Hobby Lobby Stores, Inc. v. Sebelius
568 U.S. 1401
SCOTUS2012Background
- Hobby Lobby Stores, Inc. and Mardel, Inc. are closely held for‑profit corporations controlled by a family; they self‑insure employee health plans.
- HRSA guidelines under the ACA require coverage of certain preventive services, including FDA‑approved contraceptives, in non‑grandfathered group plans.
- Applicants claim the contraception coverage mandate burdens their religious beliefs under RFRA and the Free Exercise Clause.
- District Court denied a preliminary injunction; the Tenth Circuit denied relief pending appeal.
- This Court, exercising the All Writs Act discretion, weighs whether an injunction pending appellate review is appropriate; the standard is very demanding.
- The Court denies the application, finding the rights are not indisputably clear and relief is not warranted to aid appellate jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a circuit justice may grant an injunction pending appeal in RFRA/Free Exercise challenges by closely held for‑profit corporations. | Hobby Lobby claims urgent, clear burden on religious exercise if injunction not granted. | Relief requires indisputably clear rights and compelling handling; here not demonstrated. | Denied; rights not indisputably clear. |
| Whether the All Writs Act allows extraordinary relief to stay contraception‑coverage mandate pending review. | Relief is appropriate to protect religious liberty while adjudication proceeds. | All Writs Act relief is sparingly granted and not warranted here. | Denied; discretionary, sparing relief not shown. |
Key Cases Cited
- Turner Broad. Sys., Inc. v. FCC, 507 U.S. 1301 (1993) (injunctions pending appeal are extraordinary and sparingly granted)
- United States v. Lee, 455 U.S. 252 (1982) (free exercise claims by individual employer limited by tax obligations)
- Ohio Citizens for Responsible Energy, Inc. v. Nuclear Regulatory Comm’n, 479 U.S. 131 (1986) (injunctions pending review require exceptional circumstances)
- Wisconsin Right to Life, Inc. v. Federal Election Comm’n, 542 U.S. 1305 (2004) (not expressly discussed here; cited as precedent on injunction standards)