Southern Nazarene University v. Azar
5:13-cv-01015
W.D. Okla.Dec 23, 2013Background
- Universities are Christ-centered and object to coverage of Plan B, ella, and IUDs for employees and students based on sincere religious beliefs.
- Universities provide employee and student health insurance, with multi-plan arrangements and specific exclusions for objectionable methods.
- ACA amendments require contraceptive coverage; non-exempt religious groups may seeks accommodations via self-certification and third-party arrangements.
- Temporary Enforcement Safe Harbor provided for eligible organizations, expiring for plan years beginning 2014 or later; many universities are ineligible for the exemption.
- Stipulated facts establish plan years, enrollment numbers, and that self-certification and accommodations affect how coverage is administered.
- Court grants preliminary injunction preventing enforcement of the challenged contraception coverage requirements and related self-certification regulations pending ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether RFRA imposes a substantial burden on the Universities | SNU, OKWU, OBU, MACU—burdened by self-certification and coverage requirements. | Regulations do not substantially burden sincere religious exercise. | Yes; substantial burden shown. |
| Whether the accommodation is the least restrictive means to further a compelling interest | The accommodation imposes pressure on conscience and is not least restrictive. | Regulations serve compelling interests in health and equality with accommodations. | Not demonstrated; least restrictive means not shown. |
| Irreparable harm and balance of equities | RFRA violations cause irreparable harm; burden outweighs interests. | Public health goals justify burdens and exemptions exist for others. | Irreparable harm established; equities favor plaintiffs. |
| Public interest in upholding RFRA-relief at preliminary stage | Emergency relief aligns with protecting religious liberty. | Public health policy supports enforcement. | Public interest favors injunction. |
Key Cases Cited
- Hobby Lobby Stores, Inc. v. Sebelius, 723 F.3d 1114 (10th Cir. 2013) (RFRA governs burden and least restrictive means; injunction standard)
- Kikumura v. Hurley, 242 F.3d 950 (10th Cir. 2001) (RFRA burden analysis and compelling interest framework)
- Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal, 546 U.S. 418 (U.S. 2006) (standards for evaluating compelling interests and exemptions under RFRA)
- Wisconsin v. Yoder, 406 U.S. 205 (U.S. 1972) (compelling interest framework and individualized assessment of rights)