taught: “We don’t serve people because they’re Catholic, we serve them because
are, and it’sa moral imperative for us to do so.” In accordance with these beliefs, Catholic individuals andorganizations consistently work to create a more just community by serving any and allneighbors in need, Catholic and non-Catholic alike.
Artificial interference with the creation of life, including through abortion,sterilization, and contraceptives, is contrary to Catholic doctrine.
Defendants, however, have promulgated various rules (collectively, the “U.S.Government Mandate”) that force Plaintiffs to violate their sincerely held religious beliefs.Under the U.S. Government Mandate, many Catholic and other religious organizations arerequired to provide health plans to their employees that include and/or facilitate coverage for abortion-inducing drugs, sterilization, and contraception in violation of their sincerely heldreligious beliefs. Ignoring broader religious exemptions from other federal laws, theGovernment has crafted a narrow exemption from this Mandate for certain “religiousemployers” who can convince the Government that they satisfy four criteria:
“The inculcation of religious values is the purpose of the organization”;
“The organization primarily employs persons who share the religioustenets of the organization”;
“The organization primarily serves persons who share the religious tenetsof the organization”; and
“The organization is a nonprofit organization as described in section6033(a)(1) and section 6033(a)(3)(A)(i) or (iii) of the Internal RevenueCode of 1986, as amended.”Thus, in order to safeguard their religious freedoms, religious employers must plead with theGovernment for a determination that they are sufficiently “religious.”-3-