it had been interpreted, wrongly in his view, by the court — Establishment Clause prohibition of such protection. He also disagreed with the majority's claim that a cited precedent, Braunfeld v. Brown, was distinguishable from Sherbert. Harlan's dissenting opinion Harlan, in a characteristically formalist reading of the relevant law, argued that the Commission denied Sherbert unemployment based on the same reason they might any secular claimant, that she was not "available for work" because of a private decision she had made. More centrally, he rejected the majority opinion, arguing that the Free Exercise Clause only required neutrality toward religion in this case, which would not include exempting Sherbert, though the Constitution would permit a legislature to create such an exemption. Sherbert test In Sherbert, the Court set out a three-prong test for courts to use in determining whether the government has violated an individual's constitutionally protected right to the free exercise of religion. The first prong investigates whether government has burdened the individual's free exercise of religion. If government confronts an individual with a choice that pressures the individual to forego a religious practice by imposing a penalty or withholding a benefit, the government has burdened the individual's free exercise of religion. However, not all burdens placed on religious exercise are constitutionally prohibited under the test. If the first prong is passed, the government may still constitutionally impose the burden on the individual's free exercise if the government can show it possesses some compelling state interest that justifies the infringement (the compelling interest prong) and no alternative form of regulation can avoid the infringement and still achieve the state's end (the narrow tailoring prong). Limiting Sherbert test The Supreme Court sharply curtailed the Sherbert Test in the 1980s, culminating in the 1990 landmark case Employment Division v. Smith. In Smith, the court held that free exercise exemptions were not required from generally applicable laws. In response to the Smith decision, Congress passed the 1993 Religious Freedom Restoration Act (RFRA) to reinstate the Sherbert Test as a statutory right. The RFRA purported to restore strict scrutiny analysis to all free exercise cases in which the plaintiff proves a substantial burden on the free exercise of his or her religion. However, four years later, the court struck down RFRA as applied to Constitutional interpretation. In City of Boerne v. Flores, 521 U.S. 507 (1997), the court found that RFRA, as applied to