Several federal appellate courts reached different results on constitutional challenges to the Affordable Care Act (ACA), where secular employers argued that ACA’s mandate to cover contraceptive services violates their religious freedoms under the First Amendment and the Religious Freedoms Restoration Act. First, the U.S. Court of Appeals for the District of Columbia Circuit in Wheaton College v. Sebelius, Nos. 12-5273 & 12-5291, 2012 WL 6652505 (D.C. Cir. Dec. 17, 2012), ruled that lawsuits brought by two non-profit religious colleges were premature, despite the court’s finding that the colleges’ employees could sue under ERISA to enforce their rights to contraceptive coverage, because the mandate is not being enforced against non–profit secular employers and final agency guidance on the mandate’s application to such employers is not expected until August 2013. Second, in Hobby Lobby Stores, Inc. v. Sebelius, No. 12-644, 2012 WL 6698888 (Dec. 26, 2012) and No. 12-6294 (10th Cir. Dec. 20, 2012), the U.S. Supreme Court and the Court of Appeals for the Tenth Circuit refused to issue a preliminary injunction pending appeal to prevent enforcement of the mandate as to Hobby Lobby, a closely held, for-profit corporation claiming religious freedoms based on its owners’ beliefs. In Hobby Lobby, the district court held the mandate would not substantially burden the owners’ exercise of religion. Third, the U.S. Court of Appeals for the Seventh Circuit issued a preliminary injunction to prevent enforcement of ACA’s mandate as to a small, family-run, for-profit business in Korte v. Sebelius, No. 12-15488, 2012 WL 6757353 (7th Cir. Dec. 28, 2012), reasoning that the mandate would preclude the owners from operating the business according to their Catholic beliefs.