The United States v. Lee case in 1926 revolved around the issue of whether or not the federal government had the right to tax a religious institution, specifically a sect of Amish people who believed that insurance (including social security) was against their religion. The Supreme Court ruled in favor of Arthur Lee, an IRS agent, stating that while freedom of religion is important and protected by the Constitution, it does not exempt individuals from societal obligations such as paying taxes. This decision set a precedent for future cases involving conflicts between religious beliefs and legal responsibilities.

In the dissenting opinion for United States v. Lee, Justice Oliver Wendell Holmes Jr., joined by Justices Brandeis and Stone, argued that the majority's decision to allow a civil suit against government officials was an overreach of judicial power. They contended that such suits could potentially disrupt governmental operations and infringe upon executive authority. The dissenters believed that if there were any grievances with tax collection methods or amounts, they should be addressed through legislation rather than litigation. They also expressed concern about setting a precedent where every taxpayer could sue individual officers whenever they disagreed with their taxes - this would lead to chaos in administration of law and order. In essence, the minority opinion held firm on upholding sovereign immunity doctrine which protects federal employees from being sued in their official capacity unless explicitly allowed by Congress.