Bob Jones v. United States

Bob Jones University v. United States (1983) was the Supreme Court case that settled the decade-long legal battle over whether the IRS had the authority to deny tax-exempt status to private religious schools that practiced racial discrimination. The Court ruled 8-1 in favor of the IRS, with only Justice William Rehnquist dissenting. Chief Justice Warren Burger's majority opinion held that an institution seeking tax-exempt status must serve a public benefit and must not be contrary to established public policy. Since eliminating racial discrimination in education was a compelling governmental interest, the IRS had the authority — indeed the obligation — to deny exemptions to discriminatory institutions, even when those institutions claimed religious justification for their policies. Bob Jones University had prohibited interracial dating and marriage as a matter of official policy, grounded in its interpretation of biblical teaching on the separation of races. The university had been fighting the IRS since 1970, when its exemption was first threatened under the Green v. Connally standard. It eventually lost its exemption in 1976 and spent years in litigation. The Reagan administration's involvement made the case infamous. In January 1982, the Reagan White House announced it would reverse IRS policy and restore tax-exempt status to Bob Jones University and Goldsboro Christian Schools, both of which had explicitly discriminatory policies. The decision was made in part to satisfy Religious Right constituencies who had been chafing under the IRS rules. The resulting public outcry — and the revelation that the administration had coordinated with segregationist institutions — was severe enough that Reagan was forced to reverse course within days, asking Congress to legislate what the administration had just tried to grant by executive action. Congress refused. The episode exposed, in unusually stark terms, the racial politics embedded in the Religious Right coalition. The 8-1 decision against Bob Jones University in May 1983 was a definitive legal defeat, though it came after the movement had already achieved its major political victory: the Reagan presidency.

Documented themes

• Christian Nationalism
• Anti-Democratic
• Political Strategy
• Race & Civil Rights

Connections to Bob Jones v. United States

• Bob Jones University influenced (1983) — Bob Jones University's decision to refuse compliance with IRS non-discrimination requirements and fight in court was the direct cause of the landmark Supreme Court case that bears its name. After the IRS revoked BJU's tax exemption in 1976, the university pursued litigation through the federal courts, arguing that the IRS lacked authority to deny exemptions on non-discrimination grounds and that doing so violated the university's First Amendment rights to religious exercise. The case was consolidated with a similar challenge from Goldsboro Christian Schools. The resulting Supreme Court decision, Bob Jones University v. United States (1983), definitively resolved the legal question — ruling 8-1 that the IRS had full authority to deny exemptions to racially discriminatory institutions — and set a precedent that has governed tax-exempt status and public policy requirements for nonprofit institutions ever since.
• Reagan Restores Bob Jones Tax Exemption influenced (1983) — The Reagan administration's January 1982 announcement that it would restore tax-exempt status to Bob Jones University and Goldsboro Christian Schools fundamentally altered the political and procedural context of the pending Supreme Court case. The administration notified the Court that it was withdrawing its defense of the IRS's position, requiring the Court to appoint an independent attorney — William T. Coleman Jr. — to argue in support of the IRS policy that the administration had just abandoned. The maneuver created an unusual situation in which the executive branch was nominally a party to a case it had decided not to defend. The resulting public controversy and Reagan's subsequent forced reversal heightened the case's national profile and made its outcome a referendum on whether the federal government would stand behind its non-discrimination policy. The 8-1 ruling in May 1983 provided the definitive answer.

Sources

• Bad Faith: Race and the Rise of the Religious Right — Randall Balmer (2021), pp. 80-105
• The Real Origins of the Religious Right — Randall Balmer (2014), pp. Politico Magazine, May 27, 2014
• White Evangelical Racism: The Politics of Morality in America — Anthea Butler (2021), pp. 80-95