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Active U.S. Courts of Appeals

Chiles v. Salazar 

Counseling with teenager


Kaley Chiles works as a licensed professional counselor in Colorado who helps clients with various issues, including gender identity and sexual orientation. Chiles sees her work as an outgrowth of her Christian faith, and numerous clients come to her because she shares their own faith-based convictions and worldview. These clients believe that life will be more fulfilling if aligned with the teachings of their faith. Though Chiles never promises that she can solve these issues, she, like her Christian clients, believes that sexuality and gender identity issues can, with God’s help, be brought into alignment with the teachings of one’s faith.

But in 2019, Colorado enacted its Counseling Censorship Law. That law censors licensed counselors from having any conversation with clients under age 18 that “attempts or purports to change an individual’s sexual orientation or gender identity, including efforts to change behaviors or gender expressions or to eliminate or reduce sexual or romantic attractions or feelings toward individuals of the same sex.” Conversely, the law allows such conversations if they support a client in exploring a gender identity different than the client’s sex or if they accept a person’s same-sex orientation. Any counselor who crosses the line, even inadvertently, could face steep penalties—up to $5,000 for each violation, possible suspension from practice, and even revocation of the counselor’s license.

Colorado’s Law violates Chiles’s freedom of speech and her free exercise of religion, and it harms both counselors and clients. The government has no business censoring conversations between clients and counselors, nor should a counselor be used as a tool to impose the government’s biased views on her clients.

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John Bursch
John Bursch
Senior Counsel, Vice President of Appellate Advocacy
John Bursch is senior counsel and vice president of appellate advocacy with Alliance Defending Freedom.