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Keywords

injunctionobjection
objection

Related Cases

Little Sisters of the Poor Saints Peter and Paul Home v. Pennsylvania, 591 U.S. 657, 140 S.Ct. 2367, 207 L.Ed.2d 819, 2020-2 USTC P 50,146, 2020 Employee Benefits Cas. 253,182, 20 Cal. Daily Op. Serv. 6686, 2020 Daily Journal D.A.R. 6994, 28 Fla. L. Weekly Fed. S 519

Facts

The Commonwealth of Pennsylvania filed an action for declaratory and injunctive relief against federal officials regarding interim final rules (IFRs) that exempted certain employers from providing contraceptive coverage due to religious or moral objections. After the Departments of Health and Human Services, Labor, and Treasury issued final rules, Pennsylvania, joined by New Jersey, amended its complaint to challenge these rules. The District Court granted a nationwide preliminary injunction against the final rules, which was upheld by the Third Circuit.

The Commonwealth of Pennsylvania filed an action for declaratory and injunctive relief against federal officials regarding interim final rules (IFRs) that exempted certain employers from providing contraceptive coverage due to religious or moral objections.

Issue

Did the Departments of Health and Human Services, Labor, and Treasury have the authority under the Affordable Care Act to create exemptions for employers with religious or moral objections to providing contraceptive coverage?

Did the Departments of Health and Human Services, Labor, and Treasury have the authority under the Affordable Care Act to create exemptions for employers with religious or moral objections to providing contraceptive coverage?

Rule

The ACA grants the Health Resources and Services Administration the authority to define preventive care and screenings, which includes the ability to create exemptions from its own guidelines.

As legal authority for both exemptions, the Departments invoke § 300gg–13(a)(4), which states that group health plans must provide women with 'preventive care and screenings … as provided for in comprehensive guidelines supported by [HRSA].'

Analysis

The Supreme Court found that the ACA's provision allowed HRSA to create exemptions for employers with religious or moral objections. The Court emphasized that the text of the ACA did not impose limits on HRSA's discretion to define preventive care, and thus the exemptions were valid. The Court also noted that the procedural claims against the exemptions were unfounded, as the Departments had satisfied the APA's notice and comment requirements.

The Departments had the authority under the ACA to promulgate the religious and moral exemptions. Pp. 2379 – 2384.

Conclusion

The Supreme Court reversed the Third Circuit's decision, holding that the Departments had the authority to create exemptions for employers with religious or moral objections under the ACA, and remanded the case with instructions to dissolve the nationwide preliminary injunction.

The Supreme Court, Justice Thomas, held that ACA authorized Health Resources and Services Administration (HRSA) to exempt or accommodate employers’ religious or moral objections to providing no-cost contraceptive coverage.

Who won?

The prevailing party was the federal government, as the Supreme Court ruled in favor of the Departments' authority to create exemptions under the ACA.

The prevailing party was the federal government, as the Supreme Court ruled in favor of the Departments' authority to create exemptions under the ACA.

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