Diocese of Fo
UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA FORT WAYNE DIVISION ____________________________________ ) DIOCESE OF FORT WAYNE-SOUTH ) BEND, INC.; CATHOLIC CHARITIES ) OF THE DIOCESE OF FORT WAYNE– ) SOUTH BEND, INC.; SAINT ANNE ) HOME & RETIREMENT COMMUNITY ) OF THE DIOCESE OF FORT WAYNE- ) SOUTH BEND, INC.; FRANCISCAN ) ALLIANCE, INC.; UNIVERSITY OF ) SAINT FRANCIS; and OUR SUNDAY ) VISITOR, INC., ) ) Plaintiffs, ) v. ) CASE NO.: ) KATHLEEN SEBELIUS, in her official ) capacity as Secretary of the U.S. ) Department of Health and Human ) Services; HILDA SOLIS, in her official ) capacity as Secretary of the U.S. ) Department of Labor; TIMOTHY ) GEITHNER, in his official capacity as ) Secretary of the U.S. Department of ) Treasury; U.S. DEPARTMENT OF ) HEALTH AND HUMAN SERVICES; ) U.S. DEPARTMENT OF LABOR; and ) U.S. DEPARTMENT OF TREASURY, ) ) Defendants. ) ) COMPLAINT AND DEMAND FOR JURY TRIAL 1. This lawsuit is about one of America’s most cherished freedoms: the freedom to practice one’s religion without government interference. It is not about whether people have a right to abortion-inducing drugs, sterilization, and contraception. Those services are, and will continue to be, freely available in the United States, and nothing prevents the Government itself from making them more widely available. But the right to such services does not authorize the Government to force the Plaintiffs to violate their own consciences by making them provide, pay for, and/or facilitate those services to others, contrary to their sincerely held religious beliefs. American history and tradition, embodied in the First Amendment to the United States Constitution and the Religious Freedom Restoration Act (“RFRA”), protects religious entities from such overbearing and oppressive governmental action.
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