# Burwell v. Hobby Lobby Stores Inc. (2014) A landmark U.S. Supreme Court decision (June 30, 2014, 5-4) holding that **closely-held for-profit corporations can exercise religion** under the Religious Freedom Restoration Act (RFRA) of 1993, and can therefore claim exemption from federal regulations — specifically, the Affordable Care Act's contraceptive-coverage mandate — when those regulations substantially burden the corporation's religious exercise and are not the least-restrictive means of advancing a compelling government interest. The opinion was authored by Justice [[Samuel Alito]]; Chief Justice [[John Roberts]] and Justices [[Anthony Kennedy]], [[Antonin Scalia]], and [[Clarence Thomas]] joined. Justice [[Ruth Bader Ginsburg]] wrote a sharp dissent (joined by Sotomayor, Breyer, and Kagan) warning that the decision would "have startling breadth" and was a "decision of startling breadth." ## Why It Mattered *Burwell v. Hobby Lobby* was the **first Supreme Court decision extending free-exercise rights to a for-profit corporation** — an unprecedented expansion of the *[[Citizens United v. FEC]]*-era doctrine that corporations could exercise constitutional rights, here applied specifically to religious exercise. The decision relied on RFRA (a federal statute) rather than the [[First Amendment]]'s Free Exercise Clause, but the underlying logic — that corporations are persons capable of religious exercise — has been the doctrinal anchor for an expanding line of cases extending religious-liberty exemptions into employment, anti-discrimination, healthcare-coverage, and tax contexts. The decision's substantive holding allowed [[Hobby Lobby]] (the Green family's privately-held arts-and-crafts chain) and other closely-held corporations to refuse to cover four specific contraceptive methods (the morning-after pill and three forms of intrauterine devices) the Green family considered "abortifacients." The Court's reasoning emphasized that a less-restrictive accommodation (the existing exemption for nonprofit religious organizations, in which the government would directly arrange contraceptive coverage with insurers) could be extended to closely-held corporations. ## The Doctrinal Trajectory *Burwell v. Hobby Lobby* opens a doctrinal trajectory that runs through several subsequent landmark cases: - ***Little Sisters of the Poor v. Pennsylvania*** (2020) — extending the Hobby Lobby logic from for-profit corporations to religious nonprofits, with even broader exemption authority - ***[[Bostock v. Clayton County]]*** (2020) — Title VII protections for LGBTQ workers; subsequent litigation has tested whether *Hobby Lobby*-style RFRA defenses limit Bostock - ***303 Creative LLC v. Elenis*** (2023) — public-accommodations-law exemptions for businesses with "expressive" religious objections to providing services for same-sex weddings - ***Groff v. DeJoy*** (2023) — Title VII religious-accommodation standard expansion - The ongoing *Hobby Lobby line of cases* in lower courts continues testing the limits of corporate-religious-exemption doctrine The decision is also the doctrinal anchor for arguments that for-profit corporations should be exempt from anti-discrimination law in housing, employment, and public accommodations on religious-liberty grounds — an argument with substantial reach in the post-2020 conservative legal movement. ## Position in the Christian Nationalism Ecosystem For the Right Wing KB, *Burwell v. Hobby Lobby* is the **anchor case** of the contemporary religious-liberty / corporate-religious-exemption legal program of the [[Christian Nationalism Ecosystem]]. The case was argued by [[Becket Fund]] (then known as Becket Fund for Religious Liberty), and the Becket-led docket since 2014 has substantially built on the corporate-religious-personhood doctrine *Hobby Lobby* established. The Green family's broader institutional-cultural infrastructure — [[Hobby Lobby]] itself, [[Museum of the Bible]] (opened 2017), the Bible-curriculum-in-public-schools project — operates within and amplifies the legal-cultural environment the case helped create. ## See Also - [[Hobby Lobby]] - [[Becket Fund]] - [[Museum of the Bible]] - [[Christian Nationalism Ecosystem]] - [[Religious Liberty]]