I had seen it, Howard, but did not include it in my post because it's such
an idiosyncratic case and hasn't been addressed on the merits yet by a
district court, let alone any court of appeals.  In a certain respect, I
suppose, it's a bit like a modern, RFRA-version of *Mozert*.

On Tue, Jul 21, 2015 at 7:35 AM, Friedman, Howard M. <
howard.fried...@utoledo.edu> wrote:

>  Marty-- Have you seen yesterday's 8th Circuit opinion that could open a
> whole new line of challenges?
> http://religionclause.blogspot.com/2015/07/8th-circuit-parents-have-standing-to.html
>
>  ------------------------------
> *From:* religionlaw-boun...@lists.ucla.edu [
> religionlaw-boun...@lists.ucla.edu] on behalf of Marty Lederman [
> lederman.ma...@gmail.com]
> *Sent:* Monday, July 20, 2015 12:23 PM
> *To:* Law & Religion issues for Law Academics
> *Subject:* Developments in contraceptive coverage
>
>   FYI, a post on developments of the past few months, in three parts:
>
>  http://balkin.blogspot.com/2015/07/update-on-contraception-coverage.html
>
>  *First*, a quick note on the government's new final rules regarding the
> religious accommodation (including its extension to some for-profit
> employers such as Hobby Lobby, Inc.).  *Second*, a summary of the courts
> of appeals' treatment of the nonprofit challenges.  And *third*, a
> discussion of the handful of *cert. *petitions that already have been
> filed in the nonprofit cases--with particular emphasis on the theories of
> complicity that those petitions allege in support of the argument that the
> accommodation imposes a "substantial burden" on the plaintiffs' religious
> exercise.
>
>  I'd be very grateful if listmembers would let me know if I've gotten
> anything wrong, or overlooked anything of note.  And if you become aware of
> any further court of appeals decisions or cert. petitions, please let me
> know ASAP, so that I can update.  Thanks
>
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