Dickinson v. United States

Summary

The Supreme Court held that there was no basis in fact for denying Dickinson's claim to a ministerial exemption from military service under the Universal Military Training and Service Act. The Court concluded that his uncontroverted evidence established that religious work was his vocation and that limited secular employment did not defeat the exemption. His conviction for refusing induction was reversed.

Holdings

1. A selective service classification denying a ministerial exemption cannot stand when the registrant's evidence places him prima facie within the statutory exemption and the record contains no affirmative evidence incompatible with that claim.
2. Limited secular employment does not by itself defeat a ministerial exemption when the registrant otherwise regularly performs ministerial activities as a vocation.
3. Part-time, occasional, or irregular preaching and teaching are insufficient; the claimant must clearly establish that religious activities are regularly performed as a vocation and satisfy the statutory criteria.

Questions Presented

1. Whether the selective service authorities had a basis in fact for denying Dickinson's claim to a ministerial exemption under § 6(g) of the Universal Military Training and Service Act.
2. Whether a registrant otherwise satisfying the ministerial-exemption criteria loses the exemption merely because he performs limited secular work.
3. Whether a selective service board may deny an exemption based solely on suspicion and speculation when the evidence supporting the registrant's claim is uncontroverted.

Disposition

reversed