As you GetReligionistas have repeatedly stressed in recent years, the battles over the Health and Human Services contraceptives mandate is not a simple story involving two levels of conflict, with churches and religious groups being granted an clear exemption and for-profit corporations over on the losing side of the religious-liberty equation.

As this battle has continued in the courts, things have only grown more complex – both for the Obama White House and the journalists who cover it.

For starters, there was that whole Hobby Lobby ruling and the fine-tuning in the regulations that has taken place since then. Meanwhile, the really interesting legal wars have focused on doctrinally-defined schools, ministries and parachurch groups that are caught in the middle. This is where things get really complicated and, frankly, many journalists do not seem to understand what all of the fuss is about.

In news reports, journalists continue to describe a wave of court victories for the White House – while having to admit that there are religious groups who don't see things that way. A new story in The New York Times offers a classic example of this struggle to frame the debate:

WASHINGTON -- Four federal appeals courts have upheld efforts by the Obama administration to guarantee access to free birth control for women, suggesting that the government may have found a way to circumvent religious organizations that refuse to provide coverage for some or all forms of contraception.

While pleased with the rulings, administration officials are not celebrating.