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Not all burdens on religion are unconstitutional. The state may justify a limitation on religious liberty by showing that it is essential to accomplish an overriding governmental interest.
Appellee, a self-employed farmer and carpenter who was a member of the Old Order Amish religion, sued in the United States District Court for the Western District of Pennsylvania for a refund of the social security taxes paid by him pursuant to 26 USCS 3101 et seq. on account of his employment of other members of that religion on his farm and in his carpentry shop. Appellee claimed that the imposition of the taxes violated his First Amendment free exercise rights and those of his employees, because members of the Old Order Amish religion believed that there was a religiously based obligation to provide for their fellow members the kind of assistance contemplated by the social security system, and that therefore their religion prohibited acceptance of social security benefits and payment of social security taxes. The District Court held the statutes requiring the claimant to pay social security taxes unconstitutional as applied on the basis of both an exemption provided in 26 USCS 1402(g) for self-employed persons who conscientiously opposed acceptance of social security benefits and the First Amendment. On appeal, the government argued that the payment of social security taxes did not threaten the integrity of the Amish religious belief or observance.
Was the imposition of social security taxes unconstitutional as applied to persons who object on religious grounds to the receipt of public insurance benefits?
The Court held that the imposition of social security taxes was not unconstitutional as applied to such persons as appellee who objected on religious grounds to receipt of public insurance benefits and to payment of taxes to support public insurance funds. The Court noted that while there was a conflict between the Amish faith and the obligations imposed by the social security system, not all burdens on religion were unconstitutional. The state may justify a limitation on religious liberty by showing that it was essential to accomplish an overriding governmental interest. In this case, the Court held that, although compulsory participation in the social security system interfered with the employer's free exercise rights, the requirement was valid because it was essential to accomplish an overriding governmental interest. The Court found that it was necessary for the tax imposed on employers to support the social security system to be uniformly applicable to all, except as explicitly provided in 26 U.S.C.S. § 1402(g), which exempted the self-employed Amish but not all persons working for an Amish employer.