## Facts

- Masterpiece Cakeshop, Ltd. was a bakery in Lakewood, Colorado, owned by Jack Phillips, a devout Christian who created custom cakes.
- In July 2012, Charlie Craig and David Mullins, a same-sex couple, requested a custom wedding cake.
- Colorado did not recognize same-sex marriage at the time of the request.
- Phillips refused to create a wedding cake for a same-sex wedding due to religious objections, but offered to sell other baked goods to the couple.
- The couple filed a charge under the Colorado Anti-Discrimination Act (CADA), which bars discrimination based on sexual orientation by places of public accommodation.
- After an investigation, the Colorado Civil Rights Division found probable cause and referred the matter to the Colorado Civil Rights Commission.
- An Administrative Law Judge found Phillips violated CADA and rejected his Free Exercise and Free Speech defenses; the Commission affirmed and ordered remedial measures, including compliance reporting and requiring equal wedding-cake service terms.
- During the Commission process, a commissioner made remarks characterizing religious justifications for discrimination as akin to defenses of slavery and the Holocaust; the comments were not disavowed by the Commission.
- In separate matters, Colorado declined to find CADA violations where other bakers refused to create cakes bearing messages opposing same-sex marriage.
- The Colorado Court of Appeals affirmed the Commission, concluding CADA was applied in a neutral, generally applicable manner consistent with the First Amendment.

## Issues

1. Whether the Commission’s application of CADA to Phillips violated the Free Exercise Clause because the state failed to act with religious neutrality.
2. Whether applying CADA to require Phillips to create a custom wedding cake compelled speech in violation of the Free Speech Clause.

## Decision

- The Supreme Court reversed the Colorado Court of Appeals in a 7–2 decision.
- The Court held the Commission’s handling of the case violated the State’s First Amendment obligation to proceed in a manner neutral toward religion.
- The Court relied on (1) statements by commissioners reflecting hostility to Phillips’s religious beliefs and (2) disparate treatment compared to the state’s resolution of other cake-refusal complaints.
- The Court resolved the case on Free Exercise grounds and did not issue a broad ruling on compelled speech or on general religious objections to same-sex wedding services.
- The Court described the holding as fact-specific and limited to the circumstances of this adjudication.

## Legal Principles

- Government enforcement of public-accommodations laws must be neutral toward religion; state decisionmakers may not show hostility to religious beliefs or viewpoints in adjudication.
- A Free Exercise violation may be found where official statements and the overall process indicate animus or lack of religious neutrality, undermining fair and impartial enforcement.
- Disparate treatment of analogous complaints can support a finding that the state failed to apply the law in a religion-neutral way.
- The decision did not establish a general exemption from public-accommodations laws for religious objectors and left broader compelled-speech questions unresolved on the majority’s reasoning.

## Conclusion

The Court set aside the Commission’s order because the adjudicatory process reflected hostility to Phillips’s religious beliefs and inconsistent treatment of comparable cases, making the enforcement of CADA incompatible with the Free Exercise Clause’s requirement of religious neutrality.


Masterpiece Cakeshop, Ltd. v. Colo. Civ. Rts. Comm'n, 584 U.S. 617 (2018)