Masterpiece Cakeshop v. Colorado Civil Rights Commission

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Masterpiece Cakeshop v. Colorado Civil Rights Commission
Seal of the United States Supreme Court.svg
Argued December 5, 2017
Decided June 4, 2018
Full case name Masterpiece Cakeshop, Ltd., et al., Petitioners v. Colorado Civil Rights Commission, et al.
Docket nos. 16-111
Citations 584 U.S. ___ (more)
138 S. Ct. 1719
Prior history Judgment for plaintiff, Craig v. Masterpiece Cake Shop et al., No. 14CA1351 (2015); cert. granted, 137 S. Ct. 2290 (2017)
Holding
By failing to act in a manner neutral to religion, the Colorado Civil Rights Commission violated the First Amendment to the United States Constitution.
Court membership
Chief Justice
John G. Roberts
Associate Justices
Anthony Kennedy · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Samuel Alito · Sonia Sotomayor
Elena Kagan · Neil Gorsuch
Case opinions
Majority Kennedy, joined by Roberts, Breyer, Alito, Kagan, Gorsuch
Concurrence Kagan, joined by Breyer
Concurrence Gorsuch, joined by Alito
Concurrence Thomas, joined by Gorsuch
Dissent Ginsburg, joined by Sotomayor
Laws applied
U.S. Const. amend. I

Masterpiece Cakeshop v. Colorado Civil Rights Commission, 584 U.S. ___ (2018), was a case in the Supreme Court of the United States that dealt with whether owners of public accommodations can refuse certain services based on the First Amendment claims of free speech and free exercise of religion, and therefore be given an exemption from laws ensuring non-discrimination in public accommodation — in particular, by refusing to provide creative services, such as making a wedding cake for the marriage of a same-sex couple, on the basis of the owner's religious beliefs.

The case dealt with Masterpiece Cakeshop, a bakery in Lakewood, Colorado, which refused to provide a wedding cake to a gay couple based on the owner's religious beliefs. The Colorado Civil Rights Commission, evaluating the case under the state's anti-discrimination law, the Colorado Anti-Discrimination Act, found the bakery discriminated against the couple and issued specific orders for the bakery to follow. Following appeals within the state that affirmed the Commission's decision, the bakery took the case to the U.S. Supreme Court.

In a 7-2 decision, the Court ruled on narrow grounds that the Commission did not employ religious neutrality, violating Masterpiece owner Jack Phillips' rights to free exercise, and reversed the Commission's decision. The Court did not rule on the broader intersection of anti-discrimination laws, free exercise of religion, and freedom of speech, due to the complications of the Commission's lack of religious neutrality.

Procedural history[edit]

Facts of the case[edit]

Masterpiece Cakeshop in Lakewood, Colorado

In 2012, same-sex couple Charlie Craig and David Mullins from Colorado made plans to be lawfully married in Massachusetts and return to Colorado to celebrate with their family and friends. At that time state law did not provide for same-sex marriage in Colorado, though by 2014 the state had allowed same-sex marriages, and the Supreme Court of the United States would affirm that gay couples have the fundamental right to marry in Obergefell v. Hodges 576 U.S. ___ (2015).[1]

Craig and Mullins visited Masterpiece Cakeshop in Lakewood, Colorado in July 2012 to order a wedding cake for their return celebration. Masterpiece's owner Jack Phillips, who is a Christian, declined their cake request, informing the couple that he did not create wedding cakes for same-sex marriages owing to his Christian religious beliefs, although the couple could purchase other baked goods in the store. Craig and Mullins promptly left Masterpiece without discussing with Phillips any details of their wedding cake.[2]:2 The following day, Craig's mother, Deborah Munn, called Phillips, who advised her that Masterpiece did not make wedding cakes for same-sex weddings[2]:2 because of his religious beliefs and because Colorado did not recognize same-sex marriages.[3][2]:1–2

Colorado Civil Rights Commission[edit]

While another bakery provided a cake to the couple, Craig and Mullins filed a complaint to the Colorado Civil Rights Commission under the state's public accommodations law, the Colorado Anti-Discrimination Act, which prohibits businesses open to the public from discriminating against their customers on the basis of race, religion, gender, or sexual orientation.[4][3] Colorado is one of twenty-one U.S. states that have anti-discrimination laws against sexual orientation.[5] Craig and Mullins' complaint resulted in a lawsuit, Craig v. Masterpiece Cakeshop.[6] The case was decided in favor of the plaintiffs; the cake shop was ordered not only to provide cakes to same-sex marriages, but to "change its company policies, provide 'comprehensive staff training' regarding public accommodations discrimination, and provide quarterly reports for the next two years regarding steps it has taken to come into compliance and whether it has turned away any prospective customers."[7]

Colorado Court of Appeals[edit]

Masterpiece appealed the decision to the Court of Appeals with the aid of Alliance Defending Freedom, and refused to comply with the state's orders, instead opting to remove themselves from the wedding cake business;[4] Phillips claimed that this decision cost him 40% of his business.[8] Alongside the Colorado Civil Rights Commission, the American Civil Liberties Union represented Craig and Mullins during the appeals.[3] The state's decision was upheld on the grounds that despite the nature of creating a custom cake, the act of making the cake was part of the expected conduct of Phillips' business, and not an expression of free speech nor free exercise of religion.[4][9] The court distinguished its decision in Craig from another case, brought to the Commission by William Jack, in which three bakeries refused to create a cake for Jack with the message "Homosexuality is a detestable sin. Leviticus 18:22",[2]:21 citing that in the latter, the bakeries had made other cakes for Christian customers and declined that order based on the offensive message rather than the customers' creed, whereas Masterpiece Cakeshop's refusal to provide Craig & Mullins with a wedding cake "was because of its opposition to same sex marriage which...is tantamount to discrimination on the basis of sexual orientation."[2]:21

The Supreme Court of Colorado declined to hear an appeal.[9]:3

Before the Supreme Court[edit]

Petition for writ of certiorari[edit]

Masterpiece Cakeshop petitioned the U.S. Supreme Court for certiorari (review), under the case name Masterpiece Cakeshop, Ltd. v. Colorado Civil Rights Commission, of the following question:[10]

Whether applying Colorado's public accommodations law to compel Phillips to create expression that violates his sincerely held religious beliefs about marriage violates the Free Speech or Free Exercise Clauses of the First Amendment.[9]

Both the Colorado Civil Rights Commission and the American Civil Liberties Union (ACLU) urged the Supreme Court to reject the appeal, fearing that a Court decision in favor of the business would create a "gaping hole" in civil rights laws on the basis of religion.[4] The final briefs at the certiorari stage were received in December 2016.[10] The Court agreed to hear the case in the 2017 term[11] and oral arguments were heard on December 5, 2017.[12]

In further filings, Masterpiece requested that the Colorado anti-discrimination law be reviewed by the Supreme Court under strict scrutiny. He further identified that while the state's law is to assure that same-sex couples had access to the same services as heterosexual couples, the law goes too far in its enforcement, since Craig and Mullins were easily able to obtain a wedding cake from a different vendor in the state.[13] Masterpiece further believed the anti-discrimination law can be used to selectively discriminate against religion, as the Commission has allowed bakers to refuse to provide cakes with anti-same-sex marriage messages on them, even though the Commission said these refusals were appropriate due to the offensiveness of the messages and not on the basis of religion.[13] The State and the ACLU countered these points, stating the law was aimed only at conduct of a business, not their speech, and in cases like a wedding cake, "[no] reasonable observer would understand the Company’s provision of a cake to a gay couple as an expression of its approval of the customer's marriage".[13] They further argued that the cakeshop could provide catchall language to explain that any services they provide do not endorse any expressions of free speech associated with it, an allowance within the anti-discrimination law.[13]

Amicus briefs[edit]

Around 100 legal briefs were filed by third parties, roughly equally split in supporting either side of the case.[12] Many civil rights organizations filed briefs in support of Craig and Mullins, including the NAACP Legal Defense Fund,[14] the Lawyers' Committee for Civil Rights Under Law, Southern Poverty Law Center,[15] the Washington Lawyers' Committee for Civil Rights and Urban Affairs,[16] and the Civil Rights Forum, a group of plaintiff-side civil rights attorneys.[17]

Among those supporting Phillips include the United States Department of Justice under the Trump administration.[18][5] While the Department asserts that anti-discrimination laws are necessary to prevent businesses that provide goods and services, these laws cannot be used to compel a business into expressing speech they do not agree with, nor used to provide goods and services with such expressions without the ability for the business to assert they do not agree with those expressions.[13] The brief was criticized by several organizations, including those that support LGBT rights, claiming the brief as a pattern of hostile actions by the Trump administration and fearing that a decision in favor of Masterpiece would enable such businesses to have a "license to discriminate".[18][19]

Oral arguments[edit]

Oral arguments for the plaintiffs were provided by Kristen Waggoner for the Alliance Defending Freedom, representing Phillips, and the Solicitor General of the United States Noel Francisco, presenting the United States' government case as amicus curiae in support of Masterpiece Cakeshop. The defendants' arguments were given by Colorado Solicitor General Frederick Yarger, on behalf of the Colorado Civil Rights Commission, and David D. Cole of the ACLU, on behalf of Craig and Mullins. Questions asked by the Justices attempted to determine where the bounds of a cake baker's rights and the rights of those soliciting his services would extend by considering several hypothetical situations involving the making of and selling custom cakes, including situations related to racial and gender-preference discrimination.[20]

Experts believed the Supreme Court's opinions in the case would be divided, with the ultimate decision falling on the opinion of Justice Anthony Kennedy, who has historically been a swing vote in his term. In his past case history, he has been a strong supporter of gay rights (having authored all of the landmark gay rights rulings by the Supreme Court: Romer v. Evans in 1996, Lawrence v. Texas in 2003, United States v. Windsor in 2013, and Obergefell v. Hodges in 2015), and a corporation's freedom of speech in his majority opinion for Citizens United v. FEC 558 U.S. 310 (2010), and freedom of religion through his concurrence with the majority in Burwell v. Hobby Lobby Stores, Inc. 573 U.S. ___ (2014).[5][21][22][23][24]

Opinion of the Court[edit]

Majority opinion[edit]

The Court issued its ruling on June 4, 2018, ordering a reversal of the decision made by the Colorado Civil Rights Commission. The majority opinion was written by Justice Anthony Kennedy, and joined by Chief Justice John Roberts, and Justices Samuel Alito, Stephen Breyer, Elena Kagan and Neil Gorsuch. The opinion stated that although a baker, in his capacity as the owner of a business serving the public, "might have his right to the free exercise of his religion limited by generally applicable laws", a State decision in an adjudication “in which religious hostility on the part of the State itself” is a factor violates the "State’s obligation of religious neutrality" under the Free Exercise Clause of the First Amendment to the Constitution.[25] Kennedy's opinion stated that the Commission's review of Phillips' case exhibited hostility towards his religious views. The Commission compared Phillips' religious beliefs to defense of slavery or the Holocaust. Kennedy found such comparisons "inappropriate for a Commission charged with the solemn responsibility of fair and neutral enforcement of Colorado’s anti-discrimination law".[26] Kennedy's opinion also cited the three exemptions the commission previously granted for the non-discrimination law arising from the William Jack complaints. The opinion also noted differences in handling previous exemptions as indicative of Commission hostility towards religious belief, rather than maintaining neutrality.[27] Kennedy's opinion noted that he may have been inclined to rule in favor of the Commission if they had remained religiously neutral in their evaluation.[28]

Concurring opinions[edit]

Justice Kagan wrote a concurring opinion, joined by Breyer, taking particular notice of the narrow grounds of the ruling.[29] Justice Gorsuch also wrote a concurring opinion, joined by Alito. Both Kagan's and Gorsuch's concurrence considered how the Commission handled Masterpiece differently than prior exemption requests. Kagan and Gorsuch concurrence agreed the Commission exhibited hostility towards Phillips' religious beliefs and concurred with the reversal. Kagan cited as significant differences between prior Commission exemptions and the instant case. She posited the Commission could have ruled differently in the two situations if they had stayed religiously-neutral. Gorsuch indicated the Commission should maintain consistency among similar cases.[30]

Justice Clarence Thomas wrote another opinion, concurring in part and concurring in judgment, joined by Gorsuch. Thomas found that the Majority opinion did not consider the free speech, free exercise or anti-discrimination implications of the case, despite significant attention during oral arguments.[31][32] Thomas opined support for Masterpiece, both on grounds of free speech and free exercise.[33]

Dissenting opinions[edit]

Justice Ruth Bader Ginsburg wrote the dissenting opinion, joined by Sonia Sotomayor. Ginsburg believed that the Commission acted fairly in evaluating the case, saying "what critically differentiates them is the role the customer’s 'statutorily protected trait,' played in the denial of service".[34]

Analysis[edit]

The Court avoided ruling broadly on the intersection of anti-discrimination laws and rights to free exercise.[35] Kennedy's decision specifically noted the hostility towards Phillips made by the Commission as their reason to reverse the ruling, but because of the existence of this hostility in the current case, they could not rule on the broader issue regarding anti-discrimination law and the free exercise of religion. Kennedy stated that "[t]he outcome of cases like this in other circumstances must await further elaboration in the courts, all in the context of recognizing that these disputes must be resolved with tolerance, without undue disrespect to sincere religious beliefs, and without subjecting gay persons to indignities when they seek goods and services in an open market".[36][37] Kennedy's decision affirmed that there remains protection of same-sex couples and gay rights which states can still enforce through anti-discrimination laws, a point also agreed to by Ginsburg's dissent.[32] The general constitutionality of anti-discrimination laws to prevent discrimination against sexual orientation affirmed by the Masterpiece decision was reflected in lower courts that same week, in a case decided by the Arizona Court of Appeals, Brush & Nib Studio v. Phoenix,[38] which upheld the city of Phoenix's anti-discrimination ordinance that included sexual orientation. The Court of Appeals extensively quoted Masterpiece in affirming the Arizona Superior Court's prior decision.[39][40][41]

The Alliance Defending Freedom, which represented Masterpiece, supported the Court's decision in finding that condemned the Commission's review of Phillips' case, stating that "Tolerance and respect for good-faith differences of opinion are essential in a society like ours".[32] The American Civil Liberties Union welcomed the part of the decision affirming protection of gay rights, stating that the Court "reaffirmed its longstanding rule that states can prevent the harms of discrimination in the marketplace, including against L.G.B.T. people".[32]

Another predominate case involving anti-discrimination laws and religious freedom that was in the court system during Masterpiece was the Arlene's Flowers lawsuit in Washington, with the issue over flower arrangements being provided for a same-sex wedding. Prior to the decision in Masterpiece, a petition for writ of certorari had been issued to the Supreme Court. Following the decision of Masterpiece, the flower shop owner used that decision to assert that they were shown similar religious hostility, and requested their case to be reheard. On June 25, 2018, the Supreme Court dismissed the pending petition, and ordered that lower courts review the flower shop's case in a similar light as Masterpiece.[42]

Masterpiece's basis of evaluating statements of public officials to determine if there was religious hostility in evaluating cases arose in Justice Sotomayor's dissent in Trump v. Hawaii, 585 U.S. ___ (2018), which dealt with President Trump's travel ban against several nations which had a high Muslim population. While the majority ruled that the ban was within the President's powers and sent the case back to lower courts to rule on other matters, Sotomayor believed that the decision of Masterpiece should have been used to judge President Trump and his administration's statements that she believed showed hostility towards Muslims and would have not justified the ban.[43]

Public opinion[edit]

A nationwide and state-by-state poll on the issue conducted throughout 2017 by the Public Religion Research Institute as part of the annual American Values Atlas survey revealed that 60% of Americans, including a majority or plurality in every state, opposed allowing religiously-based refusals of services or products to gay people by small business owners (colloquially known as "the baker's exception"), while 33% supported allowing such religiously-based refusal, and 7% had no opinion.[44][45][46]

Subsequent events[edit]

Masterpiece Cakeshop became involved in a similar case in 2018, stemming from an incident in June 2017. The bakery refused to bake Autumn Scardina, a Colorado lawyer, a cake to celebrate her gender transition, which would have had a pink interior and blue exterior. Philips stated later that he refused to bake such a cake based on his Christian beliefs that one does not get to choose their gender. Scardina complained to the Colorado Division of Civil Rights, which found in June 2018 sufficient evidence that the bakery discriminated against her transgender status, and ordered the parties into compulsory mediation. Philips subsequently filed a lawsuit against the state in August 2018 to seek a permanent injunction to prevent the state from enforcing its anti-discrimination laws against him as well as punitive damages. Colorado Governor John Hickenlooper, who is named as a defendant in the suit, expects that the case will require the Supreme Court to revisit its decision from Masterpiece, as the previous ruling "did not address the basic issue" of religious freedom.[47][48]

See also[edit]

References[edit]

  1. ^ Barnes, Robert (June 26, 2017). "Supreme Court to take case on baker who refused to sell wedding cake to gay couple". The Washington Post. Retrieved June 26, 2017. 
  2. ^ a b c d e Craig v. Masterpiece Cake Shop et al., No. 14CA1351 (Colo. Ct. of App. August 13, 2015)
  3. ^ a b c Parloff, Roger (March 6, 2017). "Christian Bakers, Gay Weddings, and a Question for the Supreme Court". The New Yorker. Retrieved June 27, 2017. 
  4. ^ a b c d Savage, David (June 26, 2017). "Supreme Court will hear case of Colorado baker who refused to make wedding cake for same-sex couple". The Los Angeles Times. Retrieved June 26, 2017. 
  5. ^ a b c Savage, David (September 12, 2017). "Colorado cake maker asks Supreme Court to provide a religious liberty right to refuse gay couple". The Los Angeles Times. Retrieved September 14, 2017. 
  6. ^ "Colo. judge orders Christian baker to bake gay wedding cake. Will he say no?". Christian Science Monitor. December 7, 2013. Retrieved June 6, 2015. 
  7. ^ "Charlie Craig and David Mullins v. Masterpiece Cakeshop". August 13, 2015. 
  8. ^ Roberts, Roxanne (November 30, 2017). "Wedding cakes can be stunning creations. But do they qualify as art?". The Washington Post. Retrieved December 1, 2017. 
  9. ^ a b c "Petition for a Writ of Certiorari" (PDF). Retrieved 16 April 2017. 
  10. ^ a b "Docket for case No. 16-111". Supreme Court of the United States. Retrieved 16 April 2017. 
  11. ^ de Vogue, Ariane; Diaz, Daniella (June 25, 2017). "Supreme Court agrees to hear religious liberty case next term". CNN. Retrieved June 25, 2017. 
  12. ^ a b Wolf, Richard (November 2, 2017). "Free speech v. same-sex marriage case floods high court". USA Today. Retrieved November 14, 2017. 
  13. ^ a b c d e Howe, Amy (September 11, 2017). "Wedding cakes v. religious beliefs?: In Plain English". SCOTUSblog. Retrieved September 14, 2017. 
  14. ^ "Brief of Amicus Curiae NAACP Legal Defense & Educational Fund in Support of Respondents" (PDF). October 30, 2017. Retrieved June 26, 2018. 
  15. ^ "Brief amici curiae of Lawyers' Committee for Civil Rights Under Law, et al" (PDF). October 30, 2017. Retrieved June 26, 2018. 
  16. ^ "Brief of Amicus Curiae Washington Lawyers' Committee for Civil Rights and Urban Affairs, Public Interest Law Center, Chicago Lawyers' Committee for Civil Rights, and Mississippi Center for Justice in Support of Respondents" (PDF). October 30, 2017. Retrieved June 26, 2018. 
  17. ^ "Brief of Amicus Curiae for the Civil Rights Forum in Support of Respondents" (PDF). October 30, 2017. Retrieved June 26, 2018. 
  18. ^ a b S.M. (September 8, 2017). "The Department of Justice backs a baker who refused to make a gay wedding cake". The Economist. Retrieved 12 September 2017. 
  19. ^ Moreau, Julie (September 11, 2017). "Department of Justice's Gay Rights Brief Slammed by Advocates as 'License to Discriminate'". NBCNews. Retrieved September 11, 2017. 
  20. ^ "Live Coverage: Supreme Court Hears Same-Sex Wedding Cake Case". The Wall Street Journal. December 5, 2017. Retrieved December 5, 2017. 
  21. ^ Liptak, Adam (September 16, 2017). "Cake Is His 'Art.' So Can He Deny One to a Gay Couple?". The New York Times. Retrieved September 18, 2017. 
  22. ^ Hurley, Lawrence (September 27, 2017). "No matter how you slice it, U.S. jurist Kennedy key vote in cake case". Reuters. Retrieved September 27, 2017. 
  23. ^ Howe, Amy (7 December 2017). "Argument analysis: Conservative majority leaning toward ruling for Colorado baker (UPDATED)". SCOTUSblog. Retrieved 7 December 2017. With Kennedy seemingly holding the key vote, the couple and their supporters at first seemed to have reason to be optimistic. 
  24. ^ Hurley, Lawrence (September 27, 2017). "No matter how you slice it, U.S. jurist Kennedy key vote in cake case". Reuters. Retrieved February 7, 2018. 
  25. ^ Slip op., pp. 2-3, Masterpiece Cakeshop, Ltd. v. Colorado Civil Rights Commission, case no. 16-111, U.S. Supreme Court (June 4, 2018).
  26. ^ Pavich, Katie (June 4, 2018). "Supreme Court Overwhelmingly Rules in Favor of Colorado Baker in Wedding Cake Case". Townhall. Retrieved June 4, 2018. 
  27. ^ Volokh, Eugene (June 4, 2018). "The Masterpiece Cakeshop Decision Leaves Almost All the Big Questions Unresolved". Reason. Retrieved June 4, 2018. 
  28. ^ Rubin, Jennifer (June 4, 2018). "In baker's case, neither side has much reason to rejoice". The Washington Post. Retrieved June 4, 2018. 
  29. ^ Sherman, Mark (June 4, 2018). "Supreme Court rules in favor of Colorado baker who wouldn't make same-sex wedding cake". chicagotribune.com. Retrieved June 4, 2018. 
  30. ^ Sheppard, Ilya (June 4, 2018). "Masterpiece Cakeshop Ruling Tastes Good, But Is Empty Calories". The Cato Institute. Retrieved June 4, 2018. 
  31. ^ Epps, Garrett (June 4, 2018). "Justice Kennedy's Masterpiece Ruling". The Atlantic. Retrieved June 4, 2018. 
  32. ^ a b c d Liptak, Adam (June 4, 2018). "Supreme Court Sides With Colorado Baker Who Turned Away Gay Couple". The New York Times. Retrieved June 4, 2018. 
  33. ^ Whelan, Ed (June 4, 2018). "Masterpiece Cakeshop Victory". National Review. Retrieved June 4, 2018. 
  34. ^ Slip op., pp. 2-3, Masterpiece Cakeshop, Ltd. v. Colorado Civil Rights Commission, case no. 16-111, U.S. Supreme Court (June 4, 2018)
  35. ^ Liptak, Adam (June 4, 2018). "Supreme Court Sides With Baker Who Turned Away Gay Couple". The New York Times. ISSN 0362-4331. Retrieved June 4, 2018. 
  36. ^ "Supreme Court rules narrowly for Colorado baker who wouldn't make same-sex wedding cake". Reuters. June 4, 2018. Retrieved June 4, 2018 – via CBS News. 
  37. ^ Barnes, Robert (June 4, 2018). "Supreme Court rules in favor of baker who would not make wedding cake for gay couple". The Washington Post. Retrieved June 4, 2018. 
  38. ^ Brush & Nib Studio v. Phoenix , No. 1 CA-CV 16-0602 (Ariz. Ct. App. June 7, 2018).
  39. ^ Johnson, Chris (June 7, 2018). "Court Applies Masterpiece Cakeshop Ruling to Uphold Ariz. LGBT Ordinance". Washington Blade. Retrieved June 9, 2018. 
  40. ^ Ring, Trudy (June 8, 2018). "Arizona Court Uses Cakeshop Case to Affirm LGBT Rights". The Advocate. Retrieved June 9, 2018. 
  41. ^ Stern, Mark Joseph (June 7, 2018). "Making Sense of Masterpiece Cakeshop". Slate. Retrieved June 9, 2018. 
  42. ^ Wolf, Richard (June 25, 2018). "First cake, now flowers: Supreme Court gives florist who refused to serve gay wedding a new hearing". USA Today. Retrieved June 25, 2018. 
  43. ^ Hurd, Hilary; Schwartz, Yishai (June 26, 2018). "The Supreme Court Travel Ban Ruling: A Summary". Lawfare. Retrieved June 28, 2018. 
  44. ^ "Emerging Consensus on LGBT Issues: Findings From the 2017 American Values Atlas". Public Religion Research Institute. 
  45. ^ "PRRI - American Values Atlas". Public Religion Research Institute. 
  46. ^ "Same-sex marriage has support among most American religious groups, study shows". National Catholic Reporter. 
  47. ^ Garcia, Nic; Mitchell, Kirk (August 15, 2018). "Masterpiece Cakeshop owner sues Hickenlooper, claiming religious persecution despite Supreme Court ruling". The Denver Post. Retrieved August 16, 2018. 
  48. ^ Doubek, James (August 16, 2018). "Colorado Baker Sues State Again, After Refusing To Make Cake For Transgender Woman". NPR. Retrieved August 16, 2018. 

Further reading[edit]

External links[edit]