Masterpiece Cakeshop v. Colorado Civil Rights Commission

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2018 U.S. Supreme Court case on free expression

2018 United States Supreme Court case

Masterpiece Cakeshop v. Colorado Civil Rights Commission, 584 U.S. 617 (2018), was a case in the Supreme Court of the United States that addressed whether owners of public accommodations can refuse certain services based on the First Amendment claims of free speech and free exercise of religion , and therefore be granted an exemption from laws ensuring non-discrimination in public accommodations—in particular, by refusing to provide creative services, such as making a custom wedding cake for the marriage of a gay couple , on the basis of the owner's religious beliefs.

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

In a 7–2 decision, the majority ruled that the Commission did not employ religious neutrality, citing the Commission's hostility towards Masterpiece owner Jack Phillips's religious objections. The Supreme Court found the Commission violated his rights to free exercise, and reversed the Commission's decision. The Court did not rule on the broader intersection of anti-discrimination laws, free exercise of religion, and freedom of speech, due to the complications of the Commission's lack of religious neutrality, which was later evaluated in _303 Creative LLC v. Elenis _ (2023).

Procedural history

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Facts of the case

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Masterpiece Cakeshop in Lakewood, Colorado

In 2012, same-sex couple Charlie Craig and David Mullins from Colorado made plans to be lawfully married in Massachusetts and return to Colorado to celebrate with their family and friends. At that time the state constitution prohibited same-sex marriage in Colorado , though by 2014 the state had allowed same-sex marriages, and the Supreme Court of the United States would affirm that gay couples have the fundamental right to marry in _Obergefell v. Hodges _ 576 U.S. 644 (2015).

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

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Colorado Civil Rights Commission

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While another bakery provided a cake to the couple, Craig and Mullins filed a complaint with the Colorado Civil Rights Commission under the state's public accommodations law, the Colorado Anti-Discrimination Act, which prohibits businesses open to the public from discriminating against their customers on the basis of race, religion, gender, or sexual orientation.

Colorado is one of twenty-one U.S. states that include sexual orientation as a protected class in their anti-discrimination laws . Craig and Mullins's complaint resulted in a lawsuit, Craig v. Masterpiece Cakeshop. The case was decided in favor of the plaintiffs; the cake shop was ordered not only to provide cakes to same-sex marriages, but to "change its company policies, provide 'comprehensive staff training' regarding public accommodations discrimination, and provide quarterly reports for the next two years regarding steps it has taken to come into compliance and whether it has turned away any prospective customers".

Colorado Court of Appeals

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Masterpiece appealed the decision to the state Court of Appeals with the aid of Alliance Defending Freedom , and refused to comply with the state's orders, instead opting to remove themselves from the wedding cake business; Phillips claimed that this decision cost him 40% of his business. Alongside the Colorado Civil Rights Commission, the American Civil Liberties Union represented Craig and Mullins during the appeals. The state's decision was upheld on the grounds that despite the nature of creating a custom cake, the act of making the cake was part of the expected conduct of Phillips's business, and not an expression of free speech nor free exercise of religion.

The court distinguished its decision in Craig from another case, brought to the Commission by William Jack, in which three bakeries refused to create a cake for William Jack with the message "Homosexuality is a detestable sin. Leviticus 18:22", : 21  citing that in the latter, the bakeries had made other cakes for Christian customers and declined that order based on the offensive message rather than the customers' creed, whereas Masterpiece Cakeshop's refusal to provide Craig and Mullins with a wedding cake "was because of its opposition to same sex marriage which...is tantamount to discrimination on the basis of sexual orientation". : 21 

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

Before the Supreme Court

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Petition for writ of certiorari

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

Whether applying Colorado's public accom

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