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Matt Melone

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Mandating Contraception: The Law Over Politics

Posted: 05/30/2012 8:30 pm

The Obama administration stirred up a hornet's nest with the contraception mandate, which will require religious-affiliated employers to provide free contraception to employees. The angry response from religious groups, Notre Dame and the Archdiocese of New York among them, was predictable. As many as 43 organizations are challenging the constitutionality of the mandate.

Critics claim the requirement is a violation of the First Amendment, of freedom of religion. Perhaps we are arguing the wrong point. Before the nation muddies the waters -- and the political arena -- with yet another Constitutional issue, I ask that we all pause. There is a limit to religious freedom. Reasonable people do not suggest the law carve out exceptions for human sacrifice, hard-core drug use, or bigamy.

The debate actually centers on where the line between religious freedom and a citizens' secular obligations to society should be drawn. This is not a Constitutional issue, but a less glamorous and equally compelling statutory issue.

Let's work through it.

Whether religious groups are to be exempted from laws is a political question, according to current Constitutional precedent. In 1990, the Supreme Court ruled that users of the narcotic peyote could be denied unemployment benefits even if their use was religiously motivated. The Court ruled that as long as laws were neutral toward religion -- and generally applicable -- they didn't violate Freedom of Religion just because they failed to carve out a few exemptions.

Critics of the decision, however, believed that any infringement upon religious liberty could be justified only by a compelling government interest and only if the measure provided the least restrictive means to achieve it.

Critics of Smith won the day politically and by 1993 turned that power into the Religious Freedom Restoration Act. This statute prohibits the government from imposing a "substantial burden" upon a person's free exercise of religion unless it can demonstrate both that "compelling government interest" and the "least restrictive means" of achieving it. The statute -- now only pertinent to federal legislation -- says one more thing: It applies to all subsequent federal legislation.

In other words, it applies to President Obama's Patient Protection and Affordable Care Act. Ultimately, whether the contraceptive mandate will survive depends on the answer to three questions based on this Act.

First, does mandatory contraception coverage "substantially burden" the free exercise of religion? Requiring a religious organization to offer a product or service contrary to its principles may well impose a substantial burden. The Court recently ruled in an employment case that "government interference with an internal church decision that affects the faith and mission of the church itself" is prohibited. It's not clear whether the ruling includes church-run hospitals, universities, and other institutions whose missions can be fairly described as secular.

I understand that a mandate that violates a deeply held belief may cause anguish. On the other hand, it is also plausible that any burden imposed by the mandate is not substantial because the requirement in no way alters the group's doctrinal beliefs, does not require any employee to violate her conscience and use the coverage provided. Plus, it's applicable in an employment context, not a sectarian context.

Second, if so, does mandated contraception coverage further a compelling government interest? I believe the government can demonstrate that cheap and easy access to contraceptives is a compelling government interest to reduce unwanted pregnancies. Anyone can take notice of the societal costs imposed by them. Moreover, access to contraceptives assists in a women's right to reproductive freedom, a right deemed fundamental in Roe v. Wade.

Finally, does the rule further that interest by the least restrictive means? The third question is perhaps the most difficult for the government. Despite the administration's recent compromise, there may be less restrictive means of accomplishing the same result. For example, employees of exempt religious-affiliated employers could be provided contraceptives through a government-funded program that eliminates any connection to the employer. Costs could be kept low, given that the exemption would apply to a narrow group of employers and the fact that the administration initially imposed the costs upon private insurers without much push-back. If necessary, a mechanism for funding the program could be enacted.

In one sense, removing the Constitution from the debate is a good thing. It brings the issue squarely into the political arena. The immediate, loud, and visceral response to the mandate has shown that the political process can handle extremely sensitive subjects.

Whether the federal government exceeded its constitutional authority will be decided shortly. Whether the narrower mandate regarding contraception coverage violates the First Amendment is not clear. What is clear is the administration will run this mandate through the gauntlet of the Religious Freedom Restoration Act.

 
FOLLOW COLLEGE
The Obama administration stirred up a hornet's nest with the contraception mandate, which will require religious-affiliated employers to provide free contraception to employees. The angry response fro...
The Obama administration stirred up a hornet's nest with the contraception mandate, which will require religious-affiliated employers to provide free contraception to employees. The angry response fro...
 
 
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celticmaiden7475
01:06 AM on 06/05/2012
The church is hiring people of all different backgrounds to work at univerisities and hospitals and I would think the employees could have a discrimination case if they are denied access to birth control in their insurance plans.
09:33 AM on 06/02/2012
“There is more than sufficient evidence, including tell-tale internal documents, that show the president’s men cut a ‘carrot-and-stick’ deal with Big Pharma for reelection support.  If the pharmaceutical companies cooperated they would avoid higher taxes and reap a few important benefits, as well,” according to Dan Weber, president of AMAC.
“The benefits included a major policy change that would potentially end the ability of seniors to purchase cheaper prescription drugs from offshore sources.”
Weber said that the issue is not whether a deal was cut, but who cut the deal, the White House or Senate surrogates.  He cited Texas Congressman Mike Burgess who said the documents describe “a sequential, planned, organized strategy for the White House to trade policy for politics.”
madame48
NO..it's a gop Cookbook !Tempus edax,homo edacior
08:17 PM on 06/01/2012
My TeaBorg senator says that a Christian Scientist CEO takes over...should be able to pull chemo, sugery etc from employee coverage...My husband and I are morally against alchohol and sloth...so with that logic he should be able to pull coverage for meds or procedures resulting from a couch potato beer drinker. How insane is that?
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03:54 PM on 06/01/2012
This is extremely worrying. "Constitutional issue" or not (the author is deceptively unclear either way), this will be piggy-backed by those in the United States who merely have an axe to grind against religion (see their opinions on taxing churches, rinse, and repeat). The lack of free, specifically Catholic-distributed birth control is hardly a life-threatening situation, but the Entitlement Era will march on regardless, so I expect to be tempted to see what I can get out of it myself...
madame48
NO..it's a gop Cookbook !Tempus edax,homo edacior
08:18 PM on 06/01/2012
we should get to decide what is in YOUR coverage then
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10:58 PM on 06/01/2012
Well, I'm a good enough citizen that I won't be asking the government to force my employers to give me free Viagra, that's for sure, and I won't make it a "men's rights" issue if they don't. Some people in this country could learn a thing or two.
09:23 PM on 05/31/2012
This argument fails on many levels. First, it's not another statute which defines whether a law is constitutional. It's Constitution itself. Second, it's not a question of the employee's religious rights in this case. It's the right of religious employers to follow their beliefs, and not be forced to take action which violates those.
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NWBrunette
Blessed Girl
10:50 AM on 05/31/2012
If you don't like birth control, don't use it.

If you don't like gays, don't marry one.

In the meantime, do something Christlike for the planet, like feed the hungry or heal the sick.
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canobserv
09:16 AM on 06/01/2012
religion has become the bane of human existance.........and the root of most of the e v il in the world(Ok greed is running a close second)
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04:07 PM on 06/01/2012
Religion cannot be mankind's scapegoat for all personal failings, my friend. Plenty of nonreligious agree with as much.
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04:03 PM on 06/01/2012
Glad you brought that up. As read above, the meaning of "heal the sick" is being stretched to every first-world entitlement imaginable. Which version are you invoking, perchance?
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09:35 AM on 05/31/2012
Mr. Melone, while you laid out effectively both side of your case, I suggest there is one area of your case that is flawed.
That is the suggestion that the Government could offer contraceptives through a Government funded program.

I believe this too would cause a big uproar from those same religious people who are objecting now, on the grounds that "their" tax dollars are funding contraceptives.

Isn't that exactly the grounds that they have been trying to, and have been shutting down Planned Parenthood Clinics?
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SteveMD2
01:36 AM on 06/07/2012
while the govt spend about $650 million on faith based initiatives, otherwise known as evangelizing on my money.

Lets not forget that side also. Religion wants to run its own course, so be it. Let it pay for it

reminds me of the bruha in IL re civil unions and the church shutting down its adoption service, claiming it was being forced to let gays adopt.

Convenienty forgetting that it could do as it pleased, as long as it didnt state 677 mil of state money. Isnt lieing a sin?
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07:16 AM on 06/07/2012
exactly. These churches happily accept those dirty 677 million tax dollars FROM the great unwashed citizens who support contraceptives
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MeinNH
Ooooo Silly Me
09:30 AM on 05/31/2012
"First, does mandatory contraception coverage "substantially burden" the free exercise of religion?"

NO because the employee is paying for the coverage, not the employer.
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scooter1
Bias is irrelevant to truth
08:58 AM on 05/31/2012
if you don't want to use contraception, don't. That is your religious right. But, if you're an organization that wants to participate in commerce that involves all Americans, you have to abide by the rules and regulations. And, as an private corporation or business operating in the public domain, you have no business imposing your religious belief of NOT using contraception on everyone else. Epic fail.
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NWBrunette
Blessed Girl
10:51 AM on 05/31/2012
Spot on.
04:12 PM on 05/31/2012
When your religious rights cost me money then I am opposed to it. I am also opposed to human sacrifices, voodoo and various other things which could or are part of a religion. For instance, the Koran says heads or hands should be cut off depending on the crime but Muslims do not have the right to do that in America. Religulous imposition of "religion" which hurts society, hurts me and should be against the law.
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Earl Gray
Lighting up straw men everywhere
08:13 AM on 05/31/2012
This is a nicely framed argument, but misses a couple of very compelling points.

First, nobody’s “mandating contraception”. What the law requires is that these things be covered under health insurance policies. Framing the “argument” this way is inflammatory and distorts the subject.

Second, as pointed out, this is an employee benefit. It is not "paid BY the EMPLOYER", but, rather, it is a tax exempt component of compensation paid TO EMPLOYEES. It’s no different than the withholding taxes that these same entities have "paid" since they were enacted generations ago.

These payroll taxes go to fund such diverse programs as capital punishment, food cattle and hog research and waging war, all of which are against some religion or another. Yet these "payments" have never been questioned nor has any entity fought to prevent their responsibility to make those payments ON BEHALF OF EMPLOYEES.

If a comprehensive health care plan is to include contraceptive benefits, “religious employers” are free to stop offering health care in their compensation packages. They could increase base pay to cover the value of such packages (and the payroll taxes associated with that value) and leave the entire health care coverage issue up to the employees.

Religious groups are great at rationalizing things when it suits them. The “Sabbath elevators” in hospitals that protect observant Jews from violating the “no work” tenant and fish fries and pizza for observant Catholics during Lent are but two examples.

There’s no “First Amendment” issue here.
Chauncey1186
EMAILGATE!!!
09:30 AM on 05/31/2012
Well-said!

F & F'd.
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09:36 AM on 05/31/2012
Exactly, Thank you.
darcy
I'm the one on the left
08:00 AM on 05/31/2012
What's the point of discussing the laws involved in this issue? The SCOTUS is now stacked with partisan conservatives of the extreme variety. There won't be anything fair or balanced about the decision.
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Earl Gray
Lighting up straw men everywhere
08:16 AM on 05/31/2012
Au contraire, mon frere. SCOTUS's majority opinion will mirror the opinions of F*x News. What could be more "fair and balanced" than that?

=P
06:44 AM on 05/31/2012
The question is not if women of a religion use birth control. The question is can the government force religion to go again what the believe. Birth control is accessable already through PP and free clients. It cost 7 dollars at walmart. Religious schools and hospitals are some of the best there are. They pay well and they provide thier own health care. Birth control is not a right that is covered under the consititution but religious freedom is. This was a political play from the beginning. Obama is out to divide the country along many lines. He has to divide it to get re-elected. He believes everyone is stupid and will not see what is behind the things he is doing.
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Rimser
07:43 AM on 05/31/2012
Please, please, please stop repeating the bs that "it costs $7 at Walmart". Maybe, just maybe, one particular formulation costs "$7 at Walmart", but one formulation is not one-size-fits-all. Birth control per se may not be a right, but reproductive freedom is pursuant to Roe v. Wade. The churches are the ones politicizing the issue. Whether or not a congregant, an employee, a bystander uses birth control is a matter for their own health and conscience. It has NOTHING to do with the church's stand on the matter. NO ONE is telling the church to change its doctrine. The church, however, seems hell-bent-for-leather to impose its doctrine on everyone.
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09:38 AM on 05/31/2012
Fanned. Thank you.
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NWBrunette
Blessed Girl
10:31 AM on 05/31/2012
Precisely.
darcy
I'm the one on the left
08:03 AM on 05/31/2012
Hogwash. Contraceptive devices are part of a woman's healthcare. Also, the pill is used to treat other conditions, such as dysmenorrhea. The Catholic Church should lose its tax exempt privilege; it has been meddling in politics too long.
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lrobb
Gold Standard = four paws and a tail
04:13 AM on 05/31/2012
I believe the author's suggestion that employees of certain religious employers be allowed to purchase contraceptive coverage outside of that provided by their employer is actually the compromise the churches were expecting. When they didn't get it, they sued.

We could have saved ourselves an incredible amount of headache, not to mention increasing our international economic competitiveness, if we had abandoned employer-based health insurance the minute WWII ended and the wage controls were lifted. If everyone simply purchased their health insurance the same way they get their auto insurance health care costs would never have skyrocketed in the first place.

I purchase my auto/homeowners insurance through an insurance co-operative in another state which returns me a dividend yearly. The cost is about 30% less than the brands you see advertised on TV. There is no reason health insurance shouldn't be sold the same way.
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Gynn
07:55 AM on 05/31/2012
And your allegory is indicative of a functional system which is readily available for 40 million Americans?
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wmnorton
Moderate where moderate used to be
01:34 AM on 05/31/2012
Why do people believe that the Catholic parishiners are blindingly following the Bishops? Especially on this subject. You should pay more attention to the fact that 98% of Catholics have used Contraception, and not just the Rhythm method. Where you need to concentrate is what it is going to cost. 28 States already required the Church to provide contraception, the Bishops didn't say a thing. Why did they speak up now? They were going to have to start paying for the contraception in 22 more states. But if they could get the Federal Goverment to change the way the law was, they would no longer have to pay for concraception in 28 States. They got the Federal Government to change, now they do not need to provide the benefit anywhere, thereby saving Millions of dollars. As people in the know always say "Follow the money."
But you say they won why sue, it is no longer about contraception, it is about them doing their part to help Romney defeat Obama. If Obama gets relected and any of the old men on te Supreme court die, then the makeup of the court will swing back to the left and they will have missed their chance to overturn Roe.
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yorkiemum
Women Remembered In November!
03:59 AM on 05/31/2012
If a school mandates that students must purchase health insurance through a specific insurance company as a condition of enrollment, the health care covered by that company and pharmaceuticals covered by that company, should not be dictated by the school, nor should the school be privy to the medical treatment of the patient/student.
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Michael Sandy
05:08 AM on 05/31/2012
I agree. Unfortunately, some people on the right hold to the notion that if a company pays for something, it owns it and everything associated with it. And infringing on what the company does with what it has bought is somehow attacking capitalism.

So if a company pays for health care, it owns the bodies of its workers. And can therefore interpose itself between their employees and their employee's doctors.
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wmnorton
Moderate where moderate used to be
08:19 AM on 05/31/2012
Of course, There used to be recognition that there was just as much a doctor/patient relationship as there was a lawyer/client relationship. But somehow it is alright to interpose the government into the doctor/patient relationship if any of the care is paid for from government sources, but the same is not true for the lawyer/client privaledge even though all of the services of public defenders is paid for by the government. We need to return to the previous position on doctr/patient privaledge.
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lrobb
Gold Standard = four paws and a tail
04:19 AM on 05/31/2012
The Catholic Church is not a democracy. Parishioners don't get to choose their own dogma, only whether or not to selectively follow what the Church decrees. The Church has decreed contraception to be against its teachings. Ergo that should be the end of it.

Since we do not have a state religion, and no one is compelled to attend a particular church or any at all, it is up to the individual not the government to determine whether or not they will adhere to their religion's dictates. The government has absolutely no business telling any church run business--or any business run by an individual or board of directors which happens to be very religious--that they must provide coverage for something which is anathema to them.
07:34 AM on 05/31/2012
First off you really don't understand what the Bishops are trying to do, think power and money.

Second, the Pope has finally relented on allowing African Catholics to use condoms because too many wives were dying of Aids.

Thirdly, it has NOTHING to do with religion and everything to do with defining what health care coverage consists of. Once defined then the Church groups are either providing healthcare or they are not. If they are not they pay a fine and the employee can get subsidized health care through the exchanges. But the Church wants to force their dogma on non-members and also NOT pay the fine. That makes employees of Catholic instituions second class citizens and that's a NO NO.

Lastly, I'm surprised that you didn't comment on Wendall's piece about the fact that under Obamacare there is federal funding available for the creation of CO-OP's. But I do agree that employer-based health care has got to go.
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Gynn
07:53 AM on 05/31/2012
False. You religious convictions do not give you the right to deny others medical access. You are confusing the acting parties. Forcing religious people to take contraceptives is a violation of religious liberty. Forcing religious people to care for their employees isn't.