United States v. Seeger

Supreme Court of United States
380 U.S. 163 (1965)

ELI5:

Rule of Law:

For the purpose of statutory conscientious objector status, a 'religious training and belief' includes any sincere and meaningful belief that occupies a place in the life of its possessor parallel to that filled by the belief in God of those who are traditionally religious.

Facts:

Daniel Seeger was drafted into the armed forces and claimed conscientious objector status based on 'religious belief' and a 'faith in a purely ethical creed.'
Seeger stated he preferred to leave the question of belief in a Supreme Being open, citing his 'skepticism or disbelief in the existence of God' but affirming his 'devotion to goodness and virtue for their own sakes.'
Arno Jakobson was drafted and claimed conscientious objector status, stating a belief in a 'Supreme Being' as the 'Supreme Reality' and 'ultimately responsible for the existence of man.'
Jakobson defined religion as the 'sum and essence of one’s basic attitudes to the fundamental problems of human existence' and his primary religious law as 'no man ought ever to wilfully sacrifice another man’s life.'
Forest Britt Peter was drafted and claimed conscientious objector status, stating it depended on the definition of Supreme Being but that his moral code against taking human life was superior to his obligation to the state.
Peter attributed his beliefs to 'democratic American culture' and its philosophical traditions and said of his beliefs, 'you could call that a belief in the Supreme Being or God. These just do not happen to be the words I use.'

Procedural Posture:

Daniel Seeger was convicted in the U.S. District Court for the Southern District of New York for refusing induction after his conscientious objector claim was denied.
The U.S. Court of Appeals for the Second Circuit (intermediate appellate court) reversed Seeger's conviction.
Arno Jakobson was convicted in the U.S. District Court for the Southern District of New York for refusing induction after his claim was denied.
The U.S. Court of Appeals for the Second Circuit (intermediate appellate court) reversed Jakobson's conviction.
Forest Britt Peter was convicted in the U.S. District Court for the Northern District of California for refusing induction after his claim was denied.
The U.S. Court of Appeals for the Ninth Circuit (intermediate appellate court) affirmed Peter's conviction.
The U.S. Supreme Court granted certiorari in all three cases and consolidated them to resolve the legal questions presented.

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Issue:

Does the conscientious objector exemption in § 6(j) of the Universal Military Training and Service Act, which requires a 'belief in a relation to a Supreme Being,' exempt individuals whose sincere and meaningful opposition to war stems from beliefs that are not traditionally theistic but occupy a place in their lives parallel to that of a belief in God?

Opinions:

Majority - Justice Clark

Yes. The statutory requirement for conscientious objector status is met if a person holds a sincere and meaningful belief which occupies in their life a place parallel to that filled by the God of those traditionally qualifying for the exemption. Congress's use of 'Supreme Being' rather than 'God' was intended to broaden the scope of the exemption to include all religions, while excluding purely political, sociological, or philosophical views. The legislative history indicates the focus should be on the individual's sincere conviction, not their membership in a particular sect or adherence to orthodox theology. This interpretation avoids serious constitutional questions under the Establishment Clause by not preferring theistic religions over non-theistic ones. The beliefs of Seeger, Jakobson, and Peter, being sincere and occupying this central, parallel position in their lives, all qualify under this standard.

Concurring - Justice Douglas

Yes. The term 'Supreme Being' must be construed broadly to save the statute from being unconstitutional. A narrow interpretation that prefers traditional, theistic religions over others would violate the Free Exercise Clause and the equal protection component of the Fifth Amendment's Due Process Clause. To avoid this 'serious constitutional doubt,' the Court must interpret the statute to include the diverse religious beliefs present in the nation, such as those found in Hinduism and Buddhism, which have non-anthropomorphic and complex concepts of a supreme power. A sophisticated and tolerant Congress would not have intended a parochial definition, and therefore any sincere belief that fills the same role as a traditional belief in God is entitled to the exemption.

Analysis:

This case significantly broadened the legal definition of 'religion' for statutory purposes, shifting the inquiry from the content of a belief (theism) to its function and sincerity in an individual's life. By establishing the 'parallel position' test, the Court allowed non-theistic, but deeply held, ethical and moral belief systems to qualify for conscientious objector status. This functional approach not only expanded the scope of the exemption but also served as a key example of the doctrine of constitutional avoidance, where the Court interprets a statute in a way that prevents it from having to decide a difficult constitutional question, in this case, a potential violation of the First Amendment's religion clauses.

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