FTA:
Since the installation of the current conservative supermajority on the U.S. Supreme Court, RFRA has been used several times to advance Christian, conservative interests. In Fulton v. City of Philadelphia, the Supreme Court held that Philadelphia’s nondiscrimination policies violated RFRA by precluding a Catholic adoption agency from contracting with the city because it refused to place children with LGBTQ+ families. The court also used the free exercise clause and RFRA to invalidate the mandate for employers to provide contraceptive coverage in Little Sisters of the Poor v. Pennsylvania. The Ninth Circuit itself relied on the free exercise clause to overturn a public school’s decision not to recognize a Christian student group that required students to hold Christian beliefs to join in Fellowship of Christian Athletes v. San Jose Unified School District.