��֭����

Legal Principle at Issue

Does the Religious Freedom Restoration Act allow a for-profit corporation to deny contraceptive coverage to its employees, based on the religious objections of its owners?

Action

The Court ruled 5-4 in favor of Hobby Lobby, holding that closely held for-profit corporations can be exempt from regulations that violate the owners’ religious beliefs. Writing for the majority, Justice Samuel Alito said the contraceptive mandate within the Patient Protection and Affordable Care Act of 2010 substantially burdened the company’s exercise of religion.

Facts/Syllabus

The owners of Hobby Lobby and two other closely held for-profit corporations believe that life begins at conception and that it would violate their Christian faith to facilitate access for their employees to contraceptive drugs or devices. Those same corporations also sued the Department of Health and Human Services and other federal officials and agencies under the Religious Freedom Restoration Act of 1993 (RFRA) and the Free Exercise Clause, seeking to enjoin application of the contraceptive mandate included in the Patient Protection and Affordable Care Act of 2010, at least insofar as it requires those corporations to provide health coverage for the four objectionable contraceptives. Multiple federal district courts denied preliminary injunctions sought by the petitioners. The U.S. Court of Appeals for the Third Circuit upheld a district court ruling that a for-profit corporation could not “engage in religious exercise” under RFRA or the First Amendment, and that the mandate imposed no requirements on the owners in their personal capacity. However, the Tenth Circuit reversed district court decision to deny a preliminary injunction to Hobby Lobby, holding those businesses are “persons” under RFRA, and that the corporations had established a likelihood of success on their RFRA claim because the contraceptive mandate substantially burdened their exercise of religion. The court held that HHS had not proved that the mandate was the “least restrictive means” of furthering a compelling governmental interest.

Importance of Case

The ruling in Burwell v. Hobby Lobby Stores was the first time the Supreme Court recognized that for-profit corporations could claim religious exemptions under the Religious Freedom Restoration Act of 1993, sparking a national debate over religious liberty versus reproductive rights. The ruling also changed how contraceptive coverage could be implemented under the Affordable Care Act.