Monaghan v. Sebelius
2012 U.S. Dist. LEXIS 182857
E.D. Mich.2012Background
- Plaintiffs Monaghan and Domino’s Farms Corp. challenge the ACA contraception mandate under RFRA and First Amendment claims.
- Monaghan, a Catholic, alleges compliance with the mandate would violate his religious beliefs because it would require DF to provide contraception coverage.
- DF is a secular, for-profit company owned by Monaghan; the mandate would impose penalties if not complied.
- Plaintiffs filed an emergency TRO request seeking to enjoin enforcement of the mandate against them.
- Court resolves the motion on the briefs, GRANTING the TRO, with further order for a form of TRO to be submitted.
- Court discusses RFRA standing, substantial burden, and least restrictive means in relation to the government’s asserted compelling interests.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| RFRA standing to sue | Monaghan has RFRA standing via corporate action affecting his beliefs | No RFRA standing for a for-profit corporation or its owner to claim religious exercise | Monaghan has RFRA standing to plead the claim |
| Whether the mandate substantially burdens free exercise | Abiding by the mandate would require DF to provide contraception, conflicting with Catholic beliefs | Mandate serves public health and equality goals and is narrowly tailored | Court assumes substantial burden but finds government failed to show compelling interest and least restrictive means |
| Compelling government interest/least restrictive means | Government has not identified an actual problem requiring constrained religious exercise and exemptions exist | Public health improvement and gender equality are compelling interests; exemptions do not negate the interests | Government failed to establish a sufficiently compelling interest or least restrictive means given the record |
Key Cases Cited
- Thomas v. Review Bd. of Ind. Emp't Sec. Div., 450 U.S. 707 (U.S. 1981) (courts not arbiters of scriptural interpretation)
- United States v. Lee, 455 U.S. 252 (U.S. 1982) (assumed substantial burden on religious exercise in some contexts)
- Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah, 508 U.S. 520 (U.S. 1993) (strict scrutiny applies to laws burdening religious practice)
- Wisconsin v. Yoder, 406 U.S. 205 (U.S. 1972) (compelling interest for religious beliefs in education context)
- Brown v. Entertainment Merchants Ass'n, 131 S. Ct. 2729 (U.S. 2011) (public health and societal interests weighed against free expression rights)