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Keywords

appealhearingdiscriminationregulationcivil rightsobjection
civil rightsobjection

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Masterpiece Cakeshop v. Colorado Civil Rights Commission, 584 U.S. 617, 138 S.Ct. 1719, 201 L.Ed.2d 35, 102 Empl. Prac. Dec. P 46,050, 86 USLW 4335, 18 Cal. Daily Op. Serv. 5293, 2018 Daily Journal D.A.R. 5291, 27 Fla. L. Weekly Fed. S 289

Facts

Masterpiece Cakeshop, owned by Jack Phillips, a devout Christian, refused to create a wedding cake for a same-sex couple, Charlie Craig and Dave Mullins, citing his religious opposition to same-sex marriage. The couple filed a complaint with the Colorado Civil Rights Commission under the Colorado Anti-Discrimination Act (CADA), which prohibits discrimination based on sexual orientation. The Commission ruled against Phillips, stating that his refusal constituted discrimination, and the Colorado Court of Appeals affirmed this decision. Phillips sought review from the Supreme Court, arguing that the Commission's actions violated his First Amendment rights.

Masterpiece Cakeshop, Ltd., is a Colorado bakery owned and operated by Jack Phillips, an expert baker and devout Christian. In 2012 he told a same-sex couple that he would not create a cake for their wedding celebration because of his religious opposition to same-sex marriages.

Issue

Did the Colorado Civil Rights Commission's order violate the Free Exercise Clause of the First Amendment?

Did the Colorado Civil Rights Commission's order violate the Free Exercise Clause of the First Amendment?

Rule

The Free Exercise Clause of the First Amendment requires that government actions must be neutral toward religion and cannot show hostility toward religious beliefs. While states can protect the rights of individuals against discrimination, they must do so in a manner that respects the religious freedoms of individuals and does not impose regulations that are hostile to religious beliefs.

The Free Exercise Clause bars even subtle departures from neutrality on matters of religion. U.S.C.A. Const.Amend. 1.

Analysis

The Supreme Court found that the Colorado Civil Rights Commission did not act with the required religious neutrality when adjudicating Phillips' case. The Commission's comments during hearings indicated hostility toward Phillips' religious beliefs, which compromised the fairness of the proceedings. Additionally, the disparate treatment of Phillips compared to other bakers who had refused to create cakes with anti-gay messages suggested a lack of neutrality. The Court concluded that the Commission's actions violated the Free Exercise Clause by failing to respect Phillips' sincere religious objections.

Conclusion

The Supreme Court reversed the decision of the Colorado Civil Rights Commission, holding that its actions violated the Free Exercise Clause due to a lack of religious neutrality.

Who won?

The Supreme Court ruled in favor of Jack Phillips, the owner of Masterpiece Cakeshop, concluding that the Colorado Civil Rights Commission's actions were not neutral and showed hostility toward his religious beliefs. The Court emphasized the importance of protecting religious freedoms and ensuring that government actions do not discriminate against individuals based on their religious views. This ruling underscored the need for a balanced approach that respects both the rights of same-sex couples and the religious beliefs of business owners.

The Commission's treatment of Phillips' case showed elements of a clear and impermissible hostility toward the sincere religious beliefs motivating his objection.

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