ABSTRACT
The Court’s decisions in Yoder, Sherbert, and Thomas seemed to represent a more robust interpretation of free exercise guarantees. However, any hopes that the Court had settled ona consistent, protective jurisprudence were soon dashed. The Supreme Court issued a series of decisions that were not only inconsistent in result but also did not even pretend to utilize a consistent standard.The Court would announce one standard in one case and ignore it or, sometimes, expressly repudiate it in a subsequent case. Then, the Court might go back to the previous standard as if it had been used along. Further, without seeming to appreciate the implications of its own analysis, the Court would offer reasoning in some cases that cast doubt on the correctness of its previous decisions. The jurisprudence was utterly chaotic.
