason why it had an interest in denying CSS from the exemption while making it available to others.  Here’s how the Supreme Court articulated its rationale in its concluding paragraphs:   That leaves the interest of the City in the equal treatment of prospective foster parents and foster children. We do not doubt that this interest is a weighty one, for “[o]ur society has come to the recognition that gay persons and gay couples cannot be treated as social outcasts or as inferior in dignity and worth.” Masterpiece Cakeshop, 584 U. S., at ––––, 138 S.Ct., at 1727. On the facts of this case, however, this interest cannot justify denying CSS an exception for its religious exercise. The creation of a system of exceptions under the contract undermines the City's contention that its non-discrimination policies can brook no departures. See Lukumi, 508 U.S. at 546–547, 113 S.Ct. 2217. The City offers no compelling reason why it has a particular interest in denying an exception to CSS while making them available to others. * * * As Philadelphia acknowledges, CSS has “long been a point of light in the City's foster-care system.” Brief for City Respondents 1. CSS seeks only an accommodation that will allow it to continue serving the children of Philadelphia in a manner consistent with its religious beliefs; it does not seek to impose those beliefs on anyone else. The refusal of Philadelphia to contract with CSS for the provision of foster care services unless it agrees to certify same-sex couples as foster parents cannot survive strict scrutiny, and violates the First Amendment.   In view of our conclusion that the actions of the City violate the Free Exercise Clause, we need not consider whether they also violate the Free Speech Clause.   Fulton v. City of Philadelphia, Pennsylvania, 210 L. Ed. 2d 137, 141 S. Ct. 1868, 1882 (2021)   Disclaimer: The Religion Law Quizzes are provided as a service to you. They are intended only for educational purposes. Nothing in the Quizzes is intended to be legal advice and they should not be relied upon as conclusive on any issue discussed therein.   HERE IS AN AI GENERATED SUMMARY OF TODAY’S PODCAST   Description Welcome to Religion Law Quiz no.94, an enlightening episode of the esteemed Religion Law Podcast with your host Michael Fielding. This episode continues our deep dive into key legal principles resulting from the Supreme Court's landmark 2021 decision in the Fulton v. City of Philadelphia case. Today's quiz discusses the Supreme Court's recognition of the equal dignity and worth of gay individuals and couples, while paradoxically ruling in favor of Catholic Social Services, who denied certifying same-sex couples as foster parents due to their religious beliefs. We explore why the court ruled the way they did, based on the city's non-discrimination policies and its system of exceptions. We delve into the court's concluding paragraphs, in which it underscores that while equal treatment of prospective foster parents and children is paramount, this cannot justify denying CSS an exception for its religious exercise in this specific case. The court emphasizes that CSS's refusal to engage in contract with the city of Philadelphia over the remarked issue violates the First Amendment. In our next episode, no.95, prepare to dive into the Supreme Court's 2023 decision, Groff v. DeJoy, encompassing employment law. Remember, the Religion Law Quiz Podcast is a platform for educational purposes and not a source of legal advice. If you found this episode genuinely helpful and informative, feel free to share it and leave a review. Till our next episode, keep being a positive influence in your community!

Religion Law Quiz #93   A city speculates that it will be sued if it grants an exception to its non-discrimination policies to a religious institution.  Does that constitute a sufficient basis for the city to satisfy strict scrutiny?    (Scroll down for the answer)   Answer: No.  Here’s how the Supreme Court addressed that question.    As for liability, the City offers only speculation that it might be sued over CSS's certification practices. Such speculation is insufficient to satisfy strict scrutiny, see Brown v. Entertainment Merchants Assn., 564 U.S. 786, 799–800, 131 S.Ct. 2729, 180 L.Ed.2d 708 (2011), particularly because the authority to certify foster families is delegated to agencies by the State, not the City, see 55 Pa. Code § 3700.61. Fulton v. City of Philadelphia, Pennsylvania, 593 U.S. 522, 542, 141 S. Ct. 1868, 1882, 210 L. Ed. 2d 137 (2021)   Disclaimer: The Religion Law Quizzes are provided as a service to you. They are intended only for educational purposes. Nothing in the Quizzes is intended to be legal advice and they should not be relied upon as conclusive on any issue discussed therein.   HERE IS AN AI GENERATED SUMMARY OF TODAY’S PODCAST   Welcome to Episode 93 of the Religion Law Podcast. In this episode, we continue our discussion on the prominent Fulton v. City of Philadelphia decision from 2021. Hosted by Michael Fielding, we delve into whether the possibility of a city being sued can form an adequate basis for the city to meet the high bar of "strict scrutiny". In the Fulton case, the City of Philadelphia suggested it might face lawsuits if exceptions to its non-discrimination policies were made for religious institutions. We explore whether this potential legal threat is enough to satisfy the rigorous criteria of strict scrutiny and discuss the Supreme Court's stance on this intriguing religious freedom issue. Through this episode, we shed light on the Supreme Court’s ruling that speculation of being sued is not sufficient to meet strict scrutiny. The reason being that if the threat of potential lawsuits were considered as standard, the government could always justify its actions, turning the strict liability standard into a nullity due to the perpetual risk of lawsuits. By navigating through this complex issue, you will better understand the practical implications of legal rulings and their connection to religious freedom. Tune in and enhance your understanding of religion law in a simple, engaging Q&A format. Remember, these quizzes are solely for educational purposes and should not be relied upon for legal advice. If you find our content valuable, share it and leave a review. Until our next episode, continue to be a positive influence.

Religion Law Quiz #92   If a city has a compelling interest in generally enforcing its non-discrimination policies will those policies survive strict scrutiny because the city’s interest is compelling?    (Scroll down for the answer)   Answer:  That is the wrong question to be asking.  The issue is not whether the city has a compelling interest in generally enforcing its non-discrimination policies but rather if it has a compelling interest in denying an exception to the religious entity impacted by the regulation.  Here’s what the Supreme Court has said:     The City asserts that its non-discrimination policies serve three compelling interests: maximizing the number of foster parents, protecting the City from liability, and ensuring equal treatment of prospective foster parents and foster children. The City states these objectives at a high level of generality, but the First Amendment demands a more precise analysis. See Gonzales v. O Centro Espírita Beneficente União do Vegetal, 546 U.S. 418, 430–432, 126 S.Ct. 1211, 163 L.Ed.2d 1017 (2006) (discussing the compelling interest test applied in Sherbert and Wisconsin v. Yoder, 406 U.S. 205, 92 S.Ct. 1526, 32 L.Ed.2d 15 (1972)). Rather than rely on “broadly formulated interests,” courts must “scrutinize[ ] the asserted harm of granting specific exemptions to particular religious claimants.” O Centro, 546 U.S. at 431, 126 S.Ct. 1211. The question, then, is not whether the City has a compelling interest in enforcing its non-discrimination policies generally, but whether it has such an interest in denying an exception to CSS.   Fulton v. City of Philadelphia, Pennsylvania, 141 S. Ct. 1868, 1881 (2021) (emphasis added).    Disclaimer: The Religion Law Quizzes are provided as a service to you. They are intended only for educational purposes. Nothing in the Quizzes is intended to be legal advice and they should not be relied upon as conclusive on any issue discussed therein.   HERE IS AN AI GENERATED SUMMARY OF TODAY’S PODCAST     Welcome to another enlightening episode of the Religion Law Podcast. In this episode, your host, Michael Fielding, dives deep into the intricacies of religious freedom and other intricate, religion law-related topics using a crisp question-and-answer format. Episode 92 poses a thought-provoking quiz about non-discrimination policies in cities and their impact on religious groups. The moot question is whether the city's compelling interests to enforce these policies could lead to these policies surviving strict scrutiny, or if there are deeper considerations to explore. With reference to the Supreme Court's verdict in Fulton v. City of Philadelphia, Fielding explicates the key issue which is not solely about the city’s compelling interest in enforcing non-discrimination policies in general, but whether it has a compelling interest in denying an exception to a religious entity impacted by the regulation. The episode successfully unravels the Supreme Court's instruction that determining whether a particular regulation passes constitutional muster hinges on whether the city's compelling interest justifies the denial of an exception to the impacted religious entity. Sharing these deep insights, Fielding continues his mission to inspire listeners to be an influence for good in the world through a deeper understanding of religious law.

Religion Law Quiz #91   Today’s Religion Law Quiz is going to challenge you in a very novel way.  Let’s see how you do.    How would you describe to a kindergartner how a government policy can survive strict scrutiny when dealing with religion?        (Scroll down for the answer)   Answer:  Here’s how the Supreme Court explained strict scrutiny in more easy-to-understand terms:    A government policy can survive strict scrutiny only if it advances “interests of the highest order” and is narrowly tailored to achieve those interests. Lukumi, 508 U.S. at 546, 113 S.Ct. 2217 (internal quotation marks omitted). Put another way, so long as the government can achieve its interests in a manner that does not burden religion, it must do so.   Fulton v. City of Philadelphia, Pennsylvania, 141 S. Ct. 1868, 1881 (2021).    Disclaimer: The Religion Law Quizzes are provided as a service to you. They are intended only for educational purposes. Nothing in the Quizzes is intended to be legal advice and they should not be relied upon as conclusive on any issue discussed therein.   HERE IS AN AI GENERATED SUMMARY OF TODAY’S PODCAST   Welcome to this thought-provoking episode of the 'Religion Law Podcast', where we delve deeper into the realm of religious freedom and related legal topics. Join your host, Michael Fielding, as he challenges you to break down and simplify complex legal concepts. In this episode, we embark on Religion Law Quiz number 91, where Michael challenges you to describe a complex concept in a simple manner. The challenge here is to take your understanding of religion law back to basics - explaining it as you would to a kindergartner. The question posed today - Can you explain how a government policy can survive strict scrutiny when dealing with religion? A tricky question indeed, but guided by the Supreme Court ruling in the case of Fulton v. City of Philadelphia, we unravel the answer. The verdict states - A policy can only withstand strict scrutiny if it advances paramount interests and is minimally invasive in achieving those interests. In simpler terms, if the government has a crucial purpose for implementing a policy and can do so without burdening religion, that's the approach to take. But the task doesn't end here. Can you further simplify this answer and explain it to a non-lawyer? By the end of this episode learn, absorb, and make these intricate law principles more accessible by explaining them to others in your life. This podcast serves as an educational platform and is not to be used for legal advice. If this episode helps you to better understand the complex world of religion law, please share it and leave a review. Remember, with every episode you learn, you become more influence in religion law. Stay tuned for the next Religion Law Quiz!

Religion Law Quiz #90   A city has a municipal code which has a formal system of discretionary exemptions for religious institutions.  Will such a regulatory scheme withstand judicial review if the court applies strict scrutiny?    (Scroll down for the answer)   Answer: No.  This is a bit of a trick question because the system fails no matter what level of scrutiny the court applies.  As the Supreme Court has said, “No matter the level of deference we extend to the City, the inclusion of a formal system of entirely discretionary exceptions in section 3.21 renders the contractual non-discrimination requirement not generally applicable.”  Fulton v. City of Philadelphia, Pennsylvania, 141 S. Ct. 1868, 1878 (2021).    The Supreme Court then went on to say:   The creation of a formal mechanism for granting exceptions renders a policy not generally applicable, regardless whether any exceptions have been given, because it “invite[s]” the government to decide which reasons for not complying with the policy are worthy of solicitude, Smith, 494 U.S. at 884, 110 S.Ct. 1595—here, at the Commissioner's “sole discretion.”   Fulton v. City of Philadelphia, Pennsylvania, 141 S. Ct. 1868, 1879 (2021)   Disclaimer: The Religion Law Quizzes are provided as a service to you. They are intended only for educational purposes. Nothing in the Quizzes is intended to be legal advice and they should not be relied upon as conclusive on any issue discussed therein.   HERE IS AN AI GENERATED SUMMARY OF TODAY’S PODCAST   Welcome to the 90th episode of the Religion Law Podcast, the enlightening series dedicated to examining religious freedom and related legal matters. Join our host, Michael Fielding, as he reveals the inner workings of religious legal issues using an intriguing and insightful question-and-answer format. Today's query focuses on the legality and judicial scrutiny of a city's regulatory system, specifically dealing with discretionary exemptions for religious institutions. Can such a regulatory framework withstand the rigorous examination of the courts under strict scrutiny? Drawing on the 2021 Fulton v. City of Philadelphia Supreme Court decision, Fielding explains how a regulatory system with a formal allowance for discretionary exemptions fails under any level of judicial scrutiny. The assessment emphasizes the Supreme Court's argument that this system is not generally applicable as it allows government officials to decide whether a party is exempted or not based on personal discretion. The episode sheds light on the failings of discretionary exemptions, highlighting why such a legal structure fails to meet the constitutional standards due to its inconsistent application. A key takeaway from this episode is the importance of fairness and consistency in the law, especially when it comes to religious institutions. While these podcasts are for educational purposes only and not a source of legal advice, they are an engaging way to learn about religious law. The concrete examples and in-depth explanations provided in each episode make this an invaluable tool for understanding the intricacies of this particular facet of the law. Join us next time for quiz number 91, a brief but very practical session. Happy learning, and remember: keep being an influence for good!

Religion Law Quiz #89   Can the government discriminate against religion when acting in a managerial role?    (Scroll down for the answer)   Answer: No.  The Supreme Court has plainly stated, “We have never suggested that the government may discriminate against religion when acting in its managerial role.”  Fulton v. City of Philadelphia, Pennsylvania, 141 S. Ct. 1868, 1878 (2021).   Disclaimer: The Religion Law Quizzes are provided as a service to you. They are intended only for educational purposes. Nothing in the Quizzes is intended to be legal advice and they should not be relied upon as conclusive on any issue discussed therein.   HERE IS AN AI GENERATED SUMMARY OF TODAY’S PODCAST   Welcome to another insightful episode of the Religion Law Podcast. This episode features Quiz number 89, with the probing question: Can the government discriminate against religion when acting in a managerial role? Join your host, Michael Fielding, as he delves into the case study of Fulton v. City of Philadelphia, Pennsylvania (2021) to provide clarity on the subject. The answer, as defined by the Supreme Court, is a resounding "no." The court maintains that governments, regardless of the roles they assume, should not use their position to discriminate against religion. This episode further elaborates on the constitutional safeguards that are meant to protect religious freedoms from being unjustly encroached upon by governmental management roles. As the podcast unfolds, you'll discover the significance and practical applicability of these overarching constitutional protections. The city, when performing any managerial role, is not excused from respecting religious rights. Understand the legal requirements that need to be met before any burden on religion can be justified. Get ready to get enlightened in this thought-provoking episode of Religion Law Podcast. This episode is intended purely for educational purposes and should not be relied upon as legal advice. As always, your host, Michael, encourages you to keep being a positive influence. Pick up some insightful legal knowledge and enjoy the music!

Religion Law Quiz #88   In Fulton v. City of Philadelphia, Pennsylvania, 141 S. Ct. 1868, 1878 (2021) the regulations adopted by Philadelphia “incorporates a system of individual exemptions, made available in this case at the ‘sole discretion’ of the Commissioner. The City has made clear that the Commissioner ‘has no intention of granting an exception’ to” Catholic Social Services.  Id. (citations omitted).  Was the City of Philadelphia in the right to take this position?       (Scroll down for the answer)   Answer:  No.  As the Supreme Court said, “the City ‘may not refuse to extend that [exemption] system to cases of ‘religious hardship’ without compelling reason.”  Fulton v. City of Philadelphia, Pennsylvania, 141 S. Ct. 1868, 1878 (2021) (citation omitted).    Disclaimer: The Religion Law Quizzes are provided as a service to you. They are intended only for educational purposes. Nothing in the Quizzes is intended to be legal advice and they should not be relied upon as conclusive on any issue discussed therein.   HERE IS AN AI GENERATED SUMMARY OF TODAY’S PODCAST     Welcome to another insightful episode of Religion Law Podcast. In this episode, our host, Michael Fielding, dissects the Fulton v. City of Philadelphia Supreme Court decision from 2021. A significant case concerning religious freedom and law regulations adopted by the City of Philadelphia, that stirred much contemplation and discussion. In this judgment, the City of Philadelphia established a system of individual exemptions, made available at the sole discretion of the Commissioner. Interestingly, the Commissioner expressly stated that no exemption would be granted to Catholic social services. This led to the big question - was the city of Philadelphia right in taking this stance? Many held their views, but here's what the Supreme Court thought - the city was not in the right. The Supreme Court emphasised that if a law significantly burdens the exercise of religion, the government must have a compelling reason for it. The ruling that discretionary determination by a commissioner does not constitute a compelling reason was a key takeaway from the Fulton v. City of Philadelphia decision. Tune into this riveting episode as we continue dissecting this on Religion Law Quiz number 89. The Religion Law Quizzes intention purely lies in educating listeners about religious freedom and other religion law-related topics in a fun, question-and-answer-style format. We hope this episode leaves you with some food for thought around religion laws and their complexities. Don't forget to share it with others and leave a review if you find it helpful. Until next time, keep learning and keep influencing for the better.

Religion Law Quiz #87   Today’s Religion Law Quiz is definitely a tougher one.  Let’s see how you do.    In Fulton v. City of Philadelphia, Pennsylvania the Supreme Court stated that “Government fails to act neutrally when it proceeds in a manner intolerant of religious beliefs or restricts practices because of their religious nature.”  141 S. Ct. 1868, 1877 (2021).  The Supreme Court then went on to identify two specific guidelines for determining that a law is not generally applicable.  What were those two items?    (Scroll down for the answer)   Answer:  Here’s how the Supreme Court answered that question.  The specific examples are at the beginning of the first and third paragraphs below.    A law is not generally applicable if it “invite[s]” the government to consider the particular reasons for a person's conduct by providing “ ‘a mechanism for individualized exemptions.’ ” Smith, 494 U.S. at 884, 110 S.Ct. 1595 (quoting Bowen v. Roy, 476 U.S. 693, 708, 106 S.Ct. 2147, 90 L.Ed.2d 735 (1986) (opinion of BURGER, C. J., joined by POWELL AND REHNQUIST, JJ.)). For example, in Sherbert v. Verner, 374 U.S. 398, 83 S.Ct. 1790, 10 L.Ed.2d 965 (1963), a Seventh-day Adventist was fired because she would not work on Saturdays. Unable to find a job that would allow her to keep the Sabbath as her faith required, she applied for unemployment benefits. Id., at 399–400, 83 S.Ct. 1790. The State denied her application under a law prohibiting eligibility to claimants who had “failed, without good cause ... to accept available suitable work.” Id., at 401, 83 S.Ct. 1790 (internal quotation marks omitted). We held that the denial infringed her free exercise rights and could be justified only by a compelling interest. Id., at 406, 83 S.Ct. 1790. Smith later explained that the unemployment benefits law in Sherbert was not generally applicable because the “good cause” standard permitted the government to grant exemptions based on the circumstances underlying each application. See 494 U.S. at 884, 110 S.Ct. 1595 (citing Roy, 476 U.S. at 708, 106 S.Ct. 2147; Sherbert, 374 U.S. at 401, n. 4, 83 S.Ct. 1790). Smith went on to hold that “where the State has in place a system of individual exemptions, it may not refuse to extend that system to cases of ‘religious hardship’ without compelling reason.” 494 U.S. at 884, 110 S.Ct. 1595 (quoting Roy, 476 U.S. at 708, 106 S.Ct. 2147); see also Lukumi, 508 U.S. at 537, 113 S.Ct. 2217 (same).   A law also lacks general applicability if it prohibits religious conduct while permitting secular conduct that undermines the government's asserted interests in a similar way. See id., at 542–546, 113 S.Ct. 2217. In Church of Lukumi Babalu Aye, Inc. v. Hialeah, for instance, the City of Hialeah adopted several ordinances prohibiting animal sacrifice, a practice of the Santeria faith. Id., at 524–528, 113 S.Ct. 2217. The City claimed that the ordinances were necessary in part to protect public health, which was “threatened by the disposal of animal carcasses in open public places.” Id., at 544, 113 S.Ct. 2217. But the ordinances did not regulate hunters’ disposal of their kills or improper garbage disposal by restaurants, both of which posed a similar hazard. Id., at 544–545, 113 S.Ct. 2217. The Court concluded that this and other forms of underinclusiveness meant that the ordinances were not generally applicable. Id., at 545–546, 113 S.Ct. 2217.   Fulton v. City of Philadelphia, Pennsylvania, 141 S. Ct. 1868, 1877 (2021)   Disclaimer: The Religion Law Quizzes are provided as a service to you. They are intended only for educational purposes. Nothing in the Quizzes is intended to be legal advice and they should not be relied upon as conclusive on any issue discussed therein.   HERE IS AN AI GENERATED SUMMARY OF TODAY’S PODCAST   Welcome to another riveting episode of Religion Law Podcast, where issues regarding religious freedom and other religion law-related topics are dissected. Your host, Michael Fielding, presents a quiz that aims to enlighten and challenge your understanding of these complex matters. In Quiz 87, we dive into the intricacies of the Supreme Court's 2021 decision, Fulton v. City of Philadelphia, Pennsylvania. In the mentioned decision, the Supreme Court stated that a government acts against neutrality when it doesn't tolerate religious beliefs or restricts practices due to religious nature. Drawing from this case, the podcast subsequently explores two guidelines that determine when a law is not generally applicable. These critical points are intricately explained, providing context and past decisions to paint a clearer picture, all while testing listeners' grasp of the subject matter. This episode allows listeners to delve deeper into the criteria for a law’s general applicability, with diverse examples to enhance comprehension. We engage with Sherbert v. Verner and Church of Leukemia, The Bible Inc. Versus Hialeah to illustrate both points. Through these, listeners witness how religious and secular conduct can impact a law's general applicability. Remember, this Podcast aims to educate and inform listeners about the sophisticated world of religion law and is not intended as a source of legal advice. We invite you to share this episode and leave a review if you've learned or gained valuable insight.