United States v. Lee (1982)

Summary

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.

United States v. Lee
Argued November 2, 1981
Decided February 23, 1982
Full case nameUnited States v. Lee
Citations455 U.S. 252 (more)
102 S. Ct. 1051; 71 L. Ed. 2d 127
ArgumentOral argument
Case history
Prior497 F. Supp. 180 (W.D. Pa. 1980)
Holding
The tax imposed on employers to support the Social Security System does not violate the Free Exercise Clause due to its need to be uniformly applicable and its accomplishment of an overriding governmental interest.
Court membership
Chief Justice
Warren E. Burger
Associate Justices
William J. Brennan Jr. · Byron White
Thurgood Marshall · Harry Blackmun
Lewis F. Powell Jr. · William Rehnquist
John P. Stevens · Sandra Day O'Connor
Case opinions
MajorityBurger, joined by Brennan, White, Marshall, Blackmun, Powell, Rehnquist, O'Connor
ConcurrenceStevens

Background edit

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 edit

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 edit

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 edit

References edit

  1. ^ United States v. Lee, 455 U.S. 252 (1982)
  2. ^ "Live Blog: Contraception Cases at Supreme Court". Wall Street Journal blogs. March 25, 2014. Retrieved March 25, 2014.

Further reading edit

  • 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. (ed.). 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.

External links edit

  • Text of United States v. Lee, 455 U.S. 252 (1982) is available from: Justia  Library of Congress  Oyez (oral argument audio)