Why did Justice Ginsburg disagree that the Religious Freedom Restoration Act applied to for-profit corporations?

In her dissent in Burwell v. Hobby Lobby Stores, Inc., Justice Ruth Bader Ginsburg argued that the Religious Freedom Restoration Act (RFRA) was never intended to grant for-profit corporations the right to seek religious exemptions from generally applicable laws.1

Ginsburg contended that the majority fundamentally misread the RFRA’s scope. She maintained that Congress designed the act solely to restore the "compelling-interest balancing test" used by the Supreme Court prior to the 1990 decision in Employment Division, Department of Human Resources of Oregon v. Smith. In her view, the RFRA merely codified this pre-existing constitutional rule; it did not expand the class of entities eligible for religious accommodation to include for-profit corporations, which had never previously been recognized as having such rights.1

Furthermore, Ginsburg warned that the ruling created a "startling" precedent. She argued that the decision ignored the harm imposed on employees—specifically women denied contraceptive coverage—and invited a proliferation of claims by allowing for-profit entities to opt out of regulations they deem offensive to their faith.1