# Becket Fund The most-establishment-respectable of the major religious-liberty litigation shops in the contemporary [[Christian Nationalism Ecosystem]] — analytically distinct from [[Alliance Defending Freedom]] (broader CN-aligned docket and policy advocacy), [[Liberty Counsel]] (more aggressive culture-war litigation), [[First Liberty Institute]] (military and public-school religion-clause docket), and [[American Center for Law and Justice]] (Robertson-era populist evangelical). Founded in 1994 by Kevin Hasson and named for Saint Thomas Becket (the 12th-century Archbishop of Canterbury murdered for resisting Henry II), the Becket Fund positions itself as a *religious-pluralism* advocate — taking on cases for Muslim, Jewish, Sikh, Native American, and Hindu plaintiffs in addition to its overwhelmingly Catholic and Christian-evangelical clientele. Becket's cumulative case-list is among the most consequential of the post-1990 religious-liberty docket: ***[[Burwell v. Hobby Lobby]]*** (2014, contraceptive-mandate exemption for closely-held religious corporations); ***Little Sisters of the Poor v. Pennsylvania*** (2020, contraceptive-mandate exemption for religious nonprofits); ***Hosanna-Tabor v. EEOC*** (2012, "ministerial exception" to employment-discrimination law); ***Holt v. Hobbs*** (2015, RLUIPA accommodation for Muslim prisoners); ***[[Carson v. Makin]]*** (2022, Maine school-tuition program required to include religious schools). The pluralism positioning is genuine — Becket has represented non-Christian religious plaintiffs — but the institutional effect of the docket is overwhelmingly to expand religious-liberty exemptions and religious-funding access in ways that disproportionately benefit conservative Christian institutions. For the Right Wing KB, Becket is the **respectability-credentialed wing** of the Legal-Litigation Infrastructure layer (see [[Christian Nationalism Ecosystem]]). Its cases typically generate amicus support from the Federalist Society network, draw favorable opinions from the Roberts Court's Catholic-conservative majority, and provide the constitutional vehicles through which CN-aligned policy outcomes (religious-school funding, religious-exemption-from-anti-discrimination-law, religious-display rights) are operationalized. Its analytical role differs from ADF's: where ADF often argues *for* the political-cultural CN program, Becket argues *for the doctrinal reshaping* of religion-clause jurisprudence in ways that the political-cultural program then exploits. ## Founding and Leadership **Kevin "Seamus" Hasson** founded the Becket Fund in 1994. Hasson's background was establishment Catholic legal: a graduate of Notre Dame Law School, he had worked at **Williams & Connolly** (one of Washington's most prestigious litigation firms) and in the **Office of Legal Counsel** at the U.S. Department of Justice before founding Becket. The organization's framing — named for the saint who died resisting royal interference with the church — was deliberately chosen to position religious-liberty litigation as defending institutional religious autonomy against state encroachment, a Catholic-inflected framing distinct from the evangelical-Protestant emphasis on individual religious expression. Hasson stepped down as president in 2011 due to health issues. **William Mumma** served as interim president before **Mark Rienzi** assumed the presidency in 2018. Rienzi, a professor at Catholic University's Columbus School of Law, had previously served as Becket's senior counsel and personally argued several of the organization's most important Supreme Court cases, including *Little Sisters of the Poor*. Other key staff include **Eric Rassbach** (vice president and senior counsel), **Lori Windham** (senior counsel who argued *Hobby Lobby* at the appellate level), and **Diana Verm Thomson** (vice president of legal strategy). ### Leonard Leo and the Board **[[Leonard Leo]]** — the Federalist Society co-chairman and architect of the conservative judicial pipeline — has served on Becket's board of directors. Leo's involvement is significant for two reasons. First, he reportedly **rescued Becket from insolvency at least twice** through personal fundraising and donor network connections, making him an institutional savior figure. Second, Leo's dual role on Becket's board and atop the Federalist Society judicial pipeline creates a structural connection between the organization that litigates religious-liberty cases and the network that selects the judges who decide them — a vertically integrated litigation strategy. ## Finances Becket operates as a lean organization relative to its impact. Revenue was approximately **$11.2 million** in 2021 (the most recent widely reported figure). Funding comes from private donors and grants from movement-conservative funders; Becket does not disclose its donor list. The organization is substantially smaller than [[Alliance Defending Freedom]] (~$100M+ annual revenue) but punches above its weight in SCOTUS impact per dollar. ## The Pluralism Strategy Becket's most distinctive institutional feature is its deliberate representation of **non-Christian religious plaintiffs** — a strategic positioning that distinguishes it from every other major religious-liberty firm. Notable non-Christian clients have included: - **Muslim prisoners** (*Holt v. Hobbs*, 2015 — beard-grooming accommodation under RLUIPA) - **Sikh soldiers** (military turban and beard accommodation cases) - **Native American sacred sites** (Apache Stronghold — *Chi'chil Biłdagoteel* / Oak Flat mining dispute, pending) - **Jewish institutions** (various zoning and land-use cases under RLUIPA) - **Santería practitioners** (amicus work in animal-sacrifice cases) The pluralism positioning serves multiple functions. It provides Becket with credibility before liberal and swing justices who might be skeptical of a purely conservative-Christian litigation agenda. It generates favorable press coverage and academic commentary. And it creates doctrinal precedents — particularly under RFRA and RLUIPA — that apply across all religious traditions, including the conservative-Christian institutions that are Becket's primary constituency. ## Major Supreme Court Cases Becket's SCOTUS record is extraordinary: the organization has been involved in **at least 13 Supreme Court cases and has never lost one** (through 2025). The major cases: ### *Hosanna-Tabor Evangelical Lutheran Church and School v. EEOC* (2012) **9-0.** The foundational "ministerial exception" case. A teacher at a Lutheran school was fired after developing narcolepsy and filing an ADA claim. The Court held unanimously that the [[First Amendment]] bars employment-discrimination suits by "ministers" against their religious employers — establishing a robust ministerial exception that exempted religious organizations from a wide range of employment-law requirements. Becket represented the church. The case's significance extended far beyond the specific facts: it established that religious organizations have broad autonomy to hire and fire employees who perform religious functions, insulating them from Title VII, ADA, ADEA, and related statutes. ### *Burwell v. Hobby Lobby Stores, Inc.* (2014) **5-4.** The case that extended RFRA protections to closely-held for-profit corporations, allowing [[Hobby Lobby]] to refuse to provide contraceptive coverage (specifically IUDs and emergency contraception, which the company characterized as abortifacients) under the ACA's employer mandate. Becket represented Hobby Lobby. Justice Alito's majority opinion held that RFRA's protections extend to corporations owned by religious individuals, and that the government had failed to use the least restrictive means to advance its interest in contraceptive access. Justice Ginsburg's dissent warned the decision was "of startling breadth" and would invite a flood of religious-exemption claims. *Hobby Lobby* is arguably the single most consequential religious-liberty decision of the 21st century: it established that for-profit corporations can hold religious beliefs for RFRA purposes — a doctrinal move that opened vast new territory for religious-exemption litigation. ### *Little Sisters of the Poor* (2016 and 2020) The saga spanned two Supreme Court appearances. The Little Sisters, an order of Catholic nuns operating nursing homes for the elderly poor, objected to the ACA's contraceptive mandate — even to the accommodation mechanism (a form notifying the government of their objection, which would trigger third-party coverage). They argued that signing the form made them complicit in providing contraception. **Zubik v. Burwell** (2016) — the Court punted via a per curiam opinion, vacating the lower court decisions and directing the parties to work out a compromise. No compromise materialized. **Little Sisters of the Poor v. Pennsylvania** (2020) — **7-2.** The Court upheld the Trump administration's broad religious and moral exemptions to the contraceptive mandate. Becket represented the Little Sisters. The case functionally ended the contraceptive-mandate litigation cycle by blessing sweeping exemptions. ### *Holt v. Hobbs* (2015) **Unanimous.** Becket represented **Gregory Holt**, a Muslim prisoner in Arkansas who sought to grow a half-inch beard consistent with his religious beliefs. The Court held that the prison's grooming policy violated RLUIPA. The case is the canonical example of Becket's pluralism strategy in action — representing a Muslim inmate generated a RLUIPA precedent that benefited religious claimants of all faiths. ### Recent Cases (2024–2026) **Catholic Charities Bureau v. Wisconsin (2025)** — **9-0.** The Court held that a Catholic social-services organization was exempt from state unemployment-tax obligations under the "church plan" exception. Becket represented Catholic Charities. Another unanimous victory extending institutional religious autonomy. **Mahmoud v. McKnight (2025)** — Pending. A challenge by Muslim parents to mandatory LGBTQ-inclusive curriculum materials in Montgomery County, Maryland, public schools. The parents sought an opt-out on religious grounds; the school district refused. Becket represents the parents. The case tests whether public schools must accommodate religious objections to curriculum content — a new frontier with significant implications for both religious-liberty and LGBTQ-rights law. **Apache Stronghold / Chi'chil Biłdagoteel** — Pending. A challenge to federal authorization of a copper mine at Oak Flat (Chi'chil Biłdagoteel), a site sacred to the San Carlos Apache. Becket represents the Apache Stronghold. The case tests whether RFRA protects Native American sacred sites on federal land from government-authorized destruction — the most ambitious application of Becket's pluralism strategy. ## KB Significance Becket occupies a specific analytical niche in the [[Christian Nationalism Ecosystem]]: it is the **respectability-credentialed doctrinal engineer** of the religious-liberty litigation apparatus. Its cases do not advance the CN political program directly (that is ADF's role) but reshape the constitutional landscape — ministerial exceptions, corporate religious liberty, religious-school funding, religious autonomy from anti-discrimination law — in ways that the political program then exploits. The pluralism strategy is not window dressing; it is a litigation methodology that produces stronger precedents by presenting sympathetic non-Christian plaintiffs and generating unanimous or near-unanimous opinions. But the institutional beneficiaries of the doctrinal architecture Becket builds are overwhelmingly conservative Christian organizations. The Leonard Leo board connection is the structural key: Becket litigates before judges whom Leo's Federalist Society network helped select, creating a vertically integrated pipeline from case selection through judicial confirmation to favorable ruling. ## See Also - [[Alliance Defending Freedom]] - [[First Liberty Institute]] - [[Liberty Counsel]] - [[American Center for Law and Justice]] - [[Federalist Society]] - [[Christian Nationalism Ecosystem]] - [[Religious Liberty]]