United States v. Lee
455 U.S. 252 (1982)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
The government's compelling interest in maintaining the fiscal integrity of the social security system outweighs the burden placed on individuals who object to paying social security taxes on religious grounds, and thus does not violate the Free Exercise Clause of the First Amendment.
Facts:
- Edwin D. Lee, a member of the Old Order Amish, is a farmer and carpenter.
- Lee's religious beliefs prohibit him from accepting public insurance benefits, such as Social Security, and also prohibit him from paying into such systems.
- The Amish faith requires its members to provide for the elderly and needy within their own community.
- From 1970 to 1977, Lee employed several other Amish individuals in his business.
- During this period, Lee failed to withhold social security taxes from his employees' wages and also failed to pay the employer's share of social security taxes.
Procedural Posture:
- The Internal Revenue Service assessed Edwin Lee more than $27,000 for unpaid social security taxes.
- Lee paid $91 of the assessment, representing the amount owed for one quarter.
- Lee sued the United States in the U.S. District Court for the Western District of Pennsylvania, seeking a refund and claiming the tax violated his First Amendment rights.
- The District Court found the tax statutes unconstitutional as applied to Lee and ruled in his favor.
- The United States filed a direct appeal of the District Court's decision to the Supreme Court of the United States.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the imposition of social security taxes on employers who object on religious grounds to paying the tax and receiving benefits violate the Free Exercise Clause of the First Amendment?
Opinions:
Majority - Chief Justice Burger
No, the imposition of social security taxes on employers who object on religious grounds does not violate the Free Exercise Clause. While the compulsory participation in the social security system does interfere with the sincere religious beliefs of the Amish, not all burdens on religion are unconstitutional. A limitation on religious liberty is justified if it is essential to accomplish an overriding governmental interest. Here, the government's interest in the mandatory and continuous participation required for the fiscal vitality of the comprehensive national social security system is very high. Allowing myriad religious exemptions would undermine the system's soundness and would be difficult to administer. There is no principled way to distinguish this from other tax objections based on religion, and the tax system could not function if such challenges were permitted. Congress created a narrow, specific exemption for self-employed individuals in § 1402(g), and extending this exemption judicially to employers is not warranted, as it would impose the employer's religious beliefs on the statutory scheme applicable to employees.
Concurring - Justice Stevens
Concurring in the judgment. The Court's balancing test, which requires the government to show an 'overriding interest,' is the wrong standard; the burden should be on the objector to show a unique reason for an exemption from a neutral law of general applicability. Under the majority's test, Lee should have won, as accommodating the Amish would be administratively simple and fiscally minimal. However, the judgment is correct because allowing this exemption would create a risk of having to process a 'myriad of other claims' and would entangle the government in evaluating the merits of different religious beliefs, which raises Establishment Clause concerns. The proper holding is that there is virtually no room for a constitutionally required exemption on religious grounds from a valid, neutral tax law of general application.
Analysis:
This decision establishes the significant power of the government's interest in a uniform tax system when weighed against free exercise claims. It signals that neutral, generally applicable laws, especially in the context of taxation, will almost always withstand First Amendment challenges based on religious objections. The Court's reluctance to expand a legislative exemption created by Congress reinforces a principle of judicial restraint. This case sets a high bar for future litigants seeking religious exemptions from broad, mandatory government programs, effectively limiting the scope of the Sherbert test in the tax context.
Unlock the full brief for United States v. Lee