Hostility to Religion: The Growing Threat to

Religious Liberty in the United States

Many of the first European settlers on American shores sought freedom from religious
persecution. Decades later, the Founding Fathers considered religious liberty to be a paramount
principle in the new United States. Religious liberty is our first freedom,! not only because it is
listed first in the "ill of Rights but because without it, all other freedoms are impossible# $he
Founders affirmed that allegiance to %od precedes allegiance to the state, and that our rights
come from our &reator, not the go'ernment. $his is the essential assumption upon which our
entire system of go'ernment has been built. Religious liberty was so important to the Framers
of the new United States &onstitution that they included it in the First Amendment# &ongress
shall ma(e no law respecting an establishment of religion, or prohibiting the free e)ercise
thereof . . . .!

Fast forward three hundred years, and hostility to religious e)pression in the public s*uare is
reaching le'els unprecedented in the history of the United States. Militant atheists target long+
e)isting crosses and historical mar(ers of America,s religious heritage in public places. $eachers
tell young school+children they can,t read their "ible in school. -ri'ate citi.ens and the
go'ernment ali(e are attac(ing religious e)pression by other citi.ens. /hether it,s a media
bac(lash to merely e)pressing a faith position on se)uality, or the use of nondiscrimination laws
to punish religious business owners for their decisions, threats to free speech and free e)ercise
are heating up both in the courts and the public s*uare.

$his publication contains a list of documented accounts of hostility toward faith in the United
States today, bro(en down in the following four definable types of incidents# Section 0#
Suppression of Religious E)pression in the -ublic S*uare1 Section 00# Suppression of Religious
E)pression in Schools and Uni'ersities1 Section 000# &ensure of Religious 2iewpoints Regarding
Se)uality1 and Section 02# Suppression of Religious E)pression on Se)uality Using
3ondiscrimination 4aws.

Most of the documented accounts here ha'e occurred within the past se'eral years. $his, in and
of itself, is troubling. "ut in some areas, particularly with regard to statements and positions on
se)uality 5many of which are documented in Sections 000 and 02 below6, hostility toward
religion has increased at an e)ponential rate. $his trend should cause any freedom+lo'ing
indi'idual to be truly alarmed.

Americans urgently need to be aware of the suppression of religion in this regard. 7et this
should not 8ust concern those whose rights are most immediately affected, for the principles
underlying suppression of rights in this area will 'ery *uic(ly and easily lead to the restriction
and suppression of free in*uiry and critical thin(ing. All should be concerned that suppression

9uly :;<=
0ssue Analysis 0S<=%;<
FAMILY RESEARH !U"IL
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:;:+ABA+:<;; C fax :;:+ABA+:<A= C 5>;;6 ::D+=;;> order line
www.frc.org
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of rights, particularly as outlined in Sections 000 and 02 of this publication, is the product of
more insidious forces which ultimately will erode liberties for all Americans, regardless of
'iewpoint or le'el of concern with these immediate issues.

As Americans, awareness grows, we can focus our attention on the public debate and the state
of the law. 4iberty does not maintain itself, and in a democracy, many 'oices are constantly
clamoring for desired protections and pri'ileges to be enshrined in law. As we become more
fully aware of and engaged on the issue of hostility toward religion, we can more effecti'ely
defend ci'il liberties and restore religious liberty to its proper place in American society.
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Se#tion I: Atta#$s on Religious E%&ression in the
'ubli# S(uare

Attac(s on the e)pression of religion in the public s*uare! of go'ernment and public property,
land, and buildings are not recent. For many years, those opposed to crosses and monuments in
public places ha'e attempted to use the courts to ha'e these displays declared unconstitutional,
often under Establishment &lause grounds. ?owe'er, .ealous atheist groups increasingly ha'e
focused their hostility on pri'ate religious e)pression which is only 'ery tenuously connected to
go'ernment. $hey ha'e continued to harass small towns and localities which merely maintain
the traditions handed to them in'ol'ing years of public prayer, displays of religious history on
public buildings, or crosses on 'eterans, memorials.

@ften, not (nowing any better and lac(ing proper counsel, localities capitulate to the demands
of those hostile to any public e)pression of faith. ?owe'er, capitulation is not necessary, as
attorneys and ad'ocates are ready to help. Following are documented incidents of hostility to
religious e)pression in the public s*uare.

Girl )arred *ro+ Singing ,-u+baya. )e#ause It /as a ,Religious. Song 0 August 112 34445
Samantha Schul., an eight+year+old girl from -ort &harlotte, Florida, was barred from singing
Eumbaya! at a "oys F %irls &lub talent show because the song included the words @h,
4ord.! "ill Sadlo, the club,s Director of @perations, worried parents would complain if
children went home and said they heard a religious song at the nonsectarian camp.! ?e said,
GwHe don,t want to ta(e the chance of a child offending another child,s religion.! Randy "ouc(,
the club,s local director, chimed in# /e 8ust can,t allow any religious songs. . . . 7ou ha'e to
chec( your religion at the door.! Samantha,s parents were li'id at not being gi'en notice that
their daughter,s song would be barred. ?er mother said, 0 learned that song in %irl Scouts, not
in church. . . . 0t,s a campfire song, for goodness, sa(e.! Mr. Sadlo agreed the club should ha'e
notified the girl,s parents earlier that the song would not be allowed, and apologi.ed to the
family.
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Seniors )anned *ro+ Singing hrist+as arols in Their Ho+es 0 6e#e+ber 34475
Seniors li'ing in facilities owned by the ?ousing Resource De'elopment &orporation were told
they could not sing &hristmas carols. Following an attorney,s demand letter, the facility
re'ersed its decision.
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8oluntary A*ter9'rison Rehab enter losed )e#ause o* Its Faith9)ased Te#hni(ue 0
May 344:5
$he "ristol &ounty, Massachusetts, sheriff,s department funded a rehabilitation program to
help recently released prisoners deal with drug addiction and reintegrate into society.
Americans United for Separation of &hurch and State threatened legal action against the county
for funding a faith+based organi.ation. $he sheriff ga'e in to the pressure and e)pelled the
group from the facility.
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ALU /or$s to Sto& Touris+ Grant *ro+ Going to hristian on#ert 0 "o;e+ber 342 344<5
?ernando &ounty, Florida, ma(es grants a'ailable for e'ents that will bring tourists into the
county in order to spur economic de'elopment and promote the county as a tourist destination.
$he $ourist De'elopment &ouncil appro'ed a grant for the Freedom Fest, a &hristian music
festi'al held on the Fourth of 9uly wee(end. Despite the secular purpose of the grant and the
neutral manner in which it is granted, the American &i'il 4iberties Union 5A&4U6 complained
about the funds going to a religious festi'al. 0n response to the complaints, the festi'al was
forced to change its name from the %od and &ountry! festi'al to the Family, Freedom, and
&ountry! festi'al, and the grant had to be gi'en directly to 'endors instead of the organi.ation
promoting the festi'al. $he A&4U still warned that any o'ert religious o'ertones! at the e'ent
would cause trouble! for the county.
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Freedo+ *ro+ Religion Foundation Threatens Te#hni#al olleges in /is#onsin *or Ha;ing
Good Friday Holiday 0 =anuary 344>5
$he Freedom from Religion Foundation 5FFRF6 sent letters to technical colleges in /isconsin
claiming that ha'ing %ood Friday as a holiday was unconstitutional. Se'eral of the technical
colleges indicated that they would eliminate their celebration of the holiday.
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All hrist+as 6is&lays )anned *ro+ /ashington State a&itol )uilding a*ter o+&laint
*ro+ Freedo+ *ro+ Religion Foundation 0 !#tober ?42 344>5
After recei'ing a complaint from the Freedom from Religion Foundation, the state of
/ashington banned all holiday displays other than the holiday tree! inside its capitol
building.
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Freedo+ *ro+ Religion Foundation Atta#$s Mother Teresa Sta+& 0 =anuary 34145
$he United States -ostal Ser'ice 5US-S6 honored Mother $eresa, a 3oble -eace -ri.e recipient,
with a memorial stamp for her humanitarian relief. $he Freedom from Religion Foundation
critici.ed the stamp as a 'iolation of US-S regulations by honoring a religious figure and called
on its members to boycott the stamp and begin a letter+campaign to e)pose the dar(er side! of
Mother $eresa.
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Federal Reser;e )oard 6e+ands )an$ Re+o;e Religious hrist+as 6e#orations 0
6e#e+ber 34145
An @(lahoma ban( was forced to remo'e "ible 'erses from its website, crosses from teller
stations, and buttons that carried a &hristian &hristmas message for a day after a 'isit from
Federal Reser'e employees. $he Federal Reser'e "oard ruled that ban(s may not ma(e any
religious statement as doing so might discourage people from applying for loans. $he Federal
Reser'e employees chec(ing the ban( to ma(e sure it complied with regulations cited the
religious material and demanded its remo'al. After the president of the ban( challenged the
Federal Reser'e, the religious items were restored while the Federal Reser'e made a more
thorough in'estigation of the issue.
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Freedo+ *ro+ Religion Foundation Threatens o++issioner *or Ha;ing a ross and
"ati;ity S#ene in His 'ersonal !**i#e 0 6e#e+ber 34145
$he Freedom from Religion Foundation sent a letter to Dennis 4enno), a county drain
commissioner, threatening a lawsuit if he would not remo'e a cross and 3ati'ity scene from his
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personal office. FFRF claimed the display is a 'iolation of the Establishment &lause. 4enno)
commented, $his is my pri'ate office in my pri'ate area, 0,m not trying to force my faith down
anybody,s throatG1H 0,m 8ust saying 0 celebrate &hristmas.!
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!ba+a Ad+inistration Tries to -ee& 'rayer o** /orld /ar II Me+orial 0 "o;e+ber 34115
$he @bama Administration opposed the /orld /ar 00 Memorial -rayer Act of :;<<, which
would ha'e put a copy of Fran(lin D. Roose'elt,s D+Day prayer on the /orld /ar 00 Memorial
in /ashington, D.&. $he Administration claims that, under the &ommemorati'e /or(s Act, it
is prohibited to put anything on a memorial that will hide part of it. Senator Rob -ortman
renewed efforts to ha'e the prayer placed at the memorial in May of :;<A.
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ity Threatened *or Renting A+&hitheater to hristian Musi#ian 0 A&ril 72 34135
A resident of Draper, Utah, threatened to sue the city if it did not cancel a Michael /. Smith
concert because the city rented the city,s amphitheater to the &hristian musician and facilitated
tic(et sales through the city,s website. $he city refused to cancel the concert and noted that it
treated the Michael /. Smith concert in the same manner that it treats all groups that desire to
perform at the amphitheater.
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Atheist Grou& )ullies Santa lara2 ali*ornia to Re+o;e Histori#al Mar$er 0 A&ril 72 34135
$he Freedom from Religion Foundation demanded that Santa &lara, &alifornia, remo'e a
granite cross from Memorial &ross -ar(. $he Santa &lara 4ions &lub had donated the cross for
the par( as a historical mar(er to mar( the location of a mission built in <JJB.
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Stea$house Threatened *or ,hur#h Me+ber A&&re#iation 6ay. 0 =une 112 34135
$he /estern Si..lin, Stea(house in /iggins, Mississippi, de'eloped promotional offers to
attract customers. @ne such offer was the church member appreciation day,! during which
church members could get a discount at the stea(house. $he Freedom from Religion
Foundation threatened the stea(house for offering this discount, asserting that this promotion
'iolated the &i'il Rights Act. $he restaurant responded by stating that it would discontinue
including churches in GitsH discount promotions and programs mo'ing forward and will only
offer them to other local businesses and companies that are not religious in nature.!
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Go;ern+ent )ans 'rayer at Ho+eless Shelter 0 =uly 34135
$he United &aring Shelter 5U&S6 in E'ans'ille, 0llinois, allowed prayer before a free meal
pro'ided by the shelter. $he prayers were open to all and were not mandatory. $he U.S.
Department of Agriculture, howe'er, demanded that U&S stop the prayers or stop accepting
federal assistance to feed the homeless. $he U&S now permits only a moment of silence before
meals.
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Seniors Threatened with Re+o;al o* hrist+as Tree 0 6e#e+ber @2 3413
Senior citi.ens in 4os Angeles, &alifornia, were threatened with the remo'al of a &hristmas tree
from the communal area of their assisted li'ing apartment comple). 0nitially, the company
running the comple) planned to remo'e all religious holiday items from the apartment
comple),s communal areas. After residents strongly protested, the company re'ersed course
and claimed it ne'er intended to prohibit the celebration of the holidays, and that the planned
remo'al of the &hristmas tree was due to a misunderstanding.
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Atheist Grou& 6e+ands 8ietna+ 8eterans Me+orial )e Re+o;ed 0 February :2 341?5
$he Freedom from Religion Foundation sent a letter to &oos "ay, @regon, demanding that the
city remo'e its 2ietnam 2eterans, Memorial because the memorial includes a cross. Since the
FFRF sent its letter, the cross has been 'andali.ed and a bomb was placed on the cross near a
playground. &ity officials, howe'er, are not bac(ing down and ha'e refused to remo'e the
cross.
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Atheists Target "ati;ity S#ene 0 6e#e+ber @2 341?
$he Freedom from Religion Foundation 5FFRF6 wrote a letter to local officials in &hipley,
Florida and demanded that the city remo'e a nati'ity scene from the grounds surrounding its
&ity ?all, alleging that the crKche represented a 'iolation of the separation of church and state.

7et many locals supported the crKche,s presence. Resident Anne &henault said she en8oyed the
nati'ity scene and that those who disli(ed it were not forced to embrace its sentiment. /e
thin( it represents the ma8ority of the beliefs of the people that li'e here,! she said. Many
&hipley residents showed up to a city council meeting to show their support for the crKche and
to fight bac( against attempts to ha'e it remo'ed from the &hipley &ity ?all grounds.

A local reporter unwittingly put the Freedom from Religion Foundation on notice of the crKche
when he contacted the organi.ation to learn if the nati'ity,s presence is constitutional. ?e then
published an apology, e)plaining that he had contacted the organi.ation, among others, out of
curiosity and did not intend to spar( contro'ersy o'er the nati'ity. $he newspaper clarified that
it did not desire the remo'al of the crKche. &ouncil members ha'e so far pledged to (eep the
nati'ity in place.
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Se#tion II: Atta#$s on Religious E%&ression in
S#hools and Uni;ersities

Religious e)pression in our public schools has been a source of conflict and contro'ersy for
some time. 7et student rights and the rights of school employees are often sub8ected to
Establishment &lause concerns. Some of the same atheist groups opposed to religious
e)pression in the public s*uare ha'e also targeted our schools, and by e)tension, our children in
those schools. 4ocal communities across the nation ha'e, historically, successfully determined
how their children are to be educated L as parents, their children, and local administrators and
teachers come together and participate in a microcosm of democracy. 7et outside groups hostile
to faith often inter8ect themsel'es to these local communities, threatening legal action if the
communities do not capitulate to their demands. As is often the case in other situations, local
go'ernments do not (now better, lac( proper counsel, and therefore gi'e in to these groups,
wishes. 7et capitulation within the academic arena is not necessary. Attorneys and ad'ocates
are ready to help these communities protect religious e)pression in their schools and educate
their children as they see fit. Following are documented incidents of hostility to religious
e)pression in our schools.

Ele+entary Student Told She annot Read Religious )oo$ as Her Fa;orite )oo$ about
hrist+as Traditions 0 6e#e+ber 34415
A second+grade teacher at 3orthwest Elementary School in Massachusetts, as part of a class
pro8ect, as(ed students to bring boo(s to class about their &hristmas traditions. 4aura %res(a, a
second+grader, brought a boo( called The First Christmas, but her teacher stopped her from
reading it because it was religious. A lawsuit was filed against the school district for 'iolating
4aura,s First Amendment rights.
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Tea#her 're;ents -indergarten Student *ro+ 'raying be*ore Sna#$s 0 A&ril 34435
Eindergartner Eayla "roadus prayed, %od is good. %od is great. $han( you, %od, for my
food,! with two classmates at her school in Saratoga Springs, 3ew 7or(, at the snac( table
before they ate their snac(. ?er teacher silenced the prayer, scolded Eayla, and informed the
school,s lawyer. A lawsuit ensued o'er the child,s prayer.
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Students Told They May 'aint 'anels at the S#hool So Long As "one Re*eren#e God or =esus
0 May 34435
/hen students at the "oca Raton School District in Florida were permitted to paint panels
around the high school, members of the Fellowship of &hristian Athletes were told that they
could not paint messages with references to %od or 9esus. $he members and their parents filed a
lawsuit against the school to stop the discrimination.
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Musli+ Student Sus&ended *or /earing Head o;ering 0 !#tober 344?5
3ashala ?earn, an ele'en+year+old Muslim girl in the Mus(ogee -ublic School District, was
suspended twice for wearing a head co'ering, since the school district,s dress code did not
allow hats, caps, bandannas, plastic caps, and hoods on 8ac(ets.! After a lawsuit was filed
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critici.ing the dress code as unconstitutional, the school district changed the code to allow for
religious e)ceptions.
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Student Threatened with Sus&ension *or 'osting Flyers o* the Ten o++and+ents 0
=une 344A5
?igh school 8unior 9ason Farr wanted to see the $en &ommandments posted in his school and
other schools in his district. So he posted flyers of the $en &ommandments, which resulted in a
threat of a fi'e+day suspension. Additionally, Farr was informed that the "ible was not suitable
material for the silent reading period, despite the fact that it fulfilled the school,s page and
genre re*uirements for reading material.
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Middle S#hool Students Sto&&ed *ro+ 'raying at the Flag&ole 0 !#tober 34475
$hree students at a middle school in "arnegat, 3ew 9ersey, met at the flagpole and started to
pray. A school administrator stopped the students, telling them that they could not participate
in See 7ou at the -ole,! that their prayers were creating a disturbance,! and they must stop
mi)ing school and religion. Upon being threatened with a lawsuit, the school re'ersed its
decision and allowed a do+o'er! prayer meeting.
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Uni;ersity 6enies Funding to Student Grou& That is ,Too Religious. 0 344@5
$he Uni'ersity of /isconsin+Madison Roman &atholic Foundation was denied funds from the
student acti'ity fee funding on the grounds that the organi.ation was too religious.! $he
Foundation appealed to the Student 9udiciary. $he Freedom from Religion Foundation
pressured the Student 9udiciary to withhold funding, but the Student 9udiciary re'ersed the
uni'ersity,s decision and granted the funding.
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High S#hool an#els ,6i;ersity 6ay. Instead o* In#luding hristians 0 Mar#h <2 344@5
$he 2iro*ua ?igh School planned a di'ersity day! in order to showcase the 'iewpoints of
'arious religious groups, se)ual orientations, and nationalities, but stated that &hristian groups
and former homose)uals would be e)cluded. After a legal organi.ation inter'ened on behalf of
the e)cluded groups, the school district cancelled the e'ent entirely rather than include them.
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ollege Student 'enaliBed *or hoosing to /rite about Religious 'oe+ 0 =uly 3A2 344<5
"ethany Roden, a student at $arrant &ounty &ollege in $e)as, was assigned to write a response
paper on two poems of her choice for an English composition class. Roden chose poems with
religious themes and incorporated her religious beliefs into her essay. ?er professors penali.ed
her for including religious themes in her essay. Upon recei'ing a demand letter, the college
changed Roden,s grade from a " to an A.
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Student 'enaliBed *or Mentioning =esus in a hrist+as 'oe+ 0 6e#e+ber ?2 344<5
An ele'en+year+old student in ?attiesburg, Mississippi, was penali.ed for mentioning 9esus in a
&hristmas poetry assignment. ?is teacher as(ed him to submit a rewrite of the poem. Upon
being o'erruled by the principal, the teacher then refused to display the students, poems as
promised.
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'rin#i&al and Athleti# 6ire#tor ri+inally harged *or 'raying o;er a Meal 0
=anuary 3<2 344>5
-rincipal Fran( 4ay and Athletic Director Robert Freeman were charged with criminal
contempt because they prayed o'er a meal. $he A&4U had recei'ed an in8unction prohibiting
school employees from promoting religion at school e'ents. 4ay and Freeman were found not
guilty of 'iolating the in8unction.
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!regon S#hool )ans hrist+as Trees2 Santa laus2 and 6reidels 0 6e#e+ber <2 344>5
An elementary school in Ashland, @regon, banned &hristmas trees, Santa &laus figures, and
dreidels following a complaint from a parent. $he school decided that the only acceptable
decorations are wreaths, snowfla(es, snowmen, candles, and candy canes. $he school,s
&hristmas tree, which had no religious decorations, was replaced with a large snowman.
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8irginia S#hool )ans Students *ro+ 'osting the Ten o++and+ents on Their Lo#$ers 0
February 3?2 34115
$he Floyd &ounty ?igh School administration banned students from posting religious material
in the school. $his censorship resulted when students who are members of the Fellowship of
&hristian Athletes placed copies of the $en &ommandments on the fronts of their loc(ers. $he
administration remo'ed these copies of the $en &ommandments from each loc(er that
displayed them.
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High S#hool lass 'resident Threatened with Arrest *or 'raying at Graduation 0
May 3A2 34115
$he class president of ?ampton ?igh School ?ampton, $ennessee wanted to pray at her
graduation. $he principal of the school, howe'er, said that any students who attempt to pray
would be stopped, escorted from the building by police, and arrested. After recei'ing a demand
letter, the school re'ersed its policy.
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Student Sus&ended *or Identi*ying As a hristian and Stating 8iews on Ho+ose%uality 0
Se&te+ber 34115
Da(ota Ary, an honors student in Fort /orth, $e)as, mentioned to a friend during %erman
class that he is a &hristian and that he belie'es homose)uality is wrong. $he comment was a
result of the %erman teacher,s discussion of homose)uality with the class and the teacher,s
displaying of a picture showing two men (issing. $he teacher o'erheard Ary,s comment and
became irate. $he teacher then sent Ary to the principal, who suspended Ary for three days.
After the school was confronted with its discrimination against Ary,s &hristian beliefs, it
rescinded his punishment.
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Residents and Tea#hers 'rohibited *ro+ 'raying at S#hool Flag&ole 0 "o;e+ber 34115
Freedom from Religion Foundation complained to a 9ac(son'ille, Florida, school about
pri'ately+organi.ed, wee(ly prayers around its flagpole before school begins, which had
occurred for the pre'ious twel'e years. 0n response, the county school board re*uested the
prayers stop. /hen the prayers continued, the school district,s attorney said it would use
whate'er legal means necessary to remo'e Ron "a(er, the minister leading the prayers, from
the grounds. $he school district only stopped its action against the prayers after Mr. "a(er
promised to only lead prayers off school grounds.
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Grou& 6e+ands S#hool )and Sto& 'laying ,God )less A+eri#a. 0 August 34135
$he Freedom from Religion Foundation demanded that the /ayland ?igh School band in
/ayland, Massachusetts, stop playing %od "less America! on -earl ?arbor Day and
Memorial Day. $he FFRF,s letter to the school stated that playing %od "less America! on a
repetiti'e basis sends a message to students that the school is endorsing and compelling belief
in a god.! $he school did not ac*uiesce to the group,s demands.
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Atheist Grou& Threatens S#hool *or Tea#hing Two Songs that Mention God in Musi# lass 0
August @2 34135
$he Freedom from Religion Foundation threatened the Shenendehowa &entral Schools of
&lifton -ar(, 3ew 7or(, because the school district,s music class includes two songs that
mention %od in their lyrics. $he school district refused to change its curriculum, noting that the
songs were used appropriately to teach specific musical concepts, and as the basis for secular
classroom acti'ities.! FFRF did not follow through on its threats against the school district.
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!$laho+a S#hool )ullied into Re&la#ing hrist+as Songs with ,Se#ular /inter9The+ed
Songs. 0 6e#e+ber 34135
$he Freedom from Religion Foundation threatened Sulphur Elementary School in Sulphur,
@(lahoma, for including &hristmas songs referencing the historical reason for &hristmas in the
school,s December play. FFRF claimed that references to a baby boy! as the reason for the
season! are di'isi'e! and the &hristmas songs should be replaced with generic secular
winter+themed songs.! $he school submitted to the FFRF,s demand.
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Atheist !&&osition to ,Merry hrist+as2 harlie )rown. an#els S#hool Field Tri& 0
6e#e+ber 34135
Students in 4ittle Roc(, Ar(ansas, were planning to ta(e a field trip to see Merry Christmas,
Charlie Brown, a stage adaptation of the classic A Charlie Brown Christmas. $he school e)plained
to parents that the play would enhance GtheirH child,s creati'e imagination in the area of
dramatic arts.! $he school also pro'ided notice that the play contained religious themes. As a
result of the opposition to the students, being allowed to see the play, the play was canceled
due to safety concerns.
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EE! In;estigates Firing o* Tea#her *or Gi;ing a )ible to a Student 0 =anuary 1A2 341?5
/alt $ut(a, a substitute teacher in 3ew 9ersey, was fired by the -hillipsburg School District for
handing a "ible to a student who as(ed for one. /hen the student was the last to enter through
a door, Mr. $ut(a said, $he first shall be last, and the last shall be first.! $he student repeatedly
in*uired about the origin of the phrase. E'entually, Mr. $ut(a found the *uote in a poc(et 3ew
$estament and showed it to the student. $he student then commented that he did not own a
"ible, so Mr. $ut(a offered the poc(et "ible to the student. $he school district then fired Mr.
$ut(a. /ith help from 4iberty 0nstitute, Mr. $ut(a filed a charge of discrimination against the
school district with the U.S. E*ual Employment @pportunity &ommission 5EE@&6. /ithout
conducting the re*uired re'iew, the EE@& dismissed Mr. $ut(a,s complaint. After 4iberty
0nstitute pressured the EE@& to perform the re*uired in'estigation and disco'ered e'idence
that the school district fired Mr. $ut(a because of his membership in $he %ideons 0nternational,
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the EE@& reopened its in'estigation and re*uested that Mr. $ut(a and the school district enter
mediation.
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S#hool )ans Tea#hers *ro+ Mentioning Religion in 'ersonal )iogra&hies 0 =anuary 332 341?5
$he 9ac(son+Madison &ounty School District in 9ac(son, $ennessee, as(ed its teachers for
biographical information for the district,s website. As would be e)pected in a di'erse selection
of teachers, some of the teachers found religion important to their li'es and incorporated this
into their biographies. $he Freedom from Religion Foundation accused these teachers of
pushGingH religion on a capti'e audience! and demanded that the religious messages be
scrubbed! from the biographies. $he school district responded by re*uiring all teachers to
remo'e any religious elements from their personal biographies.
AB


'ennsyl;ania S#hool 6istri#t 6enies E(ual A##ess to Religious lub 0 February 341?5
/hen the %ood 3ews &lub, a &hristian student club, wanted to start an after+school program at
Foose Elementary School in ?arrisburg, -ennsyl'ania, the school responded that the club
would ha'e to pay a M<,:;; annual fee to use the school,s facilities because the club is religious.
@ther nonprofit organi.ations are granted free use of the school facilities after school. $he %ood
3ews &lub filed a lawsuit against the school district to be treated fairly.
=;


Florida ollege Student Sus&ended *or Re*using to ,Sto+& on =esus. 0 Mar#h 341?5
A professor at Florida Atlantic Uni'ersity re*uired the students in his class to write 9esus! on a
piece of paper and then stomp on the paper. Ryan Rotela, a Mormon student in the class,
refused to stomp on the paper because of his religious beliefs. Rotela then reported the incident
to uni'ersity officials. 0nstead of protecting Mr. Rotela,s religious liberty rights, howe'er, the
uni'ersity officials brought academic charges against Rotela and suspended him. Following a
legal demand from 4iberty 0nstitute, the uni'ersity re'ersed its decision, apologi.ed to Rotela,
e)punged the academic charges, and agreed to allow Mr. Rotela to ta(e the class from a
different professor.
=<


8aledi#torian Silen#ed during S&ee#h *or Sharing His Faith 0 =une 341?5
Remington Reimer, 'aledictorian of 9oshua ?igh School in 9oshua, $e)as, planned to gi'e his
'aledictorian address and, upon graduation, attend the U.S. 3a'al Academy. /hen Reimer
began to spea( about his faith during his 'aledictorian address, howe'er, that was all put at
ris(. $e)as law prohibits schools from editing 'aledictorian addresses, but as soon as Reimer
began to spea( about liberty and his faith, school officials cut his microphone. Furthermore, the
principal of 9oshua ?igh School threatened to send a letter to the U.S. 3a'al Academy to ruin
Reimer,s reputation in retaliation for Reimer,s spea(ing about his faith. Following a demand
letter from 4iberty 0nstitute, school officials apologi.ed to Reimer and pro'ided assurances that
no further discrimination against student religious speech will occur in the future.
=:


ollege Student !rdered to Hide ross "e#$la#e 0 =une 3:2 341?5
Audrey 9ar'is, a student at Sonoma State Uni'ersity, was wor(ing at a student orientation fair
when her super'isor told her to hide her cross nec(lace because it might offend others! and
might ma(e incoming students feel unwelcome.! 9ar'is, a de'out &atholic, was so upset by the
incident that she left the student fair. 4iberty 0nstitute assisted Ms. 9ar'is in see(ing a religious
<:

accommodation from Sonoma State Uni'ersity, and the uni'ersity is now in'estigating the
religious discrimination.
=A


S#hool )ans Religious hrist+as arols2 E;en without the /ords 0 "o;e+ber 1>2 341?
A band director at a South &arolina public charter school recently prohibited students from
performing 9oy to the /orld! and @ &ome All 7e Faithful.! $he carols were banned, e'en
though the words to the songs were not going to be sung. $he school claimed it recei'ed a
communi*ue from the A&4U or another group! after the students began rehearsing, and the
school responded by banning the songs. 7et the students had chosen these songs, and contrary
to the school,s belief, it did not ha'e to play songs from other religions in order to comply with
the &onstitution. Alliance Defending Freedom sent a letter to the school informing the school
that the songs were constitutional.
==
After recei'ing the letter, the school remo'ed its ban on the
music.
=D


-indergartner Told by Tea#her to Sto& 'raying during S#hool Lun#h Ti+e 0 Mar#h 341A
At &arillon Elementary School in @'iedo, Florida, when Marcos -ere.,s daughter bowed her
head to pray, a teacher interrupted her and said, 7ou,re not allowed to do that.! $he fi'e+year+
old loo(ed surprised and responded, "ut it,s good to pray!Nto which the teacher replied, 0t,s
not good.! $he little girl tried to pray again but was stopped. /hen she got home and
e)plained what happened, Marcos and his wife were furious. My fi'e+year old should not feel
conflicted about prayer with respect to trying to follow rules or authority. /e remain speechless
that our daughter had to e)perience GthatH from an indi'idual with an agenda.! $hey contacted
the school, demanding to (now why their fi'e+year+old would be prohibiting from e)ercising
her religious rights. $he principal promised to in'estigate, but when she *ui..ed school
employees, no teacher remembered the incident. Either way, she assured the -ere. parents that
she too( the matter seriously. -lease (now that students are permitted to pray during school. 0
will remind all staff members of this.! A spo(esman at Florida,s Seminole &ounty -ublic
Schools echoed the policy, which allows prayer as long as it isn,t disrupti'e.
=I


Student Told to Sto& )ringing )ible to S#hool *or Reading Ti+e 0 A&ril 341A
0n &ypress, $e)as, parents were furious to hear that a teacher told their second+grader to stop
bringing her "ible to school for the class,s silent reading time. $he teacher apparently informed
the young female student that the "ible is inappropriate reading material! and that she should
not bring it bac( to school again. $he girl,s parents, who were afraid to go public with the story,
turned to 4iberty 0nstitute for help. /hen its attorneys raised the concerns with school officials,
a spo(esman released a statement distancing itself from the teacher,s intolerance and e)plaining
that as long as students can any boo( that they can read, understand, and is deemed
appropriate by the school. As such, religious material, including the "ible, that meets these
guidelines would be permissible for a classroom assignment andOor independent reading.!
=J


/restling Tea+ Harassed *or /earing T9Shirts with )ible 8erses 0 A&ril 341A
$he Freedom from Religion Foundation is targeting a /est 2irginia wrestling team for posting
a "ible 'erse on the school,s athletic page, and for wearing t+shirts 5paid for by the students6
with a "ible 'erse printed on them. $he 'erse, 0 can do all things through ?im that strengthens
me,! has been the team,s motto for months. 3ow, fearing an e)pensi'e and time+consuming
lawsuit, the local superintendent is ordering the high school to delete -hilippians =#<A from the
<A

website. /hile the wrestlers complied with this re*uest, they draw the line at the shirts they
had made for the team. 0t,s not part of the official uniform,! said an attorney representing one
of the (ids. 0f a student athlete doesn,t want to wear that shirt, they don,t ha'e to. 0t,s not a
re*uirement.! And these students are willing to go to court to pro'e it. 0t,s frustrating for the
parents,! said lawyer "ill Merriman, because they see a lot of other t+shirts being worn by
students that are certainly not religiousNbut they are offensi'e. 3obody is saying they can,t
wear those shirts.!
=>


Tea#her on*is#ates StudentCs )ible during Reading Ti+e 0 A&ril <2 341A
0n "roward &ounty, Florida, teacher Swornia $homas ordered one of her fifth gradersN
%io'anni RubeoNto hand o'er his "ible that he was reading during the class,s free reading
time. %io'anni as(ed Swornia to call his parents, which she did. 0n a 'oicemail left for
%io'anni,s father Rubeo, she said, 0 noticed that he G%io'anniH has a boo(Na religious boo(N
in the classroom. ?e,s not permitted to read those boo(s in my classroom.! Rubeo subse*uently
contacted the school,s principal, @rinthia Dias, who brought in the school,s legal department.
"ut none of them were willing to ac(nowledge that %io'anni has a constitutional right to read
the "ible. Facing a hostile school administration, Rubeo retained 4iberty 0nstitute as his counsel.

As 4iberty 0nstitute pointed out to the school, students are well within their rights to read
Scripture. "anning religious boo(s li(e the "ible 'iolates %io'anni,s ci'il rights to religious
free speech and free e)ercise,! said ?iram Sasser, 4iberty 0nstitute Director of 4itigation. $he
school,s actions e)emplify the hostility to religion that the U.S. Supreme &ourt has
condemned.! Faced with a lawsuit from the child,s parents, "roward &ounty reconsidered. 0n a
'ictory for religious liberty and common sense, school district officials say they will allow the
"ible as part of the Accelerated Reader -rogram.!
=B





<=

Se#tion III: ensure o* Religious 8iew&oints
Regarding Se%uality

0n one of the more alarming and fastest growing trends demonstrating an increase in hostility to
religious e)pression, pri'ate citi.ens increasingly are finding themsel'es sub8ect to censure and
hostility when they simply ma(e a statement or ta(e a public stance on se)uality for no other
reason than it is in accord with their religious con'ictions.

&onsistent with a 'ariety of religious faiths as they concern marriage and se)uality, many
Americans simply cannot appro'e of a willful embrace of se)ual practices contrary to their
religious teachings and conscienceNwhether homose)uality or another se)ual practice. $hey do
not want to be forced to do so by law, and ha'e a right to not be forced to do so. $his is a matter
of serious con'iction, conscience, and deeply held religious beliefs, and affects the ability to
spea( freely and the freedom to li'e and act according to one,s beliefs. 7et many are ridiculed
and shamed in the court of public opinion for simply ha'ing a 'iewpoint based on religion.
0ndeed, indi'iduals ha'e not e'en had to ma(e a statement to be sub8ect to such hatred1 a
simple donation to a political group years pre'ious is enough to draw hostility for this
unacceptable! 'iewpoint.

/hile much of this censure occurs outside the realm of go'ernment action 5and the protection
of the First Amendment6, it is not wholly unrelated. For law follows culture and if ci'il
discourse and public debate de'ol'e to the point where opposing 5and religious6 'iews are no
longer heard or e'en tolerated, court decisions and laws will not be long behind. Due to rapidly
growing hostility to religious 'iewpoints regarding marriage and se)uality, many of these
incidents ha'e occurred *uite recently. $he following are documented incidents of hostility
toward religious 'iewpoints and speech on the topic of se)uality.

!hio Library 'rohibits hristian Grou& *ro+ Meeting to 6is#uss Traditional Marriage
Unless Ad;o#ates o* Ho+ose%ual Marriage Also 'resent 0 May 34475
A &hristian group re*uested access to a community room in the 3ewton Falls 4ibrary in
7oungstown, @hio, for a meeting about the biblical perspecti'e of traditional marriage. $he
library director denied the re*uest because the library,s policy re*uired that any time a
contro'ersial sub8ect! was discussed, the opposing 'iewpoint must also be presented. $he
policy was re'ised only after a lawsuit was filed.
D;


E+&loyee Fired a*ter olu+n on Ho+ose%uality 0 February 344@
0n :;;D, Matt "arber was fired by Allstate 0nsurance &ompany for allegedly using a company
laptop to write a column against homose)uality 5which 'iolated Allstate,s di'ersity!
standards6. "arber sued Allstate and ultimately settled the case. "arber is now a popular
conser'ati'e writer and is associate dean of the 4iberty Uni'ersity School of 4aw, as well as 'ice
president of 4iberty &ounsel Action.
D<




<D

E+&loyee Fired *or Religious and 'oliti#al Message /ritten on His ar 0 !#tober 344@5
4uis -adilla, a &argill Foods employee, was fired o'er the display of a sign on his pri'ate
'ehicle. $he sign said, -lease 'ote for marriage on 3o'. J.! $he statement reflected the
employee,s religious con'iction that marriage should remain a union of one man and one
woman. $he company re*uested that Mr. -adilla remo'e the sign, and he did. Mr. -adilla
restored the message before returning to wor( the ne)t day. 0n an attempt to a'oid further
conflict with his employers, he e'en par(ed on what he belie'ed to be a public street, but it was
in fact also company property. &argill subse*uently fired Mr. -adilla, and a statement from the
company,s attorney said he was dismissed because of insubordination, for ignoring orders to
remo'e a sign that could be reasonably construed as a show of hostility and intolerance
toward homose)uals.! After others spo(e out on his behalf, and after he met with &argill
management, the company restored his employment with full bac( pay and benefits, and said
the incident would be erased from Mr. -adilla,s employment record.
D:


San 6iego Fire9Fighters For#ed to 'arti#i&ate in Gay 'ride 'arade 0 =uly 344:5
San Diego, &alifornia, hosted a %ay -ride -arade! and demanded that its firefighters
participate in their official capacities or face retaliation. Four of those firefighters were
&hristians who ob8ected to attending the parade because of their religious beliefs. $he city
threatened the firefighters with disciplinary action if they refused to participate. During the
parade, the firefighters were sub8ect to 'erbal abuse and se)ual gestures. $he firefighters sued
the city and were awarded appro)imately MA;,;;;.
DA


ounselor Fired *or Re*using to Assist in ounseling Gay Relationshi&s 0 August 312 344:5
A &hristian counselor for the &omputer Sciences &orporation, Marcia /alden, was fired
because she refused to lie about why she was referring clients with same+se) relationship
problems to other counselors. /alden told a homose)ual client from the &enter for Disease
&ontrol 5&D&6 that her personal 'alues would interfere with the clientOtherapist relationship,
ne'er mentioning her religious ob8ections. 0n response, the client complained to the &D& that
/alden was homophobic. /alden reiterated to her super'isors that she had no problem
counseling homose)ual indi'iduals, but her religious beliefs pre'ented her from conducting
relationship counseling for those in homose)ual relationships. ?er super'isors suggested that
she lie to homose)ual clients and tell them she did not ha'e much e)perience with relationship
counseling. /alden refused to lie about why she was referring clients and was ultimately fired
for not altering her approach.! $he Ele'enth &ircuit re8ected claims that /alden,s free e)ercise
rights were 'iolated under the First Amendment, affirming the district court,s summary
8udgment ruling against her.
D=


E+&loyee Fired *or olu+n on Ho+ose%ual Rights 0 May 132 344<
&rystal Di)on, a Uni'ersity of $oledo human resources employee, was fired in :;;> after
writing a column critical of homose)ual rights.! A blac( &hristian, she argued that those
choosing to embrace a homose)ual lifestyle are not ci'il rights 'ictims.! Ms. Di)on,s editorial
letter in the Toledo Free Press ob8ected to the idea that those choosing the homose)ual lifestyle
are Pci'il rights 'ictims,! because they 'iolate %od,s di'ine order.! She identified herself in the
letter as Associate 2ice -resident for ?uman Resources at the Uni'ersity of $oledo. $he
uni'ersity proceeded to terminate her employment on the grounds that her free e)pression
'iolated her responsibility to uphold the uni'ersity,s nondiscrimination statement, which
<I

includes se)ual orientation. She sued, and in December :;<: the Si)th &ircuit &ourt of Appeals
ruled that the uni'ersity had legitimate grounds to fire her. She appealed further, but
unfortunately, the U.S. Supreme &ourt has declined to ta(e the case.
DD


Graduate Student E%&elled *ro+ 'rogra+ )ased on "ondis#ri+ination 'oli#y a*ter She
Re*used to o+&ro+ise Her Religious )elie*s 0 =anuary 344>
9ulea /ard was enrolled as a student in a graduate counseling program at Eastern Michigan
Uni'ersity 5EMU6. As part of a practicum course, /ard was assigned a potential client see(ing
assistance for a same+se) relationship. /ard (new that she could not affirm the client,s
relationship without 'iolating her religious beliefs about e)tramarital se)ual relationships, so
she as(ed her super'isor how to handle the matter. &onsistent with ethical and professional
standards regarding counselor referrals, /ard,s super'isor ad'ised her to refer the potential
client to a different counselor. /ard followed that ad'ice. $he client was not in the least
negati'ely impacted and indeed ne'er (new of the referral.

Shortly thereafter, EMU informed /ard that her referral of the potential client 'iolated the
American -sychological Association,s 5A-A6 nondiscrimination policy, which mirrors many
nondiscrimination laws enacted across the country. EMU also told /ard that the only way she
could stay in the counseling program would be if she agreed to undergo a remediation!
program, the purpose of which was to help her see the error of her ways! and change her
belief system! as it related to pro'iding counseling for same+se) relationships. /ard was
unwilling to 'iolate or change her religious beliefs as a condition of getting her degree, and
therefore she refused remediation.!

At a subse*uent disciplinary hearing, EMU faculty denigrated /ard,s &hristian 'iews and
as(ed se'eral uncomfortably intrusi'e *uestions about her religious beliefs. Among other
things, one EMU faculty member as(ed /ard whether she 'iewed her brand! of &hristianity
as superior to that of other &hristians, and another engaged /ard in a theological bout!
designed to show her the error of her religious thin(ing. Following this hearing, in March :;;B,
EMU formally e)pelled /ard from the program, basing its decision on the A-A,s
nondiscrimination policy. At that time, /ard had been enrolled in the counseling program for
three years and was only <A *uarter hours away from graduation.

/ard filed suit against EMU officials. After the trial court dismissed her claims, /ard won a
unanimous 'ictory from the Si)th &ircuit &ourt of Appeals. /hen ruling in /ard,s fa'or, that
court noted that GtHolerance is a two+way street,! for if it were otherwise, nondiscrimination
measures would mandateGH orthodo)y, not anti+discrimination.! After being sent bac( down to
the district court, the case settled. $he abuse of religious liberty in the name of tolerance! that
the Si)th &ircuit diagnosed is the same abuse that other American citi.ens regularly suffer, all
o'er this country. 0t is 'isited upon them by the 'ery nondiscrimination laws that, ironically
enough, purport to protect the religious from discrimination.
DI


'ageant ontestant Ridi#uled *or 8iews on Marriage 0 May 132 344>
&arrie -re8ean, Miss &alifornia USA, was ambushed by pageant 8udge -ere. ?ilton during the
final round of the contest. ?ilton as(ed -re8ean for her opinion of same+se) marriage. ?er
respectful and historically normal! response, in which she stated, 0 belie'e that marriage
<J

should be between a man and a woman, no offense to anybody out there, but that,s how 0 was
raised and 0 belie'e that it should be between a man and a woman,! was considered so
outrageous that the e'angelical &hristian contestant was widely moc(ed and ridiculed.
DJ


MinisterCs In;itation to "ational 'rayer Lun#heon Re;o$ed be#ause o* His o++ents on
Ho+ose%uality in the Military 0 February 34145
An ordained minister and Marine &orps 'eteran was punished for spea(ing out on a topic
unrelated to his planned comments at the 3ational -rayer 4uncheon at Andrews Air Force "ase
outside of /ashington, D.&. $he minister critici.ed -resident @bama,s call to end the military,s
don,t as(, don,t tell! policy, resulting in his in'itation to spea( at the 3ational -rayer
4uncheon being rescinded. $he minister critici.ed the action as blac(+listing! to suppress
unwanted 'iewpoints.
D>


'ro*essor Fired *or Tea#hing atholi# 8iew o* Ho+ose%uality in ,Introdu#tion to
atholi#is+. lass 0 May 3<2 34145
Dr. Eenneth 9. ?owell, an ad8unct profess at the Uni'ersity of 0llinois, was fired from his
position after a lecture on the &atholic 'iew of homose)uality set off a firestorm of
insensiti'ity! complaints on campus. Although Dr. ?owell had gi'en the same lecture for
nearly ten years to his 0ntroduction to &atholicism class this was the first time it had spar(ed
such debate. After Dr. ?owell,s attorneys sent a letter to the Uni'ersity threatening legal action
if Dr. ?owell,s First Amendment rights were not respected, the uni'ersity agreed to reinstate
him as a member of the faculty.
DB


ounseling Student For#ed to A&&ro;e o* Ho+ose%uality to o+&lete 6egree 0 =uly 332 3414
9ennifer Eeeton, a former counseling student at Augusta State Uni'ersity 5ASU6, was ordered
by her school to complete remedial training after e)pressing her 'iews concerning
homose)uality. Faculty members told 9ennifer she couldn,t complete the degree program if she
did not complete a remediation plan, which included attending di'ersity wor(shops, reading
articles about counseling lesbian, gay, bise)ual and transgender students, and submitting
monthly writing assignments.
I;
9ennifer filed a lawsuit in federal court alleging constitutional
'iolations, but her claims were dismissed.
I<


Student and Mother )ullied by 'ro*essor *or Her 8iews on Se%uality 0 !#tober 3414
Ms. %illian 9ohn+&harles was a single mom, mathematics teacher, and African American who
had been enrolled in Roose'elt Uni'ersity,s Ed.D. program since :;;B. 0n @ctober :;<;, in a
class discussion led by a liberal professor, 9ohn+&harles said she does not belie'e homose)uals
are born gay.! As the professor,s mistreatment against her escalated, she describes in a legal
complaint how he bullied her by falsely accusing her of ha'ing a negati'e and disparaging!
'iew of gay peopleNthough she stated clearly in class that, as a teacher, she treats all her
students with the same respect without regard to se)ual orientation.! /ithin a year of the
initial classroom incident, 9ohn+&harles was e)pelled from the doctoral program, citing
unsatisfactory academic performance 5despite her A.D< %-A6. 9ohn+&harles may be
contemplating legal action.
I:




<>

o+&any SubDe#ted to Hostility *or Religious 8alues 0 =une 3411
/hen Access -rinted Media recei'ed a re*uest to print ad'ertisements for the opening of a new
gay bar in the Seattle area, it ob8ected to the 8ob out of moral con'ictions. Mi(e Reis and his
partner, Mar( ?urst, placed a :,D;;+flier order with Eent+based company Access -rinted Media,
which ad'ertises business and promotional printing you can rely on.! $he flyers ad'ertised
the grand opening of Diesel, a new gay bar. An employee responded to the print re*uest with
the following email# 3ot that we,re against homose)uals at all, but because (nowing that our
printed products will be ad'ertising and promoting the $ind o* li*estyle that goes against our
+orals Gemphasis originalH is something that Gthe ownerH can,t bring himself to do...!

$he employee reiterated that the decision was nothing against homose)uals themsel'es. /e,re
8ust not morally able to promote that (ind of a lifestyle.! /hile the company has no written
document that outlines the business,s moral+related printing policy, it also refused to print an
ad'ertisement for a tarot reader. /e,re a small business owned by a small conser'ati'e
&hristian family. 0,m sorry but we ha'e 'alues and we can print whate'er we want.! $he A&4U
of /ashington 8umped in and indicated it would be glad to hear from the bar owner and
pro'ide assistance if he wishes to pursue the matter.! 3e'ertheless, the bar was able to fulfill
their flyer order elsewhere.
IA


E! 6raws Fire *or 8iews on Marriage 0 =uly 3413
$he fact that &hic(+fil+A &E@ Dan &athy opposed same+se) marriage and donated to
traditional 'alues groups prompted gay! acti'ists to call for protests and a national boycott,
with &hicago Mayor Rahm Emanuel and "oston Mayor $homas M. Menino attempting to ban
&hic(+fil+A from the city and se'eral uni'ersities barring &hic(+fil+A from their campuses.
Although the boycott effort bac(fired in the short term, when &hic(+fil+A Appreciation Day!
and grassroots goodwill resulted in a dramatic increase in the chain,s income, o'er the longer
term, the intimidation had its desired effect# Dan &athy now says he made a mista(e! and has
become wiser.!
I=


Atte+&ted Murder o* Fa+ily Resear#h oun#il E+&loyees be#ause o* !rganiBationCs Stan#e
on Ho+ose%uality 0 August 172 34135
A man planned to engage in mass+murder of the employees of four religious organi.ations and
then smear &hic(+fil+A sandwiches on the employees, faces because of their opposition to
homose)ual marriage. After shooting a security guard at the Family Research &ouncil,
howe'er, the man was subdued by Family Research &ouncil 5FR&6 employee 4eo 9ohnson, who
pre'ented loss of life through his actions.
ID


hie* 6i;ersity !**i#er Sus&ended *or Signing 'etition on Marriage 0 !#tober 3413
0n @ctober :;<:, %allaudet Uni'ersity suspended its chief di'ersity officer Angela Mc&as(ill for
signing a petition calling for Maryland,s same+se) marriage law being put to a referendum 'ote
instead of being implemented by lawma(ers. /hen the names on the petition became public, a
%allaudet faculty member confronted Mc&as(ill and then alerted uni'ersity leaders in a formal
letter. Mc&as(ill and another faculty member who reportedly signed the letter were referred to
during a press conference as e)tremist faculty! and a few rotten apples.! Despite the fact that
she ne'er publicly stated her position on gay marriage, and has said that she supports all
students, regardless of their race or se)ual orientation, Mc&as(ill was still put on paid
<B

administrati'e lea'e after refusing to issue an apology for signing the petition. 7et opponents
and proponents of same+se) marriage ha'e both critici.ed the Uni'ersity for disciplining
Mc&as(ill for signing the petition. Since then, the 0nternet has erupted with support for
Mc&as(ill and calls for her to be reinstated by %allaudet, which is a uni'ersity for the deaf and
hard of hearing.

Subse*uently, the president of %allaudet Uni'ersity has said that Mc&as(ill is welcome to
return to the uni'ersity. 7et an attorney representing Mc&as(ill said that would li(ely only
happen if the uni'ersity compensates her for the emotional distress she endured, along with the
damage to her reputation. $here are also calls for uni'ersity trustees to e)amine the situation. 0
am dismayed that %allaudet Uni'ersity is still a uni'ersity of intolerance, a uni'ersity that
manages by intimidation, a uni'ersity that allows bullying among faculty, staff and students,!
Mc&as(ill is reported as saying at a press conference regarding her situation, with the assistance
of an interpreter. Unfortunately, the lawsuit Mc&as(ill had filed in federal court was dismissed
in April :;<= in part due to interpretations of what political acti'ity! is protected by D& law.
II


onsultantCs ontra#t Ter+inated be#ause o* 8iews on Marriage 0 August 341?5
Fran( $ure( had ser'ed as leadership consultant to the &isco &orporation for a number of
years, and ran training seminars for the company. A student in one of $ure(,s classes, on which
he had always recei'ed e)cellent feedbac(, went on the 0nternet and read about his 'iews
pertaining to natural marriage. $he student then complained to an ?R professional. $ure(,s
contract was summarily terminated for failure to abide by inclusion and antidiscrimination
policies.! 3otably 5and ob'iously6, he was not included! precisely because of his beliefs. $his
all occurred despite the fact that $ure( had ne'er e)pressed this 'iew at wor(, but only through
a boo( he authored. And $ure( was fired without ha'ing been addressed about the issue or
gi'en opportunity to spea(, and despite high regard from other employees and managers.
IJ


)road#aster Fired when 'ast State+ent on Marriage /as Unearthed 0 Se&te+ber 341?
Football star &raig 9ames 5now an FR& employee6 was fired by Fo) Sports Southwest after a
%@- debate tape showing him e)pressing &hristian beliefs in opposition to homose)ual
marriage! came to light. -re'iously, during a :;<: Republican primary debate for a U.S.
Senate seat in $e)as, then+candidate 9ames was as(ed about his 'iews on marriage, to which he
responded that he belie'ed marriage e)clusi'ely to be one man with one woman. $he e)istence
of that debate 'ideo apparently was enough to get 9ames fired within days of being hired by
Fo) Sports Southwest as a college football analyst. A Fo) spo(esman told the Dallas Morning
News, /e 8ust as(ed oursel'es how &raig,s statements would play in our human resources
department. . . . ?e couldn,t say those things here.! 9ames says he was fired o'er his religious
beliefs, and filed a complaint with the $e)as /or(force &ommission.

$he $e)as /or(force &ommission subse*uently launched an in'estigation into whether 9ames
suffered from religious discrimination when he was fired. $he state agency, which has authority
o'er such employment matters in $e)as, issued a charge! document against Fo) Sports
Southwest and began an in'estigation. Fo) Sports -resident Eric Shan(s has admitted in a
deposition that a senior 'ice president at the networ( anonymously told the media that 9ames
was fired for his religious 'iews. Shan(s denied that this was actually the reason. 7et internal e+
mails show that 9ames, remar(s about traditional marriage were a topic of con'ersation
:;

immediately before he was fired. $he $e)as /or(force &ommission issuing a charge of
discrimination against Fo) Sports Southwest and conducting an in'estigation is a serious step
toward holding Fo) Sports accountable for 'iolating the law and religious liberty on &raig
9ames,! said ?iram Sasser, the 4iberty 0nstitute,s Managing Director for Strategic 4itigation. At
time of publication, the parties were engaged in mediation as re*uested by the $e)as /or(force
&ommission and the matter remained ongoing.
I>


Air For#e Ethi#s Ad;isor SubDe#ted to S+ear a+&aign *or 8iews on Se%uality 0
"o;e+ber 341?
Mi(e Rosebush is a former Focus on the Family employee who subse*uently was employed as a
research analyst for the Air Force Academy,s &enter of &haracter and 4eadership De'elopment.
/hile employed for the Academy, Mr. Rosebush was a positi'e influence among the students,
wor(ing in the ethics program that guides young cadets. 3e'ertheless, he became the ob8ect of a
'icious attac( and sub8ect of a nationwide smear campaign to remo'e him from the Academy,
all for his pri'ate 'iews on faith, marriage, and homose)uality. &iting a paper he wrote in :;;B,
Sanctification &oaching# Se)ual -urity and -eace for &hristian Men with Same+Se)
Attractions,! those opposed to his 'iews ha'e irrationally fanned the flames of hatred against
him. And while an academy spo(esperson noted that Mr. Rosebush does not and will not
counsel cadets,! homose)ual acti'ists ha'e held up his religious 'iews as an e)ample of
intolerance! that should no longer be condoned by the Academy.
IB


'o&ular Media Figure SubDe#ted to Hatred *or 8iews on Se%uality 0 6e#e+ber 341?
0n an inter'iew with GQ Magazine, Duc( Dynasty star and Robertson family patriarch -hil
Robertson e)pressed the 'iew that he belie'ed the "ible and that it stated that homose)uality
was sinful. -hil stated his support for natural marriage and used the boo( of &orinthians to
e)plain it# Don,t be decei'ed,! he said. 3either the adulterers, the idolaters, the male
prostitutes, the homose)ual offenders, the greedy, the drun(ards, the slanderers, the
swindlersNthey won,t inherit the (ingdom of %od. Don,t decei'e yourself. 0t,s not right.!

$he gay rights lobby reacted harshly, demanding the immediate censorship of or end to the
Robertson,s show, and AFE reacted by dropping -hil from the show. ?is personal 'iews in no
way reflect those of AFE 3etwor(s, who ha'e always been strong supporters and champions of
the 4%"$ community. $he networ( has placed -hil under hiatus from filming indefinitely.! 7et
the outpouring of support for -hil was widespread, and AFE re'ersed course and reunited
with the Robertsons shortly thereafter. Despite all the criticism, -hil has been unbending. My
mission today is to go forth and tell people about why 0 follow &hrist and also what the "ible
teaches, and part of that teaching is that women and men are meant to be together.!
J;


A##o+&lished Te#h Entre&reneur Hounded out o* His =ob 6ue to 8iews on Se%uality 0
A&ril 341A
0t was recently unco'ered! that Mo.illa co+founder "rendan Eich had donated money to the
:;;> -rop > campaign run in &alifornia in support of natural marriage. @ne would thin( Mr.
Eich had 8ust been con'icted of a felony when he was then sub8ected to protests on $witter as
employees demanded he step down for committing this crime,! the crime! of thin(ing
differently. $hose opposed to Mr. Eich,s 'iews demanded that he be remo'ed from his position.
$here was no e'idence that Mr. Eich had e'er acted in a discriminatory manner at Mo.illa, and
:<

he e'en stated his support for company policies. 3e'ertheless, three Mo.illa board members
*uit in protest. E'en dating site @E&upid opposed! Mr. Eich. Ultimately, Mr. Eich chose! to
resign.

?owe'er, e'en people who disagree with Mr. Eich,s position on this issue recogni.ed the
importance of protecting freedom of speech and e)pression for all, regardless of 'iewpoint.
Andrew Sulli'an, a gay writer and same+se) marriage supporter, wrote# $he whole episode
disgusts me L as it should disgust anyone interested in a tolerant and di'erse society.!
J<


'ubli# Health 6ire#tor 'la#ed on Lea;e *or 8iews on Se%uality 0 May 12 341A
Dr. Eric /alsh, the -ublic ?ealth Director for -asadena, &alifornia, was placed on
administrati'e lea'e for e)pressing 'iews consistent with his &hristian faith in the pri'ate
conte)t of se'eral sermons. Despite the fact that these 'iews were e)pressed pri'ately 5/alsh
has actually e)pressed support for di'ersity! in the conte)t of his employment6, the mayor
directed an in*uiry! into /alsh,s statements. Moreo'er, A0DS ?ealthcare Foundation
-resident Michael /einstein denounced /alsh,s comments $hursday, saying he did not thin(
/alsh could realistically separate his religious 'iews from his actions as a public official.!
J:


Real Estate Media 'ersonalities Had T8 Show ut o** *or 8iews on Se%uality 0 May <2 341A
As sons of a preacher, Da'id and 9ason "enham ha'e ne'er shied away from their beliefs,
which led them to bac( the 3orth &arolina marriage amendmentNa stance the brothers seem
now to be paying for, than(s to radical acti'ists in organi.ations li(e %4AAD.

0f faith costs us a $2 show, so be it,! they told reporters. Anyone who suggests that we hate
homose)uals or people of other faiths is either misinformed or lying. @'er the last decade,
we,'e sold thousands of homes with the guiding principle of producing 'alue and breathing
life into each family that has crossed our pathNand we do not, nor will we e'er discriminate
against people who do not share our 'iews.!

3e'ertheless, the outpouring of fury against the brothers for merely e)pressing a tenet of their
faith was loud and widespread. 0n addition, Sun$rust "an(, which partnered with the brothers,
announced it would drop them as financial partners due to their position on marriage. "ut soon
after, "eth McEenna, a Sun$rust spo(esperson, said only that the ban( clarified! its policies
with a 'endor! and reinstated the brothers, property partnership. Sun$rust supports the
rights of all Americans to fully e)ercise their freedoms granted under the &onstitution,
including those with respect to free speech and freedom of religion.!
JA


Two Men Threatened by Go;ern+ent Union *or Su&&orting 6u#$ 6ynasty 0 =une 341A
$he American %o'ernment Employees Union told two senior+management+le'el federal
employees at Eglin Air Force base that they were being fired for putting Duc( Dynasty stic(ers
on their truc(s. $he union said that the men had great influence o'er a di'erse wor(force
because of their high positions and should not be allowed to remain in them because they might
be unfair in their dealings with or promotions of those they super'ised, particularly
homose)uals and African+Americans. $he union official said that it,s definitely <;; percent
inappropriate for an organi.ation that espouses a .ero tolerance policy.! $he whole debate
stemmed from the contro'ersial comments made by -hil Robertson to GQ maga.ine in :;<A.
::

$he men were condemned in an email that went out to se'eral hundred employees. 0 see the
email that went out accusing me and my boss of being racist,! one of the accused men said.
$hat couldn,t be farther from the truth. 0,m pro+family. 0,m pro+life. 0 don,t ha'e a problem
with anybody who doesn,t agree with me.! $han(fully, the Air Force correctly determined that
the two men had the right to display the stic(ers on their truc(s.
J=



:A

Se#tion I8: Su&&ression o* Religious 8iew&oints
on Se%uality Using "ondis#ri+ination Laws

0n another alarming trend, people of faith are increasingly find themsel'es sub8ect to legal
action 5along with censure and hostility6 when their religious con'ictions pre'ent them from
offering ser'ices that would legitimi.e or promote actions they belie'e to be against their
religion. $hough the e)ercise of faith can be minimi.ed and curtailed by any number of alleged
go'ernmental 8ustifications or rationales, many of the threats to free e)ercise, free speech, and
free e)pression today come in the form of laws or policies prohibiting discrimination on the
basis of se)ual orientation. $hus, the fourth and final broad category of this publication
documenting hostility to religion lies at the intersection of religious e)pression and
nondiscrimination laws.

4aws prohibiting discrimination on the basis of se)ual orientation andOor gender identity are
increasing in pre'alence around the country, and generally compel e*ual treatment 5and thus
appro'al6 of a 'ariety of se)ual practices. %i'en &hristian orthodo)y as it concerns marriage
and se)uality, &hristians 5and those of other faiths6 do not want to be compelled to act in ways
by which they must appro'e of se)ual lifestyles their religion teaches to be wrong. 7et these
laws ha'e this e)act effect, and force those ob8ecting on the basis of religious belief to 'iolate
their consciences or face legal action. "ecause of the recent enactment of numerous such laws,
many of the incidents documented below ha'e occurred 'ery recently.
JD


Such nondiscrimination! is a matter of serious concern, as it forces those of faith to 'iolate
their consciences, their con'ictions, and their deeply held religious beliefs. 0t conse*uently
affects their ability freely to e)ercise their religion. /hen &hristian wedding photographers
who belie'e same+se) marriage is wrong are forced to pro'ide their ser'ices at a same+se)
wedding, under threat of fines imposed by nondiscrimination laws, religious e)ercise is clearly
and seriously imperiled. lane Photogra!hy "# $illo%& is one of the more well (nown of such
cases, but as we document here, many similar situations ha'e arisen as a result of
nondiscrimination laws and ordinances. $hese cases ha'e resulted in ad'erse outcomes for
people of faith whose consciences pre'ent them from participating in, or promoting, what they
regard as wrong according to their religious teachings. As documented below, due to
nondiscrimination laws, many of these men and women ha'e been compelled by the
go'ernment to 'iolate their consciences and act against their religious beliefs.

hristian 'hotogra&her For#ed to 'hotogra&h a Sa+e9Se% /edding 0 Se&te+ber 344@55
Elaine and 9onathan ?uguenin ha'e operated 3ew Me)ico+based Elane -hotography, which
speciali.ed in wedding photographs. Elaine ?uguenin, an artist with a degree in photography,
has been the lead photographer for the company and employed a photo8ournalistic style in her
wor(, using her pictures to tell stories for her clients.

0n going about their wor(, both Elaine and 9onathan were e'er+mindful about the messages
communicated through the photographs ?uguenin created. &ompany policy ensured that they
:=

would ne'er tell a story or con'ey a message contrary to their belief system. As belie'ing
&hristians, the ?uguenins belie'ed the "ible,s teaching that marriage is the union of one man
and one woman.

0n September :;;I, 2anessa /illoc( as(ed Elaine ?uguenin to create pictures of her same+se)
commitment ceremony. ?uguenin belie'ed that the pictures she would create at the e'ent
would tell a story of marriage at odds with her religious con'ictions and what she belie'ed to
be %od,s plan for marriage. As a result, she politely declined. 0nterestingly, ?uguenin would
ha'e gladly pro'ided other types of photography ser'ices to a customer who identified as
homose)ual. For instance, she would ha'e happily ta(en a portrait of such a customer, or
filmed a graduation ceremony. "ut what /illoc( and her partner wanted ?uguenin to do was
to participate in, and promote, their homose)ual marriage. ?uguenin was being as(ed to 'ideo+
record the entire ceremony and edit and splice it together to tell the Plo'e story, of their
wedding. She would ha'e to pose the couple intimately, ga.ing romantically and lo'ingly into
one another,s eyes, while holding hands and (issing.

?uguenin would ha'e to create the memory of their wedding, portraying it as a 8oyous e'ent,
when Elaine belie'ed it was sinful and saddened %od. She was not being as(ed to merely ta(e a
photograph of a person who identifies as homose)ual, something she gladly would ha'e done.
She was being as(ed to participate in, and use her talents to create speech that actually
promoted an acti'ity she belie'ed was sinful. $his was far different than, say, ser'ing someone
at a lunch counter. And so she declined to participate. After ?uguenin said no,! /illoc(
readily found another photographer eager to help her celebrate her day, and that photographer
charged less money than ?uguenin had to tell the story of the ceremony.

$his was not enough for /illoc(. Unwilling to let the ?uguenins conduct their li'es consistent
with their religious beliefs, /illoc( sued the company under the 3ew Me)ico ?uman Rights
Act, alleging unlawful discrimination on the basis of se)ual orientation. $he 3ew Me)ico
?uman Rights &ommission used the Act to punish the ?uguenins for declining to photograph
/illoc(,s ceremony, and ordered them to pay nearly MJ,;;; in attorneys, fees to /illoc(,s
attorney.

$he 3ew Me)ico Supreme &ourt upheld the decision, ruling that the ?uguenins, rights to free
e)ercise of religion, guaranteed by the &onstitution, must yield to the state,s antidiscrimination
law. @ne of the 8udges wrote that, while he understood that all the ?uguenins wanted was to be
let alone to li'e their li'es according to their faith, they must surrender their right to freely
e)ercise their religion as the price of citi.enship.! @n April J, :;<=, the U.S. Supreme &ourt
declined to hear the case, and the ruling of the 3ew Me)ico Supreme &ourt against Elane
-hotography stands.

$he ?uguenins spent almost a *uarter of their young li'esNall while trying to ma(e a li'ing
and raise a familyNtrying to 'indicate First Amendment rights that were gi'en pride of place
in our nation,s founding and still+go'erning documents. $he courts ruled against them,
determining that their rights to act according to their faith and be faithful to their
understanding of what %od wants them to do are not as important as the state
antidiscrimination law.
JI

:D

) E ) !wner Sued *or Re*using to Rent Roo+ to Sa+e9Se% ou&le in Her !wn Ho+e 0 344:
-hyllis 7oung, a practicing &hristian, resides with her husband in their family home in
?onolulu, ?0. 0t has <,B:I s*uare feet and <; Q roomsN= bedrooms, : Q bathrooms, a family
room, dining room, li'ing room, and (itchen. $he 7oungs ha'e owned this house for AD years,
ha'ing raised their children and been 'isited by their grandchildren here.

$he 7oungs also rented out one or more rooms of this family home, where they also resided.
"ecause of her sincerely held religious beliefs, she has not allowed unmarried opposite+se)
couples or same+se) couples to rent a room with a single bed together. 7oung belie'es that
se)ual intercourse is only proper in opposite+se) marriage and so it is immoral for opposite+se),
unmarried couples or same+se) couples to engage in se)ual beha'ior. She would not e'en allow
her adult daughter to share a room with her li'e+in boyfriend when they 'isited. 7oung has
based her beliefs about se)ual morality upon the teachings of the "ible and the &atholic &hurch.

7oung has called her rental business Aloha "ed F "rea(fast, but Aloha has no chec(ing
account. All payments for rooms in Aloha are made payable to -hyllis. Unli(e hotels, Aloha has
no employees, no cler(, or office into which members of the public enter. 0n fact, people may
not enter 7oung,s home without her permission. She generally has (ept her door loc(ed, li(e
other homeowners. 3o one has e'er (noc(ed on her door and as(ed to stay in Aloha and
Aloha! is not e'en listed in the phone boo(. $he residence,s listing is under the name of Don
and -hyllis 7oung. /hen someone phones, Mrs. 7oung has answered with some 'ariation of,
?ello, this is -hyllis.! $he 7oungs and their guests all share the li'ing space of the house,
including the family room, bathrooms and (itchen. Mrs. 7oung has stored some of her personal
belongings in the closet of each room she rents to her guests and also allowed guests to use her
personal computer, located in her own bedroom. "ecause of the intimate li'ing arrangements
7oung shares with her guests, she is selecti'e in determining who she will welcome into her
home and will not allow couples to stay in Aloha if allowing them to do so would 'iolate her
religious con'ictions.

Diane &er'elli and $ae(o "ufford, a couple who identify as lesbian,! as(ed to rent a room with
a single bed in the 7oung,s home. She declined because allowing a same+se) couple to share a
room with only one bed in her home 'iolates her beliefs. &er'elli and "ufford complained to the
&i'il Rights &ommission, which found probable cause that 7oung had 'iolated the state
nondiscrimination law, which prohibits discrimination on the basis of se)ual orientation.

7oung appealed that decision to the state trial court. @n April <D, :;<A, the trial court 8udge
found that 7oung had engaged in unlawful discrimination when she declined to rent a roomN
in her own homeNto a same+se) couple. $he case has been appealed to the ?awaii intermediate
&ourt of Appeals. $he trial court,s ill+considered ruling, if permitted to stand, will pre'ent
7oung and others from choosing the people they rent rooms to in their own homes. 0f 7oung
does not ha'e this freedom, she will be forced to stop renting her property. $his will li(ely
pre'ent her and her husband from meeting their monthly mortgage obligations, thus forcing
them to gi'e up the home in which they raised their children.
JJ


:I

hristian Grou& For#ed to Host Sa+e9Se% /edding in Its )oardwal$ 'a;ilion 0 =une 344:
$he @cean %ro'e &amp Meeting Association was founded in <>IB by a small band of Methodist
clergymen on the 3ew 9ersey shore. 0t is a religious association that pro'ides a 'enue for
religious ser'ices, including Sunday ser'ices, "ible studies, camp meetings, re'i'al gatherings,
gospel music programs, religious educational seminars, and other religious e'ents. Upon its
incorporation, the Association pledged that it would use its facilities for %od,s glory and would
abstain from using them in any way inconsistent with the doctrines, discipline, or usages of the
Methodist Episcopal &hurch.! As part of its outreach programs to the community, the
Association has made regular use of its pri'ately owned, open+air "oardwal( -a'ilion
o'erloo(ing the Atlantic @cean. Each day throughout the summer, the Association has hosted
o'ertly and e)clusi'ely religious e'ents in the "oardwal( -a'ilion, e'ents ranging from "ible
studies to worship ser'ices and re'i'al meetings. E'ents held in the "oardwal( -a'ilion ha'e
been consistent with the religious beliefs and doctrines of the Association.

0n <BBJ, the Association began operating a wedding ministry in many of its pri'ate places of
worship, including the "oardwal( -a'ilion. "ecause this ministry was a means of &hristian
outreach to the community, the Association permitted members of the public to ha'e their
weddings in the "oardwal( -a'ilion. 0n March :;;J, ?arriet "ernstein as(ed the Association if
she could use the -a'ilion for a ci'il+union ceremony with her same+se) partner, 4uisa -aster.
$he Association belie'ed, based on its interpretation of the ?oly "ible and its reading of the
Methodist "oo( of Discipline, that marriage is the uniting of one man and one woman. $he
Association also belie'ed that homose)ual beha'ior is incompatible with &hristian teaching,
and thus it does not condone that practice.

3aturally, then, the Association denied the couple,s re*uest because the proposed use of the
facility 'iolated the Association,s religious beliefs. 0n 9une :;;J, the couple filed a
discrimination complaint with the 3ew 9ersey Di'ision on &i'il Rights, alleging that the
Association,s denial of their re*uest amounted to unlawful discrimination under the 3ew
9ersey 4aw Against Discrimination. $he Di'ision agreed, concluding in @ctober :;<:, that the
Association had 'iolated the State,s nondiscrimination law, despite the fact that the -a'ilion
was a place of religious worship used by a religious organi.ation. As a result, the Association
has stopped renting out the "oardwal( -a'ilion for weddings.
J>


$he complaining couple neither suffered nor sought any monetary damages. 3or were they left
without a suitable 'enue for their e'ent, as e'idenced by the fact that they held their ci'il+union
ceremony on September A;, :;;J, on a fishing pier in @cean %ro'e. $his case, li(e others
discussed, was not about a lac( of access to ser'ices or facilities. 0nstead, the couple filed their
complaint to compel a religious organi.ation to act in a manner that would 'iolate core tenets of
its religious faith. $he go'ernment permitted the couple to use the nondiscrimination laws to
pre'ent the Association from operating its programs and acti'ities consonant with its religious
faith.
JB


oo$ie Sho& Settles o+&laint o* 6is#ri+ination *or Re*using to reate Rainbow oo$ies
and a$e *or ,o+ing !ut. elebration 0 !#tober 3414
9ust &oo(ies, a coo(ie shop owned by Da'id and 4ily Stoc(ton and located at the 0ndianapolis
&ity Mar(et, ignited a firestorm in @ctober :;<; after employees refused to fill a special order of
:J

rainbow coo(ies and multicolored cupca(e for a coming out! celebration hosted by an 0ndiana
Uni'ersity -urdue Uni'ersity+0ndianapolis group. $he Stoc(tons were subse*uently accused of
discrimination for refusing to sanction the e'ent because it was against their 'alues. Shop
owners Da'id and 4ily Stoc(ton said they were within their rights to refuse the re*uest and that
the shop didn,t ha'e the capacity to fulfill the order. $he city in'estigated whether the shop had
'iolated the city,s anti+discrimination ordinance, but the Stoc(tons ultimately settled the
complaint. Under the agreement, the Stoc(tons ac(nowledged they understand the city,s e*ual
opportunity ordinance and agreed to update the 9ust &oo(ies website concerning special
orders. $he city will also post a public notice regarding the anti+discrimination ordinance.
>;


ountry ) E ) Sued *or Re*using to Host Sa+e9Se% Re#e&tion 0 =uly 3411
0n the bucolic 2ermont countryside, 9im and Mary @,Reilly operate the /ildflower 0nn, a family
owned bed+and+brea(fast. "ecause 2ermont legally recogni.es same+se) unions, the @,Reillys, a
committed &atholic family, had a well+established business practice when approached by
anyone as(ing the 0nn to host an e'ent celebrating a same+se) marriage or ci'il union# 9im
@,Reilly would disclose his deeply held religious con'iction that marriage is the union of one
man and one woman, while ne'ertheless maintaining that the 0nn would host ceremonies or
receptions for same+se) unions because that is what the State,s nondiscrimination law re*uires.
@,Reilly would disclose this information about his religious con'ictions because he felt
compelled to be honest with potential customers. $his practice was appro'ed by the 2ermont
?uman Rights &ommission in :;;D, which concluded that there were no reasonable grounds
to belie'e that /ildflower illegally discriminated! merely by @,Reilly,s communicating his
beliefs to a potential customer who in*uired about celebrating a ci'il union on the property.

0n :;<< the A&4U teamed up with the 2ermont ?uman Rights &ommission, the same entity
that had blessed the @,Reillys, conduct 8ust si) years before, in a lawsuit against /ildflower.
$he lawsuit began when a former /ildflower employee falsely claimed that the inn would not
allow a same+se) wedding reception. "ut the A&4U and the go'ernment did not merely
challenge /ildflower,s alleged unwillingness to host a same+se) reception1 they directly
attac(ed the @,Reillys, appro'ed practice of disclosing their religious beliefs about marriage to
potential customers.

$he @,Reillys, e)pression of their religious beliefs came at great cost. $he real+world
implications of a protracted legal battle with the go'ernment and the A&4U 5and the prospect
of paying the go'ernment,s and the A&4U,s attorneys, fees6 threatened to ban(rupt the
@,Reillys and shutter the business they had wor(ed so hard to build. Although the &ommission
agreed that the @,Reillys acted in good+faith reliance on its :;;D ruling, the go'ernment and the
A&4U demanded that the @,Reillys pay M<;,;;; to the &ommission as a ci'il penalty and
M:;,;;; to a charitable trust set up by the A&4U,s clients. Forced with the prospect of
potentially losing their business, the @,Reillys relented and agreed to these terms in August
:;<:. $his case was not about access to ser'icesNthe A&4U,s clients were easily able to find a
'enue for their reception, and the /ildflower,s business practice did not deny ser'ices to
anyone, but merely disclosed the @,Reillys, rele'ant religious con'ictions. /hat the
go'ernment and the A&4U really ob8ected to was the @,Reillys, mere mention of their 'iews
about marriageN'iews that conflict with the pre'ailing political orthodo)y in 2ermont.

:>

For this, the go'ernment and A&4U insisted that the @,Reillys be punished. $his case
demonstrates the threat that nondiscrimination laws present to religious libertyNthat those
who disagree with the go'ernment,s 'iews about issues implicating a statutorily protected
classification may pay dearly for the e)ercise of their constitutional rights.
><


)ridal Store !wner Threatened *or 6e#lining to 'ro;ide a 6ress *or a Sa+e9Se% /edding 0
August 3411
Donna Saber, owner of ?ere &omes the "ride in Somers -oint, 3ew 9ersey, has had callers
threatening to burn down her store and throw a bric( through the window after she reportedly
refused to pro'ide a dress for a same+se) marriage with the understanding that it was illegal.!
For simply sta(ing out her position, Saber,s store has been the target of protests and boycotts.
Saber says she is simply trying to li'e peacefully and run her business.
>:


atholi# hur#h For#ed to Shut 6own Ado&tion Agen#ies to A;oid 8iolating )elie*s 0
"o;e+ber 3411F Mar#h 142 344@
$he state of 0llinois ended its historic relationship with &atholic &haritiesNwhich was the first
organi.ation to inspire child welfare ser'ices in that stateNbecause the organi.ation would not
adopt children to homose)ual couples. Adoptions by homose)ual couples would 'iolate well+
established Roman &atholic &hurch doctrine. Although &atholic &harities was willing to refer
homose)ual couples to other adoption agencies, the state refused to accommodate them.
0ronically, this religious+based discrimination is in response to the Religious Freedom -rotection
and &i'il Unions Act. $he Act, when combined with state antidiscrimination laws, re*uires
homose)ual ci'il unions to be treated li(e marriages, but only pro'ides protection for religious
clergy who decline to officiate a ci'il union. 0t is estimated that two+thousand children will now
ha'e to transition to new agencies.
>A
0n Massachusetts, the &atholic &hurch also shut down a
successful adoption agency following the state supreme court,s imposition of same+se)
marriage to a'oid being forced to place children in same+se) households.
>=
&atholic entities
ha'e similarly been discriminated against for their 'iews in the District of &olumbia and San
Francisco, &alifornia, and ha'e chosen to shut down adoption ser'ices rather than be force to
'iolate their conscience by the go'ernment.
>D


) E ) Sued *or Stating Intention to "ot Host Sa+e9Se% /edding on Religious Grounds 0
"o;e+ber 12 3411
9im and "eth /alder owned the $imber &ree( "ed and "rea(fast in -a)ton, 0llinois. @n
February <D, :;<<, homose)ual acti'ist $odd /athen Nanticipating enactment of 0llinois, ci'il
unions! lawNsent them an email stating# Do you plan on doing same+se) ci'il unions starting
9une <stR! 9im /alder replied# 3o. /e only do /eddings.! 0n response, /athen enlisted the
help of the A&4U and filed a complaint with the 0llinois ?uman Rights &ommission# As a
result of Respondent,s 'iolation of the Act, &omplainant has suffered substantial mental and
emotional distress as well as the stigmati.ing in8ury and depri'ation of personal dignity that
accompanies denials of e*ual access to places of public accommodation.! /althen see(s
monetary damages, attorneys, fees and an order directing Gthe /aldersH to cease and desist
from any 'iolation! of the ?uman Rights Act.

$he /alders fired bac(, howe'er. 3o business owner may be forced to 'iolate his sincerely
held religious beliefs merely because someone demands it,! said Ste'e Am8ad, an attorney for
:B

$imber &ree(. &onstitutional and state laws guarantee religious freedom for e'ery American,
including business owners. $hese complaints Gby /athenH ignore those fundamental freedoms
and are further e)amples of the threat the homose)ual legal agenda poses to e'ery American,s
basic rights.!

$imber&ree( does not host ci'il union ceremonies for same+se) or opposite+se) couples, so the
discrimination charge is baseless,! added attorney "ryan "eauman. $imber&ree( has done
nothing wrong, and their right to freely e)ercise their faith should not be threatened.! $he
answers filed in response to the complaints filed by Mar( and $odd /athen assert that
$imber&ree( did not engage in se)ual+orientation discrimination under the 0llinois ?uman
Rights Act! and that applying specific portions of the act to this situation would actually 'iolate
the state,s Religious Freedom Restoration Act, federal law, and the First Amendment to the U.S.
&onstitution.
>I


a$e ottage under Fire *or Re*using to 'ro;ide a$e *or Sa+e9Se% /edding 0
"o;e+ber 142 3411
2ictoria &hildress, owner of 2ictoria,s &a(e &ottage in Des Moines, 0owa, refused to pro'ide a
wedding ca(e for a homose)ual couple, and came under fire for her decision. &hildress told
$rina 2odras(a and 9anelle Sie'ers that she could not ma(e the ca(e they re*uested because of
her con'ictions for their lifestyle,! and made sure they understood she was not discriminating
against them, but 8ust honoring her wal( with %od.! 3e'ertheless, 2odras(a described the
encounter as degrading,! and said she felt li(e they were chastised for wanting to do business
with her.! According to Sie'ers, &hildress introduced herself and as(ed if 2odras(a was her
sister. Sei'ers replied# 3o, this is my partner.! &hildress as(ed them to sit down and said, /e
need to tal(.! &hildress then said, 0,ll tell you 0,m a &hristian, and 0 do ha'e con'ictions. . . .
0,m sorry to tell you, but 0,m not going to be able to do your ca(e.! 2odras(a then said that
was fine and 0 appreciated her being honest.!

&hildress has maintained that it is her right to refuse to do the ca(e# 0 didn,t do the ca(e
because of my con'ictions for their lifestyle. 0t is my right as a business owner. 0t is my right,
and it,s not to discriminate against them. 0t,s not so much to do with them, it,s to do with me
and my wal( with %od and what 0 will answer 5to6 him for.! &hildress continued# $hey
than(ed me for being honest with them, and they were 'ery pleasant. 0 did not belittle them,
spea( rudely to them. $here were no condescending remar(s made, nothing.! At time of
publication, no legal action appears to ha'e been ta(en. ?owe'er, under 0owa law, people li(e
Ms. &hildress could be forced to ser'e causes in 'iolation of their conscience.
>J


'rint Artist Sued *or Re*using to 'ro+ote Gay Li*estyle 0 Mar#h 3413
"laine Adamson was the managing owner of ?ands @n @riginals, a printing company in
4e)ington, Eentuc(y, that speciali.es in producing promotional materials. Adamson, a
practicing &hristian who stri'es to li'e consistently with "iblical commands, has not
distinguished between conduct in his personal life and his actions as a business owner. As a
result, he has a'oided using his company to design, print, or produce materials that con'ey
messages or promote e'ents or organi.ations that conflict with his sincerely held religious
con'ictions.

A;

?ands @n @riginals has ser'ed customers that Adamson (new self+identified as homose)ual,
and it has employed 5and, at time of publication, continues to employee6 persons who identify
as homose)ual. "ut Adamson has not wanted to produce printed materials that promote
homose)ual 'eha"ior. Doing so would conflict with his sincerely held religious beliefs about se)
and se)uality. 0n March :;<:, the %ay and 4esbian Ser'ices @rgani.ation 5%4S@6, an ad'ocacy
organi.ation that promotes same+se) relationships and homose)ual conduct, as(ed Adamson
and his company to print promotional shirts for the 4e)ington -ride Festi'al, which 5li(e %4S@6
celebrates same+se) relationships and homose)ual conduct. Adamson politely declined the
re*uest because he (new that the content of those shirts and the e'ent that they would promote
would communicate messages clearly at odds with his religious beliefs. Adamson ne'ertheless
did offer to connect %4S@ with another company that would print the shirts for the same price
that ?ands @n @riginals would ha'e charged. 7et this courtesy was not enough for the %4S@
and its members. $hey belie'ed that Adamson and his business should be punished for his
ob8ection to their messages. As a result, the %4S@ filed a discrimination complaint with the
4e)ington+Fayette Urban &ounty ?uman Rights &ommission, alleging that ?ands @n @riginals
unlawfully discriminated on the basis of se)ual orientation.

$his discrimination complaint had nothing to do with ensuring access to ser'ices since soon
after filing its nondiscrimination complaint, %4S@ filled its shirt order with little trouble when
another company offered to print the shirts for free. 3e'ertheless %4S@ continuesNto this
dayNto press its claim against Adamson and his company by not dismissing its complaint. $o
add in8ury to insult, upon filing its discrimination complaint, %4S@ and its allies began a public
campaign against ?ands @n @riginals in the community, which included, among other things,
a page on the group,s website and a "oycott ?ands @n @riginals! Faceboo( page. As a result
of the public pressure created by %4S@, some of ?ands @n @riginals, large customersNsuch as
the Uni'ersity of Eentuc(y, the Fayette &ounty -ublic School System, and the Eentuc(y "lood
&enterNha'e publicly stated that they are placing a hold on further business with Adamson
and his company, resulting in a significant loss of business for ?ands @n @riginals. $his
de'elopment has 8eopardi.ed the li'elihood of Adamson,s many employees and the future of
his company.

0n 3o'ember :;<:, the &ommission found probable cause to belie'e that ?ands @n @riginals
'iolated the local nondiscrimination ordinance. "y simply stri'ing to conduct himself
consistently with his faith, Adamson now faces a legal struggle that threatens to appro)imate in
time and pain the one already endured by other citi.ens 5e.g. the ?uguenins in 3ew Me)ico6.
>>


a$e 6esigner For#ed to Ma$e a$e *or Sa+e9Se% /edding against His )elie*s 0 =uly 3413
9ac( -hillips has used his artistic talents to design and create wedding ca(es and ba(ed goods
for the last =; years. $wenty years ago, he started Masterpiece &a(eshop, and since that time he
has ser'ed thousands of customers in &olorado without regard to race, religion, se)ual
orientation, or any other status.

0n addition to being a ba(er, -hillips has been a committed &hristian who belie'es that he
should li'e consistently with what he belie'es to be true. As a conse*uence, -hillips has sought
to operate his business in accordance with his faith, e'en when doing so might cost him.

A<

/hile -hillips ser'ed all !eo!le, because of his faith he chose not ser'e all e"ents. For instance, he
has chosen not to ba(e any ?alloween+themed goods, e'en though ?alloween typically
pro'ides ba(eries increased re'enue+ma(ing opportunities, because he belie'es that &hristians
should not promote ?alloween. ?e has chosen to close his store on Sunday, so his employees
might be able to go to church if they so desire.

0n 9uly :;<:, &harlie &raig and Da'id Mullins as(ed -hillips to ma(e a wedding ca(e to
celebrate their same+se) ceremony. 0n an e)change lasting about A; seconds, -hillips politely
declined, e)plaining that he would gladly ma(e them any other type of ba(ed item they wanted
but that he could not ma(e a ca(e promoting a same+se) ceremony because of his faith. &raig
and Mullins, now represented by the American &i'il 4iberties Union, immediately left the shop
and later filed a complaint with the &olorado &i'il Rights Di'ision. After the &i'il Rights
Di'ision found probable cause, the complaint was heard by an administrati'e law 8udge, who
ruled in fa'or of &raig and Mullins and against -hillips. -hillips filed an appeal with the
&olorado &i'il Rights &ommission but the &ommission upheld the administrati'e law 8udge,s
ruling. At time of publication, -hillips was considering an appeal to the &olorado &ourt of
Appeals.
>B


a$e Artist Undergoes ,Rehabilitation. *or Re*using to )a$e a$e *or Sa+e9Se% /edding 0
=anuary 1:2 341?
Melissa and Aaron Elein owned Sweet &a(es by Melissa, a ba(ery located in %resham, @regon.
$hey declined, because of their religious beliefs, to ba(e a wedding ca(e for a same+se)
wedding.! $he same+se) couple filed a complaint against the Eleins with the @regon "ureau
of 4abor and 0ndustries 5"@406. $he commissioner of "@40, "rad A'a(ian, has been *uoted as
saying that, $he goal is ne'er to shut down a business. $he goal is to rehabilitate.!

3e'ertheless, "@40 ruled against the Eleins, and issued an administrati'e decision saying that
Sweet &a(es engaged in discrimination against the same+se) couple. Due to threats and fearing
for their safety, the Eleins closed Sweet &a(es by Melissa in September :;<A. At time of
publication, the complaint against the ba(ery is mo'ing into a period of reconciliation. 0f the
parties cannot reach an agreement, "@40 could file formal ci'il charges against Sweet &a(es and
the Eleins could be e)posed to hea'y fines.
B;


'arty 8enue 6raws Ire *or Re*using to Host Sa+e9Se% /edding 0 February 341?
"en Allen and 9ustin ?udgins contacted All @ccasion -arty -lace near Fort /orth, $e)as, and
re*uested that the All @ccasion host their same+se) wedding. All @ccasion -arty -lace refused
to do so out of religious ob8ections to same+se) marriage. 0n a response to Mssrs. Allen and
?udgins, an employee stated# 0t is because of %od that 0 will not be a part in your reception,
and 0 (now he lo'es you, but not what you are doing. . . . 0 simply said 0 cannot rent to you
which is also my right.!

Allen said it doesn,t really ma(e sense to me! to be denied this opportunity simply because
you date someone of the same+se)! in today,s day and age.! Allen,s beliefs ob'iously
conflicted with those of the people who ran All @ccasion -arty -lace, yet the business owners
maintained that their consciences and beliefs dri'e their li'es too. All @ccasion -arty -lace is
located outside the Fort /orth city limits, and therefore does not fall under the city,s anti+
A:

discrimination code. Still, the case has nonetheless spar(ed the ire of local lesbian, gay, bise)ual,
and transgender 54%"$6 rights ad'ocates.
B<


Florist Sued *or Re*using to reate Arrange+ent *or Sa+e9Se% /edding 0 A&ril 341?
Si)ty+eight+year+old "arronelle Stut.man, the sole owner of Arlene,s Flowers in Richland, /A,
has for her entire career ser'ed and employed people who identify as homose)ual. @ne of her
longtime clients, whom she had ser'ed for nine years while (nowing that he identified as
homose)ual, as(ed her to design the floral arrangements for his same+se) wedding.! Ms.
Stut.man had always considered him a friend. She responded by telling him that, while he
(new she lo'ed him, her religious con'ictions would not allow her to design floral
arrangements that would support same+se) marriage.! ?e responded by bringing suit against
her, as did the State of /ashington. "oth suits alleged 'iolations of /ashington,s state
nondiscrimination law.

Ms. Stut.man filed a countersuit against the State of /ashington, arguing that the
nondiscrimination law, as applied to Ms. Stut.man, was unconstitutional because it forced her
to act contrary to her religious con'ictions and also forced her to promote a message that she
did not wish to con'ey. At time of publication, this matter is currently before the "enton
&ounty, /A, Superior &ourt. 3o matter which side wins in the state superior court, the matter
li(ely will be appealed and the litigation is pro8ected to drag on for years.
B:


a$e Sho& Ta$ing Heat *or Re*using to 'ro;ide a$e *or o++it+ent ere+ony 0
May 341?
-am Regentin, owner of Fleur &a(es, ob8ected to pro'iding a wedding ca(e for a same+se)
couples, commitment ceremony. Ms. Regentin ob8ected to pro'iding the ca(e due to her
&hristian beliefs, and is now recei'ing criticism for doing so. Regentin has said she belie'es she
has the liberty to li'e by my principles.!
BA


Fa+ily Far+ Sued *or Re*using to Host Sa+e9Se% /edding 0 "o;e+ber 341?
4iberty Ridge Farm, in Schaghtico(e, 37, is the home of the %ifford family. 0t is a wor(ing farm
that has been in the family for many years, and the main structure on the property is where the
%iffords reside, raise their children, and engage in the pri'ate affairs of family life. $he %ifford
family has chosen to allow people on their property for certain select e'ents on gi'en days at
gi'en times. $heir home is not opened indiscriminately li(e a hotel, and although 'isitors pay
for certain e'ents held on the property, the %iffords ha'e determined the types of acti'ities they
will or will not allow.

$he family holds deeply+held religious beliefs, and one of these is that %od created the design
for marriage as the union of one man and one woman in a lifelong and e)clusi'e relationship.
$he %iffords ha'e not denied access to the Farm to any 'isitor on the basis of race, religion, se),
and other factors including se)ual orientation. E'eryone has been welcome to attend any
scheduled e'ents on their property1 the %iffords would e'en permit a same+se) couple to hold a
reception on their property. "ut they would not allow same+se) a marriage ceremony, because it
'iolated their religious beliefs.

AA

Melissa Erwin and 9ennifer Mc&arthy wanted to hold their wedding at 4iberty Ridge Farm. $he
%iffords declined to allow them to do so because of their religious beliefs and Erwin and
Mc&arthy then filed a complaint with the 3ew 7or( Di'ision of ?uman Rights. $here was an
e'identiary hearing in 3o'ember :;<A before an administrati'e law 8udge 5A496. $he A49 as(ed
both sides for briefs after that hearing1 these briefs were submitted on 9anuary J, :;<=. 9im
$rainor, representing the %iffords, argued in his brief that 4iberty Ridge Farm did not fit within
the definition of public accommodation, and also that the Farm did not decline pro'ide ser'ices
because of the se)ual orientation of the complainants but rather because of the %iffords, beliefs
about marriage. $he case is ongoing.
B=


atholi# S#hool Sued o;er Re*usal to Hire Indi;idual in Sa+e9Se% Marriage 0
=anuary ?42 341A
0t loo(ed li(e Matthew "arrett was going to be hired at the &atholic Fontbonne Academy in
Milton, Massachusetts, but then administrators noticed his emergency contact form. @n it,
"arrett had identified his homose)ual spouse! as the person to call. $he Academy called him
into the office and rescinded the 8ob offer. $he headmaster was polite but resol'ed. Fontbonne
Academy does not discriminate against anyone based on their se)ual orientation,! said
Assistant ?ead of School %regg &hambers. "ut it is guided by the religious doctrines and
beliefs of the Roman &atholic &hurch GwhichH has a 'ery specific belief that marriage between
two persons of the same+se) is contrary to the teachings of the &atholic &hurch and that belief
informs policies of how Fontbonne Academy and all &atholic schools are to operate on this
issue.!
BD
$hat didn,t sit well with "arrett, who contacted the local %ay F 4esbian Ad'ocates F
Defenders 5%4AD6 and filed a complaint with the state. Religiously+affiliated entities do not
ha'e a free pass to do as they please in how they treat employees,! %4AD insisted. @ther
liberals piled on, arguing that "arrett wouldn,t ha'e been wor(ing in the classroom, imposing
his agenda on the students. %4AD subse*uently filed a complaint with the Massachusetts
&ommission Against Discrimination 5M&AD6 against Fontbonne Academy. Fontbonne
Academy will now ha'e its religiously moti'ated 'iews sub8ected to the scrutini.ing eye of the
state and the M&AD.
BI


Uni;ersities Target hristian Grou&s Using ,Anti96is#ri+ination. Rules 0 =une 341A
"owdoin &ollege, along with the &alifornia State Uni'ersity public system and se'eral other
colleges, is see(ing to e)clude e'angelical groups from official uni'ersity recognition starting in
the Fall :;<= semester. $hese uni'ersities are employing nondiscrimination rules to say that any
student must be allowed to be a leader of any student group, no matter his or her religious
beliefs. $he "owdoin &hristian Fellowship does not agree. 0t would compromise our ability to
be who we are as &hristians if we can,t hold our leaders to some sort of doctrinal standard,!
"owdoin graduate and former leader of "&F Sac(ary Suhr told The New (or& Times. %roups li(e
"&F 'iew such liberal uni'ersity policies as encroachments on their religious liberty and are
refusing to agree to such policies. 0f these groups lose official uni'ersity recognition, that could
mean they are denied access to the uni'ersity,s name, facilities, money, and other important
benefits.
BJ




A=

on#lusion

$hese stories feature real Americans who are trying to li'e peaceful, faithful li'es, but find their
conscience and liberty under attac(. $hey are fathers, mothers, sons, and daughters. Many of
them loo( li(e us and our neighbors.

/ith little warning, they are attac(ed and marginali.ed by those who are see(ing to redefine
the rights gi'en by %od and e)pressed by our Founders and earlier Americans. $he 'ictims in
these stories are caught in the center of a larger struggleNas their fellow citi.ens see( to
redefine rights through policy, law, and culture. $his narrati'e pits our historical understanding
of the notion of religious libertyNan e)pansi'e 'ision that includes the ability to apply one,s
faith to all the details of one,s lifeNagainst a more recent understanding of freedoms in which
rights! to a religion+free! en'ironment or to unfettered se)ual e)pression are crafted into new
law and ele'ated to the le'el of and e'en abo'e our foundational constitutional rights of
freedom of speech and religion.

/hile the incidents listed abo'e are troubling, there is still time to address and counter the
many current threats to religious liberty. Although most of these accounts ha'e occurred within
the past se'eral years, it is important to reactNnot simply with urgent concern for those whose
rights are most immediately affectedNbut also with prudent, informed ad'ocacy for the
principles underlying our religious liberty. $he suppression of religious liberty is not entirely
disconnected from the restriction and suppression of free in*uiry and critical thin(ing we are
obser'ing today. /e should be concerned that the suppression of rights, particularly as
outlined in Sections 000 and 02 of this publication, is the product of more insidious forces which
ultimately will erode ci'il liberties for all Americans, e'en if they hold a different 'iewpoint
than our own. $hus all these threats are properly countered by addressing not only the primary
religious liberty issues but also the underlying philosophical thin(ing that leads to such attac(s
in the first place.

/e must first become aware of religious liberty 'iolations. $hen we can focus on legal, policy,
and cultural responses to these 'iolations. 4iberty does not maintain itself. @nly as we become
more fully aware of and engaged on the issue of hostility toward religion, can we effecti'ely
defend ci'il liberties and restore religious liberty to its proper place in American society.


T $his story has been published in $he 4iberty 0nstitute and Family Research &ouncil,s 8oint
publication )ndenia'le* The +,r"ey of -ostility to .eligion in Ameri%a and has been reprinted with
permission.
TT $his story has been published by Alliance Defending Freedom and has been reprinted with
permission.


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Many of the laws pro'iding special protection for se)ual orientation and gender identity ha'e been enacted within
the last few years. $he ?uman Rights &ampaign and the American &i'il 4iberties Union pro'ide lists of the cities,
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lane Photogra!hy "# $illo%&, A;B -.Ad DA 53.M. :;<A6,
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