Hobby Lobby Stores Inc V BurwellEdit
Hobby Lobby Stores Inc v. Burwell is a 2014 Supreme Court decision that sits at the crossroads of religious liberty, corporate rights, and health-care policy under the Affordable Care Act. The Court held that the Religious Freedom Restoration Act (RFRA) protects the religious exercise of certain closely held for-profit corporations, and that applying the ACA’s contraceptive mandate to those businesses could violate RFRA. The decision, issued by a 5-4 majority, has been a focal point in debates over the reach of religious liberty in the corporate world and the balance between conscience rights and employee health requirements. The case involved the privately owned Hobby Lobby chain as well as other family businesses challenging the government’s mandate to provide coverage of certain contraceptives in employee health plans, under the ACA Affordable Care Act and the contraceptive mandate Contraceptive mandate.
The ruling underscored a tension that recurs in debates over government power and religious liberty: should private, for-profit entities with a small number of owners be treated as individuals capable of exercising religion, and how should government policy accommodate such claims without undermining broader public health or employment rights? The decision is frequently cited in discussions about the scope of RFRA, the rights of business owners, and the limits of compelled-conscience exemptions in federal policy. It remains a reference point in debates over how to reconcile religious beliefs with employee benefits and access to preventive health services.
Background
Legal and doctrinal context: RFRA was enacted in 1993 to restore a federal standard of scrutiny for laws that substantially burden religious exercise. Under RFRA, the government must demonstrate a compelling interest and use the least restrictive means to further that interest when a law substantially burdens religious exercise. The prior trend under the Employment Division v. Smith framework shifted the burden of proof away from claimant protections, prompting RFRA’s passage. The case centers on whether RFRA can extend to for-profit corporations and, if so, under what circumstances. See Religious Freedom Restoration Act and related discussions of RFRA’s scope.
Facts of the case: Hobby Lobby Stores, Inc. and other family-owned businesses challenged the ACA’s contraception mandate, which required health plans to cover certain contraceptives for employees. The owners argued that some forms of contraception violated their religious beliefs. A companion challenge involved Conestoga Wood Specialties Corp. and other companies with similar objections. The government offered an accommodation intended to sever the connection between the employer and the provision of contraceptive coverage, but the companies argued that even this accommodation imposed a substantial burden on their religious exercise.
The seven-member subset dispute: The government’s position rested on the idea that corporations are legal persons capable of complying with and being bound by federal health policy, and that accommodations could alleviate any burdens. The challengers argued that forcing them to provide coverage violated the owners’ religious beliefs, and RFRA obligated the government to accommodate or exempt such beliefs.
Closely held corporations: A central feature of the decision is the concept of a closely held corporation—one with a small number of owners who exercise predominant control over the entity. The Court’s analysis treated closely held corporations as potentially capable of exercising religion in a way that RFRA protects, in contrast to large public corporations where ownership is diffuse. See Closely held corporation.
Supreme Court decision
The majority opinion: Authored by Justice Samuel A. Alito Jr., the Court held that RFRA applies to for-profit corporations and that the contraceptive mandate, as applied to the petitioners, imposed a substantial burden on their exercise of religion. The Court reasoned that the owners’ sincere religious beliefs were entitled to protection under RFRA, and that requiring the owners to act in ways contrary to those beliefs would burden religious exercise in a manner not sufficiently outweighed by the government’s interests. The majority also discussed the possibility of accommodation as a means to satisfy public health goals without forcing a religiously objecting employer to fund or facilitate objectionable contraception.
Who joined and who dissented: The majority consisted of Justices Roberts, Scalia, Kennedy, Thomas, and Alito. The dissenting opinion was written by Justice Ginsburg and joined by Justices Breyer, Sotomayor, and Kagan, who argued that the ruling risks expanding exemptions in ways that could undermine access to preventive services for employees and communities.
Legal implications of the decision: The ruling affirmed that the government must consider RFRA when applying broad health mandates to religiously motivated employers and that a carefully tailored exemption or accommodation can be required to protect religious exercise. It did not categorically declare that all contraceptive coverage requirements were unconstitutional for all entities; rather, it scrutinized the specific application of the mandate to closely held, religiously motivated businesses. See Contraceptive mandate and Religious Freedom Restoration Act.
Aftermath and impact
Immediate legal effects: The decision narrowed the way in which the federal government could compel religiously motivated, privately held businesses to provide certain health benefits. It prompted further litigation and legislative and regulatory consideration around how to implement RFRA in the context of federal health policy, and it shaped subsequent court decisions involving religious liberty and corporate rights. See Little Sisters of the Poor Saints Peter and Paul Home v. Pennsylvania for related questions about exemptions and accommodations in the ACA context.
Policy and political reaction: Supporters argued the ruling was a principled defense of religious liberty and private property rights, emphasizing that individuals should not be forced to act against deeply held beliefs. Critics contended that the decision could undermine access to contraception and put women at risk of losing coverage, particularly for employees of religiously affiliated organizations and small businesses. The debate hinges on balancing conscience protections with access to preventive health services, and it has influenced ongoing discussions about how to structure exemptions, accommodations, and government interests in public health policy.
Longer-term legal landscape: Hobby Lobby has informed subsequent debates about corporate personhood, the reach of RFRA, and how courts address disputes between religious liberty and statutory mandates. It has been part of broader conversations about how lawmakers should design health-coverage rules to preserve both religious freedom and employees’ rights to health benefits. See Constitutional law and Religious freedom in the United States for broader context.
Cultural and institutional effects: The decision fed into a broader narrative about the protection of religious expression in the public sphere and the role of private business in public policy. It is cited in discussions about corporate influence, public policy design, and the philosophy of limited government.