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Catholic Charities of Sacramento, Inc. v. Superior Court
Citations: 85 P.3d 67; 10 Cal. Rptr. 3d 283; 32 Cal. 4th 527; 32 Employee Benefits Cas. (BNA) 2346; 2004 Cal. Daily Op. Serv. 1737; 2004 Daily Journal DAR 2614; 2004 Cal. LEXIS 1667Docket: S099822
Court: California Supreme Court; March 1, 2004; California; State Supreme Court
Catholic Charities of Sacramento, Inc. initiated legal proceedings against the Superior Court of Sacramento County, with the Department of Managed Health Care and others as real parties in interest. The case was decided by the Supreme Court of California on March 1, 2004, with certiorari denied on October 4, 2004. Various legal representatives appeared for the petitioner, Catholic Charities, including the Law Office of James Francis Sweeney and several amici curiae supporting the petitioner from organizations such as Catholic Charities USA and the California Catholic Conference. Conversely, the respondents were represented by the Attorney General's office, supported by multiple amici curiae, including the American Civil Liberties Union and other advocacy groups. The document lists numerous parties involved, highlighting a significant interest in the case from various religious and civil rights organizations. Eve C. Gartner and others represent various Planned Parenthood organizations as Amici Curiae in support of the Respondent in a case concerning a church-affiliated employer's constitutional challenges to the Women's Contraception Equity Act (WCEA). Other organizations, including the American College of Obstetricians and Gynecologists and various labor unions, also provide support as Amici Curiae. The Supreme Court denied certiorari on October 4, 2004. The case addresses the WCEA, enacted in 1999, which mandates that certain health and disability insurance contracts cover prescription contraceptives to eliminate gender discrimination in healthcare benefits and improve access to contraceptives. Evidence presented to the Legislature indicated that women incur significantly higher out-of-pocket healthcare costs than men, largely due to contraceptive expenses and the financial burdens of unintended pregnancies. While many health maintenance organizations covered contraceptives, a gap existed for some preferred provider and indemnity plans, leaving about 10% of commercially insured Californians without contraceptive coverage. The WCEA does not obligate employers to offer any drug coverage; however, if they do provide prescription drug coverage, it must include contraceptives. Religious employers can opt for policies that exclude contraceptive coverage that conflicts with their religious beliefs. Catholic Charities of Sacramento, Inc. is identified as the plaintiff, challenging the WCEA's compliance with the establishment and free exercise clauses of the U.S. and California Constitutions, which the lower courts rejected. The court ultimately affirmed the lower court's decision. Catholic Charities, while independently incorporated, identifies itself as associated with the Roman Catholic Bishop of Sacramento and functions as an extension of the Roman Catholic Church. The organization provides various social services, including immigrant resettlement, elder care, counseling, food, clothing, affordable housing, and vocational training for the developmentally disabled, as part of its social justice ministry. It offers health insurance, including prescription drug coverage, to its 183 full-time employees through Blue Shield of California and Kaiser Permanente but does not cover prescription contraceptives due to its adherence to Catholic doctrine, which views contraception as sinful. Under the Women's Contraceptive Equity Act (WCEA), a "religious employer" can exclude contraceptive coverage if it violates religious tenets. The WCEA defines a "religious employer" based on four criteria, including the primary purpose of inculcating religious values, employment of individuals who share its religious beliefs, serving primarily individuals of the same faith, and being a nonprofit organization as per the Internal Revenue Code. Catholic Charities does not meet any of these criteria: its corporate purpose is to provide social services to the general public rather than directly promote religious values, it employs a diverse workforce, serves people of various faith backgrounds, and does not qualify as a nonprofit under the specific sections of the tax code. Consequently, Catholic Charities is not exempt from the WCEA mandate. Although the WCEA allows employers to avoid contraceptive coverage by not providing prescription drug insurance, Catholic Charities argues that this does not fully resolve the conflict between the law and its religious beliefs. The organization believes it has a moral obligation to offer comprehensive benefits, including prescription drug insurance, to ensure the well-being of its employees and their families, in line with its interpretation of Roman Catholic teachings. Catholic Charities initiated legal proceedings against the State of California and its departments, seeking a declaratory judgment that the Workplace Religious Freedom Act (WCEA) is unconstitutional and requesting an injunction against its enforcement. The organization challenges the WCEA based on the establishment and free exercise clauses of both the U.S. and California Constitutions. The superior court denied Catholic Charities' request for a preliminary injunction, concluding there was little likelihood of success on the merits. The Court of Appeal also denied a petition for writ of mandate to review the ruling, prompting the current review. In its brief, Catholic Charities presents eight constitutional challenges related to the WCEA, all concerning religious autonomy and free exercise rights. The first three arguments assert that the WCEA unlawfully interferes with the autonomy of religious organizations. The organization further claims that the WCEA imposes an undue burden on its free exercise rights, proposing that the law should be subjected to strict scrutiny, despite the Supreme Court's ruling that neutral, generally applicable laws do not exempt individuals from compliance based on free exercise claims. Lastly, Catholic Charities argues that the WCEA does not even pass the rational basis test. Regarding religious autonomy, Catholic Charities argues that the WCEA infringes on matters of religious doctrine and governance, citing the precedent set in Watson v. Jones, which established that civil courts must defer to decisions made by church authorities in ecclesiastical disputes. This rule emphasizes that civil courts lack the expertise to adjudicate religious matters and that church members consent to church governance. Although Watson predated the First Amendment's incorporation into the Fourteenth Amendment, its reasoning has been recognized as constitutionally significant in later cases, establishing that legislatures are also bound by these constitutional limitations. Catholic Charities contends that the enactment of the WCEA infringes on church governance and conflicts with its religious beliefs regarding contraception. However, this assertion is deemed incorrect as the case pertains to the relationship between a nonprofit public benefit corporation and its employees, many of whom are not Catholic. While the WCEA may conflict with Catholic Charities' beliefs, it does not constitute a legislative determination of religious matters. The concept of the "ministerial exception" has been recognized by courts, allowing for non-governance of church-minister relationships under Title VII of the Civil Rights Act. However, this case does not involve Title VII, and Catholic Charities does not claim any employees hold ministerial duties, rendering the exception inapplicable. Additionally, Catholic Charities argues that the First Amendment prohibits the government from determining an institution's eligibility for exemptions based on the perceived religious or secular nature of its activities. This argument is rejected, as the WCEA provides accommodations for religious employers to avoid paying for contraceptives that conflict with their beliefs. The Supreme Court has upheld the alleviation of government-imposed burdens on religious exercise as a legitimate legislative aim. Distinctions between religious and secular activities are essential for effective legislative accommodation, and such distinctions have consistently been upheld by courts, contrary to Catholic Charities' claims, which primarily rely on a single lower court decision, Espinosa v. Rusk. The court invalidated an antisolicitation ordinance due to its involvement of municipal officials in defining religious activities, which conflicted with Supreme Court precedent allowing exemptions for religious organizations from general laws to alleviate burdens on religious exercise. The Espinosa decision focused on content-based prior restraints on speech, ruling that an ordinance requiring officials to approve the religious intent behind fund solicitation violated the principle established in Cantwell v. Connecticut, which permits regulation of the time, place, and manner of solicitations but prohibits censorship based on content. The government can distinguish between secular and religious entities for accommodating religious exercise, but laws targeting religious beliefs are impermissible and must be scrutinized to prevent religious discrimination. Catholic Charities contends that the WCEA's exemption for "religious employers" violates the establishment clause by necessitating an inquiry into the religious purpose of employers and the beliefs of their employees and clients. The criteria for identifying a "religious employer" involve assessing the entity's purpose, employee beliefs, and client demographics. While such inquiries may raise establishment clause concerns, Catholic Charities claims it does not meet any criteria for the exemption, meaning no inquiry into its religious beliefs is likely. Thus, the establishment clause does not render the statute unconstitutional in this case. In terms of free exercise, Catholic Charities argues that the WCEA infringes on its rights by compelling it to provide insurance coverage for contraceptives, which conflicts with its religious beliefs. Any analysis of this claim must reference the Supreme Court's ruling in Employment Div. Ore. Dept. of Human Res. v. Smith. The high court in Smith established that religious beliefs do not exempt individuals from complying with valid laws that the state has the authority to regulate. While the government cannot regulate religious beliefs directly, individuals must adhere to neutral laws of general applicability, even if such laws conflict with their religious practices. Allowing religious beliefs to excuse non-compliance with the law would elevate those beliefs above legal standards. Prior to Smith, the court had inconsistently applied standards such as strict scrutiny in cases like Sherbert v. Verner and Wisconsin v. Yoder, which examined whether laws substantially burdened religious practices. However, Smith rejected the strict scrutiny standard and adopted a more stringent test articulated by Justice Stevens, stating that neutral laws need not demonstrate a compelling interest even if they incidentally burden religious practices. In the context of Catholic Charities' challenge to the WCEA, the act applies generally to all employers and regulates insurance policy content to address gender discrimination in health benefits, only incidentally conflicting with Catholic Charities' religious beliefs regarding contraceptives. To overcome the general rule established in Smith, Catholic Charities must demonstrate an exception. They argue on four bases for applying strict scrutiny: that the WCEA is not neutral or generally applicable, it constitutes a religious "gerrymander," it violates hybrid rights, and that the California Constitution mandates strict scrutiny, which the WCEA fails to satisfy. The document indicates that Catholic Charities will elaborate on these arguments next. Catholic Charities argues that the statute lacks neutrality and claims that the Legislature "gerrymandered" the law to specifically target Catholic employers. The analysis of a law's neutrality and general applicability indicates that a law is not neutral if it aims to restrict practices based on religious motivation. A law is considered generally applicable only if it does not selectively impose burdens on actions motivated by religious beliefs. The determination of whether a law suppresses religious conduct begins with the law’s text, which must not discriminate against religion on its face. An example from the case of Lukumi illustrates that a law can lack facial neutrality if it employs religious terminology without a discernible secular meaning, suggesting a motive to suppress a particular religion. Catholic Charities contends that the WCEA is not neutral because it uses religious terms like "inculcation of religious values" and "religious tenets" in defining exempt religious employers. However, the context of the WCEA differs from the Lukumi case; while the latter aimed to prohibit religious practices, the WCEA’s religious terminology serves to identify and exempt organizations from general requirements. Although Catholic Charities may not qualify for the exemption, other Catholic organizations might. If the WCEA imposes a burden on Catholic Charities' religious beliefs, this is due to the overarching requirement to provide contraceptive coverage, not the religious terms in the exemption. The high court has not ruled out legislative references to religion aimed at accommodating religious practices, affirming that such references serve a legitimate purpose in alleviating governmental interference with religious organizations. A strict prohibition on religious terminology in statutes designed to protect religious exercise would invalidate many existing laws, including federal provisions that exempt religious organizations from certain employment regulations. The California Fair Employment and Housing Act (FEHA) exempts certain employers identified as "religious associations or corporations" from liability for unlawful employment practices. The court has upheld statutes recognizing "religiously affiliated" associations and their missions as exempt from certain regulations. The proposed rule by Catholic Charities, which could negate these exemptions, is rejected due to a lack of support from higher court decisions. Furthermore, the analysis extends beyond mere facial neutrality regarding religion, as the First Amendment necessitates vigilance against both overt and subtle governmental hostility. Catholic Charities claims the WCEA discriminates against Catholic organizations by denying them exemptions based on their charitable activities. However, the court finds no merit in this claim, asserting that the ministerial exception does not apply in this case. Catholic Charities also argues that the First Amendment prohibits the government from determining a religious institution's exemption eligibility based on whether its activities are classified as "religious" or "secular." This argument addresses specific criteria required for an exemption under the WCEA. The court counters that the WCEA's exemption is meant to relieve religious employers from burdens that conflict with their beliefs, a legislative purpose deemed permissible by the Supreme Court that does not violate the establishment clause. The court emphasizes that distinguishing between religious and secular activities is essential for effective legislative accommodations and has been recognized constitutionally by Congress and state legislatures. Catholic Charities' position is primarily based on a single lower court decision, Espinosa v. Rusk, which dealt with the improper involvement of officials in defining religious activities and has limited applicability. The excerpt addresses the limitations on governmental power concerning religious organizations, emphasizing that decisions such as Espinosa cannot override the U.S. Supreme Court's established principle that the government may constitutionally exempt religious organizations from general laws to alleviate significant burdens on religious exercise. Key cases cited include Corporation of Presiding Bishop v. Amos, Hobbie v. Unemployment Appeals Commission of Florida, and Employment Division v. Smith. The court in Espinosa invalidated an ordinance that allowed municipal officials to pre-approve the religious purpose of fundraising applications, which was seen as a violation of free speech principles established in Cantwell v. Connecticut. Unlike the ordinance in Espinosa, the WCEA does not impose restrictions on speech, allowing for a distinction between secular and religious entities to accommodate religious exercise. However, any law that specifically targets religious beliefs is impermissible and must be scrutinized to prevent "religious gerrymandering." Catholic Charities argues that the WCEA's definition of "religious employer" could lead to excessive governmental entanglement with religion, violating the establishment clause. This concern focuses on the criteria used to identify a "religious employer," which require an inquiry into the entity's religious purpose and the religious beliefs of its employees and clients. Judicial opinions have criticized such inquiries that probe into an organization's religious beliefs. Notably, Catholic Charities admits in its complaint that it does not meet any of the criteria for the exemption under the WCEA. Catholic Charities acknowledges that its mission is not to promote religious values, does not exclusively hire or serve Catholics, and does not qualify under specific provisions of the Internal Revenue Code. As a result, there has been no significant inquiry into its religious purpose or beliefs. Consequently, the establishment clause does not provide grounds to deem the relevant statute unconstitutional in this context. Regarding the free exercise of religion, Catholic Charities contends that the WCEA infringes its constitutional rights by compelling the organization to act against its religious convictions. The WCEA's requirement for employers to offer insurance coverage for prescription contraceptives conflicts with Catholic Charities' beliefs. This claim is evaluated in light of the Supreme Court's ruling in Employment Division v. Smith, which established that religious beliefs do not exempt individuals from complying with valid laws regulating matters within the state's authority. The ruling emphasizes that while the government cannot regulate religious beliefs directly, it may impose laws of general applicability without providing a religious exemption. Historical precedents show that the Court has applied varying standards to assess the constitutionality of laws impacting religious practices, at times applying strict scrutiny, but more frequently upholding laws without such rigorous analysis. Smith marked a pivotal shift in legal standards regarding the free exercise of religion, rejecting the Sherbert test and adopting a new standard articulated by Justice Stevens. The Supreme Court reaffirmed this standard, establishing that laws that are neutral and generally applicable do not require justification by a compelling government interest, even if they incidentally burden religious practices, as seen in Church of Lukumi Babalu Aye, Inc. v. Hialeah. This principle seemingly undermines Catholic Charities' free exercise claim against the WCEA, which applies uniformly to all employers, with limited exceptions for religious exemptions. The WCEA aims to regulate insurance policy content to eliminate gender discrimination in health benefits, only incidentally conflicting with Catholic Charities' religious beliefs regarding contraceptives. To challenge the WCEA, Catholic Charities seeks to establish exceptions to the general rule set forth in Smith. They argue on four grounds: that the WCEA is not neutral or generally applicable, that it constitutes a religious gerrymander, that it violates hybrid rights, and that the California Constitution mandates strict scrutiny of the WCEA. Catholic Charities presents two primary arguments to assert that the WCEA lacks neutrality and general applicability: first, that the statute's language reflects a lack of neutrality, and second, that its legislative history indicates an intent to target Catholic employers. A law is deemed non-neutral if its objective is to restrict practices based on religious motivation, and it is not generally applicable if it selectively imposes burdens on religiously motivated conduct. The determination of whether a law suppresses religion starts with its text, as facial neutrality requires that the law does not discriminate against religious practices without a secular context. In *Lukumi*, the Supreme Court determined that a city council's use of terms like "sacrifice" and "ritual" in an ordinance regulating animal slaughter indicated a motive to suppress the Santeria religion, revealing a lack of facial neutrality and a pattern of animosity towards its practices. The ordinance's language was crafted to specifically target religious animal sacrifices while exempting most secular practices, thus unnecessarily suppressing broader religious conduct for purported health and cruelty prevention reasons. Catholic Charities argues that the WCEA is similarly non-neutral due to its religious terminology, such as "inculcation of religious values," which lack secular meaning. However, the context differs from *Lukumi*, as the WCEA's use of religious characteristics serves to identify and exempt religious organizations from general statutory obligations rather than suppressing them. Consequently, while Catholic Charities cannot claim the exemption, other Catholic entities might qualify, and any burden on Catholic Charities arises from the obligation to provide contraceptive coverage, not from the terminology itself. The Court has upheld legislative references to religion as permissible for accommodating religious practices, emphasizing that such accommodations are evaluated under the establishment clause rather than the free exercise clause, allowing for necessary distinctions between religious and secular organizations. To comply with the Establishment Clause, a law must have a secular legislative purpose, which does not preclude it from having any relation to religion. The law should not demonstrate indifference to religious groups, as established in prior cases. A permissible purpose includes alleviating governmental interference with religious organizations' ability to fulfill their missions. The references to religion in the WCEA are aimed solely at this purpose. The Supreme Court has not mandated that laws avoiding burdens on religious exercise must omit explicit religious references, as seen in cases like Amos and the California Fair Employment and Housing Act. The argument posed by Catholic Charities that the WCEA is discriminatory against Catholic organizations is examined. The First Amendment demands not only facial neutrality but also protection against subtle forms of governmental hostility or discrimination. However, the claim that the WCEA gerrymanders to exclude Catholic organizations from benefits is rejected, as there is no evidence supporting that the law discriminates against the Catholic Church or any religious organizations engaged in charitable work. The Legislature granted an exception allowing religious employers to deny coverage for contraceptive methods that conflict with their religious beliefs, as requested by Catholic organizations. Most religious employers do not object to prescription contraceptives and thus are subject to the Women's Contraceptive Equity Act (WCEA). The exception for those who do object is seen as a legitimate accommodation of religious exercise. The limited scope of this exemption does not constitute discrimination against the Catholic Church, as clarified by established case law. In Larson v. Valente, the Supreme Court deemed unconstitutional a Minnesota statute that favored certain religious organizations based on their income sources, violating the Establishment Clause by preferring one denomination over another. Unlike that statute, the WCEA applies equally to all religious and nonreligious organizations, with exemptions only for those whose tenets oppose contraceptives, which is justified as a means to alleviate governmental burdens on religious exercise. Catholic employers not qualifying for exemption are treated the same as all other employers, irrespective of religious affiliation. Thus, while the WCEA may favor some Catholic employers, it does not disadvantage them compared to other employers. Catholic Charities contends that the WCEA's distinction between organizations focused on "inculcation of religious values" and those engaged in other ministries violates Larson, but the argument does not undermine the WCEA's legal framework. Catholic Charities claims that the Catholic Church is compelled to engage in "corporal works of mercy," which include actions such as feeding the hungry and sheltering the homeless, as stated in the Catechism of the Catholic Church. However, their argument that the WCEA (Women's Contraceptive Equity Act) discriminates against charitable social work as a religious practice is unfounded. The principle established in the Lukumi case, which prohibits the government from selectively burdening conduct motivated by religious belief, is not applicable here. The WCEA applies uniformly to all non-religious employers engaged in charitable work; thus, it does not impose unique burdens on religiously motivated charitable social work. Catholic Charities also argues that the WCEA was crafted to specifically exclude Catholic organizations from the "religious employer" exception, akin to the discriminatory intent found in Lukumi. However, this assertion is unsupported by the legislative history of the WCEA, which Catholic Charities mischaracterizes as intending to address a "Catholic gap" in insurance coverage for contraceptives. The term "Catholic gap" is not found in the legislative documentation and is solely attributed to Catholic Charities' brief. Testimony from a Planned Parenthood representative indicates that the legislation aimed to close gaps in contraceptive coverage, not to target religious organizations. A study highlighted in the Legislature found that about 10% of commercially insured Californians lacked coverage for prescription contraceptives, specifically identifying this group as individuals with PPO and indemnity plans, not employees of Catholic organizations. Most HMOs provide coverage for contraceptives, but not all PPO and indemnity plans do. Catholic Charities' claim that the Women's Contraceptive Equity Act (WCEA) aimed to address a "Catholic gap" in coverage lacks evidentiary support. Catholic Charities further contends that the Legislature intentionally limited the statutory exception for "religious employers" to exclude Catholic hospitals and social service organizations. Legislative history indicates that sponsors favored a narrow religious exemption, emphasizing that as activities become more secular, the requirement to cover contraceptive benefits increases. Catholic Charities interprets these statements as targeting specific Catholic organizations unfairly; however, it has been established that some Catholic organizations receive more favorable treatment under the law compared to other employers. Additionally, Catholic Charities argues that the WCEA infringes upon "hybrid rights," a concept derived from the Supreme Court case Smith, where the Court declined to apply strict scrutiny to free exercise claims unaccompanied by other constitutional protections. Catholic Charities asserts that the WCEA violates hybrid rights related to free speech and the establishment clause, thus necessitating strict scrutiny for its free exercise claim. The Supreme Court has not definitively ruled on the validity of the hybrid rights theory since the Smith decision, nor has it applied strict scrutiny to free exercise claims based on this theory. Justice Souter's concurring opinion in Lukumi critiques Smith's use of hybrid rights. Various lower federal courts have interpreted Smith's discussion of hybrid rights as non-binding and have rejected the application of a stricter standard than rational basis for hybrid claims. While some courts have assumed that hybrid claims merit heightened scrutiny, they have concluded that simply combining a free exercise claim with a meritless claim does not justify this heightened scrutiny. Catholic Charities contends that the non-free-exercise aspect of a hybrid claim need only be "colorable," but this approach has not been adopted by any court to grant relief. Justice Souter warns that if hybrid claims merely involve implicating another right, it could undermine the Smith ruling. The Sixth Circuit has dismissed the idea that review standards under the Free Exercise Clause depend on coupling with other rights. No federal court has relied solely on the hybrid rights theory to apply strict scrutiny to a free exercise claim. The E.E.O.C. v. Catholic University case mentioned hybrid rights but primarily relied on the ministerial exception. Even if the hybrid rights theory were valid, Catholic Charities has not established a meritorious constitutional claim to justify its application. Their argument concerning the provision of insurance for contraceptives as a violation of free speech is deemed lacking in merit, as the First Amendment does prevent the government from compelling individuals to express certain views, but the context does not support their claim. Catholic Charities' compliance with health care benefit regulations is not considered speech, as the law allows the organization to express its disapproval of contraceptives and advise employees against their use. Simply adhering to a law that doesn’t mandate communication of a message cannot be interpreted as support for that law. Allowing individuals to choose compliance based on personal agreement would undermine the rule of law, as illustrated by the dismissal in Buhl v. Hannigan regarding helmet laws. Catholic Charities further argues that the California Constitution's free exercise clause prohibits the state from burdening religious practice through neutral laws, unless such laws are justified by a compelling governmental interest and are narrowly tailored. The organization urges for interpretation of the state clause consistent with the U.S. Supreme Court's ruling in Sherbert. However, in Smith v. Fair Employment and Housing Com., the California Supreme Court left open the question of the appropriate standard for reviewing neutral laws under the state free exercise clause, having rejected a landlord's religious exemption claim concerning fair housing laws. The court did apply strict scrutiny to the landlord's federal claims under the Religious Freedom Restoration Act, but did not determine whether the state claim warranted the same scrutiny. The opinions in Smith reflected differing views on the interpretation of the state Constitution, but did not clarify the standard of review. Justice Kennard's concurring opinion, supported by Justice Baxter, highlights the lack of clarity regarding the protection of religious liberty under California's free exercise clause. The only relevant case, *Brunson v. Department of Motor Vehicles*, determined that plaintiffs' religious beliefs did not exempt them from statutory requirements, applying a rational basis test to evaluate free exercise claims. However, the interpretation of *Smith v. FEHC* as supporting this test is seen as erroneous, as *Smith* left the standard of review unresolved. The current case reviewed the issue independently and agreed that challenges to neutral laws should be assessed under the rational basis standard, but emphasized that federal decisions do not dictate the interpretation of the California Constitution's free exercise clause. The court asserted that the California Constitution stands independently, cautioning against relying on federal rulings to shape its application. Prior to 1990, there was no established interpretation of the state free exercise clause, and earlier cases had treated the state and federal clauses interchangeably without independent analysis. Prior to the Sherbert decision, California courts typically did not exempt religiously motivated conduct from neutral laws, emphasizing that while individuals are free to hold personal beliefs, they must adhere to reasonable regulations applicable to all. For instance, the Rescue Army case affirmed that beliefs do not exempt individuals from compliance with general laws aimed at legitimate objectives. The courts expressed concern that allowing exemptions based on religious motivation could undermine regulatory frameworks. The historical context indicates that California's free exercise clause has not significantly impacted free exercise claims since the Smith decision. The court acknowledges its authority to define the interpretation of the California Constitution's free exercise clause but determines that the challenge brought by Catholic Charities against the WCEA fails regardless. This is because the statute passes strict scrutiny, which requires that a law cannot substantially burden a religious belief unless it serves a compelling state interest in the least restrictive manner. In this analysis, a law is deemed to substantially burden religious beliefs if it conditions access to significant benefits on actions contrary to those beliefs or denies such benefits due to adherence to religious practices. Thus, the court applies a strict scrutiny standard, akin to the federal review between the Sherbert and Smith decisions. The analysis begins by assessing whether the Wisconsin Contraceptive Equity Act (WCEA) imposes a burden on Catholic Charities' religious beliefs. Catholic Charities claims that providing insurance coverage for prescription contraceptives is religiously unacceptable, supported by a declaration from a Roman Catholic priest. However, the WCEA only mandates coverage for employers who choose to provide it, allowing Catholic Charities to avoid conflict by not offering such coverage. Despite this, Catholic Charities contends that its beliefs compel it to provide insurance for prescription drugs. The priest's declaration suggests obligations of "justice and charity" that may not strictly align with religious beliefs, raising the issue of whether these beliefs can be classified as 'religious' for legal protection. The court notes that claims under the Free Exercise Clause must be rooted in religious beliefs and not mere philosophical choices, indicating that societal interests must also be considered in this context. The court acknowledges the difficulty in distinguishing between religious beliefs and philosophical choices, as well as the challenge in evaluating the plausibility of religious claims. However, it concludes that, regardless of whether the WCEA substantially burdens a religious belief, the law serves a compelling state interest—specifically, the elimination of gender discrimination—and is narrowly tailored to achieve this interest. Evidence presented to the Legislature indicated that women incur out-of-pocket health care costs that are up to 68% higher than men, primarily due to expenses related to prescription contraceptives and the costs associated with unintended pregnancies, such as health risks and increased neonatal care. Legislative analyses of the bills leading to the Women's Contraceptive Equity Act (WCEA) highlighted the elimination of this economic disparity as a key objective. Although Catholic Charities contended that the inequity addressed by the WCEA could not be classified as gender discrimination since they pay equal wages to men and women, the Legislature is deemed competent to identify subtle forms of gender discrimination, a stance supported by Congress’s amendments to Title VII, which include pregnancy-related medical conditions in the definition of sex discrimination. The only federal ruling on this matter confirms that employers must provide coverage for prescription contraceptives if their health care plans cover other prescription drugs. California's constitutional provisions against gender discrimination trigger the highest scrutiny level and underscore the compelling interest in eliminating such discrimination. Exemptions from the WCEA would undermine women's rights to equitable health benefits. Historical precedents suggest that neither the California Supreme Court nor the U.S. Supreme Court has granted exemptions to religious objectors that would negatively impact third parties' rights, as seen in cases like Wisconsin v. Yoder, where the Court limited its ruling based on the assumption that no Amish child wished to attend public school, and United States v. Lee, which stated that granting religious exemptions could impose the employer’s beliefs on employees. Congress and the courts acknowledge the Free Exercise Clause but clarify that individuals cannot be exempt from all burdens associated with exercising their religious beliefs in commercial activities. Individuals engaging in commerce cannot impose their religiously motivated conduct limitations on statutory obligations that apply to others. Relevant case law confirms that religious organizations must adhere to federal laws, such as minimum wage and equal pay requirements, underscoring that nonprofits entering the labor market are also bound by these laws. Catholic Charities contends that the WCEA (Women's Contraceptive Equity Act) could be broadened to exempt more employers from its provisions without increasing the number of women affected by discrimination by mandating public funding for contraceptives. However, there is no legal authority compelling the state to subsidize religious practices, as established in precedent cases. Additionally, the argument that the WCEA is underinclusive is rejected; the law's primary purpose is to combat gender discrimination in health benefits, not to facilitate contraceptive access for women in various employment situations where no health benefits are provided. Catholic Charities also claims the WCEA is overinclusive, arguing it applies to employers who do not discriminate based on gender. Nevertheless, this assertion simply reflects their disagreement with the Legislature’s conclusion that excluding contraceptive coverage constitutes gender discrimination. Ultimately, applying the strict scrutiny standard, the WCEA is found to satisfy constitutional requirements under the free exercise clause of the state Constitution. The state free exercise clause does not mandate the application of the Sherbert test to neutral laws that incidentally burden religious practices; this issue is left unresolved. Catholic Charities argues that the WCEA violates the rational basis test by using arbitrary criteria to define "religious employer." They contend that the legislature's classification excludes religious institutions that employ individuals of diverse faiths or that engage in outreach to all, labeling them insufficiently "religious" for exemption. However, the argument is deemed unmeritorious as the WCEA's exemption serves a legitimate interest in protecting the church-minister relationship. While the U.S. Supreme Court has not addressed this matter, lower federal courts have upheld the ministerial exemption following the Smith decision. Most organizations qualifying for the ministerial exemption engage in inculcating religious values, and many will also meet the WCEA's criteria for federal tax-exempt status. If the constitutional ministerial exception exceeds the statutory exemption, the former would prevail. Catholic Charities specifically challenges the requirement that an employer "primarily employ persons who share the religious tenets" of the entity, which is seen as lacking a rational basis. This provision, however, extends the WCEA's exemption beyond the ministerial exemption, serving a legitimate purpose by alleviating a state-imposed burden on religious exercise. Additionally, another requirement that an employer "serve primarily persons who share the religious tenets" of the entity is criticized for lacking a clear legitimate purpose, particularly when considering hypothetical scenarios such as a soup kitchen operated by church ministers. Catholic Charities of Sacramento cannot challenge the Women's Contraception Equity Act (WCEA) exemption because it admits to not meeting any of the four criteria required for "religious employer" status. The WCEA mandates that health care policies covering outpatient prescription drugs must include contraceptive coverage, but exempts certain religious employers. The criteria include: (A) the entity's primary purpose is to inculcate religious values; (B) it primarily employs persons who share its religious tenets; (C) it serves primarily those who share its religious tenets; and (D) it qualifies as a nonprofit under specific IRS provisions. Catholic Charities, defined as a nonprofit public benefit corporation affiliated with the Roman Catholic Church, provides various social services and previously offered prescription drug coverage to its employees. However, it argues that complying with the WCEA would conflict with its religious beliefs against contraception. The court affirmed that Catholic Charities is subject to the WCEA and rejected its claim that the exemption disproportionately affects religious organizations engaged in charitable work. A concurring opinion expresses concern over the compatibility of the religious employer exemption's first requirement with constitutional establishment clauses, highlighting the complexity of the issue. Catholic Charities fails to meet the fourth requirement of the exemption that it be a religious entity exempt from federal tax filing, which is acknowledged as constitutional. The First Amendment prohibits Congress and, through the Fourteenth Amendment, state governments from enacting laws that establish or prefer any religion, as articulated in California's Constitution. Laws favoring one religion over another, known as "denominational preferences," are unconstitutional. Relevant case law, such as Epperson v. Arkansas and Everson v. Board of Education, reinforces that states cannot adopt programs that assist or hinder any religion. The Supreme Court's decision in Larson v. Valente invalidated a Minnesota law that treated religious organizations differently based on their funding sources, asserting that it imposed selective burdens on certain denominations. Catholic Charities argues that the WCEA's religious employer exemption similarly advantages certain religious organizations that focus on religious teachings while disadvantaging those, like itself, focused on performing charitable works. It contends that the WCEA's requirement for contraceptive insurance coverage imposes unequal burdens on various religious organizations, paralleling the discriminatory impact of the Minnesota law in Larson. The WCEA's religious employer exemption specifically benefits religious organizations opposed to prescription contraceptives, distinguishing it from the invalidated charitable reporting exemption in Larson v. Valente. Unlike the Minnesota law, which treated non-qualifying religious organizations the same as nonreligious ones, the WCEA applies equally to Catholic employers that do not qualify, aligning them with other employers regardless of religious affiliation. The WCEA is justified under the compelling state interest of eliminating gender discrimination. However, the limitation of the exemption to organizations focused on inculcating religious values raises constitutional concerns, particularly regarding the exclusion of entities like Catholic Charities that provide social services without a primary religious mission. Catholic Charities has conceded that it does not meet the criteria for the exemption, thereby necessitating coverage for prescription contraceptives in its health plans. The dissenting opinion emphasizes the complexity and evolving nature of free exercise jurisprudence since the Supreme Court’s Smith decision, advocating for careful consideration of constitutional implications in the court's future decisions. Neutral, generally applicable laws do not need to survive compelling state interest scrutiny after the Smith decision, meaning they require no justification regardless of how they burden individual religious claimants or the significance of the government interest. However, the application of Smith to laws that directly conflict with the religious practices of organizations is unclear. The Women's Contraceptive Equity Act (WCEA) creates a narrow exemption for churches, raising the critical question of whether the government can distinguish between the religious and secular aspects of bona fide religious organizations. This distinction may infringe upon the religious freedom of parts of the organization deemed secular. While proponents of the WCEA advocate for gender equity in the workplace, the discussion centers on whether the government can mandate religiously affiliated employers to provide contraceptive coverage that violates their religious beliefs or redefine what constitutes religious conduct. The conflict between the government's interest in preventing discrimination and the constitutional right of a church to govern its affairs without interference illustrates the tension between these two significant constitutional values. The historical precedence of religious liberty has shaped the concepts of limited government and equal protection, which underpin antidiscrimination laws. The division between temporal and spiritual authority is foundational to liberal democracy, fostering concepts such as limited government, individual rights, and civil society, which is responsible for shaping public opinions. Religious institutions play a crucial role in this framework by enhancing individual autonomy and presenting alternative visions that challenge dominant societal norms. Protecting these institutions from unnecessary state interference benefits both individuals and society, while neglecting their transformative potential undermines political discourse and the principles of liberal democracy. The applicability of the Smith case to religious organizations is complex. While the Smith ruling emphasizes that individuals must comply with neutral laws even if those laws conflict with their religious beliefs, some courts argue that this does not necessarily extend to religious institutions. The current case involves a religious organization rather than an individual and addresses whether a law mandating a benefit against the organization’s theological beliefs is constitutional. The majority's analysis overlooks critical distinctions between individual and institutional rights, including the possibility that churches may be relieved from certain legal obligations under specific circumstances, a nuance the majority inadequately addresses, particularly regarding the ministerial exception. The ministerial exception to Title VII, established in cases such as E.E.O.C. v. Roman Catholic Diocese of Raleigh and Combs v. Central Texas Ann. Conf of United Methodist Church, delineates protections for religious organizations regarding employment decisions related to their ministers. This exception operates within the broader context of church autonomy, which has been upheld in cases like Serbian Eastern Orthodox Diocese v. Milivojevich and Kedroff v. St. Nicholas Cathedral, emphasizing that state interference in religious governance is impermissible. The Supreme Court's First Amendment jurisprudence clarifies that while churches have the right to self-governance and to determine their teachings, this does not extend to allowing members to violate neutral laws that may conflict with those teachings. The legislature's provision of an exemption from the WCEA for churches indicates an acknowledgment of this principle. Additionally, the government is prohibited from dissecting a religious organization into "secular" and "religious" components to impose burdens selectively on the secular side. The Supreme Court recognizes two primary ways government action can infringe on religious exercise: by disrupting personal religious practices and by interfering with church governance. If Catholic Charities qualifies as a "religious employer," it would be exempt from the WCEA's contraceptive coverage requirement, contingent on meeting specific criteria: the entity must primarily promote religious values, employ individuals who share its religious tenets, serve individuals aligned with those tenets, and maintain nonprofit status as defined by the Internal Revenue Code. Catholic Charities fails to meet the criteria for classification as a "religious employer" under the WCEA, primarily because it does not fulfill any of the four specified conditions for that designation. Although it could be classified as such if the Legislature had not narrowly defined the exemption to exclude it, plaintiffs argue that this exclusion misrepresents the Catholic Church's identity by omitting essential components, such as its healthcare and social services. The court acknowledges the government's ability to accommodate religious practices without violating the Establishment Clause, referencing the case of Corporation of the Presiding Bishop v. Amos, which emphasized the importance of community services provided by religious organizations as part of their mission. The ruling asserts that religious organizations must be protected under the Free Exercise Clause, as believers often engage in their faith through these entities. It also highlights that the government cannot discriminate among religions or create a risk of politicizing religion, as established in various landmark cases. The National Labor Relations Board v. The Catholic Bishop of Chicago illustrates the complexities of determining jurisdiction over religiously affiliated entities, with the NLRB's binary distinction between "completely religious" and "religiously associated" being deemed overly simplistic. The Supreme Court's response to this issue emphasized the need to avoid constitutional questions related to religious freedoms while recognizing the potential chilling effects on the bishops' control over religious missions if compelled to engage in collective bargaining. The court raised concerns about the National Labor Relations Board's (NLRB) jurisdiction over religious schools, indicating that such inquiry could challenge clergy-administrators' good faith positions and infringe upon rights protected by religion clauses. In *Universidad Central de Bayamon v. NLRB*, the NLRB's attempt to exempt pervasively sectarian schools did not alleviate these concerns, as the court found that board jurisdiction over institutions with religious purposes risks the same issues identified in *Catholic Bishop*. The *University of Great Falls v. NLRB* case rejected the NLRB's "substantial religious character" test for similar reasons, emphasizing that inquiries into religious beliefs are unnecessary and offensive. The court proposed a broad exemption for schools that provide a religious environment, are nonprofit, and are affiliated with recognized religious organizations, aiming to prevent government interference in religious missions. This framework seeks to uphold constitutional religious liberty without state involvement in defining religious causes. The current case, however, is distinguished by a deliberate intrusion into a religious organization’s expression of its beliefs, representing a willful government judgment about religious matters, which contradicts established legal principles against such interference. Definition can be as harmful as ongoing monitoring if used to suppress religious conduct. The City’s view of religion is limited to spiritual or evangelical aspects, leading to regulation of charitable activities like feeding the hungry. This broad secular definition exacerbates issues surrounding religious liberty. Genuine neutrality requires the state to refrain from taking sides on religious matters, ensuring diverse perspectives are represented in public discourse. The conflict centers on differing views of sexuality: one side advocates for autonomy and freedom from anxiety, while the Catholic Church condemns nonmarital sex and promotes a sacred view of marital relations. The Church argues that the state's limited exemption appears to favor dissenting opinions within the church regarding contraceptive practices and undermines its doctrine, labeling it as 'heresy' in the secular context. The First Amendment prohibits the government from intervening in internal church governance disputes, but conflicts arise when religious conduct clashes with public policy. The issue remains whether the law can compel religious organizations to support conflicting secular values. Religious bigotry, as interpreted from Smith and modified by Lukumi, implies that constitutional protection for religion is contingent upon demonstrating that government actions are motivated by anti-religious intent. Under this view, infringement on religious liberties is only prohibited if the law explicitly aims to suppress religion or treats religious conduct differently. The statute in question mandates prescription coverage for all employers, which does not specifically target religious practices, suggesting a neutral treatment of both religious and secular interests. Consequently, Catholic Charities faces challenges in proving discrimination based on anti-religious motives. However, neutrality is multifaceted, and facial neutrality does not suffice; the Free Exercise Clause also forbids covert suppression of religious beliefs. The actual effect of a law is indicative of its object, and if a law restricts practices due to their religious nature, it is not neutral and requires a compelling interest justification. The general applicability principle mandates that if comparable secular activities are not similarly regulated, the law cannot be deemed generally applicable, invoking strict scrutiny. In this case, while the defendants argue that Catholic Charities can opt out of providing prescription coverage, the organization contends that compliance would compromise its religious principles. The WCEA’s limited exemption raises concerns about genuine neutrality, as it may not sufficiently accommodate religious beliefs. The majority's characterization of this exemption as an accommodation fails to address the broader implications of government interference with religious convictions. Furthermore, it is noted that Catholic Charities employs a small fraction of California's workforce, suggesting that the impact of such religious exemptions may be limited. Some Church employees are aligned with its teachings, while others, including women of childbearing age, are not hindered from seeking alternative employment that meets their contraceptive needs. The existence of Wcea’s mandate, which most California employers do not oppose on religious grounds, actually broadens employment options. Concerns about losing talented female employees may prompt Catholic Charities to reassess its stance, but such a reconsideration does not violate the First Amendment. Federal case law supports the view that legislative distinctions between religious and secular activities of a religious entity constitute an impermissible government entanglement in religion, rendering such actions constitutionally invalid. Strict scrutiny, which has evolved over the years, now allows states to assert compelling interests more easily. While the goal of eliminating invidious discrimination is certainly compelling, the state's interest in enforcing conformity on a religiously opposed employer regarding contraception is less clear. Catholic Charities does not discriminate against women; its opposition to contraception applies universally to all forms of birth control. The WCEA’s definition of religious organizations is narrow, limiting it to those whose sole purpose is religious instruction, which raises concerns about its adequacy. The mandate only applies to employers offering prescription coverage, allowing Catholic Charities to circumvent it by discontinuing such coverage. The state aims to ensure that women are not disproportionately affected by healthcare burdens compared to others. The Women’s Contraceptive Equity Act (WCEA) seeks to alleviate financial disparities for women through employer cooperation. However, if religiously affiliated employers maintain their objections, women employed by these entities may face greater hardships. The justification for a narrow exemption focuses on concerns that broad exemptions could undermine the rule by affecting potentially hundreds of thousands of employees, limit access to nondiscriminatory health and disability insurance, and the desire to maximize coverage. Critiques of these justifications highlight that the WCEA's main objective is to address gender discrimination in health benefits, not merely to enhance access to contraceptives. There is insufficient evidence to support claims that hundreds of thousands of employees would be impacted by the exemption. Furthermore, employers have the option to self-insure, which is exempt from state regulations concerning mandated benefits and discrimination definitions under the Employee Retirement Income Security Act (ERISA). The existence of secular exemptions may bolster the case for a religious exemption under the Smith ruling, necessitating the state to justify its refusal to acknowledge a religious exception in a regulatory framework with multiple exemptions. The potential for the WCEA to withstand strict scrutiny is questioned, suggesting that recent shifts in federal interpretations could allow states to reassess free exercise issues independently. California’s Constitution is asserted to provide rights that are not contingent upon the federal Constitution, emphasizing the importance of maintaining established interpretations regardless of federal changes. The California Constitution provides an affirmative right to free speech that is deemed more expansive than the First Amendment of the U.S. Constitution. While California's establishment clause aligns with federal provisions, its free exercise clause guarantees the enjoyment of religion without discrimination, though it does not permit acts that disrupt public peace or safety. The ambiguity surrounding the drafting history of the free exercise clause leaves the applicability of strict scrutiny under California law unresolved. Other states with similar clauses have required this strict scrutiny for infringements on religious rights, necessitating a demonstration of a compelling state interest that is the least restrictive means of achieving that interest. Judicial precedents indicate that the state's interests must be significant enough to justify any limitations on religious practices, and merely using heavy-handed measures against minor issues is inconsistent with constitutional principles. Past cases, such as *People v. Woody*, have applied strict scrutiny based on the First Amendment, suggesting that California's provisions should not remain inactive in free exercise claims. The compelling state interest test requires courts to evaluate competing constitutional values, as established in *Woody*. The court determined that merely asserting potential negative impacts on a statutory scheme is inadequate. In *Woody*, uniform enforcement of neutral drug laws did not justify interference with sincere religious practices. The court emphasized the importance of protecting individual and group self-expression in a conformist society, especially when the government attempts to redefine core religious beliefs. The state failed to demonstrate a compelling interest in enforcing a contraceptive coverage mandate, as only about 10% of commercially insured Californians lack such coverage, suggesting that Catholic employers represent a minimal portion of this group. Additionally, the Legislature's refusal to broaden exemptions, which would avoid government involvement in determining religious definitions, lacks a substantial rationale. There is no evidence that exempting Catholic Charities would undermine the effectiveness of the law or create significant administrative challenges. The argument questions how granting exemptions could defeat the purpose of the bill when the coverage gap is relatively small. The summary concludes that equality should not compromise freedom, and accommodations should be made when possible. The excerpt also references the Women's Contraceptive Equity Act (WCEA), which includes specific provisions for health care service plans. A health care service plan contract providing outpatient prescription drug benefits must cover various FDA-approved prescription contraceptive methods specified by the plan. If a patient's provider determines that none of these methods are suitable based on the patient's medical or personal history, the plan must cover an alternative FDA-approved contraceptive method prescribed by the provider. Coverage for outpatient prescription benefits must be consistent for the enrollee's spouse and nonspouse dependents. Religious employers can request a health care plan without coverage for contraceptive methods that conflict with their religious beliefs. Such employers must meet specific criteria, including the inculcation of religious values, employment of individuals who share their tenets, and primarily serving individuals with similar beliefs, while also being a nonprofit as defined by the Internal Revenue Code. Employers invoking this exemption must notify prospective enrollees of the contraceptive services excluded for religious reasons. Additionally, the section clarifies that coverage for prescription contraceptive supplies is not limited to contraceptive purposes; it can include treatments for other health issues like ovarian cancer prevention or menopause symptoms. The authority of the Department of Managed Care to ensure compliance with coverage regulations is affirmed, and it is specified that no health care plan is required to cover experimental or investigational treatments. The document also notes that the regulation of disability insurance policies falls under a different code than health care service plans. Finally, the excerpt references a court case establishing tests for determining potential violations of the establishment clause. A statute must fulfill three criteria to be constitutional concerning religion: it must have a secular legislative purpose, its primary effect should neither advance nor inhibit religion, and it should not result in excessive governmental entanglement with religion. Various cases illustrate the application of these principles, including challenges to governmental actions affecting Native American practices, prison regulations, military dress codes, selective service laws, Sunday closing laws, child labor laws, compulsory vaccination, and polygamy laws. In Bowen v. Roy, the Supreme Court did not definitively rule on whether the free exercise clause prevented the federal government from requiring Native Americans to provide Social Security numbers but indicated that the case would be governed by the precedent set in Sherbert. The WCEA is argued to benefit the Catholic Church rather than discriminate against it since no other religious group opposed to contraceptives has been identified. However, this does not inherently violate the establishment clause, as laws aimed at alleviating government-created burdens on religious exercise can be valid, provided they are neutrally phrased to allow accommodation for unidentified religions. The case of Larson is cited, emphasizing that laws that explicitly discriminate among religions or denominations are unconstitutional. The Unification Church is referenced as a context for discussing the eligibility of religious organizations under the WCEA's exemption, highlighting that nothing in Catholicism precludes a Catholic organization from qualifying. It is assumed that a Catholic diocese or parish would typically meet this exemption. The precedent set in Larson allows the state to regulate organizations claiming religious status, requiring proof of their religious nature without infringing on their rights. Catholic Charities argues that the Legislature's treatment of the WCEA reflects hostility towards the Catholic Church, drawing a comparison to a case involving the Santeria religion that was suppressed by a local council. However, the legislative history of the WCEA shows no similar animosity towards Catholics. Furthermore, Catholic Charities briefly raises the establishment clause as a basis for hybrid rights, but these claims have been deemed meritless. The excerpt emphasizes that while freedom of religion is protected, it does not excuse actions that disrupt state peace or safety. It also mentions that the Supreme Court found RFRA unconstitutional and notes a misinterpretation in a related case, although the ultimate conclusion regarding the statutes in question remains unchallenged. Recent legislative amendments to the Vehicle Code are mentioned, allowing alternate identifiers beyond Social Security numbers. The obligation to provide adequate health care coverage, particularly concerning contraceptives, raises questions about the intersection of religious beliefs and legal mandates. A religious employer opposed to contraceptives could potentially avoid conflict by not covering prescription drugs and instead offering employees a raise, which may be costlier than insurance coverage. Such a law could impose a constitutionally significant burden on religious exercise by making religious practices more expensive. Nevertheless, it is unreasonable to expect legislators to refrain from regulating conduct that might economically disadvantage some religious groups due to their specific practices. At least 19 states mandate employers or insurers to provide prescription contraceptive coverage. The Supreme Court case Larson v. Valente is interpreted to prohibit laws that discriminate among religious denominations, which may not apply to Catholic Charities, a Roman Catholic organization. The constitutionality of the religious employer exemption under the Women’s Contraceptive Equity Act (WCEA) is questionable, as it may disadvantage entities focused on humanitarian efforts rather than solely religious instruction. California's law allows employers providing prescription coverage to either include contraceptives or forgo prescription coverage entirely, which could lead to a situation where all employees are worse off. Earlier versions of the WCEA included a broader conscience clause acceptable to Catholic Charities, allowing exemptions for religiously affiliated organizations, but the current version exempts only specific entities like churches and seminaries from providing contraceptive coverage. Senator Speier highlighted during legislative debates that a significant majority of California's Catholic hospitals already offer such coverage, suggesting that the issue has been largely resolved. Senator Speier highlights that a significant majority of Catholic women of childbearing age use contraception, and most Catholics believe that practicing artificial birth control does not preclude one from being a good Catholic. This acknowledgment does not preclude the government from imposing limits on religious organizations, particularly when neutral laws apply or when aggressive interventions are needed to prevent harm, as illustrated in Walker v. Superior Court (1988), where a Christian Scientist was found liable for failing to seek medical treatment for her child despite religious beliefs. Limitations on religious freedoms may be warranted in rare cases where practices endanger lives or cause serious bodily harm. In the context of employment, Catholic Charities reportedly employs fewer than 50,000 individuals, a small fraction of California's workforce, suggesting that exemptions for Catholic organizations would have a negligible impact. Citing statistics from the Bureau of Labor, it is estimated that about 5 million women aged 16 to 45 are employed in nonfarm jobs in California, with Catholic employees representing a minimal percentage. The majority's argument referencing United States v. Lee asserts that allowing exemptions for employers imposes their religious beliefs on employees; however, this interpretation is questioned, as both parties in Lee were members of the same religious community and agreed to the exemption, raising doubts about whether an employer can impose beliefs on employees who object. The state possesses the exclusive authority to enforce compliance among adults, compelling them to remain in situations against their will or to act contrary to their desires. In the case of Smith v. FEHC, the court evaluated a law against discrimination towards unmarried cohabitors, concluding that the landlady's religious objections did not constitute a substantial burden since she could choose to exit the rental business. This raises questions about the assumption that employees lack alternatives, contrasting with the options available to some religious claimants. Furthermore, even religious institutions that do not operate educational or social services may struggle with compliance under the WCEA's religious test. It is noted that not all religions actively seek converts, but those that do, such as certain Christian denominations, are commanded to spread their beliefs. Additionally, Catholic Charities highlighted that the eligibility for exemptions may vary based on the specific demographics and hiring practices of different dioceses, as well as the interpretation of theological criteria.