- Date:
- June 30, 2014
- Location:
- United States
Burwell v. Hobby Lobby Stores, Inc.
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What is the Burwell v. Hobby Lobby Stores, Inc. case about?
The Burwell v. Hobby Lobby Stores, Inc. case was a legal dispute where the Supreme Court ruled (5â4) in 2014 that the Religious Freedom Restoration Act (RFRA) allows closely held for-profit corporations to deny legally required coverage of certain contraceptive drugs in their employee health insurance plans based on religious beliefs.
Hobby Lobby, owned by the Green family, argued that a regulation under the Patient Protection and Affordable Care Act (PPACA) requiring coverage of all FDA-approved contraceptive methods infringed upon their religious freedom. The Greens believed that some of these methods were against their Christian faith, and providing coverage would be equal to facilitating abortion.
The court embraced the view that closely held for-profit corporations are legal "persons" under the RFRA and can exercise religion. The Supreme Court determined that the mandate was a substantial burden on Hobby Lobby's religious exercise and that the government had not used the least restrictive means to further its interest.
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Who were the main parties involved in this case?
Burwell v. Hobby Lobby Stores, Inc. was a legal case involving several parties. The plaintiffs were David and Barbara Green, their children, and the for-profit corporations they owned, including Hobby Lobby and Mardel Christian & Education Stores, Inc. The defendants included Kathleen Sebelius, then secretary of health and human services, and other government officials. After Sylvia Burwell's confirmation as secretary of health and human services in June 2014, the case name was changed to Burwell v. Hobby Lobby Stores, Inc. In her dissenting opinion, Justice Ruth Bader Ginsburg said that the exemption sought by Hobby Lobby and Conestoga would override significant interests of the corporationsâ employees and covered dependents and would deny legions of women access to contraceptive coverage.
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What issues led to the disagreement in this case?
The central issue in Burwell v. Hobby Lobby Stores, Inc. was whether the Religious Freedom Restoration Act (RFRA) of 1993 allowed closely held, for-profit corporations to deny legally required coverage of certain contraceptives in their employees' health insurance plans based on religious objections.
Hobby Lobby's owners, the Greens, believed that four of the FDA-approved contraceptive methods were abortifacients, and providing coverage for them would violate their Christian faith. They argued that the mandate was a "substantial burden" on their religious exercise, violating the RFRA and the free-exercise clause of the First Amendment. The Supreme Court ultimately held that the mandate violated the statutory rights of the corporations and their owners under the RFRA.
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How did the Affordable Care Act relate to this court case?
Burwell v. Hobby Lobby Stores, Inc. was a Supreme Court case addressing whether the Affordable Care Act (ACA)'s mandate requiring employer health insurance to cover contraception violated the Religious Freedom Restoration Act (RFRA).
Hobby Lobby argued that, as a closely held company, providing such coverage conflicted with the owners' religious beliefs because they believed certain contraceptives were abortifacients. The Supreme Court ruled 5â4 in favor of Hobby Lobby, stating that the RFRA protects for-profit corporations' religious freedom, allowing them to deny contraception coverage based on religious grounds. The Court held that the contraceptive mandate substantially burdened the company's religious exercise, violating the RFRA.
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What did the Supreme Court decide in the Burwell v. Hobby Lobby case?
In Burwell v. Hobby Lobby Stores, Inc. (2014), the Supreme Court ruled that the Religious Freedom Restoration Act (RFRA) of 1993 was violated when Hobby Lobby Stores, a for-profit corporation, was required to provide health insurance coverage for all contraceptive methods approved by the FDA, as mandated by the Affordable Care Act (ACA).
The owners of Hobby Lobby believed that four of those methods were abortifacients (abortion inducers) and that providing coverage for them would be inconsistent with their Christian faith. The court held that the RFRA prohibits the government from substantially burdening a person's exercise of religion, and that the contraceptive mandate constituted such a burden.
In her dissenting opinion, Justice Ruth Bader Ginsburg asserted that the courtâs decision ignored the disadvantages that religion-based opt-outs impose on others.
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How did the decision affect other companies and employees in the United States?
The Supreme Court's decision in Burwell v. Hobby Lobby Stores, Inc. allowed closely held, for-profit corporations to deny contraception coverage to employees based on religious beliefs.
Justice Ruth Bader Ginsburg, in her dissent, argued the decision's "startling breadth" could allow companies to opt out of any law conflicting with their religious beliefs (except tax laws), potentially harming employees by denying them contraceptive coverage. Ginsburg also warned that the ruling could lead to more corporations seeking religious exemptions from various regulations.
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Burwell v. Hobby Lobby Stores, Inc., legal case in which the U.S. Supreme Court held (5â4) on June 30, 2014, that the Religious Freedom Restoration Act (RFRA) of 1993 permits for-profit corporations that are closely held (e.g., owned by a family or family trust) to refuse, on religious grounds, to pay for legally mandated coverage of certain contraceptive drugs and devices in their employeesâ health insurance plans. In so ruling, the court embraced the view that closely held for-profit corporations are legal âpersonsâ under the RFRA and are therefore capable of exercising religion.
Background
Burwell v. Hobby Lobby Stores, Inc. was a consolidation of two cases, originally called Sebelius v. Hobby Lobby Stores, Inc. and Conestoga Wood Specialties Corporation v. Sebelius; the case names were changed to Burwell v. Hobby Lobby Stores, Inc. and Conestoga Wood Specialties Corporation v. Burwell, respectively, following the confirmation of Sylvia Burwell as secretary of health and human services in June 2014. The former case arose in 2012 when David and Barbara Green, their children, and the for-profit corporations they ownedâHobby Lobby, Inc. (an arts-and-crafts retailer) and Mardel Christian & Education Stores, Inc. (a chain of Christian bookstores)âfiled suit in U.S. district court, naming Kathleen Sebelius, then secretary of health and human services, and others as defendants. The individual plaintiffs (the Greens) alleged that the imminent enforcement of a regulation issued by the U.S. Department of Health and Human Services (HHS) pursuant to the Patient Protection and Affordable Care Act (2010; PPACA) would infringe their rights under the RFRA, which prohibited the government from âsubstantially burden[ing] a personâs exercise of religionâ unless âapplication of the burdenâŠis in furtherance of a compelling governmental interestâ and is âthe least restrictive means of furthering thatâŠinterest.â The Greens also contended that the regulation would violate the free-exercise clause of the First Amendment (âCongress shall make no lawâŠprohibiting the free exercise [of religion]â).
Eventually known as the contraceptive mandate, the regulation required companies with 50 or more employees to provide insurance coverage of the 20 contraceptive methods then approved by the Food and Drug Administration (FDA). Despite scientific consensus to the contrary, the Greens believed that four of those methodsâtwo types of âmorning afterâ pills and two types of intrauterine devices (IUDs)âwere abortifacients (abortion inducers). On that basis they also believed that providing coverage of those methods in their employeesâ health insurance plans would be tantamount to facilitating abortion and therefore inconsistent with the tenets of their Christian faith. They argued that, because HHS imposed considerable penalties (regulatory taxes of $100 per day per affected employee) on companies whose health insurance plans failed to provide âbasic essential coverage,â including contraceptive coverage, the contraceptive mandate constituted a âsubstantial burdenâ on their exercise of religionâa violation of both the RFRA and the free-exercise clause.
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The district court denied the Greensâ motion for a preliminary injunction against enforcement of the mandate, as did a two-judge panel of the Court of Appeals for the Tenth Circuit. After Supreme Court Justice Sonia Sotomayor, acting in her capacity as Circuit Justice for the Tenth Circuit, denied emergency injunctive relief, the Tenth Circuit granted the Greensâ motion for an expedited en banc hearing (before all judges of the court). In its ruling, the appeals court found that for-profit corporations âcan be âpersonsâ exercising religion for purposes of the [RFRA]â and that âFree Exercise rights may extend to some for-profit organizations.â The Tenth Circuit also held that âthe contraceptive-coverage requirement constitutes a substantial burden on Hobby Lobby and Mardelâs exercise of religionâ; that the corporations were likely to suffer irreparable harm unless the requirement were enjoined; and that, even assuming that the governmentâs interest in providing women with free access to the contraceptives in question was compelling, the government had failed to show that the contraceptive mandate was the least-restrictive means of furthering that interest. It accordingly reversed the district courtâs judgment and remanded the case for further consideration of the plaintiffsâ motion for a preliminary injunction.
The respondents then appealed to the U.S. Supreme Court, which agreed to hear the case in combination with a similar appeal, Conestoga Wood Specialties Corporation v. Sebelius, involving the Mennonite owners of a woodworking company. In that case the Court of Appeals for the Third Circuit had held that âfor-profit, secular corporations cannot engage in religious exerciseâ for the purposes of the RFRA or the free-exercise clause. The Supreme Court heard oral arguments on March 25, 2014.
