Quick Summary
Hobby Lobby Stores, Inc. (plaintiff), a closely held corporation with Christian owners, contested an Affordable Care Act mandate requiring them to provide contraceptive coverage, citing religious objections under RFRA. The HHS (defendant) defended the mandate as essential for women’s health care.
The Supreme Court found that closely held corporations are protected by RFRA and that the mandate imposed a substantial burden on Hobby Lobby’s religious exercise without being the least restrictive means, thus ruling in favor of Hobby Lobby.
Facts of the Case
The company Hobby Lobby Stores, Inc. (plaintiff), owned by a Christian family with deeply held religious beliefs. The Affordable Care Act required Hobby Lobby to provide health insurance coverage for certain contraceptives. The family believed that providing coverage for specific contraceptives was tantamount to facilitating abortions, which conflicted with their religious convictions.
Hobby Lobby challenged the mandate under the Religious Freedom Restoration Act of 1993 (RFRA), arguing that the federal requirement imposed a substantial burden on their exercise of religion. The United States Department of Health and Human Services (HHS) (defendant) argued that the mandate served a compelling government interest and was the least restrictive means of achieving that interest.
Procedural History
- Hobby Lobby sought a preliminary injunction to prevent enforcement of the contraceptive mandate against them.
- The district court denied their request for an injunction.
- The Court of Appeals for the Tenth Circuit reversed the district court’s decision.
- The Supreme Court granted certiorari to resolve the conflicting opinions on the matter.
I.R.A.C. Format
Issue
Whether the HHS regulations that require closely held corporations to provide health-insurance coverage for contraceptives violate the owners’ rights under the Religious Freedom Restoration Act.
Rule of Law
The Religious Freedom Restoration Act of 1993 mandates that the government may not substantially burden a person’s exercise of religion unless it is in furtherance of a compelling governmental interest and is done through the least restrictive means.
Reasoning and Analysis
The Supreme Court analyzed whether closely held corporations fall under RFRA’s protections and concluded that they do. The Court found that the contraceptive mandate placed a substantial burden on the exercise of religion by requiring business owners to provide insurance coverage for contraceptives against their religious beliefs or face severe financial penalties.
While assuming that the government’s interest in providing cost-free access to contraceptives was compelling, the Court determined that the HHS mandate was not the least restrictive means of achieving this interest. The Court pointed out alternative methods, such as extending existing accommodations for nonprofit organizations with religious objections, that could provide contraceptive coverage without imposing a direct burden on the religious exercise of employers.
Conclusion
The Supreme Court held that enforcing the contraceptive mandate against Hobby Lobby violated RFRA because it was not the least restrictive means of achieving a compelling government interest. The decision affirmed the Tenth Circuit’s ruling and remanded the Third Circuit’s decision.
Dissenting Opinions
Justice Ginsburg, joined by Justice Sotomayor and partially by Justices Breyer and Kagan, dissented, arguing that for-profit corporations cannot exercise religion and warning of potential consequences for allowing religious beliefs to exempt businesses from legal obligations.
Key Takeaways
- Closely held corporations are considered ‘persons’ capable of exercising religion under RFRA.
- A government action that substantially burdens religious exercise must serve a compelling interest through the least restrictive means.
- The Supreme Court ruled that the ACA’s contraceptive mandate did not meet this standard when applied to closely held corporations with religious objections.
Relevant FAQs of this case
What determines whether a government mandate constitutes a 'substantial burden' on religious exercise?
A ‘substantial burden’ is established when an individual or entity is compelled to violate their deeply held beliefs or face significant penalties for refusal. This assessment considers the coerciveness of the mandate and the severity of the consequences for non-compliance.
- For example: A law requiring vegetarian restaurant owners to serve meat dishes, under threat of losing their business license, would constitute a substantial burden on their religious exercise if their vegetarianism is rooted in religious beliefs.
How can a court determine if a government interest is 'compelling' in cases involving religious freedom?
A government interest is ‘compelling’ when it is essential and of the highest order. Courts evaluate the significance, immediacy, and necessity of the legislation to ascertain if it justifies an override of religious freedoms.
- For example: A law mandating vaccinations to prevent widespread disease outbreaks may be deemed to serve a compelling interest due to the vital necessity of protecting public health.
What are alternative measures a government could consider as the 'least restrictive means' to avoid infringing on religious freedom?
The ‘least restrictive means’ test requires the government to pursue alternatives that achieve their goals without impinging on religious freedoms more than necessary. This could involve granting exemptions or crafting alternative solutions that accommodate religious beliefs.
- For example: Instead of enforcing a blanket mandate, providing an opt-out option for entities with credible religious objections could be a less restrictive means to accommodate those entities while still advancing the policy goal.
References
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- [justia] Burwell v. Hobby Lobby Stores, Inc., 573 U.S. 682 (2014)
- [google.scholar] Sylvia BURWELL, Secretary of Health and Human Services, et al., Petitioners v. HOBBY LOBBY STORES, INC., et al. Conestoga Wood Specialties Corporation et al., Petitioners v. Sylvia Burwell, Secretary of Health and Human Services, et al.