Catholic Diocese of Beaumont v. Sebelius
10 F. Supp. 3d 725
E.D. Tex.2014Background
- Plaintiffs are the Catholic Diocese of Beaumont and Catholic Charities of Southeast Texas, Inc. suing the U.S. departments over ACA contraceptive-mandate coverage.
- Defendants seek to enforce a provision requiring coverage of FDA-approved contraceptives, sterilization, and related counseling.
- Plaintiffs allege the mandate violates RFRA and their Free Exercise and Free Speech rights while asserting standing.
- Court consolidates hearing with merits trial and relies on stipulated findings and record.
- Diocese is exempt as a religious employer under the Final Rules; Catholic Charities may qualify for an accommodation but is not exempt.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does RFRA require permanent injunction given substantial burden | RFRA burden exists due to self-certification obligation | Regulations do not substantially burden religious exercise | Yes; substantial burden established by self-certification requirement. |
| Is the burden on religion justified by compelling government interests and least restrictive means | Defendants fail to show least restrictive means | Public health and equal access are compelling interests | No; burden not shown to be least restrictive means. |
| Do Plaintiffs have Article III standing | Injury from self-certification and potential penalties suffices | No direct enforcement against church plans; no injury | Yes; standing established. |
| Does APA claim survive; do regulations violate APA | APA error in rulemaking | Regulations compliant with law | APA claim dismissed; injunction on RFRA governs. |
Key Cases Cited
- Yoder, 406 U.S. 205 ((1972)) (substantial burden framework for RFRA origins)
- Sherbert v. Verner, 374 U.S. 398 ((1963)) (compelling-interest framework for religious burden)
- Diaz v. Collins, 114 F.3d 69 ((5th Cir. 1997)) (RFRA substantial burden inquiry precedent)
- Moussazadeh v. Tex. Dept. of Criminal Justice, 703 F.3d 781 ((5th Cir. 2012)) (substantial burden standard and indirect coercion)
- E. Tex. Baptist Univ. v. Sebelius, 988 F. Supp. 2d 743 ((S.D. Tex. 2013)) (RFRA substantial burden and alternatives in the circuit)