Burwell v. Hobby Lobby
Burwell v. Hobby Lobby was a significant Supreme Court case that addressed the intersection of corporate rights and religious freedom in the United States. In 2012, Hobby Lobby, a craft store chain owned by the devoutly Christian Green family, challenged the Affordable Care Act’s mandate requiring employers to provide health insurance that covers certain contraceptives, which the Greens equated with abortion. The case centered on the Religious Freedom Restoration Act (RFRA), which protects individuals' rights to practice their religion without government interference. In a narrow 5-4 ruling in 2014, the Supreme Court decided that closely held corporations, like Hobby Lobby, could be considered as having religious beliefs, thus granting them the same legal protections as individuals regarding religious practices. The majority opinion stated that the government's fines for non-compliance imposed an undue burden on the corporation’s religious exercise. However, the dissenting justices warned that this ruling could allow corporations to opt out of various federal laws by claiming religious objections, raising concerns about potential effects on civil rights, particularly women's rights. This landmark decision remains a pivotal moment in discussions about corporate personhood and religious liberties in America.
Burwell v. Hobby Lobby
Burwell v. Hobby Lobby Stores, Inc. was a landmark Supreme Court case involving the religious rights of American corporations. The arts and crafts store Hobby Lobby sued the U.S. government in 2012, claiming that the government could not force the owners of a corporation to provide contraceptives to their employees if the use of those contraceptives violates the owners' religious beliefs. In a close 5–4 vote, the Supreme Court ruled in 2014 that certain corporations could be considered religious and thus should be afforded the same legal protections as a person.
Origins
Hobby Lobby, a chain of craft supply stores in the United States, opened its first store in 1972. The Green family owns and runs the corporation. The Greens are devoutly Christian and attempt to run their business in accordance with their personal and religious beliefs. They close Hobby Lobby stores on Sundays, so workers can attend church. They limit stores' operation hours, so employees can spend more time with their families. Each year, the Greens donate 10 percent of Hobby Lobby's profits to charity. Hobby Lobby also pays its workers above the minimum wage and provides health insurance plans to all full-time employees.
The conflict that caused Hobby Lobby Inc. to sue the federal government began with two pieces of legislation: the Religious Freedom Restoration Act (RFRA) and the Affordable Care Act. RFRA states that the government must avoid restricting individuals' religious practice unless the infringing law is "essential to achieve a compelling governmental interest" and the "least restrictive means" of accomplishing that interest. The Affordable Care Act, a health care and insurance overhaul passed during the Obama administration, mandates that certain businesses must provide health care that covers all Food and Drug Administration (FDA) -approved forms of contraceptives without copay.
Hobby Lobby's employee health insurance plans covered a variety of contraceptive options. However, the Greens believe that certain contraceptives, namely "the morning-after pill" and intrauterine devices (IUDs), stop a fertilized egg from implanting in the uterine wall, which they believe qualifies as abortion. The Greens religiously and morally oppose abortion and refuse to allow Hobby Lobby's health insurance plans to cover those contraceptives.
When the government began to fine the corporation for violating the new laws, Hobby Lobby filed suit against the government. The Greens claimed, according to RFRA, it was illegal for the government to force them to pay for what they considered abortions. Even though medical experts did not agree with the Greens' belief, this did not have an effect on the case. The government claimed that Hobby Lobby was a corporation composed of a large number of individual people and thus cannot hold a single religious view. Because it cannot have a religion, the government claimed Hobby Lobby cannot be subject to laws that protect religious expression. The case was first filed with the U.S. District Court for the Western District of Oklahoma in 2012. When that court denied it, the United States Court of Appeals for the Tenth Circuit granted it an appeal. The appeal court ruled in favor of Hobby Lobby. In response, the government appealed to the highest court, the U.S. Supreme Court, hoping it would overturn the original appeals court's ruling. The Supreme Court accepted the case in 2013 and heard the case in 2014.
Supreme Court Case
The Supreme Court's oral session quickly showed the sides the individual justices favored. Justices Ruth Bader Ginsberg and Sonia Sotomayor repeatedly questioned the Becket Fund for Religious Liberty, the law firm representing Hobby Lobby. Justices Samuel A. Alito and Anthony M. Kennedy similarly questioned the lawyers representing the government. Eventually, the court ruled in favor of Hobby Lobby. Justices Alito, Kennedy, Thomas, Scalia, and Roberts voted in favor of exempting Hobby Lobby, while Justices Sotomayor, Kagan, Ginsburg, and Breyer voted against it.
The court's majority opinion stated that closely held corporations, later defined as corporations in which more than 50 percent of the corporation is owned by five or fewer individuals, could hold the religious views of its owners. It also stated that RFRA does not clearly distinguish between corporations and individuals, and the Affordable Care Act could not provide exemptions for nonprofit religious organizations without providing exemptions for other religious organizations. Additionally, the court asserted that the fines imposed by the government for violating the insurance provisions of the Affordable Care Act created an unnecessary substantial burden on the religious practice of the corporation, which would be illegal if applied to an individual.
The dissenting opinion, written by Justice Ginsburg, stated that the ruling could allow closely held corporations to use religion to become exempt to any inconvenient federal legislation. Experts against the ruling used the example of a corporation theoretically becoming exempt from discrimination laws. The ruling also stated that religious beliefs are only required to be respected as long as they do not place a substantial burden on others and stated that refusing specific forms of contraception to female employees constitutes a substantial burden. Many women's rights activists agreed with the dissenting opinion and viewed the controversial ruling as a blow to women's rights to govern their own bodies. These activists noted that every female justice voted against the ruling, while every male justice—except one—voted in favor of it.
Bibliography
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