The Braunfeld v. Brown case in 1960 revolved around a Pennsylvania law that prohibited retail selling of certain goods on Sundays, which was challenged by Orthodox Jewish merchants who observed Saturday as their Sabbath and were thus forced to close their businesses for two days instead of one. The plaintiffs argued this violated the First Amendment's Free Exercise Clause because it indirectly coerced them into violating their religious practices. However, the Supreme Court upheld the law with a 6-3 decision, stating that while it may have made practicing religion more expensive for some people, it did not make any religious practice unlawful or deny anyone equal protection under the law. The court ruled that states had power to enact such laws if they served secular purposes like providing a uniform day of rest for all citizens.

In the dissenting opinion for Braunfeld v. Brown, Justice William O. Douglas argued that Pennsylvania's Sunday closing laws violated the First Amendment rights of Orthodox Jewish merchants who observed Saturday as their day of rest and were thus forced to close their businesses two days a week instead of one like other businesses. He contended that this law placed an undue burden on those practicing religions with different Sabbath observances than mainstream Christianity, thereby infringing upon religious freedom. Furthermore, he questioned whether these laws truly served a secular purpose or if they merely perpetuated Christian norms under the guise of promoting general welfare and public order.