Catholic Charities of Sacramento, Inc. v. Superior Court

Summary

The Supreme Court of California considered constitutional challenges by Catholic Charities of Sacramento to the Women's Contraception Equity Act, which required certain health and disability insurance plans covering prescription drugs to cover prescription contraceptives. The court rejected the organization's establishment-clause, free-exercise, religious-autonomy, and related challenges, concluding that the statute was validly applied to Catholic Charities. The opinion affirmed the lower courts' rulings.

Holdings

1. The WCEA does not impermissibly interfere with internal church governance or require the government to decide a question of religious doctrine because it regulates the relationship between a nonprofit corporation and its employees, most of whom do not belong to the church.
2. The WCEA's religious-employer exemption is not facially invalid merely because it uses religious criteria to identify organizations eligible for an accommodation, and Catholic Charities showed no excessive entanglement as applied to it.
3. The WCEA is a neutral and generally applicable law regulating insurance benefits, and Catholic Charities' religious objection does not excuse compliance under the general rule of Employment Division v. Smith.
4. Catholic Charities did not establish a valid hybrid-rights claim warranting strict scrutiny because compliance with the WCEA is not speech and its asserted free-speech claim lacked merit.
5. The court did not decide whether the California Constitution requires strict scrutiny for neutral, generally applicable laws that incidentally burden religion, but assumed strict scrutiny applied and held that the WCEA satisfied it.
6. Catholic Charities could not prevail on its rational-basis challenge because the exemption rationally accommodates religious exercise and Catholic Charities conceded that it failed to satisfy the exemption's independent fourth criterion.

Questions Presented

1. Whether the WCEA impermissibly interferes with religious doctrine or internal church governance.
2. Whether the WCEA's religious-employer exemption violates the establishment clause by distinguishing between religious and secular organizations or by creating excessive governmental entanglement with religion.
3. Whether the WCEA is nonneutral, not generally applicable, or a religious gerrymander under the federal Free Exercise Clause.
4. Whether the WCEA implicates hybrid free-exercise and free-speech or establishment-clause rights requiring strict scrutiny.
5. Whether the WCEA violates the California Constitution's free-exercise clause or fails rational-basis review.

Disposition

affirmed