Elane Photography, LLC v. Willock
New Mexico Supreme Court
309 P.3d 53 (2013)
- Written by Galina Abdel Aziz , JD
Facts
Elaine Huguenin owned a local business called Elane Photography, LLC (Elane) (defendant). Two women, Vanessa Willock and Misti Collinsworth, emailed Huguenin to inquire about services for their commitment ceremony. Huguenin responded that she would not photograph a same-sex ceremony because doing so would violate her religious beliefs. Willock and Collinsworth sued Elane, alleging that Elane had discriminated based on sexual orientation in violation of the New Mexico Human Rights Act (NMHRA). The NMHRA prohibited public accommodations from discriminating against individuals based on protected classifications including sex and sexual orientation in providing publicly available goods and services, subject to various exemptions. The trial court ruled for Willock and Collinsworth, and the appellate court affirmed. Elane appealed, arguing that application of the NMHRA to Elane would violate Elane’s rights under the Free Speech and Free Exercise Clauses of the First Amendment by compelling Elane, through Elane’s photography, to create and engage in positive messaging about same-sex unions that Huguenin did not share and by requiring Elane to accommodate the messages of same-sex clients. Elane also argued that the multiple exemptions from the NMHRA’s antidiscrimination provisions meant that the NMHRA could not be considered generally applicable and thus had to be justified by a compelling governmental interest and narrowly tailored to further that interest.
Rule of Law
Issue
Holding and Reasoning (Chavez, J.)
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