How did Burwell v. Hobby Lobby Stores, Inc. affect contraceptive coverage in employee health insurance plans for companies with religious objections?

In Burwell v. Hobby Lobby Stores, Inc. (2014), the U.S. Supreme Court ruled that closely held for-profit corporations can refuse to provide insurance coverage for specific contraceptive methods if doing so violates the owners' religious beliefs.12

The Court held that such corporations are "persons" under the Religious Freedom Restoration Act (RFRA) and that the federal "contraceptive mandate"—part of the Patient Protection and Affordable Care Act—imposed a "substantial burden" on their religious exercise. Because the government failed to demonstrate that the mandate was the "least restrictive means" of ensuring access to contraception, the Court found the requirement unlawful as applied to these companies.134

The ruling did not invalidate the mandate entirely but suggested that the government could use existing alternatives, such as the accommodation already provided to religious nonprofit organizations, where the insurer—rather than the employer—covers the cost of the services. The Court emphasized that this decision was specific to the contraceptive mandate and should not be interpreted as a broad exemption for other insurance requirements or as a justification for discrimination.3