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United States v. Lee (1982)

Religious Tax Exemptions: Social Security Taxes

When there is a conflict between a person's sincerely held religious beliefs and an important government program, which side should prevail? In this case, how should the courts choose between an Amish man's belief that paying Social Security taxes would entail denying his religion and the government's need for broad participation in the tax program?


Background Information

This case involved a conflict between the beliefs of the Old Order Amish and government regulations on employment and Social Security. The Amish regard the care of the sick and elderly to be one of their religious obligations; as a consequence, they believe that paying Social Security taxes (designed to care for the sick and elderly) would entail acknowledging that the government had that task rather than they. Thus, paying Social Security taxes would mean denying an important aspect of their faith.

Lee, an Amish employer, employed other Amish to work on his farm and in his carpentry shop, but failed to withhold social security taxes from his employees or to pay the employer's share of such taxes. The IRS assessed him for back taxes and Lee sued, arguing that the requirement to pay Social Security taxes infringed upon his right to the free exercise of his religion.

Court Decision

Although Congress had exempted Amish employees from participation in the Social Security program in order to accommodate their religious beliefs, the Supreme Court refused to extend this exemption by allowing Amish employers to also avoid Social Security taxes. Writing for a unanimous Court, Justice Burger offered two arguments as a basis for this decision. First, pointed out that the Congressional exemption was only for self-employed Amish, not Amish who employed others; therefore, that exemption could not be construed as being applicable here.

Second, although Burger agreed that Lee's religious beliefs were sincerely held, it simply was not true that all burdens on religion are necessarily unconstitutional. So long as the government can demonstrate a compelling interest, it could be permissible for it to create a limitation on religious liberty:

The tax system could not function if denominations were allowed to challenge it because tax payments were spent in a manner that violates their religious belief. Because the broad public interest in maintaining a sound tax system is of such a high order, religious belief in conflict with the payment of taxes affords no basis for resisting the tax.

Significance

Perhaps the most important point which came out of this decision was the principle that just because some law infringes upon religious liberty doesn't automatically mean that it is an unconstitutional violation of the Free Exercise Clause of the First Amendment. Perhaps a heavier burden lies with the government to demonstrate that the infringement should be allowed, but the fact of the matter is such demonstration is possible - so long as a compelling state interest can be argued for.

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