United States v. Lee (1982)

Background:

Edwin Lee was a member of the Old Order Amish, and employed several other Amish workers on his farm and in his carpentry shop. The Amish believe in living separately from many aspects of modern society, and place strong emphasis on members of their Amish community caring for one another instead of relying on government support or welfare programs. Due to these religious beliefs, Lee objected to participating in the Social Security system. He specifically refused to pay the employers Social Security taxes or withhold Social Security tax from his employees pay.

The Case:

Because Lee did not pay quarterly Social Security taxes, in 1978 the Internal Revenue Service (IRS) assessed and found approximately $27,000 in unpaid taxes. Lee paid the portion due for the first quarter of 1973 and sued for a refund. This was done due to the concept of sovereign immunity, which the United States is protected by, where to sue the government in federal court for a tax refund, a taxpayer generally must first pay the disputed tax and then file a claim.

Because the total tax assessment across all his employees for multiple years was approximately $27,000, Lee chose not to pay the entire sum. Instead, he made a "token" payment of $91, relying on the concept of the divisible tax doctrine. By paying this small, designated amount, Lee was able to satisfy the legal requirements to sue the IRS for a refund in the U.S. District Court. He used this lawsuit, which eventually reached the Supreme Court, to argue that the tax violated his First Amendment right to religious freedom. 

Debates From Each Side:

Lee, represented by Francis X. Caiazza, a local Pennsylvania lawyer, contested that because in the Amish religion it is a sin to not provide for the community’s elderly and needy citizens, paying the federal government for Social Security violates that provision of his religion by giving the responsibility of caring for the community to the government. He requested a religious exemption from these taxes, so he could freely practice his religion, which was protected as a constitutional right under the First Amendment.

On the opposing side, the United States, represented by Stuart A. Smith, an assistant to the Solicitor General, debated, Social Security depends on mandatory participation from employers and employees across the country, and by allowing religious exemptions, it would make the tax system difficult to administer and could threaten its financial stability. They pressed the idea, the government has a compelling interest in maintaining a uniform, nationwide tax system.

Verdict:

In a unanimous 9-0 vote, the Supreme Court ruled for the United States. The Court stated one must pay and withhold Social Security taxes, even despite religious beliefs. The Court agreed that Lee's Amish beliefs were sincere and that the law burdened his religious practice. Even so, the justices held that the government has a compelling interest in preserving a uniform Social Security tax system within the nation.

The Court elaborated, if employers could refuse to pay taxes whenever they had a religious objection, it would become nearly impossible to administer the nation's tax system fairly and effectively. Because Social Security relies on universal participation, religious exemptions were not constitutionally required. It was held, the Free Exercise Clause does not exempt individuals from complying with generally and broadly applicable tax laws, when the government has a compelling interest in enforcing them. 

Legacy:

This case reinforced the idea that while the First Amendment strongly protects religious beliefs, it does not always protect religiously motivated actions from neutral laws that apply to everyone as members of the nation. While not diminishing or demeaning the idea of freedom of religion, this ruling emphasizes the foundational ideology that the law must apply to all people equally. It was stated that if exemptions as such were made based on every religious practice, the law itself would be significantly harder to enforce while guaranteeing and acting with equality. This posed the question many still debate, on where the balance lies between individual religious liberty and the operation of essential government programs. This landmark case established important limits on the Free Exercise Clause of the First amendment, and continues to spark debate even today.