 One of his former clerks, Jonathan Papik, became an Associate Justice of the Nebraska Supreme Court in 2018.Gorsuch advocates a broad definition of religious freedom that is inimical to Church–State separation advocates.In "Hobby Lobby Stores v. Sebelius" (2013), Gorsuch wrote a concurrence when the "en banc" circuit found the Affordable Care Act's contraceptive mandate on a private business violated the Religious Freedom Restoration Act.