Wieland v. United States Department of Health & Human Services
196 F. Supp. 3d 1010
E.D. Mo.2016Background
- Paul and Teresa Wieland, lifelong Roman Catholics, object to health plans that include FDA-approved contraceptives and claim RFRA protection against the ACA contraceptive mandate.
- Mr. Wieland, a Missouri state representative, receives employer-provided coverage through Missouri Consolidated Health Care Plan (MCHCP); MCHCP previously offered an opt-out from contraceptive coverage but discontinued it after a 2013 district-court decision (Huff).
- Plaintiffs allege the Mandate forces them to choose between violating their religious beliefs by keeping coverage that includes contraceptives or losing coverage and suffering penalties under the individual mandate; they seek injunctive relief under RFRA.
- Defendants moved for summary judgment arguing Plaintiffs lack redressability and that the Mandate does not substantially burden religion or is the least restrictive means; Plaintiffs argued statutory protections (Mo. Rev. Stat. §191.724) and that an injunction would let them obtain a contraceptive-free plan.
- The Eighth Circuit previously found redressability not speculative and remanded; on summary judgment the district court again found Plaintiffs had standing and that the Mandate violated RFRA as not the least restrictive means.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing/redressability | An injunction would allow Plaintiffs to pursue a contraceptive-free plan from MCHCP (and §191.724 bars discrimination) or seek private plans/avoid penalties | Plaintiffs cannot show MCHCP (or another insurer) would actually offer a contraceptive-free plan; redress is speculative | Plaintiffs have standing; injunction would materially increase likelihood of obtaining relief (court follows Eighth Circuit) |
| Substantial burden under RFRA | Mandate coerces Plaintiffs to keep coverage that violates beliefs or forgo coverage and incur penalties — a substantial burden | Mandate regulates insurers, not individuals; mere inclusion of services not used by plaintiffs is not a substantial burden | Mandate imposes a substantial burden: it forces a choice to violate beliefs or suffer penalties/lose benefits |
| Compelling interest / least restrictive means | Government can achieve goals without burdening Plaintiffs (e.g., allow opt-outs like pre-Mandate Missouri system; let insurers decide) | Government has a compelling interest in broad access to preventive services and a workable insurance market; individualized exemptions would be administratively unworkable | Court assumes compelling interest but finds government failed RFRA’s least-restrictive-means test; alternatives exist that would further interest with less burden |
| Scope of relief | Seek injunction relieving Plaintiffs and their issuer from enforcement requiring contraceptive coverage | Government opposes broad relief that would undermine universal preventive coverage | Court permanently enjoins enforcement of Mandate as to Plaintiffs and their issuer; ruling does not affect coverage obligations for those who want contraceptives |
Key Cases Cited
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing and redressability standards)
- Anderson v. Liberty Lobby, 477 U.S. 242 (1986) (summary judgment standard)
- Burwell v. Hobby Lobby Stores, Inc., 573 U.S. 682 (2014) (RFRA protects exercise of religion; substantial-burden and least-restrictive-means framework)
- Thomas v. Review Bd. of Ind. Emp’t Sec. Div., 450 U.S. 707 (1981) (substantial-burden test under Free Exercise precedents)
- Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal, 546 U.S. 418 (2006) (government must show compelling interest and narrow tailoring under RFRA)
- Sherbert v. Verner, 374 U.S. 398 (1963) (least-restrictive-means and religious accommodation principles)
- Lyng v. Northwest Indian Cemetery Protective Ass’n, 485 U.S. 439 (1988) (distinction between incidental effects and coercion of religion)
- Wieland v. U.S. Dep’t of Health & Human Servs., 793 F.3d 949 (8th Cir. 2015) (Eighth Circuit remand finding redressability not speculative)
- Real Alternatives, Inc. v. Burwell, 150 F. Supp. 3d 419 (M.D. Pa. 2015) (contrasting district-court view on substantial burden and redressability)