The case of Zubik v. Burwell, heard by the U.S. Supreme Court in 2015, centered on the issue of religious freedom versus mandated contraceptive coverage under the Affordable Care Act (ACA). The plaintiffs were religious non-profit organizations who objected to providing contraception coverage for their employees as required by ACA regulations. They argued that even though there was an accommodation allowing them not to pay directly for such services, merely submitting a form or notification stating their objections still made them complicit in actions against their beliefs and thus violated the Religious Freedom Restoration Act (RFRA). The government countered that this did not impose a substantial burden on practicing religion and served compelling interests in public health and women's well-being. However, instead of issuing a definitive ruling after hearing arguments from both sides, the Supreme Court vacated previous judgments and remanded cases back to lower courts with instructions for parties to seek compromise solutions respecting both religious exercise rights and ensured access to contraception.

The dissenting opinion in the case of Zubik v. Burwell was not officially recorded as the Supreme Court remanded the case back to lower courts without a definitive ruling. However, it is important to note that this case revolved around religious non-profit organizations challenging an aspect of the Affordable Care Act (ACA) which required them to provide contraceptive coverage for their employees. The plaintiffs argued that even filling out a form objecting on religious grounds still made them complicit in providing contraceptives, thus violating their religious freedom rights under Religious Freedom Restoration Act (RFRA). While there wasn't an official dissent, some justices had previously expressed views suggesting they believed ACA's accommodation did not impose substantial burden on these organizations' exercise of religion and hence didn't violate RFRA.