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Hobby Lobby Stores, Inc. v. Burwell

Supreme Court of the United States · Constitutional Law

Constitutional LawReligious Freedom Restoration ActFree ExerciseCorporate RightsHealthcare RegulationRFRAclosely held corporationssubstantial burden

Facts

HHS regulations under the ACA required employer health plans to cover all FDA-approved contraceptive methods without cost sharing, including four methods that the owners of Hobby Lobby, Mardel, and Conestoga believed could operate after fertilization and therefore violated their sincere religious beliefs. These businesses are closely held for-profit corporations owned and controlled by family members who sought to run their companies in accordance with those beliefs. If they refused to provide the required coverage while continuing insurance, they faced very large monetary penalties; if they dropped insurance altogether, they still faced substantial penalties. HHS had already created an accommodation for religious nonprofit organizations under which insurers would provide separate contraceptive coverage without cost sharing to employees and without imposing net cost on the objecting employer.

Issue

Whether RFRA permits HHS to require closely held for-profit corporations to provide insurance coverage for contraceptive methods that violate the sincere religious beliefs of the corporations' owners. More specifically, whether such corporations are protected "persons" under RFRA, whether the mandate substantially burdens their exercise of religion, and whether the mandate is the least restrictive means of furthering a compelling governmental interest.

Rule

Under RFRA, the Federal Government may not substantially burden a person's exercise of religion, even through a rule of general applicability, unless it demonstrates that applying that burden to the particular claimant furthers a compelling governmental interest and is the least restrictive means of doing so. The term "person" includes closely held for-profit corporations, and courts may not second-guess the reasonableness of a claimant's sincere religious belief when assessing substantial burden.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Tulsa, Owen and Mira Patel own all voting shares of Prairie Lantern Home Goods, a for-profit corporation with 220 employees. A federal health regulation requires the company’s plan to cover a device the Patels sincerely believe destroys a fertilized embryo, and noncompliance would trigger steep daily penalties.

If Prairie Lantern sues under RFRA, what is the strongest argument that it may invoke the statute at all?

Explanation. Under the majority opinion, RFRA applies to a "person," and because RFRA does not define that term, the Dictionary Act controls unless context indicates otherwise. The Court found no contrary context in RFRA and held that closely held for-profit corporations are included. The point of extending protection to the corporation is to protect the religious liberty of the humans who own and control it. (Derived from Hobby Lobby Stores, Inc. v. Burwell (n.d.).)