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Concluded State Supreme Court

Elane Photography v. Willock

Laws That Demand Conformity in Belief and Action are About Less Tolerance, Not More


Elaine and Jonathan Huguenin of Albuquerque, New Mexico, declined to photograph a same-sex “commitment ceremony” because they could not in good conscience tell the story of a ceremony that defined marriage as something other than the union of one man and one woman. The requester filed a complaint against Elaine and Jonathan’s company, Elane Photography.

Unfortunately, the New Mexico Human Rights Commission, two state courts, and the New Mexico Supreme Court ruled against Elaine and Jonathan. In a concurring opinion, one of the justices said that violating their religious beliefs is “the price of citizenship” for the Huguenins. The U.S. Supreme Court declined to review the Huguenins’ case in 2014.

Thankfully, in 2023, the U.S. Supreme Court decided another ADF case, 303 Creative v. Elenis, which upheld the free speech rights of all Americans to express messages consistent with their beliefs.

Additional Resources

Case Profiles

Jordan Lorence
Jordan Lorence
Senior Counsel, Director of Strategic Engagement
Jordan Lorence serves as senior counsel and director of strategic engagement with Alliance Defending Freedom, where he plays a key role with the Strategic Relations and Training Team.
Jim Campbell
Jim Campbell
Chief Legal Counsel
Jim Campbell serves as chief legal counsel with Alliance Defending Freedom, where he leads the U.S. Legal Advocacy team.