Mayo Found. for Med. Educ. & Research v. United States

Mayo Found. for Med. Educ. & Research v. United States

Opinion

 [*47]  Chief Justice Roberts delivered the opinion of the Court.

Nearly all Americans who work for wages pay taxes on those wages under [***594]  the Federal Insurance Contributions Act (FICA), which Congress enacted to collect funds for Social Security. The question presented in this case is whether doctors who serve as medical residents are properly viewed as “student[s]” whose service Congress has exempted from FICA taxes under 26 U.S.C. § 3121(b)(10).

Most doctors who graduate from medical school in the United States pursue additional education in a specialty to become board certified to practice in that field. Petitioners Mayo Foundation for Medical Education and Research, Mayo Clinic, and the Regents of the University of Minnesota (collectively Mayo) offer medical residency programs that provide  [*48]  such instruction. Mayo's residency programs, which usually last three to five years, train doctors primarily through hands-on experience. Residents often spend between 50 and 80 hours a week caring for patients, typically examining and diagnosing them, prescribing medication, recommending  [****8] plans of care, and performing certain procedures. Residents are generally supervised in this work by more senior residents and by faculty members known as attending physicians. In 2005, Mayo paid its residents annual “stipends” ranging between $41,000 and $56,000 and provided them with health insurance, malpractice insurance, and paid vacation time.

Mayo residents also take part in “a formal and structured educational program.” Brief for Petitioners 5 (internal quotation marks omitted). Residents are assigned [**709]  textbooks and journal articles to read and are expected to attend weekly lectures and other conferences. Residents also take written exams and are evaluated by the attending faculty physicians. But the parties do not dispute that the bulk of residents' time is spent caring for patients.

Through the Social Security Act and related legislation, Congress has created a comprehensive national insurance system that provides benefits for retired workers, disabled workers, unemployed workers, and their families. See United States v. Lee, 455 U.S. 252, 254, 258, and nn. 1, 7, 102 S. Ct. 1051, 71 L. Ed. 2d 127 (1982). Congress funds Social Security by taxing both employers and employees under FICA on the wages employees  [****9] earn. See 26 U.S.C. § 3101(a) (tax on employees); § 3111(a) (tax on employers). Congress has defined “wages” broadly, to encompass “all remuneration for employment.” § 3121(a) (2006 ed. and Supp. III). The term “employment” has a similarly broad reach, extending to “any service, of whatever nature, performed . . . by an employee for the person employing him.” § 3121(b).

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