Hobby Lobby

[Daldolma]

This wasn't even a hard case.

RFRA re-established strict scrutiny for any legislation substantially burdening the free exercise of religion, whether or not the law is facially neutral. Forcing a company to provide contraception that is directly opposed to their sincerely held religious beliefs substantially burdens the free exercise of religion. Per RFRA, it is thus subject to strict scrutiny. That's really the end of the game since strict scrutiny is lights out when properly applied, but we can walk through the rhetoric.

The law only survives strict scrutiny if it is narrowly tailored (read: the least restrictive means) to meet a compelling interest. Providing this type of contraception almost definitely doesn't amount to a compelling state interest, but it doesn't even matter. The Court never had to touch that issue because there are a wide variety of less restrictive means available, including those already in use with non-profits.