Burwell v. Hobby Lobby Stores, Inc., Supreme Court, 2014

Facts of the Case

Hobby Lobby Stores, Inc., a for-profit corporation owned by the Green family, operates under Christian principles. The Green family objected to providing certain forms of contraception through their company’s health insurance plan, as required by the Affordable Care Act (ACA). Specifically, they objected to methods that they believe prevent the implantation of a fertilized egg, which they consider equivalent to abortion. The ACA’s contraceptive mandate required employers to provide insurance coverage for all FDA-approved contraceptive methods. Hobby Lobby argued that this mandate violated their religious freedoms as protected by the Religious Freedom Restoration Act (RFRA) of 1993.

Constitutional Question

Does the Religious Freedom Restoration Act of 1993 allow a for-profit corporation to deny its employees health coverage for contraception based on the religious objections of the company’s owners?

Arguments

For Hobby Lobby Stores (the plaintiffs):

  • The ACA’s contraceptive mandate substantially burdens the exercise of religion by requiring the Green family to either violate their religious beliefs or face significant fines.
  • The RFRA protects individuals and closely held corporations from government actions that substantially burden their free exercise of religion unless the government can demonstrate a compelling interest and use the least restrictive means.
  • The government could achieve its goals through other means that do not require the involvement of employers who object on religious grounds.

For Sylvia Burwell, Secretary of Health and Human Services (the defendant):

  • The contraceptive mandate serves a compelling government interest in providing women with access to health care and promoting public health and gender equality.
  • The RFRA was not intended to extend religious freedom protections to for-profit corporations, and allowing such exemptions could undermine regulatory goals and public health objectives.
  • The mandate is the least restrictive means of achieving the government’s interest in providing comprehensive health coverage.

The Decision

The Supreme Court, in a 5-4 decision, ruled in favor of Hobby Lobby Stores, Inc. Justice Samuel Alito, writing for the majority, held that the RFRA applies to closely held for-profit corporations, meaning that such corporations can claim religious exemptions from federal laws that impose a substantial burden on their religious exercise. The Court concluded that the ACA’s contraceptive mandate violated the RFRA because it substantially burdened the exercise of religion by the Green family, who owned Hobby Lobby. The decision emphasized that the government had not used the least restrictive means to achieve its objectives, suggesting that the government could provide the coverage directly without involving religiously objecting employers.

Significance

Burwell v. Hobby Lobby Stores, Inc. is a landmark case that significantly expanded the application of the RFRA to include closely held for-profit corporations, allowing them to seek exemptions from federal regulations based on religious objections. The decision marked a significant moment in the ongoing debate over the balance between religious freedom and government regulation, particularly in the context of healthcare and reproductive rights. The ruling raised important questions about the extent to which religious beliefs can influence the operations of for-profit businesses and the potential impact on employees who may not share those beliefs. The case continues to influence legal discussions around religious freedom, corporate rights, and the scope of federal regulatory power.