Abstract
Although NFIB v. Sebelius (hereafter, "Sebelius”) settled the question of whether individuals can be required by federal law to purchase health care insurance, it did not explore the question of whether the Affordable Care Act (ACA) unduly burdens religious liberty. 1 Multiple lawsuits have been filed before various district courts alleging that the ACA unduly burdens religious liberty since it requires that employers provide insurance plans without requiring any cost sharing for “all Food and Drug Administration approved contraceptive methods, sterilization procedures, and patient education and counseling for all women with reproductive capacity.” 2 The contraceptives covered by this mandate include abortifacient drugs and intrauterine devices that prevent embryos from implanting in the womb. 3 Contraceptives are seen by some as immoral and contrary to their religious beliefs. 4 As a result, many lawsuits have been filed seeking injunctive relief from the contraceptive mandate either entirely or just in regard to the contraceptives that are lethal to embryos.