How did the Dictionary Act influence the Supreme Court’s ruling in Burwell v. Hobby Lobby Stores, Inc.?

In the case of Burwell v. Hobby Lobby Stores, Inc., the U.S. Supreme Court utilized the Dictionary Act of 1871 to interpret the term "person" within the Religious Freedom Restoration Act (RFRA) of 1993.12

The Dictionary Act provides standard definitions for common terms used in federal statutes, explicitly stating that the word "person" may include corporations as well as individuals. In the majority opinion, Justice Samuel A. Alito, Jr. argued that because the RFRA did not indicate a narrower meaning for the term, the court should apply the definition found in the Dictionary Act.2

The court reasoned that since the RFRA already applied to individuals and nonprofit corporations, it must also extend to for-profit corporations, as there is no legal understanding of "person" that includes some corporations but excludes others. By establishing that closely held for-profit corporations qualify as "persons" capable of exercising religion, the court concluded that they could seek exemptions from the contraceptive mandate under the RFRA.21