Bowen v. Roy - 476 U.S. 693, 106 S. Ct. 2147 (1986)

Rule:

The statutory requirement that welfare benefit applicants provide a social security number is wholly neutral in religious terms and uniformly applicable. The administrative requirement does not create any danger of censorship or place a direct condition or burden on the dissemination of religious views. It does not intrude on the organization of a religious institution or school. It may indeed confront some applicants for benefits with choices, but in no sense does it affirmatively compel appellees, by threat of sanctions, to refrain from religiously motivated conduct or to engage in conduct that they find objectionable for religious reasons.

Facts:

Appellees, Stephen J. Roy and Karen Miller applied for and received benefits under the Aid to Families with Dependent Children program and the Food Stamp program. Appellees refused, however, to comply with the federal statutory requirements that participants in those programs furnish the state welfare agencies who administer the programs with their Social Security numbers and those of each member of their household as a condition of receiving benefits, and that each state agency utilizes those numbers in administering the programs. Appellees contended that obtaining a Social Security number for their 2-year-old daughter would violate their Native American religious beliefs. Thereafter, the Pennsylvania Department of Public Welfare terminated AFDC benefits payable to appellees on the child's behalf and instituted proceedings to reduce the level of food stamps that the appellees' household was receiving.  Appellees then filed an action in Federal District Court, claiming that the Free Exercise Clause of the First Amendment entitled them to an exemption from the Social Security number requirements, and requesting injunctive and other relief. 

Issue:

Were the appellees entitled to an exemption from the Social Security number requirement?

Answer:

No.

Conclusion:

The court found that the requirement did not violate the Free Exercise Clause of U.S. Const. amend. I, and that it did not require appellants to conduct their internal affairs in ways that comported with appellees' religious beliefs. The court further held that appellants' use of the social security number did not impair appellees' freedom to believe, express, and exercise their religion. The court ruled that appellants met their burden when they demonstrated that the requirement was neutral and uniform in its application and was a reasonable means of promoting a legitimate public interest. The social security number requirement was facially neutral and applied to all applicants for the benefits involved. The court then remanded the case for further proceedings because the requirement was a reasonable means of providing appellees' benefits.