United States v. Lee involved an Amish farmer’s contention that his religious beliefs precluded him from paying social security taxes or withholding them from the paychecks of his employees. The farmer sued in federal court for a refund of the taxes he paid. In its decision, the Supreme Court emphasized that not all burdens the government places on religion are unconstitutional. The government can justify a burden on religion so long as it is essential to achieving an overriding government interest. In this case, the Court found that maintenance of the social security system was an overriding interest, and allowing individual exemptions to social security taxes based on religion was impractical. The Court noted that the tax system simply could not function if it was susceptible to challenges on the grounds that certain expenditures were inconsistent with a particular individual’s religious beliefs. Thus, the requirement that employers withhold and pay social security taxes from their employees does not violate the Free Exercise Clause.
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