In the 1973 case Christian et al. v. New York State Department of Labor, Division of Employment, et al., the U.S. Supreme Court ruled in favor of a group of Seventh-day Adventists who had been denied unemployment benefits after they were fired for refusing to work on their Sabbath (Saturday). The court held that denying them benefits violated their First Amendment rights to free exercise of religion. The state argued that granting exceptions based on religious beliefs would lead to administrative difficulties and potential fraud; however, the court rejected these arguments stating that constitutional rights should not be dismissed due to administrative inconvenience or speculative concerns about fraudulent claims.

In the dissenting opinion for Christian et al. v. New York State Department of Labor, Division of Employment et al., Justice Douglas argued that the majority's decision to uphold a state law requiring unemployment benefits to be denied to individuals who refuse employment due to religious beliefs was unconstitutional. He contended that this ruling violated an individual's First Amendment rights by forcing them into a position where they must choose between their faith and financial survival, thus imposing an undue burden on their free exercise of religion. Furthermore, he asserted that there is no compelling state interest in denying these benefits as it does not serve any fiscal or administrative purpose nor promote societal welfare in any significant way.