United States v. Lee (1982)

United States v. Lee, 455 U.S. 252 (1982) was a United States Supreme Court case establishing precedent regarding the limits of free exercise of religious conscience by employers.

Background

The appellant, an Amish employer, sued the Federal Government of the United States following an assessment for unpaid Social Security taxes, claiming that the imposition of such taxes violated his freedom of conscience. The District Court had found in favor of the appellant.

Ruling

Chief Justice Warren Burger delivered the opinion of the Court, with Justices Brennan, White, Marshall, Blackmun, Powell, Rehnquist, and O'Connor, joining, and Justice Stevens separately concurring.

The Court's opinion held that the tax imposed on employers to support the social security system must be uniformly applicable to all, except if the United States Congress explicitly provides otherwise. The Court's majority opinion explained its reasoning:

The conclusion that there is a conflict between the Amish faith and the obligations imposed by the social security system is only the beginning, however, and not the end of the inquiry. Not all burdens on religion are unconstitutional. See, e. g., Prince v. Massachusetts, 321 U.S. 158 (1944); Reynolds v. United States, 98 U.S. 145 (1879). The state may justify a limitation on religious liberty by showing that it is essential to accomplish an overriding governmental interest…

Congress and the courts have been sensitive to the needs flowing from the Free Exercise Clause, but every person cannot be shielded from all the burdens incident to exercising every aspect of the right to practice religious beliefs. When followers of a particular sect enter into commercial activity as a matter of choice, the limits they accept on their own conduct as a matter of conscience and faith are not to be superimposed on the statutory schemes which are binding on others in that activity. Granting an exemption from social security taxes to an employer operates to impose the employer's religious faith on the employees.^[1]

Use as precedent

Lee was cited during oral arguments in Burwell v. Hobby Lobby (2014), a case about how the contraception requirement in the Patient Protection and Affordable Care Act affected closely held for-profit corporations.^[2]

See also

• Religious Freedom Restoration Act

References

Further reading

• Rains, Mark Stanley (1982). "United States v. Lee: An Insensitive Approach to the Free Exercise of Religion". Tulsa Law Journal 18 (2): 305–37. 
• Duthu, N. Bruce (1982). "United States v. Lee: Limitations on the Free Exercise of Religion". Loyola Law Review 28 (4): 1216–24. 
• Stevens, John V.; Tulio, John G. (1984). "United States v. Lee, a Second Look". Journal of Church and State 26 (3): 455–72. doi:10.1093/jcs/26.3.455. 
• Patrick, John J.; Long, Gerald P., eds. (1999). "Document 43: United States v. Lee (1982)". Constitutional Debates on Freedom of Religion: A Documentary History. pp. 116–9. ISBN 978-0-313-30140-7. 
• Ferrara, Peter J. (2003). "Social Security and Taxes". In Kraybill, Donald B. The Amish and the State. pp. 125–43. ISBN 978-0-8018-7430-7. 
• Guinn, David E., ed. (2006). "Socioeconomic Regulation". Faith on Trial: Communities of Faith, the First Amendment, and the Theory of Deep Diversity. pp. 123–5. ISBN 978-0-7391-1764-4. 
• Vile, John R. (2010). "United States v. Lee, 455 U.S. 252; 102 S. Ct. 1051; 71L. Ed. 2d 127 (1982)". Essential Supreme Court Decisions: Summaries of Leading Cases in U.S. Constitutional Law. p. 237. ISBN 978-1-4422-0386-0.