Bob_Jones_University_V_United_States_of_America

Assignment 4, September 23, Diahann Jacquez Case: Bob Jones University v United States (1983) Cite: 461 U.S. 574 Facts: Bob Jones University was dedicated to "fundamentalist Christian beliefs" which included prohibitions against interracial dating and marriage. In 1970, the Internal Revenue Service (IRS) changed its formal policy to adopt a district court decision that prohibited the IRS from giving tax-exempt status to private schools engaging in racial discrimination. The IRS believed that the University's policies amounted to racism and revoked its tax-exempt status. The University claimed that the IRS had violated their rights under the Religion Clauses of the First Amendment. The University was notified November 30, 1970 that the IRS was planning on revoking its tax exempt status as a "religious, charitable. . . or educational" institution. In response, the University filed suit. The IRS again notified the University on April 16, 1975 of the proposed revocation. Officially, the IRS revoked the University's tax exempt status on January 19, 1976. The University paid $21 in unemployment taxes for one employee for tax year 1975 and then filed for a refund in the United States District Court for the District of South Carolina. The Government counterclaimed for unpaid federal unemployment taxes for the taxable years 1971 through 1975, in the amount of $489,675.59, plus interest. After paying a portion of the federal unemployment taxes the University filed a refund action in Federal District Court. The Government counterclaimed for unpaid taxes for that and other taxable years. Holding that the IRS exceeded its powers in revoking the University's tax-exempt status and violated the University's rights under the Religion Clauses of the First Amendment, the District Court ordered the IRS to refund the taxes paid and rejected the counterclaim. The Court of Appeals reversed the decision. The Law in Question The court is asked to interpret the following: Can the government prohibit race discrimination at the expense of the First Amendment's Free Exercise Clauses' The Process The Supreme Court argued the following: By taking away the university’s tax-exempt status, the government is enforcing a standard for admissions and educational policies required to obtain tax-exempt status. The 14th Amendment guarantee of equal protection should take precedence over 1st Amendment rights in this case. Lower courts have repeatedly upheld the IRS’ new interpretation of the tax code which requires that all tax-exempt organizations be charitable, among other things. An organization cannot be considered charitable if it violates public policy by practicing racial discrimination. The courts have repeatedly backed the IRS’ power to make decisions and enforce tax codes without it being bound by the rules of a formal court of law. The Question before the Court Do nonprofit private schools that prescribe and enforce racially discriminatory admissions standards on the basis of religious doctrine, qualify as tax-exempt organizations under 501(c) (3) of the Internal Revenue Code of 1954' The Answer No The Reasoning Supreme Court Chief Justice Warren E. Burger stated in his final opinion of the case that the Internal Revenue Service was correct in its original decision to revoke the tax-exempt status of Bob Jones University and the Goldsboro Christian School. The institutions did not meet the requirement by providing “beneficial and stabilizing influences in community life” to be supported by taxpayers with a special tax status. The schools failed to meet this requirement due to their discriminatory practices and policies. Justice Burger also addressed the long history during which Congress gave the IRS power to make decisions without a court proceeding. He concluded that in this case, the demands of the 14th Amendment superseded those of the 1st Amendment. Burger found the “governmental interest at stake” in the case–namely, “eradicating racial discrimination in education”–to be “compelling.” He concluded that a compelling “governmental interest substantially outweighs whatever burden denial of tax benefits places on petitioners’ exercise of their religious beliefs.” Dissents/Concurrences The Supreme Court votes were as follows: 8 votes for the United States, 1 vote against. Significance Bob Jones University v. United States is significant based on the Court’s decision that racial discrimination in education violated a fundamental national public policy. The government may justify a limitation on religious liberties by showing it is necessary to accomplish an overriding governmental interest. Prohibiting racial discrimination was such a governmental interest. The Court found that not all issues with regard to religion are unconstitutional.