


A federal judge in Pennsylvania has delivered a devastating blow to religious liberty advocates, striking down Trump administration rules that protected religious organizations from being forced to provide contraception coverage to their employees. The ruling forces groups like the Little Sisters of the Poor back into lengthy court battles they thought they had already won at the Supreme Court.
U.S. District Judge Wendy Beetlestone ruled Wednesday that the 2017 religious and moral exemptions from the Affordable Care Act's contraception mandate were "arbitrary and capricious" and violated federal procedural requirements. The court has vacated the exemptions "in their entirety," potentially forcing religious organizations back into compliance with mandates they believe violate their deeply held beliefs.
Here's what makes this ruling particularly galling for religious liberty advocates: This is the exact same case where the Little Sisters won a decisive 7-2 victory at the Supreme Court in 2020. The high court ruled that the Trump administration had proper authority to grant these religious exemptions and that the rules met all procedural requirements.
But Pennsylvania and New Jersey weren't willing to accept that outcome. Instead of dropping the case after their crushing Supreme Court defeat, the states pivoted to new arguments. They "revitalized their cutting-floor arguments that they chose not to pursue at the Supreme Court last time and brought them in the district court," according to Diana Thomson, a senior attorney with Becket, the legal advocacy group representing the Little Sisters.
The district court's 55-page ruling completely sidesteps the constitutional and religious liberty questions the Supreme Court addressed, focusing instead on narrow claims that the agencies acted "arbitrarily and capriciously" when crafting the exemptions. Judge Beetlestone waited five years to issue this decision—without even holding a hearing on the constitutional issues at stake.
The contraception mandate requires employer-provided health coverage to include FDA-approved contraceptives for female employees without cost-sharing. Churches and houses of worship were automatically exempted, but religious nonprofits like universities, charities, and hospitals that employ millions of people were not.
Before the Trump rules, these religious organizations had to go through an "accommodation" process. They were required to file forms with the government to avoid directly paying for contraception, though their insurance carriers would still be required to provide the coverage. Many religious groups, including the Little Sisters, argued that even this accommodation process made them complicit in providing contraception against their beliefs.
The Trump administration's 2017 rules eliminated this bureaucratic burden entirely. Religious organizations could simply opt out of providing contraceptive coverage without having to file any notices or certifications with the government. The rules also extended similar protections to for-profit companies with religious objections and created new "moral exemptions" for those with conscientious objections.
According to the agencies' own analysis, between 70,500 and 126,400 women nationwide would lose contraceptive coverage as a result of these exemptions.
Judge Beetlestone's ruling essentially accuses the Trump agencies of solving the wrong problem. She argues there was no "rational connection" between the problem the agencies identified (RFRA conflicts) and the solution they chose (broad exemptions).
The court found that because the previous accommodation process was supposedly adequate for most religious objectors, the Trump administration went too far by exempting "all employers with objections to the mandate, even if the accommodation met their religious needs." In other words, the agencies exempted employers who supposedly had no religious objection to the status quo.
The judge also criticized the inclusion of publicly traded companies in the religious exemption, noting that the Supreme Court in Hobby Lobby suggested such companies were "unlikely, if ever" to maintain sincere religious objections. She found it "arbitrary" for agencies to agree with this assessment while simultaneously extending exemptions to publicly traded corporations.
Perhaps most significantly, the court ruled that the agencies failed to properly justify their change in position regarding contraception's safety and effectiveness. The Trump agencies had cited studies raising questions about certain contraceptive methods, but Judge Beetlestone found this analysis insufficient to justify departing from previous conclusions that contraception was safe and effective.
There's a troubling pattern emering in how progressive states approach unfavorable court decisions. When religious organizations win on constitutional grounds, opponents simply shift to procedural arguments. When they lose on procedure, they find new angles to relitigate settled questions.
The Biden administration had actually proposed new rules in 2023 that would have maintained some religious exemptions while creating an "individual contraceptive arrangement" allowing women at exempt organizations to obtain coverage directly. But after Trump's election to a second term, those proposed rules were withdrawn in December 2024, leaving the 2017 Trump rules in place.
Eric Rassbach, vice president and senior counsel at Becket, captured the frustration, saying, "It is absurd to think the Little Sisters might need yet another trip to the Supreme Court to end what has now been more than a dozen years of litigation over the same issue." But that appears to be exactly where this is headed.
This ruling raises profound questions about the stability of constitutional protections. If federal district courts can effectively nullify Supreme Court precedent by shifting from constitutional questions to administrative law claims, what prevents endless relitigation of any settled issue?
The Supreme Court's 2020 decision wasn't close—it was 7-2, with even liberal Justices Kagan and Breyer agreeing that the Trump administration had authority to create these exemptions. Justice Alito's concurrence went further, arguing that RFRA actually compelled these religious exemptions.
Yet here we are, five years later, with a district judge essentially declaring that the agencies were wrong to exercise the very authority the Supreme Court said they possessed.
Becket has made clear they "will fight as far as we need to fight to protect the Little Sisters' right to care for the elderly in peace." An appeal seems certain, and given the Supreme Court's previous ruling, likely to succeed.
But the damage extends beyond this case. Religious organizations that thought their rights were settled law after multiple Supreme Court victories now face the reality that constitutional protections mean little if opponents can simply relitigate through different legal theories.
For the Little Sisters of the Poor, an order of Catholic nuns whose only "crime" is wanting to care for the elderly without violating their religious beliefs, it's been a frustrating decade-plus of federal harassment. They've now won at the Supreme Court twice, only to find themselves back in court defending the same basic principle: that the government shouldn't force religious organizations to act against their deepest convictions.
The real question isn't whether this district court ruling will ultimately be overturned, as it almost certainly will be. The question is whether our legal system can find a way to end this cycle of harassment disguised as litigation, where victory at the highest levels provides no real finality for those simply trying to live according to their faith.