Wieland v. United States Department of Health & Human Services
2015 U.S. App. LEXIS 12463
8th Cir.2015Background
- Paul and Teresa Wieland, devout Roman Catholics, obtain family health coverage through the Missouri Consolidated Health Care Plan (MCHCP) and object on religious grounds to coverage for contraceptives, sterilization, and abortifacients.
- Missouri law previously allowed an employer- or individual-level opt-out (Mo. Rev. Stat. § 376.1199); after the district court decision in Huff invalidated that provision under the ACA, MCHCP eliminated contraceptive-free plan options and placed the Wielands in a plan that includes contraceptive coverage.
- The Wielands sued HHS (and Treasury and Labor) challenging the ACA contraceptive mandate and implementing regulations, alleging RFRA, First Amendment, Due Process, and APA violations and seeking declaratory and injunctive relief to prevent HHS from enforcing the mandate against them.
- HHS moved to dismiss for lack of standing, arguing the challenged provisions apply to group plans/issuers (not individuals) and that any relief would depend on independent actions by the State or MCHCP (neither party to the suit).
- The district court dismissed with prejudice for lack of standing; the Wielands appealed and sought a preliminary injunction pending appeal, which this Court denied administratively.
- The Eighth Circuit reversed, holding the Wielands adequately pleaded causation and redressability: HHS’s enforcement of the mandate led MCHCP to eliminate contraceptive-free options, and an injunction preventing enforcement would likely allow MCHCP (under Missouri law § 191.724) to restore an opt-out for the Wielands.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing — causation: whether injury is fairly traceable to HHS enforcement of the contraceptive mandate | The Mandate forced MCHCP to place Wielands in a plan with contraceptive coverage; enforcement threat caused the change | The Mandate does not directly bind the Wielands; any injury stems from the State/MCHCP’s independent decision not to appeal Huff | Court: Causation satisfied — the Mandate’s coercive effect led MCHCP to eliminate opt-outs; injury fairly traceable to HHS enforcement |
| Standing — redressability: whether injunctive relief against HHS would likely restore a contraceptive-free option | An injunction would allow MCHCP to rely on Mo. Rev. Stat. § 191.724 (and possibly § 376.1199 if Hobby Lobby affects Huff) to offer an opt-out | HHS: It’s speculative that MCHCP would reinstate opt-outs; statute may not require offering opt-outs | Court: Redressability satisfied — injunction would likely enable MCHCP to offer an opt-out under § 191.724 (and possibly § 376.1199 if Huff no longer controls) |
| Justiciability — challenge to regulations that apply to group plans/issuers rather than individuals | Plaintiffs may challenge enforcement as coercively applied to their group plan and causing their injury | HHS: Plaintiffs lack standing because the regulatory provisions do not directly regulate them | Court: Plaintiffs adequately alleged that enforcement against their group plan caused their injury, so challenge is justiciable for standing purposes |
| Remedy scope — whether injunction against HHS would impose decisions on nonparties (State/MCHCP) | Injunction preventing enforcement against MCHCP would likely restore opt-outs without dictating State action | HHS: Relief would improperly require the court to control independent third-party decisions | Court: Because relief would remove the coercive federal threat, the State/MCHCP could lawfully provide an opt-out; remand for merits and further proceedings |
Key Cases Cited
- Flast v. Cohen, 392 U.S. 83 (justiciability requires a case or controversy)
- Gladstone Realtors v. Village of Bellwood, 441 U.S. 91 (standing requires personal injury traceable to defendant)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (standing: elements of injury-in-fact, causation, redressability)
- Bennett v. Spear, 520 U.S. 154 (causation includes determinative or coercive effect on third parties)
- Burwell v. Hobby Lobby Stores, Inc., 573 U.S. 682 (RFRA can bar enforcement of ACA contraceptive mandate against closely held corporations)
- Hastings v. Wilson, 516 F.3d 1055 (Rule 12 standing review standard in Eighth Circuit)
- Miller v. Redwood Toxicology Lab., Inc., 688 F.3d 928 (courts may consider public-record materials on Rule 12 motions)
- Red River Freethinkers v. City of Fargo, 679 F.3d 1015 (standing inquiry is distinct from merits)