In the case of Indiana Employment Security Division et al. v. Burney, 1972, the U.S Supreme Court ruled in favor of Burney, who had been denied unemployment compensation by the state of Indiana due to her refusal to accept a job that required her to work on Sundays because it conflicted with her religious beliefs as a member of Seventh-day Adventist Church. The court held that denying unemployment benefits under these circumstances violated the Free Exercise Clause of First Amendment rights which guarantees freedom from government interference in religious practice unless there is a compelling state interest involved. This ruling set an important precedent for future cases involving conflicts between employment requirements and employees' religious practices.

The dissenting opinion in the case of Indiana Employment Security Division et al. v. Burney argued that the majority's decision was a misinterpretation of federal law and an overreach into state jurisdiction. The dissenters believed that the Federal Unemployment Tax Act (FUTA) did not require states to provide unemployment benefits to pregnant women who were unable to work due to pregnancy-related medical conditions, as it would be considered a special benefit rather than standard unemployment compensation. They contended that FUTA only required states to have laws providing for "the payment of unemployment compensation," which they interpreted as payments made when individuals are unemployed through no fault of their own, not due to physical inability or illness. Therefore, they disagreed with the majority’s view that denying such benefits constituted sex discrimination under Title VII.