Religious Health Care Provider Loses Free Exercise Claim Against Medi-Cal Managed Care Plan

In Horisons Unlimited v. Santa Cruz-Monterey-Merced Managed Medical Care Commission, 2014 U.S. Dist. LEXIS 89030 (ED CA, June 27, 2014), a religious health care provider sued over actions of Alliance, the sole Medi-Cal manged care plan in the county.  Alliance refused to credential the clinics' providers and allow new enrollments of Medi-Cal beneficiaries at the clinics. In addition to various antitrust claims, the clinic asserted infringement of its free exercise of religion. The court rejected the contention, saying:

An allegation that one member of Alliance's governing body "objected to" religious services at Horisons' clinics fails show or give rise to a reasonable inference that Alliance burdened Horisons' practice of religion by preventing Horisons from engaging in conduct mandated by Horisons' faith.