Geneva College v. Sebelius
988 F. Supp. 2d 511
W.D. Pa.2013Background
- Geneva College challenges the ACA preventive services mandate as applied to its employee health plan under RFRA.
- The Mandate requires coverage for abortifacient products and devices (ella, Plan B, IUDs).
- The Final Rules add an eligible organization self-certification process for religious organizations.
- Geneva argues the Mandate and Final Rules substantially burden its religious exercise and conscience.
- Geneva plans its 2014-15 employee health plan year and faces potential penalties if it does not comply.
- The court previously granted partial preliminary injunctions in related cases and addressed the interplay with Conestoga Wood and Hobby Lobby.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| RFRA substantial burden on Geneva's exercise of religion | Geneva asserts a substantial burden from the Mandate and Final Rules | Defendants contend the burden is minimal or not substantial due to the self-certification | GRANTED; Geneva likely to succeed on RFRA burden |
| Whether the government interests are compelling and the measure is least restrictive | Geneva argues exemptions render the rule not compelling or narrowly tailored | Defendants claim compelling health interests and exemptions satisfy strict scrutiny | GRANTED; government interests not shown to be compelling given exemptions |
| Irreparable harm and public interest favoring relief | Geneva will suffer irreparable harm to religious liberty and employee welfare | Defendants claim minimal harm due to exemptions and existing enforcement | GRANTED; irreparable harm and public interest favor relief |
| Effect of Conestoga Wood on RFRA analysis in this case | Conestoga Wood does not control nonprofit religious organizations; RFRA lines are not fixed by it | Conestoga Wood bars RFRA claims for certain corporate plaintiffs; relevance limited | GRANTED; Conestoga Wood does not conclusively bar Geneva's claims here |
Key Cases Cited
- Conestoga Wood Specialties Corp. v. Sebelius, 724 F.3d 377 (3d Cir. 2013) (RFRA rights differ for religious organizations vs. for-profit corporations; affects burden analysis)
- Hobby Lobby Stores, Inc. v. Sebelius, 723 F.3d 1114 (10th Cir. 2013) (RFRA rights for for-profit corporations; substantial burden must be justified by least restrictive means)
- Korte v. Sebelius, 735 F.3d 654 (7th Cir. 2013) (for-profit corporations as RFRA 'persons'; substantial burden under RFRA)
- Gilardi v. United States Department of Health and Human Services, 733 F.3d 1208 (D.C. Cir. 2013) (owners of closely-held corporations may have RFRA rights; burden on owners)
- Autocam Corp. v. Sebelius, 730 F.3d 618 (6th Cir. 2013) (corporations not RFRA persons; burden analysis distinctions)