Hobby Lobby Stores, Inc. v. Sebelius (Summary)

AFFORDABLE CARE ACT – PREVENTATIVE CARE COVERAGE MANDATE

Hobby Lobby Stores, Inc. v. Sebelius, No. CIV-12-1000-HE (W.D. Okla. Nov. 19, 2012)

The United States District Court for the Western District of Oklahoma denied a motion for a preliminary injunction brought by two secular corporations and individual members of the family who owns the corporations that were attempting to stop the application of the preventative care coverage mandate under the Affordable Care Act (“ACA”).

The plaintiffs claimed that the ACA’s contraceptive requirement violated the free exercise of religion clause in the First Amendment of the federal constitution and the Religious Freedom Restoration Act (“RFRA”).  The court disagreed, holding that secular, for-profit corporations do not have free exercise rights under the constitution and that the individuals, even though they do have such rights, were unlikely to prevail because the mandate was “a neutral law[] of general applicability which [is] rationally related to a legitimate governmental objective.”  With regard to the RFRA, the court also held that it did not apply to the corporate plaintiffs, and the individual plaintiffs were not “substantially burdened” by the mandate because there was not enough “direct and personal connection” between their religious exercise and the restraint on religion imposed by the mandate.