According to the 2004-2005 United States Census Bureau Statistical Abstract of the United States, Americans identify with at least thirty-five different self-described Christian religious groups. Of those Christian groups, there are at least four that have special tenets regarding medical treatment that are central to their religious beliefs. Together, members of the Jehovah's Witnesses, Church of God, Pentecostal Free Will Baptist Church, and Christian Science Church constitute slightly more than four-and-a-half percent of the United State's total population. . . Unfortunately, even though the First Amendment of the United States Constitution was designed on our founders' beliefs that religious freedom and the freedom to exercise one's religion were of chief importance, our courts systematically discriminate against members of these minority Christian religions for exercising those very rights. While it is commonly accepted that individuals have the right to practice these medically restrictive tenets, courts still punish plaintiffs by forcing them, when tortiously injured, to choose between what the majority considers "reasonable" and their own religious convictions.
Note, God v. the Mitigation of Damages Doctrine: Why Religion Should Be Considered a Pre-Existing Condition, 20 J.L. & Health 107 (2006-2007)