lee argued november decided february appellee farmer carpenter member old order amish believe religiously based obligation provide fellow members kind assistance contemplated social security system certain years employed amish work farm carpentry shop appellee failed withhold social security taxes employees pay employer share taxes believed payment taxes receipt benefits violate amish faith internal revenue service assessed unpaid taxes appellee paid certain amount sued federal district refund claiming imposition taxes violated first amendment free exercise religion rights employees district held statutes requiring appellee pay social security taxes unconstitutional applied basing holding exempts social security taxes religious grounds amish others first amendment held exemption provided available individuals apply employers employees hence appellee employees within provisions imposition social security taxes unconstitutional applied persons appellee object religious grounds receipt public insurance benefits payment taxes support public insurance funds pp conflict amish faith obligations imposed social security system burdens religion unconstitutional state may justify limitation religious liberty showing essential accomplish overriding governmental interest pp widespread individual voluntary coverage social security undermine soundness social security system make system almost contradiction terms difficult impossible administer pp difficult accommodate social security system myriad exceptions flowing wide variety religious beliefs amish wisconsin yoder distinguished principled way purposes case distinguish general taxes imposed social security act tax system function denominations allowed challenge tax payments spent manner violates religious belief broad public interest maintaining sound tax system high order religious belief conflict payment taxes affords basis resisting tax pp congress accommodated extent compatible comprehensive national program practices believe violation faith participate social security system followers particular sect enter commercial activity matter choice limits accept conduct matter conscience faith superimposed statutory schemes binding others activity granting exemption social security taxes employer operates impose employer religious faith employees tax imposed employers support social security system must uniformly applicable except congress explicitly provides otherwise pp burger delivered opinion brennan white marshall blackmun powell rehnquist joined stevens filed opinion concurring judgment post deputy solicitor general wallace argued cause briefs solicitor general lee former solicitor general mccree acting assistant attorney general murray stuart smith gary allen francis caiazza argued cause filed brief appellee william bentley ball phillip murren filed brief national committee amish religious freedom amicus curiae urging affirmance chief justice burger delivered opinion noted probable jurisdiction determine whether imposition social security taxes unconstitutional applied persons object religious grounds receipt public insurance benefits payment taxes support public insurance funds district concluded free exercise clause prohibits forced payment social security taxes payment taxes receipt benefits violate taxpayer religion reverse appellee member old order amish farmer carpenter appellee employed several amish work farm carpentry shop failed file quarterly social security tax returns required employers withhold social security tax employees pay employer share social security taxes internal revenue service assessed appellee excess unpaid employment taxes paid amount owed first quarter sued district western district pennsylvania refund claiming imposition social security taxes violated first amendment free exercise rights amish employees district held statutes requiring appellee pay social security unemployment insurance taxes unconstitutional applied supp noted amish believe sinful provide elderly needy therefore religiously opposed national social security system also accepted appellee contention amish religion prohibits acceptance social security benefits also bars contributions amish social security system district observed light beliefs congress accommodated amish members religious groups similar beliefs providing exemptions social security taxes holding based exemption statute first amendment appellee others fall within carefully circumscribed definition provided relieved paying employer share social security taxes unconstitutional infringement upon free exercise religion direct appeal judgment district taken pursuant ii exemption provided available individuals apply employers employees consequently appellee employees within express provisions thus exemption payment employer share social security taxes must come constitutionally required exemption preliminary inquiry determining existence constitutionally required exemption whether payment social security taxes receipt benefits interferes free exercise rights amish amish believe religiously based obligation provide fellow members kind assistance contemplated social security system although government challenge sincerity belief government contend payment social security taxes threaten integrity amish religious belief observance within judicial function judicial competence however determine whether appellee government proper interpretation amish faith ourts arbiters scriptural interpretation thomas review bd indiana employment security therefore accept appellee contention payment receipt social security benefits forbidden amish faith payment taxes receipt benefits violates amish religious beliefs compulsory participation social security system interferes free exercise rights conclusion conflict amish faith obligations imposed social security system beginning however end inquiry burdens religion unconstitutional see prince massachusetts reynolds state may justify limitation religious liberty showing essential accomplish overriding governmental interest thomas supra wisconsin yoder gillette sherbert verner social security system nationwide governmental interest apparent social security system serves public interest providing comprehensive insurance system variety benefits available participants costs shared employers employees social security system far largest domestic governmental program today distributing approximately billion monthly million americans design system requires support mandatory contributions covered employers employees mandatory participation indispensable fiscal vitality social security system idespread individual voluntary coverage social security undermine soundness social security program pt moreover comprehensive national social security system providing voluntary participation almost contradiction terms difficult impossible administer thus government interest assuring mandatory continuous participation contribution social security system high remaining inquiry whether accommodating amish belief unduly interfere fulfillment governmental interest braunfeld brown noted make accommodation religious action exercise state authority particularly delicate task resolution favor state results choice individual either abandoning religious principle facing prosecution difficulty attempting accommodate religious beliefs area taxation cosmopolitan nation made people almost every conceivable religious preference braunfeld supra long recognized balance must struck values comprehensive social security system rests complex actuarial factors consequences allowing religiously based exemptions maintain organized society guarantees religious freedom great variety faiths requires religious practices yield common good religious beliefs accommodated see thomas supra sherbert supra point accommodation radically restrict operating latitude legislature braunfeld supra unlike situation presented wisconsin yoder supra difficult accommodate comprehensive social security system myriad exceptions flowing wide variety religious beliefs obligation pay social security tax initially fundamentally different obligation pay income taxes difference theory least social security tax revenues segregated use furtherance statutory program principled way however purposes case distinguish general taxes imposed social security act example religious adherent believes war sin certain percentage federal budget identified devoted activities individuals similarly valid claim exempt paying percentage income tax tax system function denominations allowed challenge tax system tax payments spent manner violates religious belief see lull commissioner cert denied autenrieth cullen cert denied broad public interest maintaining sound tax system high order religious belief conflict payment taxes affords basis resisting tax iii congress accommodated extent compatible comprehensive national program practices believe violation faith participate social security system congress granted exemption religious grounds amish others confining exemption provided narrow category readily identifiable persons religious community welfare system distinguishable generality wage earners employed others congress courts sensitive needs flowing free exercise clause every person shielded burdens incident exercising every aspect right practice religious beliefs followers particular sect enter commercial activity matter choice limits accept conduct matter conscience faith superimposed statutory schemes binding others activity granting exemption social security taxes employer operates impose employer religious faith employees congress drew line exempting amish persons working amish employer tax imposed employers support social security system must uniformly applicable except congress provides explicitly otherwise accordingly judgment district reversed case remanded proceedings consistent opinion reversed remanded footnotes appellee also requested injunctive relief prevent commissioner internal revenue attempting collect unpaid balance assessments internal revenue code injunctive relief granted sparingly exceptional circumstances supp iii district therefore denied injunctive relief noted government attempt collect remaining payments relief requested supp appellee indicates scriptural basis belief provide house hath denied faith worse infidel timothy title provides part exemption individual may file application exemption tax imposed chapter member recognized religious sect division thereof adherent established tenets teachings sect division reason conscientiously opposed acceptance benefits private public insurance makes payments event death disability retirement makes payments toward cost provides services medical care including benefits insurance system established social security act order qualify exemption applicant must waive right social security benefits secretary health human services must find particular religious group makes sufficient provision dependent members precise basis district opinion clear recognized face apply appellee individual district nonetheless used language provide exemption appellee decision grant appellee exemption however appears based view statute unconstitutional applied consequently jurisdiction hear appeal see also american friends service committee instance asserted claim bizarre clearly nonreligious motivation entitled protection free exercise clause thomas review bd indiana employment security least one religious organization sought exemption see also henson commissioner member sai baba denied exemption although opposed insurance religious grounds faith provide dependent members social security act enacted provide supplementary retirement benefits following years coverage broadened cost system increased dramatically see abraham kopelman federal social security act amended provide insurance benefits retired workers auxiliaries retired workers survivors deceased workers coverage extended workers select employees previously excluded disability benefits added medicare benefits made available participants system national commission social security social security america future fiscal soundness social security system subject several studies congressional concern see congressional budget office paying social security funding options near term see follett town mccormick preacher entitled free taxes murdock pennsylvania district read extending present claims need decide whether free exercise clause compelled exemption provided congress grant exemption effort toward accommodation need decide whether congress district believed intended reach case conflicts establishment clause arise note statute compels contributions system way taxes compel anyone accept benefits indeed possible amish member upon qualifying social security benefits receive pass along amish fund parallel objectives us speculate whether ease mitigate perceived sin participation justice stevens concurring judgment clash appellee religious obligation civic obligation irreconcilable must violate either amish belief federal statute according religious duty must prevail unless government shows enforcement civic duty essential accomplish overriding governmental interest ante formulation constitutional standard suggests government always bears heavy burden justifying application neutral general laws individual conscientious objectors opinion objector must shoulder burden demonstrating unique reason allowing special exemption valid law general applicability congress already granted amish limited exemption social security taxes see matter administration relatively simple matter extend exemption taxes involved case matter fiscal policy enlarged exemption probably benefit social security system nonpayment taxes amish offset elimination right collect benefits view fact amish demonstrated capacity care social cost eliminating relatively small group dedicated believers minimal thus confine analysis government interest rejecting particular claim exemption stake case constitutional standard formulated met rejects particular claim appellee presents special problems rather risk myriad claims difficult process overstates magnitude risk amish claim applies small religious community established welfare system nevertheless agree conclusion difficulties associated processing claims tax exemption religious grounds justify rejection claim believe however reasoning supports adoption different constitutional standard purports apply analysis supports holding virtually room constitutionally required exemption religious grounds valid tax law entirely neutral general application agree holding concur judgment amish claim readily distinguishable typical claim exemption general tax obligations ground taxpayer objects government use money typical case taxpayer position supply government equivalent substitute objectionable use money opinion principal reason adopting strong presumption claims matter administrative convenience overriding interest keeping government whether legislature courts business evaluating relative merits differing religious claims risk governmental approval disapproval others perceived favoring one religion another important risk establishment clause designed preclude today holding limited claim tax exemption believe however standard places almost insurmountable burden individual objects valid neutral law general applicability ground law proscribes prescribes conduct religion prescribes proscribes better explains holdings standard articulated today see gillette selective service laws braunfeld brown sunday closing laws prince massachusetts child labor laws jacobson massachusetts compulsory vaccination laws reynolds polygamy law principal exception wisconsin yoder granted amish exemption wisconsin compulsory law actually applying subjective balancing approach purports apply today attempt distinguish yoder unconvincing precisely religious interest implicated cases wisconsin interest requiring children attend school reach age surely inferior federal interest collecting social security taxes also tension standard reasoning thomas review bd indiana employment security sherbert verner arguably however laws intended provide benefit limited class otherwise disadvantaged persons judged different standard appropriate enforcement neutral laws general applicability cf harris mcrae stevens dissenting tax exemption entails cost claimant tax exemptions dispensed religious grounds every citizen economic motivation join favored sects comparable economic motivation explain conduct employees sherbert thomas cases changes work requirements dictated employer forced employees surrender jobs preferred retain rather accept unemployment compensation case treatment religious objection new job requirements though tantamount physical impairment made impossible employee continue work changed circumstances viewed protection unequal treatment rather grant favored treatment members religious sect events decision thomas clearly compelled sherbert