CATHOLIC CHARITIES OF SACRAMENTO, INC. V. SUPERIOR COURT 32 Cal.4th 527 (2004) CASE BRIEF

CATHOLIC CHARITIES OF SACRAMENTO, INC. V. SUPERIOR COURT

32 Cal.4th 527 (2004)

NATURE OF THE CASE: Catholic (P), employer, challenged a decision, which denied P's petition for a writ of mandate and ruled in favor of real parties in interest, a trial court, a State, a state health care department, and a state insurance department, (Ps) and found that the Women's Contraception Equity Act (WCEA), Cal. Health & Safety Code 1367.25 and Cal. Ins. Code 10123.196, was not unconstitutional.

FACTS: The Legislature discovered that women during their reproductive years spent as much as 68 percent more than men in out-of-pocket health care costs, due in large part to the cost of prescription contraceptives and the various costs of unintended pregnancies, including health risks, premature deliveries and increased neonatal care. Approximately 10 percent of commercially insured Californians did not have coverage for prescription contraceptives. It passed the WCEA which required that certain health and disability insurance plans that cover prescription drugs must cover prescription contraceptives. As an exception, the law permits a 'religious employer' to request a policy that includes drug coverage but excludes coverage for 'contraceptive methods that are contrary to the religious employer's religious tenets.' Catholic Charities of Sacramento (P) is a California nonprofit public benefit corporation. It describes itself as an organ of the Roman Catholic Church. P offers health insurance, including prescription drug coverage, to its 183 full-time employees. It does not offer insurance for prescription contraceptives because it considers itself obliged to follow the Roman Catholic Church's religious teachings, because the Church considers contraception a sin, and because Catholic Charities believes it cannot offer insurance for prescription contraceptives without improperly facilitating that sin. The act defines a 'religious employer' as 'an entity for which each of the following is true: (A) The inculcation of religious values is the purpose of the entity. (B) The entity primarily employs persons who share the religious tenets of the entity. (C) The entity serves primarily persons who share the religious tenets of the entity. (D) The entity is a nonprofit organization as described in Section 6033(a)(2)(A) i or iii, of the Internal Revenue Code of 1986, as amended.' P does not qualify as a 'religious employer' under the WCEA because it does not meet any of the four criteria. P admits that its purpose ... is to offer social services to the general public that promote a just, compassionate society. The WCEA implicitly permits any employer to avoid covering contraceptives by not offering coverage for prescription drugs. P contends that this option does not eliminate all conflict between the law and its religious beliefs. P filed this action seeking a declaratory judgment that the WCEA is unconstitutional and an injunction barring the law's enforcement. The State of California, the Department of Managed Health Care and the Department of Insurance (Ds) are the defendants. P challenges under the establishment and free exercise clauses of the United States and California Constitutions. The superior court denied P's motion for a preliminary injunction. P sought a petition for writ of mandate, which the Court of Appeal denied. This appeal was granted.

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