In the case of Jensen, Director, Department of Motor Vehicles of Nebraska, et al. v. Quaring (1984), the U.S. Supreme Court ruled in favor of a woman who refused to have her photograph taken for her driver's license due to religious beliefs. The plaintiff was Beverly Quaring, a member of the Apostolic Christian Church which forbade its members from having their photographs taken as it violated their interpretation of the Second Commandment’s prohibition on graven images. She argued that this requirement infringed upon her First Amendment rights to freely exercise religion and sought an exemption based on these grounds. The State argued that requiring photos on licenses served important state interests such as preventing fraud and aiding law enforcement officers in identifying drivers during traffic stops or accidents. However, the Supreme Court held that while these were indeed compelling state interests, they did not outweigh Quaring's right to free exercise since there were other ways for authorities to verify identity without infringing upon religious freedom.

In the dissenting opinion for Jensen v. Quaring, Justice White argued that Nebraska's interest in maintaining a photo identification system for drivers' licenses outweighed Quaring's religious objections to being photographed. He believed that the state had a compelling interest in ensuring accurate and reliable identification of license holders, which was facilitated by photographic IDs. Furthermore, he pointed out that granting exceptions based on religious beliefs could potentially open up floodgates for numerous other exemptions based on various individual preferences or beliefs, thereby undermining the effectiveness of such an ID system. Thus, while acknowledging respect for free exercise of religion as protected by First Amendment rights, he asserted that it should not be absolute when it comes into conflict with significant state interests.