Bowen v. Roy (1986)
Supreme Court Decisions on Religious Liberty
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Background Information
Native American members of the Abenaki who lived in Pennsylvania sought financial help under Aid for Families with Dependent Children and the Food Stamp programs. However, they objected to the requirement that children be issued a Social Security Number in order to be eligible.
Roy, one of the objecting parents, argued that it was part of his religion to believe that control over one's life was essential to spiritual purity and "becoming a holy person." Assigning a number to his daughter, who was named Little Bird of the Snow, would "rob her of her spirit" and prevent her from acquiring spiritual power as she grew up. A Social Security Number would put her, to a degree, under the power and control of the government.
As a result, these parents' AFDC benefits were terminated and their Food Stamp payments were reduced. The parents sued because they believed that the government had infringed on their rights to practice their religion. It was their position that they should not be held to the generally applicable rules in order to receive the same assistance as all other parents.
Court Decision
In an 8-1 decision written by Chief Justice Burger, the Surpeme Court ruled against the Abenaki parents and decided that the government was permitted to require beneficiaries of these programs to supply their Social Security numbers.
According to the Court's decision, the parents objection to the use of Social Security numbers meant that they wanted the government to arrange how it conducted its internal affairs according to their personal religious beliefs - that, however, has never been accepted as a legitimate position in First Amendment cases:
Never to our knowledge has the Court interpreted the First Amendment to require the Government itself to behave in ways that the individual believes will further his or her spiritual development or that of his or her family. The Free Exercise Clause simply cannot be understood to require the Government to conduct its own internal affairs in ways that comport with the religious beliefs of particular citizens.
As an analogy, the Court argued that the Abenaki had no more right to dictate that the government not use Social Security Numbers than it did to determine the color of the filing cabinets in which their government assistance or legal records are stored.
The Court concluded that there is no constitutional requirement that no burdens be placed on religion or religious belief. The need for applicants provide their Social Security numbers was found to be religiously neutral when used to facilitate the disbursement of payments. The Court had traditionally recognized that there is a distinction between government compulsion in religion and conditions placed on receiving government benefits.
In the enforcement of a facially neutral and uniformly applicable requirement for the administration of welfare programs reaching many millions of people, the Government is entitled to wide latitude.
Significance
This decision gave the government more latitude to restricting the beliefs of certain individuals, but only so long that it is done neutrally and to meet a legitimate interest. Thus, generally applicable rules could be imposed upon people even if they felt that their religion did not permit it. Key here, however, was that the rules were part of a voluntary program.
The wide variety of religious faiths in America means that it is impossible not encroaching on the rights of at least some of them at some time. No matter what rule you pick, it may be possible to find someone who objects to it. A blanket religious exemption to any rule would result in the essential elimination of all laws.
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