The United States v. Seeger case in 1964 revolved around the interpretation of a clause in the Universal Military Training and Service Act, which exempted from military service those individuals who objected to war due to their "religious training and belief." Daniel Seeger was one such individual who refused induction into the armed forces on religious grounds, although he did not believe in a Supreme Being as required by law at that time. The U.S. Supreme Court ruled unanimously (8-0) that his objection was valid under this act despite his lack of traditional religious beliefs. The court expanded its definition of religion beyond traditional or orthodox religions, stating it also includes sincere and meaningful beliefs occupying a place parallel to that filled by God for adherents of many conventional faiths.

In the dissenting opinion for United States v. Seeger, Justice Clark argued that the majority's interpretation of "Supreme Being" was too broad and inconsistent with Congressional intent. He believed that Congress intended to limit conscientious objector status to those who held traditional religious beliefs in a Supreme Being, not simply deeply-held moral or ethical convictions. By expanding this definition, he felt the court was overstepping its bounds and effectively rewriting legislation - a power reserved for Congress alone. Furthermore, he expressed concern about how such an expansive interpretation could be consistently applied by draft boards across the country without clear guidelines on what constitutes a belief in a "Supreme Being".