Geneva College v. Burwell

Questions presented

SCOTUS records, cert granted 6 Nov 2015

The government recently declared that under federal regulations implementing the Patient Protection and Affordable Care Act of 2010 ("ACA"), it is giving "seamless coverage" of contraception to participants in the health plans of objecting religious organizations. 80 Fed. Reg. 41,318, 41,328 (July 14, 2015). Petitioner Geneva College objects as a matter of religious belief to providing a health plan that is seamless with coverage of abortifacients that may prevent the implantation of an embryo. In Burwell v. Hobby Lobby Stores, Inc., 134 S. Ct. 2751, 2785 (2014), this Court held that compelling certain for-profit religious employers to provide health insurance coverage for objectionable FDA-approved contraceptives, see 77 Fed. Reg. 8725, 8725 (Feb. 15, 2012) (the "Mandate"), violated the Religious Freedom Restoration Act ("RFRA"). Geneva College similarly sought relief from the Mandate under RFRA. Yet the decision below held that the Mandate "totally removes" Geneva College from the process, despite its use of "seamless coverage," and therefore it does not burden religious exercise under RFRA, substantially or otherwise. The question presented is: Whether, under Hobby Lobby, the Mandate's imposition of seamless abortifacient coverage on objecting religious nonprofit organizations' health plans substantially burdens religious exercise and violates RFRA.

Opinion summary

Etalia.ai summary of the majority opinion

The case involved Geneva College and other religious non-profit organizations challenging the contraceptive mandate under the Affordable Care Act (ACA), which required employers to provide health insurance covering contraception. The plaintiffs argued that this mandate violated their religious freedoms under the Religious Freedom Restoration Act (RFRA) by forcing them to facilitate access to contraceptives, contrary to their beliefs. The government provided an accommodation allowing these organizations to opt-out of directly providing coverage by notifying either their insurer or Health and Human Services (HHS). However, the plaintiffs contended that even this accommodation made them complicit in actions against their faith. The Supreme Court did not issue a definitive ruling on whether RFRA was violated but instead vacated previous judgments and remanded cases back for further consideration after suggesting both parties find a compromise solution respecting religious exercise while ensuring women receive full healthcare benefits.