Why did the Supreme Court find that the contraceptive mandate was not the least restrictive way to achieve the government’s goal?

In Burwell v. Hobby Lobby Stores, Inc., the Supreme Court ruled that the government failed to demonstrate that the contraceptive mandate was the least restrictive means of furthering its compelling interest in providing women with free access to contraception.1

The Court identified that less restrictive alternatives already existed that would achieve the government's goal without substantially burdening the plaintiffs' religious exercise:1

• Government-funded coverage: The government could have assumed the cost of providing the specific contraceptive methods to women whose employers held religious objections.1
• Existing accommodation: The government could have extended the accommodation it had already established for nonprofit religious organizations to closely held for-profit corporations. Under this system, the organization self-certifies its religious objection, and the insurance provider is then responsible for covering the cost of the services.1

The Court concluded that because these alternatives were available and would serve the government's stated interests equally well without violating the plaintiffs' religious convictions, the mandate did not satisfy the requirements of the Religious Freedom Restoration Act.1