But this is not an attempt to accommodate by someone else doing it. She refuses 
to issue any marriage licenses and has not delegated anyone else in the office 
to do it.  This is not like a religious cop who won't work on (pick the holy 
day).  And Your solution apparently would require a change in KY law, since as 
someone else noted, the law *requires* her name on it.  
 
******************
Paul Finkelman, Ph.D.
Senior Fellow
 Penn Program on Democracy, Citizenship, and Constitutionalism
 University of Pennsylvania
 and 
Scholars Advisory Panel 
National Constitution Center 
 Philadelphia, Pennsylvania 
 518-439-7296 (w)
 518-605-0296 (c) 
 [email protected] 
www.paulfinkelman.com
      From: "Volokh, Eugene" <[email protected]>
 To: Law & Religion issues for Law Academics <[email protected]> 
 Sent: Thursday, September 3, 2015 12:13 AM
 Subject: RE: Question about the Kentucky County Clerk controversy
   
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{}#yiv3619058084                Well, Title VII’s reasonable accommodation does 
allow people to hold jobs (government or otherwise) knowing that they will not 
in fact do all parts of the job, so long as the employer can accommodate them 
without undue hardship (e.g., by some sort of swap of duties).  This could be 
because they can’t do all the temporal parts of the job (“I can’t be on the job 
Friday nights after sundown”) or it could be because they can’t do all the 
subject-matter parts of the job (“I can’t process draft registration 
materials”).  The cases I cited so say, it seems to me.                   It 
also seems to me that RFRA’s strict scrutiny mandate, as applied to government 
employees, is at least as demanding as Title VII’s religious accommodation 
mandate.  It may be more demanding, if we take strict scrutiny seriously, or it 
may be about as demanding, but I doubt it would be less demanding.  If a 
religious objection can be accommodated without undue hardship, it’s hard to 
see how denying the accommodation is narrowly tailored to a compelling 
government interest.                   Then the only question is whether 
there’s a different RFRA rule for elected officials than for ordinary 
government employees.  (There is a different Title VII rule, but that’s just 
because of a statutory exclusion of religious officials.)  I would think not.  
So if that’s so, then it seems to me that the Kentucky County Clerk could 
indeed get a Kentucky RFRA exemption from the requirement that she distribute 
marriage license/certificate materials with her name listed (though that’s not 
something she can get in the defense of her federal lawsuit, but would require 
a separate suit under state law).                   As to the USDA inspector 
hypothetical, accommodating that religious objection would indeed be very 
burdensome from the government.  But say that there’s a particular meat 
processor that only ships meat on Saturdays, and this USDA inspector refuses to 
come in Saturdays to inspect that processor; instead, he arranges for a 
coworker to cover for him, because there are plenty of other tasks that he 
could do instead.  Clear case for a Title VII religious accommodation, no?  Why 
not RFRA then, too?                   Eugene                      

From: [email protected] 
[mailto:[email protected]]On Behalf Of Paul Finkelman
Sent: Wednesday, September 02, 2015 8:27 PM
To: Law & Religion issues for Law Academics
Subject: Re: Question about the Kentucky County Clerk controversy    It seems 
you raise the great RFRA question, can RFRA allow people to hold jobs 
(especially government jobs) knowing that they will not in fact do the job?  
This seems to be like Thomas v. Review Board of Indiana (1981).  Thomas's job 
changed.   He now had to make military hardware, which violated his religious 
beliefs.  He could not do his job, so he quit and was allowed to take 
unemployment compensation.  Isn't that the situation here?  The law has changed 
and the employee refuses to do her job.    Suppose an animal rights activist, 
who bases her views on religious grounds, wins a job as county health 
inspector, and refuses to certify restaurants or grocery stores or butchers, 
that sell meat.  Then has them closed down for not being certified.  Does RFRA 
protect her?  Can the same person become a USDA inspector and then refuse to 
certify inspected meat and claim a RFRA right?    It seem to me that the clerk 
in Ky, consistent with her religious beliefs, must resign, and then collect 
unemployment compensation, like Thomas.      To extend this, what if the 
legislature impeaches her, or somehow she is forced to resign because she does 
not want to go to jail. And then she runs for the same office and wins?  At 
what point can you be precluded from taking a government job that you know you 
will not do? (Can a pacifist join the army and then refuse to serve?  can a 
Quaker become the state executioner?)       
******************
Paul Finkelman, Ph.D.
Senior Fellow
Penn Program on Democracy, Citizenship, and Constitutionalism
University of Pennsylvania
and 
Scholars Advisory Panel
National Constitution Center 
Philadelphia, Pennsylvania 
518-439-7296 (w)
518-605-0296 (c) 
[email protected] 
www.paulfinkelman.com    From: "Friedman, Howard M." 
<[email protected]>
To: Law & Religion issues for Law Academics <[email protected]>
Sent: Wednesday, September 2, 2015 10:10 PM
Subject: RE: Question about the Kentucky County Clerk controversy    Kentucky 
law requires the license to be signed by the clerk or deputy 
clerk.http://www.lrc.ky.gov/statutes/statute.aspx?id=36475    I have a 
different question though. State RFRAs protect against actions by the 
government that infringe religious liberty.  Here Kim Davis "is" the 
government, i.e. she is objecting to actions she is required to take in her 
official capacity.  Should RFRAs be read to protect government officials in 
that kind of situation?    Howard Friedman    
From:[email protected] [[email protected]] on 
behalf of Paul Finkelman [[email protected]]
Sent: Wednesday, September 02, 2015 8:48 PM
To: Law & Religion issues for Law Academics
Subject: Re: Question about the Kentucky County Clerk controversy Quick 
question. Does anyone know if KY law requires the clerk to issue the license in 
the Clerk's name, as opposed to "the office of the Clerk" as Eugene suggests?   
******************
Paul Finkelman, Ph.D.
Senior Fellow
Penn Program on Democracy, Citizenship, and Constitutionalism
University of Pennsylvania
and 
Scholars Advisory Panel 
National Constitution Center 
Philadelphia, Pennsylvania 
518-439-7296 (w)
518-605-0296 (c) 
[email protected] 
www.paulfinkelman.com    From: "Volokh, Eugene" <[email protected]>
To: "Law & Religion issues for Law Academics ([email protected])" 
<[email protected]>
Sent: Wednesday, September 2, 2015 6:31 PM
Subject: Question about the Kentucky County Clerk controversy                   
I was wondering what list members thought – as a legal matter – of this 
following issue that arises in the Kentucky County Clerk controversy.  A 
federal judge issued an injunction ordering County Clerk Kim Davis to issue 
marriage licenses, including same-sex marriage licenses.  
Seehttp://www.scotusblog.com/wp-content/uploads/2015/08/Kentucky-marriage-15A250-application.pdf
 (the application for stay from the Supreme Court, with the orders below 
attached).  I think that’s quite correct.                  But as I understand 
it, Kim Davis’s stated objection is not to having any same-sex marriages be 
processed by her office, but only to authorizing the distribution of marriage 
license and certificate forms in which her name appears (see PDF p. 133 of the 
linked-to file above).  In particular, she says that she would accept the 
option of “Modifying the prescribed Kentucky marriage license form to remove 
the multiple references to Davis’ name, and thus to remove the personal nature 
of the authorization that Davis must provide on the current form” (PDF p. 40); 
presumably those forms might say “Clerk of Rowan County” or perhaps the name of 
a deputy clerk who is willing to have his or her name used for that (assuming 
there is one).                  Now I’m not sure this is a remedy that the 
federal courts could offer, or ought to offer.  But say that Davis asks for an 
injunction or for declaratory judgment from a Kentucky state court, under the 
Kentucky RFRA, seeking to exempt her from the statutory requirement of having 
her name appear on the form.  Should she prevail?                  Or stepping 
away from the same-sex marriage issue, say that every time a death warrant was 
issued in a county, the County Clerk was by statute required to sign off on it, 
as a purely ministerial task; but the County Clerk objected on religious 
grounds to the death penalty, and filed a RFRA claim asking to have that 
requirement waived, so that a deputy (who was willing to sign) would sign 
instead.  Should she prevail, again under a state RFRA?                  
Finally, say that the County Clerk was an employee rather than an elected 
officeholder, so that Title VII would apply (it doesn’t apply to elected 
officeholders).  Would the County Clerk have a right under Title VII’s 
reasonable accommodation mandate to this sort of exemption?  Compare, 
e.g.,American Postal Workers Union v. Postmaster Gen., 781 F.2d 772, 777 (9th 
Cir. 1986) (concluding that government employer had a duty to reasonably 
accommodate, by arranging transfers to other jobs, postal workers who had a 
religious objection to processing draft registration forms); McGinnis v. United 
States Postal Serv., 512 F. Supp. 517, 523 (N.D. Cal. 1980) (finding the 
government had a duty to reasonably accommodate, by offering a transfer to 
another window that wasn't used for registration materials);Haring v. 
Blumenthal, 471 F. Supp. 1172 (D.D.C. 1979) (concluding that the IRS had an 
obligation to exempt an employee from having to work on tax-exempt status 
applications from abortion clinics and other organizations that the employee 
thought it sinful to deal with); Best v. California Apprenticeship Council, 207 
Cal. Rptr. 863, 868 (Ct. App. 1984) (concluding that an apprentice training 
organization--which was treated by state law as an employer--had an obligation 
to accommodate an apprentice's religious objection to working in a nuclear 
power plant); David Haldane, Panel Backs Fired Vegetarian Bus Driver, L.A. 
Times, Aug. 24, 1996, at A18 (discussing a case in which the EEOC concluded 
that a transportation agency must accommodate a vegetarian bus driver's 
religious objections to handing out hamburger coupons as part of the agency's 
promotion aimed at boosting ridership); Felhaber et al.,Bits and Pieces, Minn. 
Employment L. Letter, Sept. 1997 (reporting that the case against the 
transportation agency was settled for $50,000).                  Eugene 
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