Narrative Opinion Summary
This case involves a legal challenge by a family and their closely-held corporation against the enforcement of the Contraceptive Mandate under the Patient Protection and Affordable Care Act (ACA) on the grounds of the Religious Freedom Restoration Act (RFRA). Initially, the district court granted a preliminary injunction preventing enforcement of the mandate against the plaintiffs, a decision affirmed by the Tenth Circuit, which found the mandate substantially burdened the corporation's religious exercise. The Supreme Court subsequently ruled in Burwell v. Hobby Lobby Stores, Inc., that the mandate violated RFRA as applied to closely-held corporations, prompting further proceedings. Following these decisions, the parties sought a permanent injunction; however, they disagreed on its scope. Plaintiffs sought a broad injunction, while defendants argued for a more limited scope. The court granted a permanent injunction favoring Hercules Industries, Inc., while leaving unresolved the standing of the individual owners and their related claims. The injunction remains effective unless modified by the court, with the government bearing the burden of proof for any changes. The case underscores the tension between religious freedom and governmental regulation, highlighting significant questions about the application of RFRA to corporate entities and the scope of judicial relief.
Legal Issues Addressed
Modification of Injunctionssubscribe to see similar legal issues
Application: The government cannot unilaterally modify the injunction unless there is a change in circumstances, and bears the burden of proof for any modification or dissolution.
Reasoning: The government has the burden of proof to justify any modification or dissolution of the injunction based on whether the regulations enforcing the Contraceptive Mandate violate Hercules’ RFRA rights.
Permanent Injunctions and Equitable Principlessubscribe to see similar legal issues
Application: The court emphasized that the scope of a permanent injunction must be narrowly tailored to address proven harm, guided by equitable principles.
Reasoning: The injunction must be narrowly tailored to address the proven harm. The order must articulate the reasons for issuance, specify its terms, and detail the acts restrained or required, in accordance with Fed. R. Civ. P. 65(d).
Religious Freedom Restoration Act (RFRA) and Closely-Held Corporationssubscribe to see similar legal issues
Application: The court determined that closely-held corporations could exercise religion under RFRA, and the Contraceptive Mandate substantially burdens their exercise of religion.
Reasoning: The Tenth Circuit found that the corporations, Hobby Lobby and Mardel, had standing to challenge the Contraceptive Mandate, but did not address the individual standing of the owners. It ruled that closely-held corporations can exercise religion under the Religious Freedom Restoration Act (RFRA) and determined that the Contraceptive Mandate substantially burdens their exercise of religion, given the unanimous religious beliefs of the owners.
Standing of Closely-Held Corporation Ownerssubscribe to see similar legal issues
Application: The standing of the individual owners of closely-held corporations to assert RFRA claims remains unresolved, impacting the scope of injunctions.
Reasoning: Both the Tenth Circuit and the Supreme Court did not decide on the standing of closely-held corporation owners to assert a RFRA claim.
Supreme Court's Authority on RFRA Claimssubscribe to see similar legal issues
Application: The Supreme Court ruled that the Contraceptive Mandate was not the least restrictive means of achieving a compelling governmental interest, affirming the Tenth Circuit’s decision.
Reasoning: The Supreme Court upheld the Tenth Circuit’s decision, affirming that closely-held corporations can exercise religion under RFRA and that the Mandate violated Hobby Lobby’s sincere religious beliefs.