Quoted in The Christian Science Monitor article, "Ruling against Obamacare birth control mandate creates legal limbo"

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“When it comes to the accommodation of religion, there are always a number of variables in play, including the sincerity of the claimants' asserted beliefs, the strength of the government's interest in denying the exemption, and the nature of the burden that the government is imposing on religious exercise,” wrote Richard Garnett, a political scientist at the University of Notre Dame in an e-mail to The Christian Science Monitor.

“There is, at present, disagreement and even confusion among scholars and courts over how to identify and evaluate alleged burdens on religion,” he added.