east texas baptist university v. burwell and little sisters of the poor home for the aged v. burwell. due to the death of justice antonin scalia before the case was decided, the supreme court was deadlocked on zubik. instead of issuing a decision, it ordered the cases back to lower courts and ordered the hhs and other responsible departments to work with the parties to come up with new rules for exemptions for the mandate that took into account the parties' concerns. as part of this, by the end of 2016, an initial period of requests for input has been opened as part of the new rule-making procedure. trump administration change shortly after taking office, president donald trump issued executive order 13798, "promoting free speech and religious liberty" in may 2017 to urge the departments responsible for the aca to issue a conscience-based exemption for the contraceptive mandate as soon as possible. by october 2017, the hhs and other agencies issued a ruling letting insurers and employers refuse to provide birth control if doing so violates their religious beliefs or moral convictions. several states immediately challenged the new rules in multiple court cases, believing the rules bypassed the process that the supreme court has issued in zubik. in separate cases from the third and ninth circuits, the rules were found to be in violation of the administrative procedure act having been issued in an arbitrary and capricious manner, and a nationwide injunction was placed on their enforcement. the injunction was challenged at the supreme court by the government in little sisters of the poor saints peter and paul home v. pennsylvania. there, in july 2020, the court ruled in a 7–2 that the new rules were valid and put into place properly, lifting the injunction. reactions more democratic politicians favor these mandates than republican politicians. barbara boxer, democratic party senator for california, and house minority leader nancy pelosi favor the obama policy. darrell issa, a republican congressman from california, said that americans are divided on this issue: "while some americans may not feel that forcing them to pay for contraception are an infringement on their religious beliefs, others consider it to be an assault against their freedom of conscience." issa's february 2012 hearing on the matter was criticized for including only men from conservative religious institutions, and no women. framing the issue some people see the matter as primarily one of women's health, such as the national women's law center. others see it as a matter of religious freedom. certain consumers of mandatory health insurance, such as students matriculated at colleges of further education, have criticized what they perceive to be discrimination in provision or in practice: employer-provided plans that cover university faculty and staff may be subject to legal mandates whereas plans that cover the student body may not. sandra fluke was invited to present oral arguments on behalf of certain female student consumers dissatisfied with restrictions attached to registration for undergraduate and graduate attendance at georgetown university school of law.