Autocam Corporation v. Kathleen Sebelius
730 F.3d 618
6th Cir.2013Background
- Autocam is a for-profit, secular corporation (Autocam and Autocam Medical) owned by Kennedy family members who are devout Roman Catholics.
- Kennedys claim their religious beliefs require them to provide health coverage but prohibit funding contraception and sterilization, which would occur if they complied with the ACA mandate.
- Autocam is self-insured; it would face substantial penalties under the ACA if it does not cover contraception and related education.
- Plaintiffs sought a preliminary injunction arguing RFRA requires exemption from the mandate; district court denied.
- Court addressed Article III standing, AIA preclusion, and whether Autocam (a corporation) can bring RFRA claims as a “person.”
- Court ultimately held Autocam is not a “person” eligible for RFRA relief and dismissed the Kennedys’ individual RFRA claims, remanding to dismiss those claims; affirmed denial of injunction on merits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| RFRA and corporate personhood | Autocam is a for-profit corporation that can exercise religion under RFRA. | RFRA protects individuals and certain entities, not for-profit secular corporations. | Autocam not a RFRA-person; merits fail. |
| Standing of the Kennedys individually | Kennedys have direct, personal injury distinct from Autocam's injury. | Shareholder standing bars RFRA claims for individuals based on the corporation's obligations. | Kennedys lack standing; dismiss Kennedy RFRA claims. |
| AIA effect on RFRA pre-enforcement challenge | AIA does not bar pre-enforcement RFRA challenge to the mandate. | AIA precludes suits seeking to restrain tax assessment/collection. | AIA does not bar the RFRA challenge. |
Key Cases Cited
- National Federation of Independent Business v. Sebelius, 132 S. Ct. 2566 (2012) (AIA preclusion discussion and regulatory context cited)
- United States v. Lee, 455 U.S. 252 (1982) (individual religious objection to government-imposed obligation context)
- Wisconsin v. Yoder, 406 U.S. 205 (1972) (free exercise rights for individuals and religious belief)
- Sherbert v. Verner, 374 U.S. 398 (1963) (pre-Smith RFRA antecedent free-exercise framework)
- Rowland v. Cal. Men's Colony, Unit II, 506 U.S. 194 (1993) (context for statutory interpretation and standing considerations)
- Franchise Tax Bd. v. Alcan Aluminium Ltd., 493 U.S. 331 (1990) (prudential standing and corporate-person conceptions in standing analysis)
- Kush v. American States Ins. Co., 853 F.2d 1380 (7th Cir. 1988) (fiduciary duties and injury attribution in corporate context)
- Stormans, Inc. v. Selecky, 586 F.3d 1109 (9th Cir. 2009) (RFRA analysis and corporate/individual rights considerations)
- O Centro Espirita Beneficente Uniao do Vegetal v. Ashcroft, 546 U.S. 418 (2006) (RFRA two-step framework and substantial burden analysis)
- Church of the Lukumi Babalu Aye v. City of Hialeah, 508 U.S. 520 (1993) (free exercise rights framework and religious freedom history)