SCOTUS Amici Curiae Brief in Advocate Health Care Network v. Stapleton (2017)

SCOTUS Amici Curiae Brief in Advocate Health Care Network v. Maria Stapleton, January 24, 2017

Since long before the earliest days of the Republic, the Catholic Church has served the poor and the downtrodden on a non-denominational basis.  The Church offers this help not because those in need are Catholic, but because those called to provide the aid are Catholic.  Indeed, charity has always been a core component of the Catholic Church’s activities, “as essential to her as the ministry of the sacraments and preaching of the Gospel.”  Deus Caritas Est No. 22.  The Church effectuates that teaching through myriad Catholic ministries, ranging from local daycare centers, soup kitchens, hospitals, healthcare centers, and schools, to charitable organizations of national and global reach.  Some of these ministries belong to one of the nearly 200 archdioceses and dioceses in the United States, but many do not.  Some are affiliated with a local parish, but many are not.  And for all but a handful, there is no corporate tie to the Holy See.  Yet, as a matter of Catholic theology, the various ministries that the Church recognizes as Catholic ministries are all part of the Church.  While they are recognized as such because they have the requisite degree of unity with the Church, they may be (and often are) civilly, structurally, and financially independent entities. 

Catholic teaching also emphasizes the value of providing retirement, healthcare, and other benefits to those who help Church-affiliated organizations carry out the charitable work of the Church.  Thus, long before the advent of ERISA, Catholic charitable organizations provided their workers with generous benefits.  In recognition of that reality (which is not unique to the Catholic Church), and to avoid imposing potentially crushing new obligations on such organizations, Congress has long exempted the benefit plans of church-affiliated organizations from the sometimes burdensome requirements of ERISA.  

16-74-16-86-16-258-tsac-United-States-Conference-of-Catholic-Bishops.pdf