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<div class="ad"> </div></div><div id="opinionator"><div align="left"><span class="timestamp published" title="2012-02-08T21:00:35+00:00">February 8, 2012, <span>9:00 pm</span></span><h3 class="entry-title">Whose Conscience?</h3>
<address class="byline author vcard">By <a href="http://opinionator.blogs.nytimes.com/author/linda-greenhouse/" class="url fn" title="See all posts by LINDA GREENHOUSE">LINDA GREENHOUSE</a></address><div class="entry-content">
<div class="inlineModule"><div class="entry categoryDescriptionModule"><p class="summary"><a href="http://opinionator.blogs.nytimes.com/category/linda-greenhouse/">Linda Greenhouse</a> on the Supreme Court and the law.</p>
</div><div class="entry entryTagsModule"><h4>Tags:</h4><p class="meta tags"><a href="http://opinionator.blogs.nytimes.com/tag/birth-control/" rel="tag">birth control</a>, <a href="http://opinionator.blogs.nytimes.com/tag/roman-catholic-church/" rel="tag">Roman Catholic Church</a></p>
</div></div><p>
In the escalating conflict over the new federal requirement that
employers include contraception coverage without a co-pay in the
insurance plans they make available to their employees, opposition from
the Catholic church and its allies is making headway with a powerfully
appealing claim: that when conscience and government policy collide,
conscience must prevail.</p><p>The rhetoric in which this claim is put
forward grows more inflammatory by the day. “The Obama administration
has just told the Catholics of the United States, ‘To Hell with you!’ ”
according to <a href="http://www.diopitt.org/hhs-delays-rule-contraceptive-coverage">Bishop David A. Zubik</a> of the Diocese of Pittsburgh. The<a href="http://www.becketfund.org/"> Becket Fund for Religious Liberty</a>,
a nondenominational organization that litigates on behalf of religious
interests, is circulating a petition under the heading: “The Obama
Administration is giving you one year to stop believing” (a reference to
the one-year delay the regulation offers to religious employers). Mitt
Romney, the likely Republican presidential nominee, joined the chorus
this week, calling the regulation “a violation of conscience.”</p><p>This
aggressive claiming of the moral high ground is close to drowning out
the regulation’s supporters, inside and outside of the Obama
administration. Maybe I’m missing something, but I haven’t seen a
comparably full-throated defense of the regulation, issued last month by
the Department of Health and Human Services, except on pure policy
grounds. (And there are indications this week that even some in the
administration, or at least in President Obama’s campaign apparatus, may
be getting <a href="http://www.nytimes.com/2012/02/08/health/policy/obama-addresses-ire-on-health-insurance-contraception-rule.html?ref=us">cold feet</a>.)
While the policy grounds are fully persuasive – the ability to prevent
or space pregnancy being an essential part of women’s health care, one
that shouldn’t be withheld simply because a woman’s employer is
church-affiliated – the purpose of this column is to examine the
conscience claim itself, directly, to see whether it holds up.</p><p>An
obvious starting point is with the 98 percent of sexually active
Catholic women who, just like other American women, have exercised their
own consciences and availed themselves of birth control at some point
during their reproductive lives. So it’s important to be clear that the <a href="http://www.guttmacher.org/pubs/Religion-and-Contraceptive-Use.pdf">conscientious objection</a>
to the regulation comes from an institution rather than from those
whose consciences it purports to represent. (Catholic women actually
have a <a href="http://www.beliefnet.com/Faiths/Catholic/2001/01/The-Catholic-Abortion-Paradox.aspx">higher rate of abortion</a>
than other American women, but I’ll stick to birth control for now.)
While most Catholics dissent in the privacy of their bedrooms from the
church’s position, some are pushing back in public. The organization <a href="http://www.catholicsforchoice.org/actioncenter/alerts/TellYourLocalMedia.asp">Catholics for Choice</a>,
whose magazine is pointedly entitled Conscience, is calling on its
supporters to “tell our local media that the bishops are out of touch
with the lived reality of the Catholic people” and “do not speak for us
on this decision.”</p><p>But suppose the counter-factual – that only
half, or one-quarter, or five percent of Catholic women use birth
control. The question would remain: Whose conscience is it? The
regulation doesn’t require anyone to use birth control. It exempts any
religious employer that primarily hires and serves its own faithful, the
same exclusion offered by New York and California from the
contraception mandate in state insurance laws. (Of the other states that
require such coverage, 15 offer a broader opt-out provision, while
eight provide no exemption at all.) Permitting Catholic hospitals to
withhold contraception coverage from their 765,000 employees would blow a
gaping hole in the regulation. The 629-hospital<a href="http://www.chausa.org/"> Catholic health care system</a>
is a major and respected health care provider, serving one in every six
hospital patients and employing nearly 14 percent of all hospital staff
in the country. Of the top 10 revenue-producing hospital systems in
2010, four were Catholic. The San Francisco-based Catholic Healthcare
West, the fifth biggest hospital system in the country, had $11 billion
in revenue last year and treated 6.2 million patients.</p><p style="color:rgb(255,0,0)"><b>These
institutions, as well as Catholic universities – not seminaries, but
colleges and universities whose doors are open to all – are full
participants in the public square, receiving a steady stream of federal
dollars. They assert – indeed, have earned – the right to the same
benefits that flow to their secular peers. What they now claim is a
right to special treatment: to conscience that trumps law.</b></p><p>But in
fact, that is not a principle that our legal system embraces. Just ask
Alfred Smith and Galen Black, two members of the Native American Church
who were fired from their state jobs in Oregon for using the illegal
hallucinogen peyote in a religious ceremony and who were then deemed
ineligible for unemployment compensation because they had lost their
jobs for “misconduct.” They argued that their First Amendment right to
free exercise of religion trumped the state’s unemployment law.</p><p>In a 1990 decision, <a href="http://supreme.justia.com/cases/federal/us/494/872/case.html">Employment Division v. Smith</a>,
the Supreme Court disagreed. Even a sincere religious motivation, in
the absence of some special circumstance like proof of government
animus, does not merit exemption from a “valid and neutral law of
general applicability,” the court held. Justice Antonin Scalia wrote the
opinion, which was joined by, among others, the notoriously left wing
Chief Justice William H. Rehnquist.</p><p>A broad coalition of
conservative and progressive religious groups pushed back hard, leading
to congressional passage of the tendentiously titled Religious Freedom
Restoration Act. It provided that a free exercise claim would prevail
unless the government could show a “compelling” reason for holding a
religious group to the same legal requirements that applied to everyone
else. After a Catholic church in Texas invoked that law in an effort to
expand into a landmark zone where no new building was permitted, the <a href="http://supreme.justia.com/cases/federal/us/521/507/">Supreme Court</a>
declared the Religious Freedom Restoration Act unconstitutional as
applied to the states. The law remains in effect as applied to the
federal government, although its full dimension remains untested.</p><p>Senator
Rob Portman, an Ohio Republican, sent a letter to Attorney General Eric
Holder on Monday asserting that the contraception regulation violates
the Religious Freedom Restoration Act, and it’s not unlikely that one or
more lawsuits may soon test that proposition. The question would then
be whether the case for the mandate, without the broad exemption the
church is demanding, is sufficiently “compelling.” Such a case would pit
the well-rehearsed public health arguments (half of all pregnancies in
the United States are unintended, and nearly half of those end in
abortion – a case for expanded access to birth control if there ever was
one ) against religious doctrine.</p><p>The court has recently been
active on the religion front. In a unanimous decision last month, the
justices for the first time recognized a constitutionally-based
“ministerial exception” from laws concerning employment discrimination.
An employee deemed by a church to be a “minister” – in this case, a
kindergarten teacher in a Lutheran school who had received ministerial
training and taught some religion classes –<a href="http://www.supremecourt.gov/opinions/11pdf/10-553.pdf"> cannot sue the church</a>
over an adverse employment decision, the court held in Hosanna-Tabor
Evangelical Lutheran Church and School v. Equal Employment Opportunity
Commission.</p><p>The plaintiff, supported by the federal government,
had argued that the 1990 Employment Division v. Smith decision precluded
the recognition of a ministerial exception from generally applicable
employment laws. Rejecting that argument in his opinion for the court,
Chief Justice John G. Roberts Jr. explained: “But a church’s selection
of its ministers is unlike an individual’s ingestion of peyote. Smith
involved government regulation of only outward physical acts. The
present case, in contrast, concerns government interference with an
internal church decision that affects the faith and mission of the
church itself.”</p><p>That language is certainly suggestive of
deference, beyond the employment area, to a church’s doctrinal claims to
special treatment. But while all nine justices signed the opinion, that
doesn’t necessarily mean that all nine would agree on its application
to the contraception requirement. The question would be whether a church
that has failed to persuade its own flock of the rightness of its
position could persuade at least five justices.<img src="http://up.nytimes.com/?d=0//&c=1&u=http%3A%2F%2Fopinionator.blogs.nytimes.com%2F2012%2F02%2F08%2Fwhose-conscience%2F%3Fpagemode%3Dprint&r=http%3A%2F%2Fopinionator.blogs.nytimes.com%2F2012%2F02%2F08%2Fwhose-conscience%2F%3Fnl%3Dtodaysheadlines%26emc%3Dthab1" border="0" height="0" width="0"><br clear="all">
</p></div></div></div><br>-- <br>Art Deco (Wayne A. Fox)<br><a href="mailto:art.deco.studios@gmail.com" target="_blank">art.deco.studios@gmail.com</a><br>