Eden Foods, Inc v. Sebelius, No. 13-1677 (6th Cir. 2013)
Annotate this CaseThe Patient Protection and Affordable Care Act and the Health Care and Education Reconciliation Act of 2010, collectively, the Affordable Care Act require that most businesses employing 50 or more individuals provide female employees with health-insurance coverage that includes, at no cost to the employee, “such additional preventive care and screenings . . . as provided for in comprehensive guidelines supported by the Health Resources and Services Administration.” 42 U.S.C. 300gg-13(a)(4). Those guidelines require plans to cover “[a]ll Food and Drug Administration approved contraceptive methods, sterilization procedures, and patient education and counseling for women with reproductive capacity.” Eden Foods, Inc., and Potter sought an injunction to prevent federal agencies from enforcing that mandate against them. They contend that offering such contraceptive services to the employees of Eden Foods would substantially burden the plaintiffs’ religious beliefs and contravene protections under the Religious Freedom Restoration Act, 42 U.S.C. 2000bb–2000bb-4 (RFRA). The district court denied relief. The Sixth Circuit affirmed. A for-profit corporation is not a “person” capable of religious exercise as intended by RFRA and individual shareholders/owners of a corporation have no standing to challenge provisions of laws that the corporation must obey.
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