Heres an interesting Healthcare Law case: Issues: The Religious Freedom Restoration Act (RFRA)(42 USC § 2000bb); Regulations implementing the Patient Protection & Affordable Care (ACA); Requirement that the plaintiff-corporations healthcare plans cover approved contraceptive methods, sterilization procedures, and patient education and counseling for female employees with reproductive capacity (the contraceptive mandate); Factors examined to determine whether plaintiffs showed entitlement to injunctive relief; Northeast OH Coal. for Homeless v. Husted; Gonzales v. National Bd. of Med. Examrs; Likelihood of success on the merits; Autocam Corp. v. Sebelius; Salmi v. Secretary of Health & Human Servs.; Claims raised by the plaintiff-sole shareholder of the corporation; United States v. Lee; Whether a for-profit secular corporation is able to engage in religious exercise under the Free Exercise Clause of the First Amendment and the RFRA; Conestoga Wood Specialties Corp. v. Secretary of U.S. Dept of Health & Human Servs. (3rd Cir.) Court: U.S. Court of Appeals Sixth Circuit Case Name: Eden Foods, Inc. v. Sebelius e-Journal Number: 55665 Judge(s): Daughtrey, Cole, and White The court concluded that the plaintiffs-corporation (Eden Foods) and its sole shareholder (Potter) failed to distinguish their challenges to the applicability of the ACAs contraceptive mandate from those raised in Autocam. Thus, it held that Eden Foods, a secular, for-profit corporation, could not establish that it can exercise religion, and that Potter could not establish standing to challenge obligations placed only upon Eden Foods, not him as an individual. The court affirmed the district courts denial of Eden Foods motion for a preliminary injunction and remanded the case to the district court with instructions to dismiss Potters claims for lack of jurisdiction. Plaintiffs asserted that offering contraceptive services to Eden Foods employees would substantially burden their religious beliefs and thus, contravene the RFRAs protections. They sought a preliminary injunction forbidding federal agencies from enforcing the mandate against them. However, the court concluded that Autocam convincingly establishes that the district court did not abuse its discretion in denying the plaintiffs requests for injunctive relief. As to Potters claims, Autocam relied on basic, well-established principles of corporate law to hold that the individual owners/shareholders of Autocam had no standing to bring their claims against the government in their individual capacities under RFRA, nor [could] Autocam assert the [individual plaintiffs] claims on their behalf. Autocam noted that incorporations basic purpose is to create a distinct legal entity, with legal rights, obligations, powers, and privileges different from those of the natural individuals who created it, who own it, or whom it employs. Autocams resolution of the standing issue constituted the law of the Sixth Circuit, and the court added that even if the Autocam decision had not been issued, it would not have ruled differently on Potters claims. Autocam also resolved Eden Foods claim that the ACAs contraceptive mandate burdened its exercise of religion. Autocam held that a for-profit corporation is not a person capable of religious exercise as intended by RFRA. This holding necessarily guided the courts analysis of the identical issue here. As in Autocam, the corporate plaintiff failed to carry its burden of showing that it had a strong likelihood of succeeding on the merits of its RFRA claims. Because Eden Foods could not establish this first and most critical of the four criteria for justifying issuance of a preliminary injunction, the district court properly denied the relief it sought.
Posted on: Tue, 05 Nov 2013 10:36:59 +0000
Trending Topics
Recently Viewed Topics
© 2015