10.2190/79VA-7E0A-WNN9-1TN0 79VA7E0AWNN91TN0 1 Loyalty Oaths: The Religious Freedom Restoration Act and the <i>Bessard</i> Case 255 266 20020509 20020509 20020509 20020509 79VA7E0AWNN91TN0.pdf http://baywood.metapress.com/link.asp?target=contribution&id=79VA7E0AWNN91TN0 4 David C. Wyld Southeastern Louisiana University, Hammond This article examines the ramifications of <i>Bessard v. California Community Colleges</i>, the first case in the employment setting decided under the Religious Freedom Restoration Act (RFRA). To set the stage for an analysis of the <i>Bessard</i> case, the thirty year history of the "compelling interest" test in public sector employment is traced from its development in the 1963 case of <i>Sherbert v. Verner</i> through its being struck down by the Supreme Court in <i>Employment Division, Department of Human Resources v. Smith</i> (1990) to its reinstatement in the Religious Freedom Restoration Act of 1993. After this examination of the judicial and legislative heritage of the RFRA and its relationship to the free-exercise clause of the First Amendment, the facts and decisions in the <i>Bessard</i> case are analyzed. A concluding discussion is then presented, examining the implications of the RFRA and <i>Bessard</i>, with an eye toward areas of possible future First Amendment litigation over employment issues in the public sector.