Skyline Wesleyan Church v. California Department of Managed Health Care, No. 18-55451 (9th Cir. 2020)
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Skyline filed suit against the DMHC in 2016, claiming, among other things, that its right to the free exercise of religion requires the DMHC to approve a health insurance plan that comports with Skyline's religious beliefs about abortion.
The Ninth Circuit reversed the district court's dismissal of the action based on lack of jurisdiction. The panel held that Skyline's claim under the Free Exercise Clause of the First Amendment is justiciable. In this case, Skyline has established each of the three elements of standing with respect to its federal free exercise claim and, relatedly, that this claim is constitutionally ripe; Skyline's free exercise claim is prudentially ripe; and the panel vacated the district court's ruling that none of Skyline's other claims are justiciable and remanded for reassessment in light of our decision regarding the justiciability of the free exercise claim. The panel declined to exercise its discretion in reaching the merits in the first instance.
Court Description: Civil Rights The panel reversed the district court’s ruling that it lacked jurisdiction over plaintiff’s federal free exercise of religion claim, vacated the district court’s ruling that it lacked jurisdiction over plaintiff’s other claims, and remanded for further proceedings. In 2014, the California Department of Managed Health Care and its Director (collectively, the “DMHC”) issued letters to seven health insurers directing them that, effective immediately, their insurance plans had to include coverage for legal abortion. The DMHC had determined that its prior practice of permitting the insurers to offer health plans with some abortion-related restrictions was not consistent with California statutory and constitutional law, which provides that legal abortion is a basic health care service that must be offered. Skyline Wesleyan Church, whose members believe that abortion is impermissible except possibly when the life of the pregnant woman is at risk, filed suit alleging, among other things, that its right to the free exercise of religion required the DMHC to approve a health insurance plan that comported with Skyline’s religious beliefs about abortion. The district court dismissed the case, reasoning that jurisdiction was lacking because (1) any injury Skyline had suffered could not be redressed by a court order directed at the DMHC; and (2) any controversy was not ripe because the DMHC had not yet received a request for approval of an SKYLINE WESLEYAN CHURCH V. CAL. DMHC 3 insurance plan that would be consistent with Skyline’s religious beliefs. The panel first held that Skyline had established each of the three elements of standing with respect to its federal free exercise claim and, relatedly, that this claim was constitutionally ripe. The panel held that Skyline had suffered an injury in fact, noting that before the letters were sent, Skyline had insurance that excluded abortion coverage in a way that was consistent with its religious beliefs. After the letters were sent, Skyline did not have that coverage, and it had presented evidence that its new coverage violated its religious beliefs. The panel further held that there was a direct chain of causation from the DMHC’s directive requiring seven insurers to change their coverage, to Skyline’s insurer’s doing so, to Skyline’s losing access to the type of coverage it wanted. Addressing redressability, the panel noted, as an initial matter, that Skyline requested nominal damages in its complaint. Nominal damages would redress Skyline’s injury, even if only to a minimal extent. The panel further concluded that Skyline’s other requested forms of relief—a declaration that the coverage requirement violated its rights under the Free Exercise Clause and a permanent injunction—would likely provide Skyline redress. The panel held that Skyline’s free exercise claim was prudentially ripe. After the DMHC formalized the abortion coverage requirement, there was an immediate effect upon Skyline: its insurer promptly amended Skyline’s plan. The panel held that Skyline’s challenge to the coverage requirement was fit for decision now and that Skyline did not need to first seek an exemption from the coverage 4 SKYLINE WESLEYAN CHURCH V. CAL. DMHC requirement because the enforcement of that requirement had already caused injury. The panel stated that aspects of its discussion of the justiciability of the free exercise claim may apply equally to Skyline’s other claims, but the parties had only briefed the merits of the federal free exercise claim on appeal. The panel vacated the district court’s ruling that the other claims were not justiciable and remanded to the district court to reassess the justiciability of Skyline’s remaining claims in light of the panel’s decision. The panel declined to exercise its equitable discretion to reach the merits of Skyline’s federal free exercise claim. The panel noted that after oral argument, the Supreme Court granted a petition for a writ of certiorari in which one of the questions presented was whether Employment Division v. Smith, 494 U.S. 872 (1990), should be revisited. Skyline’s free exercise claim turned on the application of Smith and later caselaw implementing its holding. Rather than waiting to decide the appeal until after the Supreme Court’s decision, the panel remanded for the district court to determine, after resolving whether Skyline’s other claims were justiciable, when it would be appropriate to proceed on the merits of Skyline’s claims for which there was jurisdiction.
The court issued a subsequent related opinion or order on July 21, 2020.
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