"The circuits have split. You're getting different, conflicting interpretations of law, so the line of cases will have to go to the Supreme Court, " said Carl Esbeck, a professor at the University of Missouri Law School who specializes in religious liberty issues.
Last year, the Supreme Court ruled that Obama's fiercely contested health care overhaul, known as the Affordable Care Act, was constitutional. But differences over the birth control provision in the law have yet to be resolved.
Under the requirement, most employers, including faith-affiliated hospitals and nonprofits, have to provide health insurance that includes artificial contraception, including sterilization, as a free preventive service. The goal, in part, is to help women space pregnancies as a way to promote health.
Religious groups who employ and serve people of their own faith — such as churches — are exempt. But other religiously affiliated groups, such as Catholic Charities, must comply.
Roman Catholic bishops, evangelicals and some religious leaders who have generally been supportive of Obama's policies have lobbied fiercely for a broader exemption. The Catholic Church prohibits the use of artificial contraception. Evangelicals generally permit the use of birth control, but they object to specific methods such as the morning-after contraceptive pill, which they argue is tantamount to abortion.
Obama promised to change the birth control requirement so insurance companies and not faith-affiliated employers would pay for the coverage, but religious leaders said more changes were needed to make the plan work.