In Gospel Light Mennonite Church Medical Aid Plan v. New Mexico Office of the Superintendent of Insurance, (D NM, Aug. 25, 2025), a New Mexico federal district court held that two members of a healthcare sharing ministry that was barred from operating in New Mexico by insurance regulatory authorities have standing to challenge on free exercise grounds the regulator's order that ended the ministry's operation in the state. The ministry itself was originally also a party to the lawsuit, but it was dismissed because it was challenging the action in state court.
In refusing to dismiss at this stage for lack of standing, the court said in part:
... OSI acknowledges that Plaintiffs believe “they have a biblical obligation to help their fellow man when in need which is accomplished by sharing each other’s medical expenses.”... Further, Plaintiffs present evidence—unrebutted by OSI— showing that OSI’s final order directing Gospel Light’s to cease operations tangibly interfered with their religious beliefs and practices. While Smith and Renteria admitted that they continue to pay into Gospel Light’s sharing ministry, they also testified that OSI’s final order prevented them from participating in other aspects of the program, including the ability to share in organized prayer networks which connected them to other Gospel Light members.... Importantly, Renteria stated that OSI’s actions caused her to switch her family to a different healthcare sharing ministry....
... OSI’s final order impacted Plaintiffs’ ability to fully participate in Gospel Light’s sharing ministry. That participation is a distinct part of Plaintiffs’ religious belief structure....
Plaintiffs’ statements raise a plausible inference that they share a concrete and particularized injury: the inability to utilize Gospel Light’s health sharing ministry to its full extent due to OSI’s final order. Because the scope of those injuries remains in dispute, summary judgment is inappropriate at this stage....
