In the 1985 case Bowen, Secretary of Health and Human Services, et al. v. Roy et al., Stephen J. Roy and his wife contested the requirement to obtain a Social Security number for their two-year-old daughter in order to receive welfare benefits from the government. The Roys argued that obtaining a social security number for their daughter would violate their Native American religious beliefs as they believed it would rob her spirit. They claimed this violated their First Amendment rights to freely exercise religion. The Supreme Court ruled against them stating that while individuals have freedom of belief under the First Amendment, they do not necessarily have freedom of action when it comes to public policy matters like applying for welfare benefits which require a social security number by law. The court held that governmental requirements could infringe upon personal religious practices if there is a compelling state interest - in this case ensuring proper distribution of welfare benefits.

In the dissenting opinion for Bowen, Secretary of Health and Human Services, et al. v. Roy et al., Justice Brennan argued that the government's requirement for a Social Security number to be assigned to Little Bird of the Snow infringed upon her father's religious freedom. He contended that this case was not about whether or not Mr. Roy could control how the government used his daughter’s Social Security number but rather if he could prevent its issuance in order to protect his own spiritual integrity which he believed would be violated by such an act due to his Native American faith-based beliefs. Justice Brennan stated that while it is important for administrative convenience and efficiency, these should not override fundamental rights like religious freedom without compelling justification.