Skip to main content

Payroll taxes on severance pay

United States v. Quality Stores

Updated Oct 18, 2026

In brief

Severance payments in this case count as FICA wages, and the Supreme Court overturned the Sixth Circuit's contrary ruling.

Where it stands
Decided

Decided 8-0 · March 25, 2014 · Opinion by Justice Kennedy

What it’s about
The dispute was whether severance pay to employees Quality Stores laid off counted as wages subject to federal Social Security and Medicare payroll taxes (FICA).
Who it affects
Quality Stores' severance payments at issue are subject to federal payroll taxes as FICA wages.

Summary: written with AI from the case record.

Illustration for United States v. Quality Stores, Inc.
Conceptual illustration · AI-generated

What it's about

The Supreme Court ruled that it did, overturned the Sixth Circuit, and sent the case back to that court (remanded).

FICA is the federal law behind Social Security and Medicare payroll taxes.

Question presented

Are severance payments for employees who were involuntarily terminated taxable under the Federal Insurance Contributions Act?

What the Court decided

Holding

The severance payments at issue are taxable wages for FICA purposes. 693 F. 3d 605, reversed and remanded.

Result
Reversed

The vote

  • Joined the judgment
  • Wrote an opinion
Majority · 8joined the Court's opinion
  1. Breyer
  2. Thomas
  3. Scalia
  4. Kennedywrote the opinion
  5. Ginsburg
  6. Sotomayor
  7. Roberts
  8. Alito
8 justices joined the judgment.

What's next

The case returns to the Sixth Circuit, which must proceed under the Supreme Court's ruling that these payments are FICA wages.

Documents

1

Docket activity

12
  • New analysis added

    Oct 18, 2026 · Court records

  • AI analysis generated: Case Briefing

    Oct 18, 2026 · Generated

  • New analysis added

    Oct 18, 2026 · Court records

  • AI analysis generated: Impact Analysis

    Oct 18, 2026 · Generated

  • AI analysis generated: Opinion Summary

    Oct 18, 2026 · Generated

Show 7 more
  • AI analysis generated: Decision Record

    Oct 18, 2026 · Generated

  • New analysis added

    Oct 18, 2026 · Court records

  • New analysis added

    Oct 18, 2026 · Court records

  • New analysis added

    Oct 18, 2026 · Court records

  • Case data updated: summary, question_presented, generation_metadata

    Oct 18, 2026 · Court records

  • Case data updated: question_presented, extraction_metadata

    Oct 18, 2026 · Court records

  • Opinion added: Quality Stores

    Mar 25, 2014 · Court records

Sources

Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.

Checked Oct 18, 2026Methodology

Court records and filings

Reporting and analysis