Well, both the Equal Protection Clause jurisprudence and
antidiscrimination law requires figuring out whether the defendant deliberately
treated people differently based on race, sex, religion, etc.
But I don't think we ever ask whether a private citizen's
discriminatory actions were "at bottom" based on "hostility" or rather based on
"no objection to [people's identity]" but rather a "feel[ing]" that people of
certain identities shouldn't do something. And I think we basically don't do
that even as to government actors' imputed motives, either. To give just one
example, say that an employer decides not to hire women with small children for
a particular job. There may be no evidence at all that this is based on
"hostility" to women or even "hostility to [women] receiving equal treatment"
(except in the tautological sense that all decisions to treat unequally are
based on "hostility" to equal treatment in the sense of a choice against such
equal treatment). It may be clear that the employer is very friendly to women
in many contexts, but just "feel[s] they shouldn't" work outside the home when
they have small children. But that doesn't matter for Title VII purposes.
Indeed, even if an employer requires women to contribute more to retirement
funds simply because women are statistically likelier to live much longer than
men -- with not a hint of "hostility" -- is violating Title VII.
Now maybe both the photographer -- or wedding singer or portrait
painter or calligrapher or press release writer -- who doesn't want to create
material for a same-sex wedding ceremony or similar event and the one who
objects to an interfaith event should lose under RFRA or the Free Speech
Clause. Maybe both should win. But I can't see how courts can distinguish
between them on the grounds of a perception that one's discriminatory conduct
is motivated by "hostility" and the other's is motivated by a "feeling [that
certain people] shouldn't get married to each other."
Eugene
From: religionlaw-boun...@lists.ucla.edu
[mailto:religionlaw-boun...@lists.ucla.edu] On Behalf Of Eric J Segall
Sent: Wednesday, October 12, 2016 12:10 PM
To: Law & Religion issues for Law Academics <religionlaw@lists.ucla.edu>
Subject: Re: Noteworthy, puzzling scholars' brief in Arlene Flowers
Eugene asks tough questions but of course our entire EP jurisprudence requires
smoking out pernicious v non-pernicious intent as does post Smith free exercise
law and much free speech law. I'm of course willing to cede much more to the
political process than most folks but I'm an outlier. The issue here is not
whose theology is "accurate" or "correct" but rather hostility to a group based
on pernicious discrimination is at play. That issue permeates constitutional
law.
Best,
Eric
Sent from my iPhone
On Oct 12, 2016, at 12:02 PM, Volokh, Eugene
<vol...@law.ucla.edu<mailto:vol...@law.ucla.edu>> wrote:
How exactly would courts draw the line between what is really at
bottom of various religious practices? Say someone says, "Jews' objection to
Jews marrying non-Jews stems from their viewing themselves as God's Chosen
People, and other people as not God's Chosen People." Someone else responds,
as I've heard many religious Jews say, "No, it's not that being Chosen makes us
better -- it's just that God has a particular relationship with us that
involves specific obligations." How are courts to tell whose understanding of
the proper theological interpretation is right?
Conversely, someone says "Objection to same-sex marriage at
bottom is hostility to gays receiving equal treatment." Someone else says,
"No, we're not hostile to gays or to equal treatment generally; we just think
that marriage is a special sacrament created by God for men and women." How
are courts to tell whose understanding of the proper theological interpretation
is right?
Eugene
From:
religionlaw-boun...@lists.ucla.edu<mailto:religionlaw-boun...@lists.ucla.edu>
[mailto:religionlaw-boun...@lists.ucla.edu] On Behalf Of Eric J Segall
Sent: Wednesday, October 12, 2016 11:44 AM
To: Law & Religion issues for Law Academics
<religionlaw@lists.ucla.edu<mailto:religionlaw@lists.ucla.edu>>
Cc: David Bernstein <dbern...@gmu.edu<mailto:dbern...@gmu.edu>>; Mitchell
Berman <mitch...@law.upenn.edu<mailto:mitch...@law.upenn.edu>>;
conlawp...@lists.ucla.edu<mailto:conlawp...@lists.ucla.edu>
Subject: Re: Noteworthy, puzzling scholars' brief in Arlene Flowers
I am receptive to trying to draw lines between commercial activities that are
inherently expressive and those that are not (knowing there will be quite grey
areas). But I think there is a serious difference in the real world between a
seller of flowers whose objection to same-sex marriage at bottom is hostility
to gays receiving equal treatment and a person of faith with no objection to
Jews or Catholics but feel they shouldn't get married to each other. Thus,
again, I think we can draw a line b/w requests for religious exemptions based
on group hostility and claims not based on group hostility, even conceding
Mitch's typical smart and hard hypo is a hard case.
Best,
Eric
Sent from my iPhone
On Oct 12, 2016, at 11:29 AM, Ira Lupu
<icl...@law.gwu.edu<mailto:icl...@law.gwu.edu>> wrote:
Mitch Berman's good question asks in general terms about how much "solicitude"
Fred's claim deserves. But we cannot answer intelligently unless we know the
forum and the grounds advanced for Fred. Is he asking the state legislature to
exempt religious objectors from public accommodations law? Is he raising a
compelled speech claim? A religious freedom claim under a RFRA, or a state
constitution? I would give his claim no solicitude in any of these contexts,
for reasons I have spelled out at length on this listserv and in law reviews.
But I can imagine that others might well react differently depending on the
legal context.
On Tue, Oct 11, 2016 at 2:45 PM, Mitchell Berman
<mitch...@law.upenn.edu<mailto:mitch...@law.upenn.edu>> wrote:
For what it's worth, I'd like to add another generally liberal, pluralist voice
in support of Doug and David.
I don't have a strong view regarding precisely what the doctrine should be to
govern cases of this sort, largely because I believe that the adequacy of
available alternatives will be a critical factor, and I am open to the
possibility that, due to difficulties of case-by-case inquiry into such
questions, the law (statutory or judge-made) should adopt prophylactic rules.
That acknowledged, as a matter of political morality, I also believe that folks
on my side of the aisle are often insufficiently sensitive to interests of the
Shlomo Cohens and Barronelle Stutzmans of our nation.
Take this case: in a large city, an observant Jewish photographer or dj, Fred,
declines to work at an interfaith marriage between a Jew and a Gentile. Fred
is happy to take on any other work for Jews or Gentiles, or for both together.
But he objects to being complicit in a venture-interfaith marriage-that he
deems wrongful or religiously proscribed.
Marty, Eric: how much solicitude is Fred due? (And if you choose to answer, I
ask that you do so without analogizing to interracial marriage; that's not my
case.)
Mitch Berman
From:
conlawprof-boun...@lists.ucla.edu<mailto:conlawprof-boun...@lists.ucla.edu>
[mailto:conlawprof-boun...@lists.ucla.edu<mailto:conlawprof-boun...@lists.ucla.edu>]
On Behalf Of David Bernstein
Sent: Tuesday, October 11, 2016 10:00 AM
To: Marty Lederman <lederman.ma...@gmail.com<mailto:lederman.ma...@gmail.com>>;
conlawp...@lists.ucla.edu<mailto:conlawp...@lists.ucla.edu>; Law & Religion
issues for Law Academics
<religionlaw@lists.ucla.edu<mailto:religionlaw@lists.ucla.edu>>
Subject: Re: Noteworthy, puzzling scholars' brief in Arlene Flowers
Unlike Marty, I not only don't find the argument in question shocking, I thin
it's right. I blogged about this at Volokh a couple of years ago, drawing the
analogy to a caterer who serves Jewish customers, but refuses to cater brises.
Unusually, the comments section to the post is also mostly worthwhile.
http://volokh.com/2013/12/14/refusing-provide-commercial-services-circumcision-discrimination-jews/<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fvolokh.com%2F2013%2F12%2F14%2Frefusing-provide-commercial-services-circumcision-discrimination-jews%2F&data=01%7C01%7Cmitchberman%40law.upenn.edu%7C13d4c5bc6dad441c0d4008d3f1dee56b%7C6cf568beb84a4e319df6359907586b27%7C1&sdata=xFPIZvkJedJKDTBaANgKqcsIaseHFYpKhhyuaqMcRWs%3D&reserved=0>.
Another hypothetical that could arise is an Orthodox Jewish baker who serves
all customers.
Is Refusing to Provide Commercial Services for a Circumcision Discrimination
against Jews?
by David
Bernstein<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fvolokh.com%2Fauthor%2Fdavidb%2F&data=01%7C01%7Cmitchberman%40law.upenn.edu%7C13d4c5bc6dad441c0d4008d3f1dee56b%7C6cf568beb84a4e319df6359907586b27%7C1&sdata=w6tJ5wXLE3ShHI5NRzGMgOhooyu4HI3kR8XAiqlItQw%3D&reserved=0>
on December 14, 2013 12:46 pm in You Can't Say
That!<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fvolokh.com%2Fcategory%2Fyou-cant-say-that%2F&data=01%7C01%7Cmitchberman%40law.upenn.edu%7C13d4c5bc6dad441c0d4008d3f1dee56b%7C6cf568beb84a4e319df6359907586b27%7C1&sdata=3OoPtrJs2Z8ecuN1XrNHCfCL8sn7Y1qcrDDJbQyLNt0%3D&reserved=0>
Here's the hypothetical: Shlomo Cohen has been blessed with a son, but he lives
in San Francisco, where there is a vocal anti-circumcision movement. He emails
his neighbor, a photographer, and asks him if he would photograph his son's
bris. The photographer responds, "Shlomo, no offense, but I think circumcision
amounts to genital mutilation, and I can't participate in that." Next, he
approaches his local organic/vegeterian caterer about catering the bris. The
caterer says, "you know Shlomo, I've done brises in the past, but I've been
reading some of the literature put out by the anti-circumcision people, and I
think circumcisions cause unnecessary pain to baby boys. So I don't do brises
anymore."
Shlomo files a complaint with San Francisco's human rights commission, claiming
that the photographer and the caterer are engaging in discrimination against
him based on his Jewish ethnicity and religion. There is no evidence that
either person turns down or otherwise mistreats Jewish clients or potential
clients, and both deny they do so. Should Shlomo win his case?
To me, the answer is no, and pretty obviously so. Neither defending is
discriminating against Shlomo because he's Jewish, they are discriminating
against him (if that's what you want to call it) because they disagree with his
particular actions. Indeed, I'd say they are no discriminating against Shlomo
at all, they are discriminating against potential clients who want them to help
celebrate something that violates their strongly held personal beliefs.
So, am I right? And if so, is there any sensible legal distinction that can be
drawn between my hypothetical and the cases in the news in which a photographer
and a baker were held to have discriminated against gays because they declined
to provide commercial services on moral grounds for gay weddings, but
apparently otherwise did not discriminate against gay customers?
[https://s3.amazonaws.com/ucwebapp.wisestamp.com/b9480451-2cc1-4715-8948-9a1efd33ea48/12973517_10207099065447575_2951920118584587506_o.crop_1252x1322_117,0.preview.format_png.resize_200x.png]
David E. Bernstein
Foundation Professor
Antonin Scalia Law School, George Mason Unversity
Website<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Ffaculty.law.gmu.edu%2Fdbernste%2F&data=01%7C01%7Cmitchberman%40law.upenn.edu%7C13d4c5bc6dad441c0d4008d3f1dee56b%7C6cf568beb84a4e319df6359907586b27%7C1&sdata=OicjkmD5kZuz8ikuDtFL6C8n5%2FmBLaOCmaZVILKKyYs%3D&reserved=0>
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________________________________
From:
conlawprof-boun...@lists.ucla.edu<mailto:conlawprof-boun...@lists.ucla.edu>
<conlawprof-boun...@lists.ucla.edu<mailto:conlawprof-boun...@lists.ucla.edu>>
on behalf of Marty Lederman
<lederman.ma...@gmail.com<mailto:lederman.ma...@gmail.com>>
Sent: Monday, October 10, 2016 10:40:23 AM
To: conlawp...@lists.ucla.edu<mailto:conlawp...@lists.ucla.edu>; Law & Religion
issues for Law Academics
Subject: Noteworthy, puzzling scholars' brief in Arlene Flowers
Some of you may be familiar with the Washington v. Arlene's Flowers case, which
will be argued in the Washington Supreme Court next month. Barronelle Stutzman
and her husband are the owners of Arlene's Flowers, Inc., a closely held
for-profit corporation. Over the course of nine years, Stutzman regularly sold
floral arrangements to Robert Ingersoll, knowing that he was gay. When
Ingersoll asked Stutzman to sell him flower arrangements for his wedding to
Curt Freed, however, she refused to provide them, even if they were prepared by
others in her shop, because doing so, she claimed, would "constitute a
demonstration of [her] approval for the wedding," whereas in fact she has
religious objections to same-sex marriages. (She agreed to provide the raw
materials for the arrangements--the flowers and such--but not to have her shop
do the arranging.)
The Washington Attorney General sued Arlene's Flowers, seeking an injunction
against such discrimination in the future. (Ingersoll and Freed also sued,
seeking nominal damages for the costs they incurred when Stutzman refused to
serve them.) The principal basis for the suit is a claim of discrimination on
the basis of sexual orientation, prohibited by the Washington Law Against
Discrimination (WLAD), RCW 49.60.215, which provides that "It shall be an
unfair practice for any person or the person's agent or employee to commit an
act which directly or indirectly results in any distinction, restriction, or
discrimination, . . . or the refusing or withholding from any person the
admission, patronage, custom, presence, frequenting, dwelling, staying, or
lodging in any place of public resort, accommodation, assemblage, or
amusement." The forms of prohibited discrimination are listed in RCW
49.60.030: "The right to be free from discrimination because of race, creed,
color, national origin, sex, honorably discharged veteran or military status,
sexual orientation, or the presence of any sensory, mental, or physical
disability or the use of a trained dog guide or service animal by a person with
a disability is recognized as and declared to be a civil right. This right
shall include, but not be limited to: . . . (b) The right to the full enjoyment
of any of the accommodations, advantages, facilities, or privileges of any
place of public resort, accommodation, assemblage, or amusement."
Stutzman defended on both statutory and state and federal constitutional (Free
Speech and Free Exercise) grounds; but the lower court
ruled<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fagportal-s3bucket.s3.amazonaws.com%2Fuploadedfiles%2FHome%2FNews%2FPress_Releases%2F2015%2FArlene%2527s%2520Flowers%2520summary%2520judgment.pdf&data=01%7C01%7Cmitchberman%40law.upenn.edu%7C13d4c5bc6dad441c0d4008d3f1dee56b%7C6cf568beb84a4e319df6359907586b27%7C1&sdata=vwBpopgDbYDhszeFSGxEpKHOrHtkcpBuEsW0ij1hVjo%3D&reserved=0>
in favor of the Attorney General. The appeal from that decision is now before
the Washington Supreme Court, which will hear arguments in about five weeks.
A couple of weeks ago, a group of 27 scholars, some of whom are on these
listservs, filed an amicus
brief<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fmirrorofjustice.blogs.com%2Ffiles%2Fsmith-brief.pdf&data=01%7C01%7Cmitchberman%40law.upenn.edu%7C13d4c5bc6dad441c0d4008d3f1dee56b%7C6cf568beb84a4e319df6359907586b27%7C1&sdata=gyD86DBVKtOYjHwUJkYnkYr3It7tmNRHpm3jtxviZDk%3D&reserved=0>
on behalf of Arlene's Flowers. (According to Rick Garnett, it was written by
Steve Smith, although he is not listed as counsel.) That brief does not make a
constitutional argument at all. Instead, it argues (as I read it) that the
Court should construe the Washington antidiscrimination statute so as not to
include Stutzman's refusal as prohibited discriminatory conduct in the first
place.
The theory of the brief, such as it is, is that Stutzman must not have been
engaged in discrimination on the basis of sexual orientation, since she was
willing to make arrangements for Ingersoll--a man who she knew was gay--for
purposes other than his marriage. The lower court erred, according to the
brief, "[i]n erroneously treating the religious conviction Stutzman does have
as equivalent to a different and more troublesome objection that she does not
have." She doesn't discriminate against gays and lesbians -- "only" against
same-sex marriage.
I, for one, find this argument to be rather alarming, and, best I can tell,
indefensible.
As the Washington AG writes in his brief (responding to a similar argument that
Stutzman offered), "discrimination is discrimination, whether it is complete or
partial. An employer cannot say: 'I hire women, but because of my religious
belief that women should be subservient to men, I will not hire women to
supervise men.' Similarly, it is irrelevant whether Defendants generally serve
gay and lesbian customers; their refusal to serve the weddings of gay and
lesbian customers is still prohibited discrimination."
That's obviously right, isn't it? The cases demonstrating it are legion. Bob
Jones University, for example, surely discriminated on the basis of race by
prohibiting students from interracial dating, even though it admitted black
students. Would anyone have argued with a straight face that the university
did not discriminate on the basis of race, and that it was error to treat BJU's
rule "as equivalent to a different and more troublesome objection that it does
not have [i.e., to exclude black students altogether]"? And I'm hardly an
expert on Washington state law, but there's every indication that its statutes
also reflect this idea--see, e.g., the bolded passages quoted above, including
the reference to "full enjoyment."
To be sure, it would be even worse if Stutzman categorically refused to serve
gays and lesbians; her refusal "only" in the context of a same-sex marriage
thus is not as problematic and disturbing as such a categorical "Gays not
served here" policy would be. But, understandably, Washington law, like the
analogous laws of the federal government and virtually every state, has made it
unlawful to engage in both categorical and selective discriminatory refusals to
serve. There is no reason (none that the brief offers, anyway) to think that
the Washington legislature did not mean to proscribe discrimination in cases
where the commercial proprietor "hates the sin but loves the sinner."
The amicus brief's only response to this, far as I can tell, is to argue (pp.
8-9) that Arlene's Flowers is not discriminating on the basis of sexual
orientation because Stutzman would also refuse to sell flower arrangements for
a marriage between, e.g., two heterosexual men, and she would sell arrangements
to, e.g., a gay man and a lesbian who were marrying one another.
I hope I don't need to explain why this argument is, and ought to be, dead in
the water. I'll add only this: Paul Clement offhandedly offered the same
argument as to DOMA in his
brief<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fsblog.s3.amazonaws.com%2Fwp-content%2Fuploads%2F2013%2F01%2FBLAG-merits-brief-1-22-131.pdf&data=01%7C01%7Cmitchberman%40law.upenn.edu%7C13d4c5bc6dad441c0d4008d3f1dee56b%7C6cf568beb84a4e319df6359907586b27%7C1&sdata=4wU5X0shUmyDgLpajQPlt97JN2vv5lZtEWAXndkWlR4%3D&reserved=0>
for BLAG in Windsor ("A marriage between a man and a woman would fall within
DOMA's definition even if one or both spouses were homosexual. Similarly, the
marriage of two men would fall outside the definition even if both were
heterosexual."); but at least he had the good sense to bury it in a footnote
and otherwise not rely upon it. Not surprisingly, not a single Justice in
Windsor considered this virtually buried "argument" even worth discussing.
Likewise, Kentucky ran the argument in its
brief<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fsblog.s3.amazonaws.com%2Fwp-content%2Fuploads%2F2015%2F03%2F14-574_-bs.pdf&data=01%7C01%7Cmitchberman%40law.upenn.edu%7C13d4c5bc6dad441c0d4008d3f1dee56b%7C6cf568beb84a4e319df6359907586b27%7C1&sdata=JFDggAW%2BXlwLZz9vkHYVqsRbr0YABO8F15NVWASkYos%3D&reserved=0>
in the Obergefell set of cases (see p. 26) just a bit more aggressively than
Clement did--promoting it to a single textual paragraph. Again, no Justices
thought it worthy of discussion; the majority, however, implicitly rejected it
out of hand when it wrote:
This dynamic also applies to same-sex marriage. It is
now clear that the challenged laws burden the liberty of
same-sex couples, and it must be further acknowledged
that they abridge central precepts of equality. Here the
marriage laws enforced by the respondents are in essence
unequal: same-sex couples are denied all the benefits
afforded to opposite-sex couples and are barred from exercising
a fundamental right. Especially against a long
history of disapproval of their relationships, this denial to
same-sex couples of the right to marry works a grave and
continuing harm. The imposition of this disability on gays
and lesbians serves to disrespect and subordinate them.
And the Equal Protection Clause, like the Due Process
Clause, prohibits this unjustified infringement of the
fundamental right to marry.
The scholars' amicus brief in Arlene's Flowers does not even contend with these
fairly important precedents. Nor does it even discuss the statutory language
of the Washington law, or its purpose, history, or judicial construction. It's
hard to imagine the amici think their statutory construction argument will find
favor with any of the Justices of the Washington Supreme Court. Reading the
Washington law to cover this case is not "stretching" or "distension [sic]" of
the statute, as the brief argues: It's standard-issue fare.
So what explains the brief? Is there more to be said for it than what I've
described?
_______________________________________________
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--
Ira C. Lupu
F. Elwood & Eleanor Davis Professor of Law, Emeritus
George Washington University Law School
2000 H St., NW
Washington, DC 20052
301-928-9178 (mobile, preferred)
202-994-7053 (office)
Co-author (with Professor Robert Tuttle) of "Secular Government, Religious
People" ( Wm. B. Eerdmans Pub. Co., 2014))
My SSRN papers are here:
http://papers.ssrn.com/sol3/cf_dev/AbsByAuth.cfm?per_id=181272#reg<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fpapers.ssrn.com%2Fsol3%2Fcf_dev%2FAbsByAuth.cfm%3Fper_id%3D181272%23reg&data=01%7C01%7Cesegall%40gsu.edu%7C69a9039b6aab487dc5c808d3f2b49591%7C515ad73d8d5e4169895c9789dc742a70%7C0&sdata=Cc7Dp7ZdV0%2FZqsmHi7tCcEhuO4jdMjRWbdCHrS%2FFpus%3D&reserved=0>
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