Facts of the Case
Edwin Lee, a member of the Old Order Amish, employed several other Amish workers on his farm and in his carpentry shop. He did not pay quarterly social security taxes, and in 1978, the Internal Revenue Service (IRS) assessed $27,000 in unpaid taxes. Lee paid the portion due for the first quarter of 1973 and sued for a refund. Lee argued that the tax violated his First Amendment right to free exercise of religion. In the Amish religion, it is a sin not to provide for the community’s elderly and needy citizens. Lee argued that paying the federal government for Social Security violates that provision of his religion by giving the responsibility of caring for the elderly and needy to the government. The district court held that the Social Security tax was unconstitutional as applied. The court also noted that §1402(g) provides an exception to the social security tax for certain self employed individuals. The U.S. Supreme Court heard this case on direct appeal.
Questions
Can the U.S. government require payment of Social Security taxes from those who religiously object to the receipt of the attached benefits?
Conclusions
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Yes. In a unanimous decision, Chief Justice Warren Burger wrote the majority opinion reversing and remanding. The Supreme Court held that the §1402(g) exemption only applied to self-employed individuals, not employers and employees like those involved in this case. The Court held that the tax was not unconstitutional as applied. By becoming an employer, Lee entered into commercial activity and accepted certain limits on the exercise of his beliefs.
Justice John Paul Stevens wrote a concurrence, stating that the tax objector has the burden of showing that there is a unique reason for allowing an exemption from a valid law when the objectors religious obligation and civic obligation are irreconcilable.
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