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Same-Sex Marriage, Part 8: The Threat to Individual Liberty

Same-Sex Marriage, Part 8: The Threat to Individual Liberty

Gay marriage is the defining cultural issue of our day, although many people are not aware of just what is at stake in the debate. The purpose of this series is to provide some insight into the issues behind the propaganda, and to demonstrate that it is in the best interest of all of society to promote a traditional, conjugal view of marriage. Read the other parts of the series here:

 

This article will explore the fifth reason (as listed in Part 3) promoting the conjugal view of marriage (one that is rooted in nature, rather than choice) is so significant:

5. Sexual complementarity in marriage provides a basis for the institution that distinguishes it from all other kinds of unions. If the state endorses a non-conjugal view of marriage (including same-sex marriage), then it would be implying that the conjugal or traditional view would be making arbitrary distinctions. This would present a tremendous threat to freedom for defenders of traditional marriage, who would be seen as being discriminatory for espousing the view of marriage held throughout history, opening them up to stigmatization and even punishment based on their beliefs.

Most specifically, this article will address the ways that same-sex marriage poses a threat to individual liberty – and, particularly, religious liberty.

Marriage as a Non-Arbitrary Union

Traditional marriage, between a man and a woman, is based on gender complementarity – a non-arbitrary grounding for the relationship, rooted in the potential for the bodily union of man and woman to create new life. It is nature, not human choice or will, which determines the basis for traditional marriage. As Part 7 addressed, this feature is central to the institution being just, or non-discriminatory. Marriage, because of its unique structure and features as a permanent, exclusive, monogamous union that has the potential for procreation, is a relationship like none other.

By virtue of the fact that no other relationships can be what marriage between a man and a woman is, laws supporting traditional marriage are not discriminatory. (There is no discrimination involved, for example, in saying that the relationship of two business partners who have agreed to live together to further their business ventures is not a marriage, because that relationship does not have the structure and features the marriage has.) All persons who are eligible to form the type of union that marriage is (the comprehensive union of a male and female, with the norms of exclusivity, monogamy and permanence, of the type which could potentially result in the creation of mutual children) are given equal opportunity, irrespective of sexual orientation or anything else, to have their relationship carry the label of marriage. Persons of the same sex are simply incapable of forming this kind of union.

Marriage law is not discriminatory because is necessarily distinguishes between different types of relationships, based on characteristics essential to that relationship, rather than arbitrarily discriminating against persons based on characteristics that are not essential to the relationship. It is, in fact, same-sex marriage that introduces an arbitrary, discriminatory element into the equation – the element of personal choice.

Part 7 also summarized the fact that same-sex marriage is essentially an argument around whether a relationship that is not the same union as a marriage can be called a marriage; it is a debate about labels. And it is an important debate, because labels have a significant impact on shaping culture – obtaining the label “marriage” for same-sex relationships would significantly increase cultural acceptance of homosexual lifestyles and relationships. Although the majority of the gay community seeks this end, unfortunately the alternate effect granting the “marriage” label to gay couples would have is to harm the institution of marriage itself by damaging marital norms, ultimately rendering marriage irrelevant.

Same-Sex Marriage Makes Traditional Marriage Appear Arbitrary

The demise of marriage is, of course, a societal problem of monumental proportions (for a discussion of this issue, see Parts 2, 4, 5 and 6). However, it is not the only negative consequence of the state endorsing same-sex unions as marriages.

For the state to promote relationships for the public in a fair manner, there must be some non-arbitrary elements of those relationships. Gender complementarity, of course, is the central non-arbitrary feature of the marital relationship – something created by nature, not by human choice. Patrick Lee writes, “Since a same-sex couple is unable to form the kind of union marriage is, not granting same-sex couples marriage licenses is simply a decision by the state not to engage in a confusing and harmful fiction.”[1] If the state espouses a redefinition of marriage to no longer involve opposite genders, it would, in effect, be insinuating that the gender complementarity element of marriage was an arbitrary distinction.

Put more simply, for the state to recognize same-sex marriage would impart the message that limiting marriage to opposite genders would be discriminatory, even though it is not.

Taking such a step would be significant for the jurisprudence of society. It would completely alter justice in the American political and legal system, as society would essentially begin engaging in legal and philosophical fallacy – labeling as marriages relationships that are not, and cannot possibly be marriages. Traditional marriage advocate Maggie Gallagher writes that same-sex marriage would make the statement that “marriage can be remade to mean whatever the government decides. Reality itself can be re-mastered to accommodate sexual desires.”[2] Our legal system relies on truth as its basis to function; it interprets the truth of the law for practical application. Recognizing same-sex marriage would cause the state to willingly engage in calling fiction reality, to label myth as truth. To do so would dramatically impact the ability of our system to accurately interpret the truth of the law overall.

This puts some of our most basic freedoms at risk. It would be giving the state the power to create and define the institution of marriage, rather than acknowledging that marriage is something higher and more foundational than the state. Doing so would give unprecedented power to the government, because what the government creates, the government can take away.

Threat to Freedom

One of the most significant ways justice within society would be altered is in the threat to individual freedom. State endorsement of same-sex marriage would imply that the conjugal view of marriage is discriminatory, and thereby those persons who support traditional marriage would also be viewed as proponents of discrimination. Persons who, by virtue of religious conviction or adherence to tradition, favor marriage between a man and a woman, would be labeled as bigots for espousing a view of marriage that has been virtually unchallenged throughout the history of mankind. Deeply held religious convictions or values of conscience and tradition will be recast as prejudice, and those holding them will be demonized as homophobes. Those who defend traditional marriage will be marginalized and even criminalized for their beliefs. Gallagher expounds, “For the first time in American history, mainstream, orthodox Judeo-Christian beliefs will render an American a second-class citizen, subject to a variety of bars and exclusions government imposes to reduce the reach of ‘anti-equality’ bigotry.”[3]

This fact is even acknowledged by the pro-gay marriage community: In the book Debating Same-Sex Marriage, professor and gay-marriage advocate John Corvino acknowledges, “Whatever side prevails in this debate, the other’s views will be marginalized. There’s no getting around that.”[4] Georgetown University law professor Chai Feldblum (who was nominated by President Obama, and is the first openly gay Commissioner of the Equal Employment Opportunity Commission) addressed the conflicts between rights for LGBT persons and religious liberty. Feldblum wrote, “We are in a zero-sum game: a gain for one side necessarily entails a corresponding loss for the other side[5]…And, in making the decision in this zero-sum game, I am convinced that society should come down on the side of protecting the liberty of LGBT people”.[6] When asked what she would do if homosexual rights ever conflicted with faith, she responded, “I’m having a hard time coming up with any case in which religious liberty should win.’”[7] Similarly, two amicus briefs filed with the Supreme Court (one for Proposition 8 and one for DOMA) acknowledge that there will be significant conflicts between same-sex marriage and religious liberty – and that religious organizations deserve to lose those conflicts.[8]

The message is clear: Sexual orientation is to be protected in the same way as race. And racial equality, in our legal system, wins out over religious liberty every time. When it comes down to the showdown between same-sex marriage and religious freedom, religious liberty always loses.

The reality is that same-sex marriage ushers in a culture in which homosexual relationships become equal to heterosexual relationships, where sexual orientation is equated with race, and where those who express opposition to homosexual practice in any way (or merely a preference for heterosexual marriage) face significant repercussions – repercussions similar to those who discriminate on the basis of race.

This threat to freedom is not merely conjecture; it has already begun.

Same-Sex Marriage and Threats to Freedom in Europe

There is abundant evidence throughout the world that the acceptance of same-sex partnerships is accompanied, hand-in-hand, by a corresponding focus on “tolerance” in attitude and policy. Under this philosophy of tolerance, citizens are compelled to accept non-traditional sexuality and lifestyles, even if doing so violates religious conviction, or face significant consequences. In other words, the elimination of gender complementarity as a meaningful construct in relationships and policy is accompanied by the infringement on religious liberty. “Tolerance”, on the world stage, trumps religious conviction. Europe, which is ahead of the United States in acceptance of gay lifestyles and relationships, provides a helpful guidepost for recognizing the social ties between acceptance of secular morality and the threat to religious freedom.

Nordic Countries: Denmark, which was the first country to allow same-sex couples to register as domestic partners in 1989, passed a law in June 2012 that makes it mandatory for all Lutheran churches (the state church) to conduct gay marriage ceremonies. Bishops who are unwilling to perform the ceremonies themselves are required to provide a replacement to perform the ceremony in their church, in their stead.[9] Sweden’s 2009 legislation, which gave same-sex couples the same rights as heterosexual couples, accomplished the same thing. [10] These religious leaders are forced to secure the means by which same-sex couples can marry in their churches – even in violation of their faith beliefs.

Germany: Germany, which has registered partnerships for same-sex relationships that include virtually all of the rights and benefits of marriages, also forbids parents from opting their children out of compulsory sex education classes when the content of those classes conflicts with the family’s values. A number of parents have chosen to keep their children at home to avoid indoctrination of values contrary to their faith, and, as a result, have received serious fines and prison sentences. When one such case was taken to the European Court of Human Rights, the court ruled against the parents, citing that Germany, with its system of compulsory school attendance was “ensuring the integration of children into society with a view to avoiding the emergence of parallel societies” and that “the aim of sexual education is to provide pupils with knowledge of biological, ethical, social and cultural aspects of sexuality according to their age and maturity in order to enable them to develop their own moral views and an independent approach towards their own sexuality. Sexual education should encourage tolerance between human beings irrespective of their sexual orientation and identity” (emphasis added).[11] The values of tolerance and acceptance of sexual diversity override parental rights to direct the education of their children.

United Kingdom: In 2010, England adopted a law on equality and non-discrimination (the Equality Act), which includes gender reassignment, civil partnerships, and sexual orientation as protected characteristics. Since that time, consequences have increased for those who have followed their religious convictions in relation to homosexuality. Organizations such as Christian Concern, in the United Kingdom, work to defend religious freedom. Some examples of the threat to religious liberty England has experienced, on the part of those who respond to homosexuality according to their faith, are as follows:

  • A counselor was dismissed for telling his managers that he would not be willing to provide directive sex therapy to homosexual couples, due to his religious beliefs. The situation never arose where he actually refused counseling to anyone; he was dismissed for simply telling his managers that if the issue came up with a couple, he would discuss it with his supervisors (due to his religious objections to providing such counseling). The Employment Tribunal upheld that his employer did not discriminate against him.
  • A pediatrician was terminated from her position on an adoption panel for asking to not participate in voting when homosexual couples were being considered as potential adoptive parents, due to her religious convictions. The Employment Tribunal ruled rejected her religious discrimination suit.
  • A registrar was demoted from her job because she was unwilling, due to her faith beliefs, to preside over civil partnership ceremonies for same-sex couples. Her case did not even reach the Employment Tribunal, because the tribunal had ruled, in a similar case, that registrars were required to preside over civil partnership ceremonies in spite of their religious objections.
  • Foster parents were denied the right to foster children because of their Christian beliefs about sexuality. The court ruled that homosexual rights win out over freedom of conscience with respect to fostering children, and that “there may well be a conflict with the local authority’s duty to safeguard and promote the welfare of looked-after children” if foster children were placed with parents who have biblical views on sexuality.

France: France, which has had a form of civil union for same-sex couples since 1999 and which just made same-sex marriage legal in 2013, is currently working on legislation to reform education toward a secular morality. Under this new compulsory education, “gender equality” would become a central focus, for primary schools, in the efforts of “liberating” the student from religious convictions that gender and sexuality are rooted in nature. Vincent Peillon, Minister of Education, has declared, “The goal of the secular morality is to remove all family, ethnic, social and intellectual determinisms from the pupil”. Likewise, Minister of Justice Christiane Taubira expressed to the French Assembly that “in our values, education aims to relieve pupils of social and religious determinisms and make them free citizens”.[12] Religious conviction is seen, under the values of tolerance, as a dangerous and restrictive force from which citizens must be liberated. The philosophy of tolerance of sexual diversity threatens the freedom of those who adhere to traditional morality and seek to live according to their faith beliefs or to educate their children according to their convictions.

Same-Sex Marriage and Threats to Freedom in Canada

Canada, which is about a decade ahead of the United States in recognizing same-sex marriage, provides a good benchmark for assessing the impact of same-sex marriage on the culture of marriage and individual freedom. Gay marriage in Canada has gained equal legal status to heterosexual marriage, and, along with it, the belief that “any statement of disagreement with same-sex civil marriage is thus considered a straightforward manifestation of hatred toward a minority sexual group.”[13] Through social pressure, fines, loss of tax-exempt status, social and professional marginalization, disciplinary action, and the threat of criminal punishment, those who oppose same-sex marriage or homosexual lifestyles have faced serious consequences.

The evidence of this has been seen in a variety of ways. The Saskatchewan Court of Appeals ruled, for example, that amendments drawn by marriage commissioners, which would allow them to refuse to perform a same-sex marriage ceremony if doing so violated the commissioners’ religious beliefs, were not constitutional, and were, in fact, discriminatory.[14] Several provinces demanded the resignations of commissioners who refused, out of religious conscience reasons, to perform same-sex marriages.[15] In another case, the Knights of Columbus, a Catholic men’s organization, was fined for refusing, due to their religious beliefs, to rent their facilities to a same-sex couple for their wedding reception.[16] Canadian courts have upheld disciplinary action against employees who, in the course of their personal lives, make statements criticizing homosexual relationships or lifestyles, such as the case of a British Columbian teacher who was suspended after writing an article and letters to the editor to the local newspaper in which he expressed his views against homosexuality.[17] Even a sportscaster from Toronto was not immune; Damian Goddard was fired in 2011 from the communications company for which he had worked for 15 years, for tweeting a message in support for traditional marriage.

Since the legalization of same-sex marriage, religious conscience of Catholic schools has been trampled; Bill 13, the law in Ontario, requires Catholic schools to allow gay-straight alliance clubs, even though doing so would require them to violate their faith beliefs. Parental rights have been threatened as well. In 2011 the Toronto School Board forbade parents from opting their children out of classes dealing with homosexuality, called “Challenging Homophobia and Heterosexism”, even for religious reasons. Canada provides clear examples of how same-sex marriage has led to a dramatic infringement upon the right to religious freedom, freedom of speech, and parental rights for those who support traditional marriage.

Same-Sex Marriage and Threats to Freedom in America

The threat to freedom is not unique to Canada, however. Although as of May 2013, only 12 states (and Washington, D.C.) have legalized gay marriage, the impact on religious conscience and personal liberty is already profound. Religious freedom, as understood by the framers of the Constitution, involved not simply the ability to worship as one chose, but the liberty to live out one’s faith convictions in all aspects of life – the “free exercise” of religion as stated in the First Amendment. The exclusion of gender complementarity from marriage puts this freedom at risk, as the issue is erroneously cast as one of discrimination. Freedom of religion, freedom of expression, and parental rights are all on the chopping block, as legitimate conviction, based on human tradition throughout history, is trumped by an illegitimate appeal to human rights.

Freedom of Religion: First, the freedom of individuals and organizations to freely live out their faith beliefs has been compromised, as upholding a traditional view or marriage and sexuality has become synonymous with hatred and bigotry. Consider these examples:

 

  • Catholic Charities, a non-profit organization, has closed its doors in a number of states since 2006, rather than violate its religious beliefs, because those states have determined that it is a violation of law for the agency to not provide adoptions for same-sex couples. [18]
  • In New Jersey, Ocean Grove Camp Meeting Association, a Methodist non-profit organization, refused to rent its pavilion facilities to a same-sex couple for their civil union ceremony, on religious grounds. The Office of the Attorney General found that the organization violated part of the New Jersey Law Against Discrimination. As a result, the association’s boardwalk pavilion lost its tax-exempt status.
  • In 2012, the New Mexico Court of Appeals found Christian photography business owners guilty of violating non-discrimination laws for refusing, because of their faith beliefs, to photograph the commitment ceremony of a same-sex couple. They were fined nearly $7,000.[19]
  • The California Supreme Court ruled in 2008 that Christian fertility doctors could not refuse to inseminate a lesbian because of religious beliefs, even though the doctors referred the patient to another doctor who was willing to perform the procedure.[20]
  • A New York town clerk resigned rather than sign same-sex marriage licenses against her faith convictions. The state’s Marriage Equality Act mandates that an application for a marriage license cannot be denied to same-sex couples, and that public officials who do so may be subject to criminal prosecution.
  • Christian social worker Julea Ward was dismissed from her graduate program at Eastern Michigan University because, in the course of her counseling practicum, she referred a homosexual client to another counselor, due to her religious convictions that would not allow her to affirm the client’s homosexual behavior. A federal court upheld the university’s decision.
  • Christian bed and breakfast owners in a number of states have been the brunt of lawsuits when they have refused to rent their facilities for same-sex civil unions or weddings.[21]
  • Arlene’s Flowers, which had knowingly employed and served homosexual clients for years, is currently being sued for politely declining to arrange flowers for a same-sex wedding, out of objections to participating in a ceremony that violates her faith beliefs. The case is being brought by Washington State Attorney General on behalf of the state of Washington, at taxpayer expense.[22]

The acceptance of same-sex marriage leads to discrimination against those who support traditional marriage because of their religious convictions. As sexual orientation gains the same legal ground as race, religious freedom becomes sacrificed on the altar of “tolerance” and “non-discrimination” (For a discussion of whether opposing the redefinition of marriage is discriminatory, see Part 7). Individuals and organizations are punished for putting their faith beliefs into practice – faith beliefs about the nature of marriage that have been universally accepted throughout culture and history.

In writing about the Supreme Court’s upcoming decision about same-sex marriage, Adam MacLeod explains, “So the options are clear. Either the Supreme Court creates a new fundamental right to same-sex marriage or it preserves religious liberty.”[23]

Freedom of Expression: The threat to religious freedom would be enough of a consequence, on its own, to prohibit the redefinition of marriage. Unfortunately, they are not the only freedoms at stake. Freedom of expression receives a death blow, as well:

 

  • Two official complaints were filed with the state licensing board against a high school guidance counselor in Maine, claiming that he had violated the National Association of Social Workers Code of Ethics, after he appeared in a television political ad opposing gay marriage. Although the state licensing board eventually dismissed the two complaints against him (he was represented by the Alliance Defense Fund), the case demonstrates the consequences in time, expense, and energy for those who defend traditional marriage in a public forum.[24]
  • Frank Turek, a consultant with Cisco, was fired for his political and religious views supporting traditional marriage, even though his views were not expressed during his work. After conducting leadership training for Cisco managers (a program dubbed “excellent” by those who attended), a gay manager discovered that Turek was the author of a book entitled Correct, Not Politically Correct: How Same-Sex Marriage Hurts Everyone. Cisco fired Turek without ever reading the book or talking to him.[25]
  • Former Associate Vice President for Human Resources at the University of Toledo in Ohio, Crystal Dixon (who is African-American), was fired from her position after writing an op-ed article arguing that the gay rights movement could not be compared to the civil rights movement.[26]
  • A police officer with the Los Angeles Police Department (who also serves as a pastor during his off-duty hours) was demoted from his position in community relations and denied promotions, for making comments critical of homosexuality in a funeral eulogy he performed while off duty.[27]

Parental Rights: Parental rights have also been threatened as the identification of opposition to gay marriage (and lifestyles) has become synonymous with discrimination:

One of the most notable examples of this occurred in Massachusetts. The Estabrook Elementary School in Massachusetts included the book “Who’s In a Family”, a book about a same-sex couple, in a “diversity book bag” for students as young as 5, unbeknownst to parents. Another teacher at the same school read “King and King”, a story about two princes who marry, and who are depicted kissing, to a second grade class. Although parents objected to the material, the school would not allow parents to opt their children out of the classes in which these materials were shared. The Superintendent defended the school’s decision, saying ”Lexington is committed to teaching children about the world they live in, and in Massachusetts same-sex marriage is legal.”

The parents sued the school system, asserting that the school systems’ actions violated their Constitutional rights to raise their children and to freely exercise their religion under the first amendment, and that the school system also violated Massachusetts statute that requires that parents be able to exempt their children from curriculum that primarily involves sex education. The court dismissed the parents’ case, writing, “The constitutional right of parents to raise their children does not include the right to restrict what a public school may teach their children and that teachings which contradict a parents’ religious beliefs do not violate their First Amendment right to exercise their religion.”

A culture that does not acknowledge gender complementarity as significant puts religious freedom, freedom of expression, and parental rights all at risk.

Conclusion

Gender complementarity in marriage is a non-discriminatory attribute of humanity that grounds the basis for marriage. Traditional marriage law does not discriminate against same-sex couples because it makes a legitimate legal distinction between inherently different relationships, not an arbitrary distinction between persons in relationships that are fundamentally the same. However, when gender complementarity is removed from marriage law, it implies that gender complementarity was, in fact, an arbitrary distinction. And then, because the distinction was “arbitrary”, any distinctions anywhere made on the basis of gender complementarity become perceived as being rooted in discrimination.

If the Supreme Court redefines marriage to no longer involve sexual complementarity, it will be changing the definition for everyone, including those with opposing religious beliefs. On the faulty basis of “civil rights”, religious liberty and freedom of expression, along with parental rights, become sacrificed on the altar of “tolerance”.  To fully participate in public life, citizens will have to affirm same-sex relationships, even if it goes against their deeply held convictions. Same-sex marriage becomes the tool for a genderless society in which basic freedoms are denied to those who dissent. Human tradition from two thousand years, firmly held religious belief, and even the welfare of children and families become invalid, and any who do not embrace this new conception of genderless marriage and lifestyles will reap significant consequences.

Same-sex marriage, in the effort of granting “freedom” to homosexuals to call their relationships something they, fundamentally, are not, compromises the most basic freedoms upon which America is founded.

 

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[1] Lee, P. (2012, January 30). “The Same-Sex ‘Marriage’ Proposal is Unjust Discrimination”. Public Discourse.

[2] Gallagher, M. (2011, August 23). “Defend Marriage: Moms and Dads Matter”. Public Discourse.

[3] Gallagher, M. (2011, August 23). “Defend Marriage: Moms and Dads Matter”. Public Discourse.

[4] Franck, M. (2012, July 30). “Truth and Lies, Nature and Convention: The Debate Over Same-Sex Marriage.” Public Discourse.

[5] Feldblum, C. R. (2005, September). “Moral Conflict and Liberty: Gay Rights and Religion.” In “Symposium on Justice Blackmun and Judicial Biography: A Conversation With Linda Greenhouse”. Brooklyn Law School, Georgetown University Law Center. p. 87

[6] Feldblum, C. R. (2005, September). “Moral Conflict and Liberty: Gay Rights and Religion.” In “Symposium on Justice Blackmun and Judicial Biography: A Conversation With Linda Greenhouse”. Brooklyn Law School, Georgetown University Law Center. p. 119

[7] Tony Perkins’ Update (2013, May 20). “Floral Controversy Stems From Intolerant Left”. E-mail subscription from Family Research Council reply@frc.org.

[8] Rassbach, E. (2013, March 23). “Religious Liberty and the Same-Sex Marriage Cases: The Arguments”. The Becket Fund.

[11] DOJAN and Others v. Germany, no. 319/08, 2455/08, 7908/10, 8152/10, 8155/10, 13th September 2011. European Court of Human Rights.

[12] Puppinck, G. (2013, April 23). “The Fight Against Gender Stereotypes and Parental Rights: The Case in France and Other European Countries”. Turtle Bay and Beyond.

[13] Miller, B. (2012, November 5). “Same-Sex Marriage Ten Years On: Lessons From Canada”. Public Discourse.

[14] Luhtanen, M. (2011, February 23). “The Saskatchewan Court of Appeal’s Marriage Commissioners Decision – The Never-ending Fight For Human Rights of Same Sex Couples”. The University of Calgary Faculty of Law Blog on Developments  in Alberta Law.

[15] Miller, B. (2012, November 5). “Same-Sex Marriage Ten Years On: Lessons From Canada”.

[16]Smith and Chymyshyn v. Knights of Columbus and others, File 1258 (British Columbia Human Rights Tribunal, 2005).

[17] Kempling v. British Columbia College of Teachers, Docket CA031628 (Court of Appeals for British Columbia, 2005).

[18] Marshall, J. (2011, November 21). “Jennifer Marshall: Making Adoption a Likely Option”. Sun Journal: Columns and Analysis; Carr, R. J. (2006, March 10). “Boston’s Catholic Charities to Stop Adoption Service Over Same-sex Law”. Catholic Online; Associated Press (2011, May 27). “In Objection to Gay Rights Law, Diocese Ends Adoption Work”. The Courier News: A Chicago Sun-Times Publication; Brachear, M. A. (2011, June 3).”Catholic Charities in Joliet, Peoria Opt Out of Adoptions”. Chicago Tribune News.

[19] Kirkwood, R. C. (2012, June 6). “New Mexico Court: Christian Business Owners Have No Rights”. The New American.

[20] Grossman, J. (2008, September 2). “The California Supreme Court Rules that Fertility Doctors Must Make Their Services Available to Lesbians, Despite Religious Objections”. FindLaw; Associated Press (2008, August 18). “California Top Court: Doctors Cannot Withhold Care from Gays”. Fox News.

[21] Huffington Post (2011, February 23). “Gay Couple Sues Illinois Bed and Breakfast For Refusing to Host Civil Union Ceremony”; Gram, D. (2012, August 23). “Vermont’s Wildflower Inn Settles Gay Marriage Lawsuit With Lesbian Couple”. Huffington Post Gay Voices.

[22] Tony Perkins’ Update (2013, May 20). “Floral Controversy Stems From Intolerant Left”. E-mail subscription from Family Research Council reply@frc.org.

[23] MacLeod, A. J. (2013, April 2). Marriage, Religious Liberty, and the Ban Myth. Public Discourse.

[24] Miller, K. (2009, October 29). “Yes On 1 Advocate Targeted After TV Ad”, Bangor Daily News; Alliance Defending Freedom (2010, April 12). “Complaints Dismissed Against Maine Counselor Who Supported Marriage”. News Release.

[25] Lal, Subodh S. (2011, July 8). “Cisco Vendor Fired For Writing Book Against Same-Sex Marriage”. Christian Post Business; Adams, M. (2011, June 16). “The Cisco Kid”. Town Hall.

[26] Ghose, C. (2012, December 19). “University of Toledo official’s Firing Over Anti-Gay Opinion Piece Upheld by Appeals Court”. Columbus Business First; Krudy, J. (2008, May 15). “Dixon to File First Amendment, Discrimination Suits”. Toledo Free Press.

[27] Catholic News Agency (2008, July 8). “Officer Sues LAPD Alleging Discrimination For Off-Duty Bible Quotation”; Leichman, A. (2008, July 6). “LAPD Sued Over Alleged Religious Discrimination”. Christian Post Politics.

[28] Parker v. Hurley, No. 07-1528. (United States First Court of Appeals for the First Circuit, 2008); Gay & Lesbian Advocates & Defenders (2008, Jan. 31). “Parker v. Hurley”. Case News. From Glad.org.

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