Case Analysis Assignment 1

Case Analysis Assignment #1 (May be done individually or in groups of 2 or 3 - no larger group than 3) Examine Austin v. Berryman , 878 F.2d 786 (4 th Cir. 1989). The case is attached hereto and excerpted in detail. Review the case and brief the case. Brief cases in this form: Facts Issue Decision Rationale Answer these questions at the end of your brief: 1. Who were the plaintiff and the defendant in this action? 2. Why did Austin claim that she had been forced to leave her job? 3. Why was she refused state unemployment benefits? 4. Did the state's refusal to give her unemployment compensation violate her rights under the free exercise clause of the First Amendment? 5. What logic or reasoning did the court employ in arriving at its conclusion? Due: September 17, 2020 AUSTIN v. BERRYMAN United States Court of Appeals, Fourth Circuit, 1989. 878 F. 2d 786. MURNAGHAN, Circuit Judge: We have before us for en banc reconsideration an appeal taken from an action successfully brought by Barbara Austin in the United States District Court for the Western District of Virginia against the Virginia Employment Commission, challenging a denial of unemployment compensation benefits. *** In brief, Austin charged, infer alia [among other things], that the denial of her claim for unemployment benefits, based on a Virginia statute specifically precluding such benefits for any individual who voluntarily quits work to join his or her spouse in a new location, was an unconstitutional infringement upon the incidents of marriage protected by the fourteenth amendment and an unconstitutional burden on her first amendment right to the free exercise of her religion. Her religion happened to command that she follow her spouse wherever he might go and the sincerity of her religious belief was not questioned. The district court found in Austin's favor and awarded injunctive relief and retroactive benefits.
On appeal, Judge Sprouse, writing for a panel majority, found that the denial of benefits did not implicate Austin's fourteenth amendment rights, but that it did unconstitutionally burden Austin's right to the free exercise of her religion. The panel also found, however, that any award of retroactive benefits was barred by the eleventh amendment. One panel member concurred with the panel majority as to the fourteenth and eleventh amendment issues, but dissented as to the existence of a free exercise violation. The panel opinion now, of course, has been vacated by a grant of rehearing en banc. After careful consideration of the additional arguments proffered by both sides, the Court, en banc, is convinced that the panel majority correctly concluded that denying Austin unemployment benefits did not infringe upon fundamental marital rights protected by the fourteenth amendment. To this extent, we adopt the majority panel opinion. We also find however, that the denial of benefits did not unconstitutionally burden Austin's first amendment right to the free exercise of her religion. We are persuaded that the views expressed on the first amendment, free exercise of religion claim in the opinion dissenting in part from the panel majority are correct, and we herby adopt that opinion as that of the en banc court. As we find that Austin is not entitled to any relief, we need not address whether the eleventh amendment bars an award of retroactive benefits. Austin voluntarily decided to quit her job and join her spouse in a new geographic location 150 miles away. Virginia has stated that every individual who follows such a course, no matter what the reason, religious or non-religious, is disqualified for unemployment benefits. To craft judicially a statutory exception only for those individuals who profess Austin's religious convictions, particularly in the absence of a direct conflict between a given employment practice and a religious belief, would, in our view, result in a subsidy to members of a particular religious belief, impermissible under the Establishment Clause. Accordingly, the judgment of the district court is REVERSED.
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