Grace Schools v. Burwell

Dist. Ct. erred in entering preliminary injunction in favor of plaintiffs-religious not-for-profit organizations in action seeking to prevent defendants from applying or enforcing contraceptive mandate contained in Patient Protection and Affordable Care Act (ACA) as part of plaintiffs’ health plans covering their employees/students. While plaintiffs argued that accommodation under ACA regulations, that allowed them to opt out of contraceptive mandate by filling out Form 700 or notifying govt. directly of their religious objection to contraceptive mandate, gave them no relief and violated Religious Freedom Restoration Act because said regulations caused them to be conduits to provision of same objectionable contraceptive services for their employees/students, Ct. of Appeals found that instant accommodation did not serve as conduit since provision of such services was by operation of federal law and not by any actions that plaintiffs might take. As such, plaintiffs were not entitled to preliminary injunction, although Ct. of Appeals extended said injunction by 60 days for Dist. Ct. to consider other arguments raised by plaintiffs. (Dissent filed.)