Burwell v. Hobby Lobby Stores, Inc.
Citation
573 U.S. 682 (2014)
Facts
The Affordable Care Act required employer-sponsored health plans to cover contraceptive methods approved by the FDA. HHS regulations mandated coverage of all FDA-approved contraceptives. Hobby Lobby and other closely held corporations with sincere religious objections to certain contraceptives — specifically those they believed could prevent implantation of a fertilized egg — challenged the mandate under the Religious Freedom Restoration Act (RFRA).
Issue
Does RFRA apply to closely held for-profit corporations, and if so, does the contraceptive mandate substantially burden their religious exercise without being the least restrictive means of advancing a compelling governmental interest?
Holding
Yes on both questions. The Court held RFRA applies to closely held corporations; the mandate substantially burdened the corporations’ religious exercise; and the government failed to show it used the least restrictive means because it could have paid for contraceptives directly (as it already did for exempted religious nonprofits).
Rule / Doctrine
RFRA test: a government action that substantially burdens a person’s sincere religious exercise must be the least restrictive means of serving a compelling governmental interest. The Court declined to decide whether for-profit corporations have constitutional Free Exercise Clause rights — the holding rests entirely on statutory RFRA grounds.
Significance
Hobby Lobby significantly extended the scope of religious accommodation by holding that closely held corporations can assert RFRA claims. It avoided the constitutional Free Exercise question while expanding the practical reach of religious exemptions in the employment context. The decision generated major debate about corporate religious identity and the limits of accommodation.