holding that the federal government’s “interest in assuring mandatory and continuous participation in and contribution to the social security system is very high” because such participation “is indispensable to the fiscal vitality of the social security system”
How later courts described this case
- holding that the federal government’s “interest in assuring mandatory and continuous participation in and contribution to the social security system is very high” because such participation “is indispensable to the fiscal vitality of the social security system”
- finding that the accommodation of religious conflicts with the tax system is not constitutionally-mandated because of the likelihood that a "myriad" of individual exemptions, when aggregated together, would unduly interfere with the system as a whole
- stating that “followers of a particular sect” may sometimes be subject to “statutory schemes which are binding on others” when they “enter into commercial activity as a matter of choice,” notwithstanding the limits of their own conscience and faith
- holding, in a pre- RFRA context, that “[b]ecause 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”
Written by the judges who cited it.
Distinguished
Distinguished by United States v. Philadelphia Yearly Meeting of the Religious Society of Friends, 753 F. Supp. 1300 (1990)
455 U.S. 252, 102 S.Ct. 1051, 71 L.Ed.2d 127 (1982), was distinguishable, the Yearly Meeting argued, because employer Lee sought an outright exemption, not only from withholding his employee’s taxes but also from paying taxes owed by him.
The opinion
Justice Stevens,
concurring in the judgment.
The clash between appellee’s religious obligation and his civic obligation is irreconcilable. He must violate either an Amish belief or a federal statute. According to the Court, the religious duty must prevail unless the Government shows *262 that enforcement of the civic duty “is essential to accomplish an overriding governmental interest.” Ante, at 257-258. That formulation of the constitutional standard suggests that the Government always bears a heavy burden of justifying the application of neutral general laws to individual conscientious objectors. In my opinion, it is the objector who must shoulder the burden of demonstrating that there is a unique reason for allowing him a special exemption from a valid law of general applicability.
Congress already has granted the Amish a limited exemption from social security taxes. See 26 U. S. C. § 1402 (g). As a matter of administration, it would be a relatively simple matter to extend the exemption to the taxes involved in this case. As a matter of fiscal policy, an enlarged exemption probably would benefit the social security system because the nonpayment of these taxes by the Amish would be more than offset by the elimination of their right to collect benefits. In view of the fact that the Amish have demonstrated their capacity to care for their own, the social cost of eliminating this relatively small group of dedicated believers would be minimal. Thus, if we confine the analysis to the Government’s interest in rejecting the particular claim to an exemption at stake in this case, the constitutional standard as formulated by the Court has not been met.
The Court rejects the particular claim of this appellee, not because it presents any special problems, but rather because of the risk that a myriad of other claims would be too difficult to process. The Court overstates the magnitude of this risk because the Amish claim applies only to a small religious community with an established welfare system of its own. 1 *263 Nevertheless, I agree with the Court’s conclusion that the difficulties associated with processing other claims to tax exemption on religious grounds justify a rejection of this claim. 2 I believe, however, that this reasoning supports the adoption of a different constitutional standard than the Court purports to apply.
The Court’s analysis supports a holding that there is virtually no room for a “constitutionally required exemption” on religious grounds from a valid tax law that is entirely neutral in its general application. 3 Because I agree with that holding, I concur in the judgment.
The Amish claim is readily distinguishable from the typical claim to an exemption from general tax obligations on the ground that the taxpayer objects to the government’s use of his money; in the typical case the taxpayer is not in any position to supply the government with an equivalent substitute for the objectionable use of his money.
In my opinion, the principal reason for adopting a strong presumption against such claims is not a matter of administrative convenience. It is the overriding interest in keeping the government — whether it be the legislature or the courts — out of the business of evaluating the relative merits of differing religious claims. The risk that governmental approval of some and disapproval of others will be perceived as favoring one religion over another is an important risk the Establishment Clause was designed to preclude.
Today’s holding is limited to a claim to a tax exemption. I believe, however, that a standard that places an almost insurmountable burden on any individual who objects to a valid and neutral law of general applicability on the ground that the law proscribes (or prescribes) conduct that his religion prescribes (or proscribes) better explains most of this Court’s holdings than does the standard articulated by the Court today. See, e. g., Gillette v. United States, 401 U. S. 437 (selective service laws); Braunfeld v. Brown, 366 U. S. 599 (Sunday closing laws); Prince v. Massachusetts, 321 U. S. 158 (child labor laws); Jacobson v. Massachusetts, 197 U. S. 11 (compulsory vaccination laws); Reynolds v. United States, 98 U. S. 145 (polygamy law). The principal exception is Wisconsin v. Yoder, 406 U. S. 205 , in which the Court granted the Amish an exemption from Wisconsin’s compulsory school-attendance law by actually applying the subjective balancing approach it purports to apply today. The Court’s attempt to distinguish Yoder is unconvincing because precisely the same religious interest is implicated in both cases, and Wisconsin’s interest in requiring its children to attend school until they reach the age of 16 is surely not inferior to the federal interest in collecting these social security taxes.
There is also tension between this standard and the reasoning in Thomas v. Review Bd. of Indiana Employment Security Div., 450 U. S. 707 , and *264 Sherbert v. Verner, 374 U. S. 398 . Arguably, however, laws intended to provide a benefit to a limited class of otherwise disadvantaged persons should be judged by a different standard than that appropriate for the enforcement of neutral laws of general applicability. Cf. Harris v. McRae, 448 U. S. 297, 349-357 (Stevens, J., dissenting). A tax exemption entails no cost to the claimant; if tax exemptions were dispensed on religious grounds, every citizen would have an economic motivation to join the favored sects. No comparable economic motivation could explain the conduct of the employees in Sherbert and Thomas . In both of those cases changes in work requirements dictated by the employer forced the employees to surrender jobs that they would have preferred to retain rather than accept unemployment compensation. In each ease the treatment of the religious objection to the new job requirements as though it were tantamount to a physical impairment that made it impossible for the employee to continue to work under changed circumstances could be viewed as a protection against unequal treatment rather than a grant of favored treatment for the members of the religious sect. In all events, the decision in Thomas was clearly compelled by Sherbert .