In the United States v. Lee case of 1981, the Supreme Court ruled that a self-employed Amish man named Edwin Lee must pay Social Security taxes despite his religious objections. The court held that while the First Amendment protects freedom of belief, it does not necessarily protect against conduct contrary to compelling government interest. In this case, maintaining an efficient and comprehensive Social Security system was deemed more important than accommodating individual religious practices conflicting with its operation. Therefore, even though Mr. Lee's religion prohibited him from accepting governmental benefits like social security insurance due to their belief in community reliance rather than external aid for support during old age or disability, he was still required by law to contribute towards these funds as part of his tax obligations.

In the dissenting opinion for United States v. Lee, Justice Stevens argued that the majority's decision to not grant a religious exemption from social security taxes to an Amish employer was inconsistent with previous rulings regarding First Amendment rights. He contended that if exemptions could be granted in cases such as Sherbert v. Verner and Wisconsin v. Yoder, they should also apply here because all three cases involve government actions infringing on individuals' religious practices. Furthermore, he disagreed with the majority's assertion that granting this exemption would make tax laws too complex or unmanageable; instead, he believed it is possible to accommodate these exceptions without undermining overall policy objectives or creating administrative difficulties.