Burwell v. Hobby Lobby: The 2014 Supreme Court Ruling

Burwell v. Hobby Lobby Stores was decided on June 30, 2014. The Supreme Court ruled 5–4 that the Religious Freedom Restoration Act covered closely held for-profit corporations and protected the companies in the case from a federal requirement to include certain contraceptives in employee health plans. The decision was narrower than slogans on either side suggested, but it extended federal statutory religious-exercise protection into a new corporate setting.

The dispute grew from the Affordable Care Act. Federal rules required many employer health plans to cover preventive services without patient cost-sharing. Health agencies included all Food and Drug Administration-approved contraceptive methods. Churches were exempt, and religious nonprofits had access to an accommodation, but ordinary for-profit businesses initially did not.

The companies and their objections

Hobby Lobby Stores and the affiliated Mardel bookstore chain were controlled by members of the Green family. Conestoga Wood Specialties was controlled by members of the Hahn family. Both families said their Christian beliefs prevented them from providing coverage for four methods they believed could operate after fertilization.

The companies did not object to every contraceptive method in the federal rules. That detail matters because the lawsuit concerned specific coverage and specific beliefs, not a general challenge to all preventive care. Medical organizations describe the disputed methods as contraception, not abortion. The courts nevertheless treated the owners’ religious understanding as sincere rather than judging its theological or scientific correctness.

The cases reached different results in lower appellate courts. The Supreme Court combined them to decide whether a for-profit corporation was a “person” capable of religious exercise under RFRA and, if so, whether the coverage rule survived the statute’s demanding test.

How RFRA supplied the legal test

Congress enacted the Religious Freedom Restoration Act in 1993. For federal action, RFRA says government may not substantially burden a person’s exercise of religion unless the burden advances a compelling governmental interest through the least restrictive means.

The first question was whether corporations qualified. Justice Samuel Alito’s majority opinion reasoned that federal law generally includes corporations within the word “person” and that protecting a closely held corporation can protect the people who own and direct it. The opinion noted that nonprofit corporations already exercised religion and found no categorical line excluding a business because it earned a profit.

The Court then found a substantial burden. Refusing coverage could expose the companies to large financial penalties, while providing it would violate the owners’ beliefs. The majority assumed that expanding access to contraceptive care was a compelling interest, then focused on whether the government used the least restrictive method.

The accommodation at the center of the ruling

At the time, religious nonprofit organizations could use an accommodation under which an insurer or plan administrator arranged contraceptive coverage without requiring the employer to contract or pay directly for it. The majority concluded that this existing approach showed a less restrictive option for the companies.

The opinion did not hold that employers could deny employees every benefit by asserting religion. It discussed the specific federal mandate and available alternative. It also said the reasoning should not be read to permit racial discrimination in hiring, which is governed by a different legal history and set of compelling interests.

Justice Anthony Kennedy supplied a separate concurrence emphasizing the availability of the accommodation. His vote was necessary to the five-member majority and reinforced the limited structure of the judgment. The 2014 calendar places the ruling on the final day of the Court’s term.

Justice Ginsburg’s dissent

Justice Ruth Bader Ginsburg wrote the principal dissent, joined in major part by Justices Sotomayor, Breyer and Kagan. She argued that commercial corporations were not the type of religious community RFRA was designed to protect and that the majority shifted the cost of the owners’ beliefs to employees who might not share them.

The dissent also warned about future claims involving other medical services. If courts accepted a corporation’s sincere objection and found a substantial burden, they would need to evaluate compelling interests and possible alternatives across many benefit rules. Breyer and Kagan said it was unnecessary to decide whether for-profit corporations or their owners could bring RFRA claims because the claims failed on other grounds.

The disagreement was partly about what a corporation represents. The majority saw the business as an association through which people act. The dissent stressed its separate legal identity and the diverse interests of employees. Those competing views continue to shape debates over corporate rights.

Later disputes and the ruling’s reach

After Hobby Lobby, the government extended an accommodation to qualifying closely held businesses. Litigation continued over whether completing accommodation paperwork itself burdened religious nonprofits. In Zubik v. Burwell, the Supreme Court sent several such cases back without resolving the central merits question.

Federal administrations later broadened exemptions for employers with religious or moral objections. The Supreme Court upheld the agencies’ authority to issue those exemptions in Little Sisters of the Poor v. Pennsylvania in 2020, while leaving room for other administrative-law questions.

Hobby Lobby did not repeal the Affordable Care Act or create a universal veto over regulation. It applied RFRA’s statutory test to particular companies, a particular coverage requirement and an alternative the majority considered workable. Employees’ access and cost remained the practical concern behind the dissent.

The decision sits alongside other major rulings in the full 2014 calendar. Readers comparing Supreme Court dates can use the day-of-week calculator or review United States v. Windsor, decided one year earlier. The cases involved different laws and rights, but both show how a narrow dispute over federal benefits can produce a decision with consequences far beyond one bill or one workplace.