Free Exercise Clause and child support obligation

[Volokh, Eugene]

	In re Didier, 2006 WL 2258571 (Wash. App.), raises an
interesting question (though it's possible that on the facts in this
particular case the objection was insincere):  Should parents who are
unemployed or underemployed for religious reasons -- for instance,
because they have taken a vow of poverty and committed themselves to a
monastic or missionary life -- be exempted from a child support
obligation that's based on the income the parent would have had if he
had been gainfully employed?

	The Washington Court of Appeals says no, citing Smith; but it
doesn't discuss the possibility that this might be an "individualized
exemptions" case a la Sherbert, and it doesn't the Washington state
constitution, which has been interpreted as mandating strict scrutiny in
religious exemption cases.  What  do people think would be the right
answer under either of those doctrines?  See also Hunt v. Hunt, a
mid-1990s Vermont case on the subject.

	Eugene