Burwell v. Hobby Lobby Stores, Inc., 134 S. Ct. 2751

RFRA prohibits government actions that substantially burden religious exercise unless the burden is the least restrictive means to achieve a compelling government interest.
HHS ACA contraceptive mandate requires certain employers' group plans to cover FDA-approved contraceptives without cost sharing, with exemptions for churches and some religious nonprofits.
Three closely held for-profit families (Hahns/Conestoga Wood; Greens/Hobby Lobby/Mardel) challenge the mandate on RFRA and Free Exercise grounds, arguing four contraceptives violate their beliefs that life begins at conception.
HRSA’s Women's Preventive Services Guidelines and an existing religious accommodation for nonprofits are central to the framework; the accommodation excludes coverage from the employer plan and funds contraceptive services otherwise.
The district courts and circuits differed: Third Circuit said for-profit corporations could not invoke RFRA; Tenth Circuit held they could; Supreme Court granted certiorari.
The Court holds that RFRA applies to closely held for-profit corporations, and that the contraceptive mandate substantially burdens their exercise of religion, but the least restrictive means test fails because a workable accommodation exists.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does RFRA cover for-profit closely held corporations?	Hahn/Conestoga and Greens/Hobby Lobby contend RFRA protects their religious exercise as corporate 'persons'.	RFRA protection does not extend to for-profit corporations; only natural persons or nonprofits.	RFRA applies to closely held for-profit corporations.
Does the contraceptive mandate substantially burden the objecting corporations' religion?	Providing coverage violates their sincere beliefs about abortion and life begins at conception.	Mandate is neutral and generally applicable, with a compelling interest in access to contraception.	Yes, the mandate substantially burdens religious exercise.
Is the mandate the least restrictive means to achieve the government’s interest?	There exists a workable accommodation (for nonprofits and a corporate accommodation) that would avoid burden.	No less restrictive means were adequately shown; the mandate serves broad goals.	No; RFRA requires a less restrictive means, and an accommodation exists that would suffice.
Are there viable accommodations that would satisfy RFRA?	Extending nonprofit accommodations to for-profit corporations would protect religion without harming employees.	The government already has an accommodation for nonprofits; extending it is not necessary for for-profits.	Yes; the government can extend an existing accommodation to for-profit corporations (or otherwise provide coverage without imposing burdens).

Employment Div., Dept. of Human Resources of Ore. v. Smith, 494 U. S. 872 (1990) (rejected Sherbert-style balancing for generally applicable laws)
City of Boerne v. Flores, 521 U. S. 507 (1997) (RFRA least-restrictive-means requirement; precludes overreach)
Gonzales v. O Centro Espírita Beneficiente União do Vegetal, 546 U. S. 418 (2006) (RFRA scope and compelling-interest test guidance)
United States v. Lee, 455 U. S. 252 (1982) (tax/benefit system burdens and religion; pre-RFRA context)
Gallagher v. Crown Kosher Super Market of Mass., Inc., 366 U. S. 617 (1961) (pre-Smith case recognizing corporate free-exercise claims)
Braunfeld v. Brown, 366 U. S. 599 (1961) (business practices and religious burden; pre-Smith context)
Thomas v. Review Bd. of Indiana Employment Security Div., 450 U. S. 707 (1981) (honest religious conviction ruling; line-drawing in beliefs)
Bowen v. Roy, 476 U. S. 693 (1986) (limits of government accommodation in RFRA context)