Burwell V. Hobby Lobby

Introduction:

The First Amendment establishes freedom of religion to an extent and prohibits Congress from promoting or restricting certain religious practices, through the Establishment Clause and the Free Exercise Clause. The government reserves the right to restrict religious freedom under specific circumstances, with the intention to protect the people. Various Supreme Court cases have addressed the nuances of this issue, a recent being Burwell v. Hobby Lobby Stores in 2014 in which the sovereignty of managerial religious beliefs affected employee protection.

Facts:

The Patient Protection and Affordable Care Act (ACA), under the United States Department of Health and Human Services (HHS), requires all employee health plans to ensure coverage of preventive services for all people with reproductive capacity, excusing only non-profit religious establishments and religious employers. Moreover, profit-based institutions with religious management and ownership, such as The Hobby Lobby Stores chain, are not excused from the obligations of the act.

Legal Background:

The Hobby Lobby Stores chain is owned by the Greens family, ardent believers of Christian faith and Biblical principles. Certain passages in the Bible implicitly disapprove of birth control usage, the most significant being an implicit disapproval of intentional pregnancy prevention as follows: “And God blessed them; and God said to them, “Be fruitful and multiply, and fill the earth, and subdue it; and rule over the fish of the sea and over the birds of the sky, and over every living thing that moves on the earth.” (NAS, Genesis 1:28). Thereby, the Hobby Lobby Stores rejected the supply of contraceptives to employees based on personal belief, an act against the rules of the Patient Protection and Affordable Care Act (ACA) for profit-based institutions. The Greens family deemed this obligation immoral and against the principles of the First Amendment, suing Kathleen Sebelius, the Secretary of the Department of Health and Human Services.

The case originated in the US District Court in Western Oklahoma. However, the large scale of the store chain authorized the Greens family to sue Sebelius in the HHS, claiming that the obligations of the ACA violate the Religious Freedom and Restoration Act (RFRA), and primarily the First Amendment.

After failed attempts to issue a preliminary injunction to force the cessation of the HHS contraception supply obligations, the Greens family went to the US Court of Appeals for The Tenth Circuit in Denver; The Tenth Circuit overturned the district court’s rejection of injunction, and granted injunction for the Greens family, supporting their rejection of contraception supply. The grounds were solely made on the First Amendment and the RFRA, expanding upon the existing principles and extent of religious freedom granted.

However, the United States Federal Government differed in opinion, and appealed for the United States Supreme Court review. The Supreme Court majority was in favor of Hobby Lobby, winning the Greens family the case and their right to maintain religious managerial practices. The HHS representative was Sylvia Burwell, the head of the HHS after Sebelius’s resignation. President Obama was in office during this 2014 case when the decision was made, though his role remains implicit and not heavily mentioned.

Holding:

The court ruled in favor of Hobby Lobby, taking precedence of the First Amendment and its clauses granting absolute freedom of religion. The five justices in favor were Samuel Alito, John Roberts, Antonin Scalia, Anthony Kennedy, and Clarence Thomas. Samuel Alito claimed that Hobby Lobby “is protected under the RFRA, “ and “argued that the contraceptive mandate of the ACA placed a burden on the exercise of religion of Hobby Lobby, a corporation that indeed counted as an individual with the ability to practice religion.” Alito utilized the extent of force the ACA exerted on the store chain, violating their religious beliefs. However, it is important to take into consideration that all five justices are Catholic, and their religious beliefs could have overridden their decision; such an assumption is made through research, but nothing in this regard was discussed nor considered. Both sides addressed the First Amendment’s Free Exercise Clause, to preclude religious discrimination and abide to the clause’s promise to protect an individual’s religious practices.

The Supreme Court relied on the Religious Freedom and Restoration Act (RFRA) of 1993 and the First Amendment for the foundation of the decision. 

Analysis:

Burwell v. Hobby Lobby as a case is conflicted between the freedom of religion and the right to quality healthcare. When considering the legality of Burwell v. Hobby Lobby, the First Amendments must be considered first. Thus, the Supreme Court’s decision is fair and judged in accordance with their principles and handbook. However, the female employees in the Hobby Lobby chain, and others with similar principles, suffer from inadequate provisions of contraception and overall welfare.

Although the conflict between testaments to historical amendments and more recent healthcare administrative acts seems unresolvable, the authority of the legal evidence for each argument must take precedence. The usage of the First Amendment as the basis for the Supreme Court’s decision, as opposed to the RFRA for Burwell’s arguments, substantiates their reasoning, through seniority of the historical evidence and establishment. Therefore, the Supreme Court’s decision is fair when considering the support for individual arguments, though the prevailing gender-based discriminatory practices come to light constantly. Women are discussed as subservient and subordinate to their husbands and family in the Bible, and a constant emphasis on such practice causes discrimination in business and governmental decision-making. Whether a business is justified using religious principles to exert implicit discrimination remains an ideological debate among modern activists and advocates of traditional principles.

An ideal solution presents an alternative healthcare platform for institutions that refuse to provide contraception because of religious belief; advocacy and petitions for female reproductive self-control and the right to quality healthcare. As modern activism progresses, the Supreme Court might face more complex situations of conflict, between undeniable historical documents and popular reasoning of widespread modern thought.