Home › Case briefs › Constitutional Law

Bowen v. Roy

Supreme Court of the United States · 1986 · Constitutional Law

Constitutional LawFree Exercise ClauseWelfare BenefitsSocial Security NumbersFree Exercisereligious accommodationSocial Security numbergovernment benefits

Facts

Stephen Roy and Karen Miller received AFDC and food stamp benefits but refused to provide a Social Security number for their daughter, Little Bird of the Snow, because Roy believed that obtaining and using such a number would rob her spirit and violate Native American religious beliefs. Federal law required applicants for these benefit programs to furnish Social Security numbers, and required state agencies to use those numbers in administering the programs. Pennsylvania terminated AFDC and medical benefits for the child and moved to reduce the household's food stamps. During trial it was discovered that a Social Security number had already been assigned to the child, and Roy then testified that use of the number, rather than mere issuance, would rob her spirit.

Issue

Does the Free Exercise Clause require the Government to accommodate a religious objection to statutory requirements that a Social Security number be provided by a welfare applicant and that the Government use that number in administering benefit programs? More specifically, may appellees obtain an exemption from the furnishing requirement and an injunction against governmental use of the number?

Rule

The Free Exercise Clause protects individuals from certain forms of governmental compulsion, but it does not give them a right to dictate the Government's internal procedures. Absent proof of an intent to discriminate against religion or particular religious beliefs, the Government satisfies the Free Exercise Clause when a neutral, uniformly applicable requirement for government benefits is a reasonable means of promoting a legitimate public interest.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Phoenix, Arizona, Lena Ortiz applies for a county rent-assistance program. She sincerely believes that storing her family in any digital database weakens her son’s spirit, so she asks a court to order the county to keep only handwritten paper files and to delete all electronic records about him.

How should the court rule on Lena’s Free Exercise claim seeking to control the county’s recordkeeping method?

Explanation. The majority drew a sharp distinction between burdens imposed on the claimant and demands that the government alter its own internal operations. A person may not use the Free Exercise Clause to require the government to conduct its internal affairs in a way that conforms to that person’s religious beliefs. The county’s choice to use electronic records is an internal administrative procedure, so the claim fails without any least-restrictive-means analysis.