Johnson v. Robison | |
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Argued December 11, 1973 Decided March 4, 1974 | |
Full case name | Johnson, Administrator of Veterans' Affairs, et al. v. Robison |
Citations | 415 U.S. 361 ( more ) 94 S. Ct. 1160; 39 L. Ed. 2d 389; 1974 U.S. LEXIS 108 |
Prior history | District Court for the District of Massachusetts decision for Robison, 352 F. Supp. 848; |
Holding | |
Providing different benefits for uniformed veterans and conscientious objectors does not violate equal protection or the free exercise clause. | |
Court membership | |
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Case opinions | |
Majority | Brennan, joined by Burger, Stewart, White, Marshall, Blackmun, Powell, Rehnquist |
Dissent | Douglas |
Laws applied | |
U.S. Const., amends. I, XIV |
Johnson v. Robison, 415 U.S. 361 (1974), was a case heard before the United States Supreme Court. The court held that the Veterans' Administrations' allocation of greater educational benefits to combat veterans than conscientious objectors was consistent with the United States Constitution. Robison, a conscientious objector, argued that such unequal benefits violated his 5th Amendment right to Equal Protection and his First Amendment right to free exercise of religion. The court rejected both arguments.
The United States Constitution is the supreme law of the United States. The Constitution, originally comprising seven articles, delineates the national frame of government. Its first three articles embody the doctrine of the separation of powers, whereby the federal government is divided into three branches: the legislative, consisting of the bicameral Congress ; the executive, consisting of the President ; and the judicial, consisting of the Supreme Court and other federal courts. Articles Four, Five and Six embody concepts of federalism, describing the rights and responsibilities of state governments, the states in relationship to the federal government, and the shared process of constitutional amendment. Article Seven establishes the procedure subsequently used by the thirteen States to ratify it. It is regarded as the oldest written and codified national constitution in force.
A conscientious objector is an "individual who has claimed the right to refuse to perform military service" on the grounds of freedom of thought, conscience, or religion.
The Equal Protection Clause is a clause within the text of the Fourteenth Amendment to the United States Constitution. The clause, which took effect in 1868, provides "nor shall any State [...] deny to any person within its jurisdiction the equal protection of the laws".
The court reasoned that a rational basis existed to give combat veterans better benefits than those who objected for religious reasons: namely, encouraging people to participate in the armed forces as soldiers. The court reasoned that the increased disruption and longer commitment for soldiers justified disparate allocation of benefits. As to free exercise, the court held that the withholding of benefits had only an incidental burden, if any, on religious exercise, that that burden was not intended, and that it was justified by the substantial government interest in raising an army.
In U.S. constitutional law, rational basis review is the normal standard of review that courts apply when considering constitutional questions, including due process or equal protection questions under the Fifth Amendment or Fourteenth Amendment. Courts applying rational basis review seek to determine whether a law is "rationally related" to a "legitimate" government interest, whether real or hypothetical. The higher levels of scrutiny are intermediate scrutiny and strict scrutiny. Heightened scrutiny is applied where a suspect or quasi-suspect classification is involved, or a fundamental right is implicated.
The Court also held that 38 USC section 211(a) does not preclude constitutional challenges to law administered by the Veteran's Administration.
The United States Reports are the official record of the rulings, orders, case tables, in alphabetical order both by the name of the petitioner and by the name of the respondent, and other proceedings of the Supreme Court of the United States. United States Reports, once printed and bound, are the final version of court opinions and cannot be changed. Opinions of the court in each case are prepended with a headnote prepared by the Reporter of Decisions, and any concurring or dissenting opinions are published sequentially. The Court's Publication Office oversees the binding and publication of the volumes of United States Reports, although the actual printing, binding, and publication are performed by private firms under contract with the United States Government Publishing Office.
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West Virginia State Board of Education v. Barnette, 319 U.S. 624 (1943), is a landmark decision by the United States Supreme Court holding that the Free Speech Clause of the First Amendment protects students from being forced to salute the American flag or say the Pledge of Allegiance in public school. The Court's 6–3 decision, delivered by Justice Robert H. Jackson, is remembered for its forceful defense of free speech and constitutional rights generally as being placed "beyond the reach of majorities and officials".
The Religious Freedom Restoration Act of 1993, Pub. L. No. 103-141, 107 Stat. 1488, codified at 42 U.S.C. § 2000bb through 42 U.S.C. § 2000bb-4, is a 1993 United States federal law that "ensures that interests in religious freedom are protected." The bill was introduced by Congressman Chuck Schumer (D-NY) on March 11, 1993. A companion bill was introduced in the Senate by Ted Kennedy (D-MA) the same day. A unanimous U.S. House and a nearly unanimous U.S. Senate—three senators voted against passage—passed the bill, and President Bill Clinton signed it into law.
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Wisconsin v. Jonas Yoder, 406 U.S. 205 (1972), is the case in which the United States Supreme Court found that Amish children could not be placed under compulsory education past 8th grade. The parents' fundamental right to freedom of religion was determined to outweigh the state's interest in educating its children. The case is often cited as a basis for parents' right to educate their children outside of traditional private or public schools.
The Free Exercise Clause accompanies the Establishment Clause of the First Amendment to the United States Constitution. The Establishment Clause and the Free Exercise Clause together read:
Cutter v. Wilkinson, 544 U.S. 709 (2005), was a United States Supreme Court case in which the Court held that, under the Religious Land Use and Institutionalized Persons Act (RLUIPA), facilities that accept federal funds cannot deny prisoners accommodations that are necessary to engage in activities for the practice of their own religious beliefs.
The Religious Land Use and Institutionalized Persons Act (RLUIPA), Pub.L. 106–274, codified as 42 U.S.C. § 2000cc et seq., is a United States federal law that prohibits the imposition of burdens on the ability of prisoners to worship as they please and gives churches and other religious institutions a way to avoid zoning law restrictions on their property use. It also defines the term "religious exercise" to include "any exercise of religion, whether or not compelled by, or central to, a system of religious belief." RLUIPA was enacted by the United States Congress in 2000 to correct the problems of the Religious Freedom Restoration Act (RFRA) of 1993. The act was passed in both the House of Representatives and the Senate by unanimous consent in voice votes, meaning that no objection was raised to its passage, so no written vote was taken. The S. 2869 legislation was enacted into law by the 42nd President of the United States Bill Clinton on September 22, 2000.
Employment Division, Department of Human Resources of Oregon v. Smith, 494 U.S. 872 (1990), is a United States Supreme Court case that held that the state could deny unemployment benefits to a person fired for violating a state prohibition on the use of peyote, even though the use of the drug was part of a religious ritual. Although states have the power to accommodate otherwise illegal acts performed in pursuit of religious beliefs, they are not required to do so.
Police v. City of Newark, 170 F.3d 359, was a case challenging an internal order of the City of Newark Police Department requiring its officers to be clean-shaven. The Third Circuit Court of Appeals held that the order merited strict scrutiny and did not survive exacting review. Therefore, the order violated the Free Exercise Clause of the First Amendment.
Cantwell v. Connecticut, 310 U.S. 296 (1940), is a decision by United States Supreme Court holding that the First Amendment's federal protection of religious free exercise incorporates via the Due Process Clause of the Fourteenth Amendment and so applies to state governments too.
Sherbert v. Verner, 374 U.S. 398 (1963), was a case in which the Supreme Court of the United States held that the Free Exercise Clause of the First Amendment required the government to demonstrate both a compelling interest and that the law in question was narrowly tailored before it denied unemployment compensation to someone who was fired because her job requirements substantially conflicted with her religion.
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In re Summers, 325 U.S. 561 (1945), is a 5-to-4 ruling by the United States Supreme Court which held that the First and Fourtheenth amendment freedoms of a conscientious objector were not infringed when a state bar association declined to admit him to the practice of law. The Illinois Constitution required citizens to serve in the state militia in time of war, and all lawyers admitted to the bar were required to uphold the state constitution. Petitioner Clyde Summers could not uphold that constitutional requirement due to his religious beliefs, and the Supreme Court upheld the denial of his license of practice.
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United States v. Lee, 455 U.S. 252 (1982), was a United States Supreme Court case establishing precedent regarding the limits of free exercise of religious conscience by employers.
Conscientious objection in the United States is based on the Military Selective Service Act, which delegates its implementation to the Selective Service System. Conscientious objection is also recognized by the Department of Defense.