Burwell v. Hobby Lobby Stores, Inc.

==== Religious Freedom Restoration Act ====
The United States Supreme Court ruled in ''[[Employment Division v. Smith]]'' (1990) that a person may not defy ''neutral laws of general applicability''{{efn|The meaning of ''neutral law of general applicability'' was [[Church of Lukumi Babalu Aye v. City of Hialeah|elaborated by the court in 1993]].}} even as an expression of religious belief. "To permit this," wrote Justice Scalia, citing the 1878 ''[[Reynolds v. United States]]'' decision, "would make the professed doctrines of religious belief superior to the law of the land, and in effect to permit every citizen to become a law unto himself.<ref>{{cite web|url = http://web.utk.edu/~scheb/decisions/Reynolds.htm|title = Reynolds v. United States, 98 U.S. 145, 25 L.Ed. 244 (1878)|date = 1878|access-date = September 2, 2015|archive-date = July 11, 2015|archive-url = https://web.archive.org/web/20150711013558/http://web.utk.edu/~scheb/decisions/Reynolds.htm|url-status = live}}</ref> " He wrote that generally applicable laws do not have to meet the standard of [[strict scrutiny]], because such a requirement would create "a private right to ignore generally applicable laws". Strict scrutiny would require a law to be the least restrictive means of furthering a compelling government interest.

In 1993, the US Congress responded by passing the [[Religious Freedom Restoration Act]] (RFRA), requiring strict scrutiny when a neutral law of general applicability "substantially burden[s] a person's{{efn|The [[Dictionary Act]] defines the word 'person' in any act of Congress to include corporations.}} exercise of religion".<ref name=NYTimes>{{cite news|last=Liptak|first=Adam|title=Supreme Court Hears Cases on Contraception Rule|url=https://www.nytimes.com/2014/03/26/us/politics/q-and-a-on-challenges-to-health-laws-birth-control-requirement.html|access-date=March 25, 2014|newspaper=The New York Times|date=March 25, 2014|archive-date=April 7, 2014|archive-url=https://web.archive.org/web/20140407173056/http://www.nytimes.com/2014/03/26/us/politics/q-and-a-on-challenges-to-health-laws-birth-control-requirement.html?_r=0|url-status=live}}</ref> The RFRA was amended in 2000 by the [[Religious Land Use and Institutionalized Persons Act]] (RLUIPA) to redefine ''exercise of religion'' as any exercise of religion, "whether or not compelled by, or central to, a system of religious belief", which is to be "construed in favor of a broad protection of religious exercise, to the maximum extent permitted by the terms of this chapter and the Constitution". The Supreme Court upheld the constitutionality of the RFRA as applied to federal statutes in ''[[Gonzales v. O Centro Espirita]]'' in 2006.