Filed Date: March 20, 2013
Closed Date: 2015
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On March 20, 2013, a for-profit business and its owner filed a lawsuit in the United States District Court for the Eastern District of Michigan, against the U.S. Department of Health and Human Services, under 42 U.S.C. §1983, the Administrative Procedures Act, and the Religious Freedom Restoration Act. The plaintiffs, represented by Thomas More Law Center, a Catholic non-profit legal service, alleged that the Federal Government had violated these acts and the First Amendment. The plaintiffs asked the court for an exception to the Affordable Care Act (ACA) mandate that required employers to provide health insurance coverage of contraception. Specifically, the plaintiffs claimed that providing contraception coverage would violate the owner's religious beliefs.
On March 22, 2013, the plaintiffs filed a motion for an emergency temporary restraining order and preliminary injunction. On the same day, Judge Denise Page Hood denied the motion for an emergency restraining order and scheduled a hearing on the motion for preliminary injunction. In a written opinion, the court explained that other courts had held that the contraception mandate applied only to the corporate entity, not to its officers or owners, and that any burden imposed on an individual owner was "remote and too attenuated to be considered substantial for purposes of the RFRA." Eden Foods, Inc. v. Sebelius, No. 13–11229, 2013 WL 1190001, *1, *4 (E.D. Mich. Mar. 22, 2013). Because the plaintiffs had not expressly made a distinction between the corporate entity and its owner, who brought the suit as the entity's sole shareholder, the court found that the plaintiffs had not shown that they had an action under RFRA.
On May 21, 2013, the court denied the plaintiffs' motion for a preliminary injunction in a written opinion. Again, regarding the plaintiffs' RFRA claim, it cited to the proposition that the mandate only applied to the corporate entity, and thus any burden imposed on individual owners was not considered substantial for purposes of the RFRA. On the plaintiffs' First Amendment claim, the court found that the individual plaintiff owner had not demonstrated that the contraception mandate violated the Free Exercise Clause based on his argument that the mandate was not neutral nor generally applicable, because the mandate's purpose was to promote public health and gender equality.
On the same day, the plaintiffs appealed from the order denying the motion for a preliminary injunction to the United States Court of Appeals for the Sixth Circuit. On May 31, 2013, the parties filed a joint motion in district court to stay the proceedings pending the outcome of the appeal. The district court granted the motion to stay on June 12, 2013.
On Oct. 24, 2013, Judge Martha Craig Daughtrey for the Sixth Circuit denied the plaintiffs' motion for preliminary injunction and remanded the case to district court with instructions to dismiss the case for lack of jurisdiction. Eden Foods, Inc. v. Sebelius, 733 F.3d 626, 633 (6th Cir. 2013). The court cited the law of the Sixth Circuit, announced in the recent decision in Autocam Corp. v. Sebelius, 730 F.3d 618 (6th Cir. 2013), which established that the district court did not abuse its discretion in denying the plaintiffs' requests for injunctive relief. 733 F.3d at 628. The court noted that Autocam held that the individual owners/shareholders lacked standing to bring their claims against the government in their individual capacities under RFRA, nor could they assert the individual plaintiffs' claims on their behalf. The court emphasized that incorporating a business created a "distinct legal entity, with legal rights, obligations, powers, and privileges different from those of the natural individuals who created it, who own[ed] it, or whom it employ[ed]." 733 F.3d at 631 (quoting Autocam, 730 F.3d at 624.
On November 12, 2013, the plaintiffs filed a petition with the United States Supreme Court for a writ of certiorari, and the case was placed on the docket two days later as Case No. 13-591. Soon after, on November 26, 2013, the Supreme Court granted certiorari to a substantially similar case with the same defendants, Burwell v. Hobby Lobby Stores, Inc.. On June 30, 2014, the Supreme Court issued its decision in that case, Burwell v. Hobby Lobby Stores, Inc., 134 S. Ct. 2751 (2014). In a 5-4 opinion by Justice Alito, the Court held that the HHS regulations imposing the contraceptive mandate violated RFRA, when applied to closely-held for-profit corporations.
On July 1, 2014, the Supreme Court granted the plaintiffs' petition for writ of certiorari, and on August 4, 2014, vacated the judgment in this case in light of the Hobby Lobby decision and remanded to the Sixth Circuit for further consideration.
On January 7, 2015, the Sixth Circuit remanded the case to the district court for any further proceedings.
On February 3, 2015, the defendants filed a joint motion to reopen the case at the district court level.
On February 12, 2015, the district court issued a permanent injunction enjoining the defendants from enforcing the ACA contraception mandate against the plaintiffs, and ordered that a judgment be entered in favor of the plaintiffs on their RFRA claim, and dismissing all of the other claims. The court also ordered the parties to meet and confer on the issue of attorneys' fees and costs.
On July 10, 2015, the parties notified the district court that they had reached an agreement on attorneys' fees and costs - they did not specify the details of the agreement - and that no further proceedings were necessary. We believe the case is now closed.
Summary Authors
Wyatt Fore (4/19/2013)
Richard Jolly (4/3/2014)
Elizabeth Greiter (3/12/2018)
Hobby Lobby v. Sebelius, Western District of Oklahoma (2012)
Autocam Corp. v. Sebelius, Western District of Michigan (2012)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/5284559/parties/eden-foods-inc-v-sebelius/
Daughtrey, Martha Craig (Tennessee)
Hood, Denise Page (Michigan)
Berwick, Ben (Michigan)
Berwick, Benjamin Leon (District of Columbia)
Humphreys, Bradley Philip (District of Columbia)
Daughtrey, Martha Craig (Tennessee)
Hood, Denise Page (Michigan)
Randon, Mark (Michigan)
See docket on RECAP: https://www.courtlistener.com/docket/5284559/eden-foods-inc-v-sebelius/
Last updated March 8, 2024, 3:05 a.m.
State / Territory: Michigan
Case Type(s):
Special Collection(s):
Contraception Insurance Mandate
Key Dates
Filing Date: March 20, 2013
Closing Date: 2015
Case Ongoing: No
Plaintiffs
Plaintiff Description:
A for-profit business and its owner seeking an exception to the Affordable Care Act's mandate requiring employers to provide health insurance coverage of contraception because it violated the owner's religious beliefs.
Plaintiff Type(s):
Public Interest Lawyer: Yes
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
United States Department of Health and Human Services (Washington), Federal
United States Department of Labor (Washington), Federal
United States Department of Treasury (Washington), Federal
Defendant Type(s):
Case Details
Causes of Action:
Religious Freedom Rest. Act/Religious Land Use and Inst. Persons Act (RFRA/RLUIPA)
Administrative Procedure Act, 5 U.S.C. §§ 551 et seq.
Declaratory Judgment Act, 28 U.S.C. § 2201
Constitutional Clause(s):
Available Documents:
Injunctive (or Injunctive-like) Relief
Outcome
Prevailing Party: Plaintiff
Nature of Relief:
Injunction / Injunctive-like Settlement
Source of Relief:
Form of Settlement:
Court Approved Settlement or Consent Decree
Order Duration: 2015 - None
Content of Injunction:
Issues
Reproductive rights:
General:
Discrimination-basis:
Type of Facility: