Catholic Benefits Association, The v. Burrows, 732 F.Supp.3d 1014

The Catholic Benefits Association (CBA) and the Bismarck Diocese challenged EEOC regulations implementing the Pregnant Workers Fairness Act (PWFA) and its Enforcement Guidance on Title VII, claiming they violate their religious beliefs, particularly regarding abortion, fertility treatments, and requirements around gender identity.
The Final Rule and Guidance expanded PWFA and Title VII obligations to include accommodations or non-discrimination regarding abortion, fertility treatments, gender identity pronouns, and access to facilities, which the CBA contends contradicts Catholic doctrine.
The CBA is a nonprofit supporting Catholic employers, whose membership requirements include strict adherence to Catholic teachings on life, sexuality, and related conduct.
The EEOC declined to adopt a blanket religious exemption, opting for a "case-by-case" evaluation of religious defenses, which the CBA argues creates a chilling effect on religious exercise.
CBA sought a preliminary injunction, arguing imminent irreparable harm from the threat of enforcement, and that litigation or compliance would substantially burden their religious exercise under the Religious Freedom Restoration Act (RFRA).
The court granted the injunction, finding the CBA likely to succeed on the merits and that the harm to religious exercise outweighed any competing interests.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing/Ripeness	Threat of enforcement is credible and creates a chilling effect on religious exercise.	Injuries are speculative; no enforcement has occurred; not all members necessarily covered.	Credible threat established; sufficient for standing; issues are ripe for adjudication.
RFRA Violation	Compliance or litigation with challenged rules would substantially burden religious beliefs.	Not every request burdens religion; religious defenses are available case-by-case.	Likely substantial burden; RFRA likely violated by Final Rule and Guidance.
Compelling Interest/Least Restrictive	EEOC cannot show denial of exemption is narrowly tailored/least restrictive under RFRA.	Nondiscrimination is a compelling interest; case-by-case review is the least restrictive means.	EEOC failed to show least restrictive means; specific exemption required for claimants.
Scope of Injunctive Relief	Injunction should cover present/future CBA members and contested portions of the rules.	Relief should be limited; future members excluded; certain EEOC procedures allowed to remain.	Relief granted for present/future members, but must be CBA members at time of conduct.

Lujan v. Defenders of Wildlife, 504 U.S. 555 (standing under Article III)
Burwell v. Hobby Lobby Stores, Inc., 573 U.S. 682 (RFRA protects religious exercise broadly)
Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal, 546 U.S. 418 ("compelling interest" must be specific)
Holt v. Hobbs, 574 U.S. 352 (RFRA requires scrutiny of state interest versus religious claimants)
Trinity Lutheran Church of Columbia, Inc. v. Comer, 582 U.S. 449 (government may not discriminate against religion)
Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah, 508 U.S. 520 (laws can’t target religious conduct)
West Virginia State Board of Education v. Barnette, 319 U.S. 624 (government cannot compel speech or orthodoxy)
303 Creative LLC v. Elenis, 600 U.S. 570 (speech protections and government-orthodoxy issue)