In Geneva College v. Sebelius, (WD PA, Dec. 23, 2013), a Pennsylvania federal district court granted a preliminary injunction, upholding Geneva College's objection under RFRA to complying with the final Affordable Care Act rules creating an accommodation for religious non-profits that object to the contraceptive coverage mandate. In June, the court had already granted Geneva College a similar preliminary injunction in connection with its student health insurance policies. (See prior posting.) Now it has granted a similar injunction as to the College's health plan for its employees, finding that requiring the College to submit the self-certification form called for by the final rules likely creates a substantial burden on Geneva's religious exercise:
... [I]ts submission of the self-certification form is not too attenuated from the provision of the objected to services. Instead, it is the necessary stimulus behind their provision.... Courts should not undertake to dissect religious beliefs and second-guess where an objector draws the line when analyzing substantial burden questions.Pittsburgh Post Gazette reports on the decision.