In Employment Div., Dept. of Human Resources of Oregon v. Smith (1990) 494 U.S. 872, the court concluded the compelling interest test of Sherbert v. Verner (1963) 374 U.S. 398 is inapplicable to claims that criminal laws of general application infringe on the free exercise of religion. Smith involved a claim by two members of the Native American Church who were fired from their jobs as drug rehabilitation counselors because of their ingestion of peyote and were denied unemployment compensation benefits. The court explained: " The government's ability to enforce generally applicable prohibitions of socially harmful conduct, like its ability to carry out other aspects of public policy, 'cannot depend on measuring the effects of a governmental action on a religious objector's spiritual development.' To make an individual's obligation to obey such a law contingent upon the law's coincidence with his religious beliefs, except where the State's interest is 'compelling' -- permitting him, by virtue of his beliefs, 'to become a law unto himself,' -- contradicts both constitutional tradition and common sense." (494 U.S. at p. 885.) The court nevertheless suggested the Sherbert v. Verner test may have continued vitality where the state has in place a system of exemptions to the generally applicable law, in which case the state may not refuse to extend an exemption to religious entities without a compelling interest. (494 U.S. at p. 884.) The Court held that the state of Oregon did not violate the Free Exercise Clause of the First Amendment to the United States Constitution when it refused unemployment benefits to certain practitioners of Native American peyote religion who had been fired for illegally using peyote. Id. at 890. The Court announced that a neutral law of general applicability need not be justified by a compelling governmental interest even if the law has the incidental effect of burdening a particular religious practice. Id. at 878-80. The United States Supreme Court concluded the free exercise clause did not prohibit application of Oregon drug laws to ceremonial ingestion of peyote. The Court reiterated that it has "consistently held that the right of free exercise does not relieve an individual of the obligation to comply with a 'valid and neutral law of general applicability on the ground that the law proscribes (or prescribes) conduct that his religion prescribes (or proscribes).'" (Id. 494 U.S. at 879.) The Court also specifically rejected the contention that a neutral law of general applicability that burdens a religious practice must be justified by a compelling governmental interest. (Smith, 494 U.S. at 885, 886 n.3.)