An Attempt To Be Complete In Covering the Contraceptive Coverage Mandate Decisions

As previously reported, among the many for-profit businesses challenging the Affordable Care Act's contraceptive coverage mandate was Michigan-based Eden Foods.   There have been at least two opinions in the case that seem to have fallen between the cracks of Religion Clause's coverage.  A March 22, 2013 district court opinion denied an emergency motion for a temporary restraining order in the case, and it appears that subsequently the district court denied a preliminary injunction as well.  Then in a June 28, 2013 opinion, the U.S. 6th Circuit Court of Appeals denied a motion for a preliminary injunction pending appeal of the district court's denial of a preliminary injunction. The 6th Circuit said in part: "We are not persuaded, at this stage of the proceedings, that a for-profit corporation has rights under the RFRA."