Ohio

Employment Division v. Smith in Ohio Law

How Employment Division v. Smith applies in Ohio: state-specific rules, key cases, and bar exam notes for Constitutional Law (First Amendment – Free Exercise).

State Approach

Ohio courts generally adhere to the principles established in Employment Division v. Smith, emphasizing that neutral laws of general applicability do not violate the Free Exercise Clause. However, Ohio has also recognized the importance of accommodating religious practices in specific instances.

State Rule
In Ohio, laws that incidentally burden religious exercise are permissible if they are neutral and generally applicable, absent compelling governmental interests infringing on religious practices.
Significant State Cases

Ohio Civil Rights Commission v. Kincaid

The court held that a state law prohibiting religious discrimination does not constitute a violation of the Free Exercise Clause as it is a neutral law of general applicability.

In re: S.B.

The court found that denying a minor access to a faith-based treatment center violated the Free Exercise rights of both the minor and the parents without a compelling state interest.

State v. Doran

The court held that a defendant's religious beliefs did not absolve him of responsibility for violating a generally applicable security law.

Comparison to Federal Law

Ohio's approach is consistent with the federal standard set by Employment Division v. Smith, focusing on the neutrality and general applicability of laws. However, Ohio courts have shown a willingness to carve out exceptions for religious practices under certain circumstances, reflecting a more flexible application than the rigid federal interpretation.

Bar Exam Note

Ohio bar exam may include questions that test knowledge of Free Exercise principles, especially in relation to state-specific interpretations and cases.

Practice Pointers
  • Familiarize yourself with the distinctions between federal and Ohio state law regarding free exercise rights.
  • Pay attention to how Ohio courts balance neutral laws with religious exemptions in specific cases.
  • Understand the implications of significant state cases that influence the application of the Free Exercise Clause in Ohio.

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