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Supreme Court of the United States: Autocam et al v. Sebelius et al

Supreme Court of the United States: Autocam et al v. Sebelius et al

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Published by Lori Solyom
On Petition For A Writ Of Certiorari
To The United States Court Of Appeals
For The Sixth Circuit
On Petition For A Writ Of Certiorari
To The United States Court Of Appeals
For The Sixth Circuit

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Published by: Lori Solyom on Oct 15, 2013
Copyright:Attribution Non-commercial

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03/29/2015

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No. _________
================================================================
In The
Supreme Court of the United States
---------------------------------
--------------------------------- AUTOCAM CORP., et al.,
 Petitioners,
v.KATHLEEN SEBELIUS, et al.,
 Respondents.
---------------------------------
---------------------------------
On Petition For A Writ Of CertiorariTo The United States Court Of AppealsFor The Sixth Circuit
---------------------------------
---------------------------------
PETITION FOR A WRIT OF CERTIORARI
---------------------------------
---------------------------------T
HOMAS
B
REJCHA 
 P
ETER
C. B
REEN
 T
HOMAS
M
ORE
S
OCIETY 
 29 South LaSalle St., Ste. 440Chicago, IL 60603(312) 782-1680
 
J
 ASON
C. M
ILLER
 M
ILLER
J
OHNSON
 250 Monroe Ave., Ste. 800Grand Rapids, MI 49503(616) 831-1700P
 ATRICK 
T.G
ILLEN
 
Counsel of Record
  Associate Professor Law A 
 VE
M
 ARIA 
S
CHOOL
 
OF
L
 AW
C
 ATHOLIC
 V 
OTE
L
EGAL
 D
EFENSE
F
UND
 1025 Commons CircleNaples, FL 34119(734) 355-4728ptgillen@avemarialaw.edu
Counsel for Petitioners
================================================================
COCKLE LEGAL BRIEFS (800) 225-6964WWW.COCKLELEGALBRIEFS.COM
 
i
QUESTIONS PRESENTED
 Petitioners are members of the Kennedy familyand the two companies through which the Kennedysdo business (referred to collectively as “Autocam”).When the petitioners run their business, they followthe teachings of the Roman Catholic Church. Byvirtue of their religious obligation to treat workerswell, petitioners provide their employees with agenerous (indeed award-winning), healthcare benefitsplan including up to $1,500 towards a Health Savings Account (which employees are free to use for anylawful purpose). By virtue of their religious obligationto avoid material cooperation with acts believed to bemorally wrong, petitioners have never providedcoverage or payments for abortion-inducing drugs,contraceptive drugs or devices, or sterilization.The HHS Mandate, 45 C.F.R. § 147.130, whichwas promulgated pursuant to the Affordable Care Act, 42 U.S.C. § 300gg-13 et seq., requires petitionersto provide their employees with abortion-inducing drugs, contraceptive drugs or devices, and steriliza-tion. On January 1, 2013, petitioners were required tochoose between obeying this federal mandate andthereby violating their religious beliefs or paying afine of about $19,000,000, which would cripple theirbusiness.
 
ii
QUESTIONS PRESENTED
– ContinuedThe questions presented are:1. Do petitioners have standing to advance theclaim that the HHS Mandate violates the Reli-gious Freedom Restoration Act (“RFRA”) by forc-ing individual business owners to violate theirreligious beliefs when governing the corporationthrough which they do business upon pain of ru-inous consequences?2. Does the HHS Mandate impose a substantialburden on petitioners’ exercise of religion withinthe meaning of the Religious Freedom Restora-tion Act by coercing them to violate their reli-gious convictions when conducting business uponpain of ruinous consequences?

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