Geneva College v. Sebelius
960 F. Supp. 2d 588
W.D. Pa.2013Background
- Geneva College challenges ACA preventive services mandate under RFRA as applied to abortifacient/contraceptive coverage in its 2013-2014 student health plan.
- The court previously granted standing to Geneva after reconsideration, allowing RFRA challenges to proceed.
- The mandate requires coverage for contraceptives/abortifacients; Geneva objects on religious grounds and seeks an injunction.
- Interim/Final regulations and safe harbor provisions created a complex regulatory landscape, with exemptions and accommodations under consideration.
- Geneva faces scheduling constraints as the 2013-2014 plan year approaches (August 1, 2013) and must decide on contraction and coverage terms.
- The court concludes that injunctive relief is appropriate to allow Geneva to plan and contract for the upcoming plan year without violating its religious beliefs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| RFRA substantial burden on Geneva’s exercise of religion | Geneva claims the mandate forces it to facilitate objectionable coverage. | Defendant argues the regulations are unsettled and burdens are not clearly established. | Geneva likely shows substantial burden under RFRA. |
| Compelling government interest and least restrictive means | Geneva contends the government’s interests are vague and fail strict scrutiny when tailored to Geneva. | Defendants failed to substantively argue compelling interests applicable to Geneva. | Government failed to establish a compelling interest as applied to Geneva. |
| Irreparable harm and public interest balance | Injury from compelled religious accommodation or loss of health coverage is irreparable and burdens recruitment. | Exemptions and safe harbors mitigate harm; balance weighs against injunction. | Irreparable harm shown; public interest favors relief; balance weighs in favor of injunction. |
Key Cases Cited
- Wisconsin v. Yoder, 406 U.S. 205 (Supreme Court, 1972) (substantial burden if forceful coercion violates central religious tenets)
- Sherbert v. Verner, 374 U.S. 398 (Supreme Court, 1963) (protects religious liberty against selective unemployment benefits denial)
- Thomas v. Review Bd., 450 U.S. 707 (Supreme Court, 1981) (prevents government from forcing choice between religion and benefits; not to dissect beliefs)
- O Centro Espirita Beneficente Uniao do Vegetal v. Ashcroft, 546 U.S. 418 (Supreme Court, 2006) (RFRA applies when government burdens religious exercise; need for compelling interest and least restrictive means)
- Church of the Lukumi Babalu Aye v. City of Hialeah, 508 U.S. 520 (Supreme Court, 1993) (stricter scrutiny of religious exemptions; underinclusion questioning compelling interest)