Monday, March 24, 2014

Public Accommodations and Economic Citizenship

By Mike Dorf

(Updated at 10:12 am Eastern Time and again at 1:54 pm Eastern Time)

Later this morning, I'll be recording a discussion of the Elane Photography case for a National Constitution Center (NCC) podcast to be posted soon. By the time you read this post, the Supreme Court will likely have made an announcement either granting or denying cert in the case, so the discussion should be timely. (Update 1: The SCOTUS took no action on the case today, so a cert decision will come later.)

The discussion will be moderated by NCC President (and GW Law Prof) Jeff Rosen, and will include both me and U Chicago Law Professor Richard Epstein. Once it's ready, I'll post a link to the audio in an update to this post and, depending on how the discussion goes, I may have a follow-up post. (Update 2: Audio now available here.)  Here I want to address an issue that I've been pondering in thinking about the discussion.

The format for the NCC program is a discussion, rather than a debate, but it's fair to say that Professor Epstein and I will have different views.  My view, which I expressed in an amicus brief before the New Mexico Supreme Court, in a Verdict column, and in a prior post, is that, in general, commercial enterprises are not entitled to free speech exceptions to anti-discrimination laws that target discrimination, even though that means that in order to offer their services in the marketplace, business owners and their employees will sometimes need to engage in actions that communicate messages that they do not believe.

I simply don't see a good way to exempt wedding photographers opposed to same-sex marriage from a public accommodations law without thereby also entitling bakers, florists, invitation printers, bartenders, clothiers, and virtually all other service providers from such a law. Elane Photography's own reply brief seems to make this point unwittingly, offering "print shop professionals"--read, owners of Kinko's franchises--as an example of the sort of people who will face censorship if the New Mexico Supreme Court decision is allowed to stand. In an era when everything from toast to pencil sharpening can be called "artisanal", there is no principled way to hold the line at photographers. Indeed, the application of ordinary right-not-to-speak and right-not-to-associate case law to commercial public accommodations could give even non-artisanal service and product providers an exemption from anti-discrimination law, as they could argue that the required act of association itself compels them to "express" the repugnant view that they do not find such association objectionable.

To my mind, there are at least three possible doctrinal routes to the result that I favor.  One would be to say that public accommodations laws, as applied to commercial enterprises, are narrowly tailored to advance a compelling interest in equality, and so that even assuming that such laws should be subject to the strict scrutiny that applies to full-on infringements on free speech, the infringement is justified. This was more or less what the Supreme Court said in the association context in Roberts v. United States Jaycees, when it upheld a sex discrimination ban as applied to a private association. Concurring in that case, Justice O'Connor offered a somewhat different view, arguing that the right of expressive (non)association is greatly diminished in the commercial context, and that approach could be extended to cases in which the objection is not to the message expressed by the compelled association itself but to the message expressed by the service or product provider's service or product. In one variant of this O'Connor approach, the fairly forgiving O'Brien test would apply.  In another, there would be no free speech scrutiny at all, as the infringement would be deemed completely incidental. Either way, the application of the public accommodations law would be upheld.

Professor Epstein believes and has written that laws forbidding employment discrimination are wrongheaded. His views about public accommodations are more complex. In the book to which I just linked, he says that the original 1964 Civil Rights Act was justified in including a provision forbidding race discrimination in public accommodations because, he says, Jim Crow was a system of racial segregation that was entrenched through law and coercive social practices. Federal law was thus necessary, he says, to disentrench it. But in the absence of the sort of systemic public/private/social pro-discrimination partnership that was Jim Crow, his view about public accommodations appears to be more or less the same as his view of anti-discrimination law more generally: Namely, that law is unnecessary to combat discrimination because market forces will address it; an employer who does not discriminate based on race, sex, etc., will be able to draw from a larger pool of talent than one who does, and thus will enjoy an advantage in the marketplace. Likewise, a business that does not discriminate against customers based on illicit grounds will have more customers.

Although I disagree with his conclusion, I think that Epstein's market analysis is partly correct. But even accepting his framework, there are two important limits to the upshot of his argument.

First, in small homogeneous communities, there may be sufficiently few minorities and the majority "taste" for discrimination may be sufficiently large that members of protected groups really cannot find any service providers. The Volokh/Cato/Carpenter amicus brief in Elane Photography notes that there are over 100 wedding photographers in the Abuquerque Yellow Pages and asserts that "most wedding photographers would likely be happy to take the money of anyone who comes to them." I'm willing to concede that this is probably true, but Albuquerque is a city of over half a million people. The rest of New Mexico's over 2 million citizens live in towns and cities that are substantially smaller.  The second largest city in New Mexico has less than a fifth of the population of Albuquerque. (NM population 2010 census data here.) The options for same-sex couples in the rest of New Mexico may be substantially more constrained.

Second, the point of public accommodations law is not just to ensure that everyone can find some service provider who doesn't turn him or her away based on forbidden grounds. After all, African Americans in the Jim Crow South could typically find some restaurants and motels that would take their money--but only at facilities that were segregated by race. Likewise, even in the heyday of the closet, LGBT Americans could go to specifically "gay bars" and the like. But that hardly excuses the racist or homophobic restaurateur or bar owner from operating a whites-only or straights-only business.

In short, one central feature of public accommodations law is to ensure that any citizen can get service at any business. Public accommodations laws serve to create and protect a form of economic citizenship, and not merely the kind of second-class economic citizenship that a regime of segregation affirms. For this reason, a legal regime in which exceptions to public accommodations laws are granted to expressive businesses would undermine such laws at their core, not their periphery.


Keith K said...

I agree with the goal and abhor the discrimination permitted under a scheme that eliminates the prohibitions for Elane Photography to deny services.

That said, there's a non-frivolous argument here on the other side as well.

Many wrote that Ted Olson was wrong in pushing the cases too quickly before the Courts which creates a backlash against gay rights, etc...

We saw how economic markets and realities forced Hobby Lobby in Marlboro, NJ to start carrying Jewish items they long prohibited in their stores without any lawsuit being filed or legislation ratified.

I'd much prefer a system where bigots are outed and one can choose to deny them business, thereby coercing a system (without government involvement) that is much more equitable and prevents that kind of backlash in terms of legislation to prevent it, etc...

Is that too naive or can it be a reality? The difference between now and Jim Crow is that the Jim Crow laws effectively made a store wishing to offer equal access illegal. Under that kind of a scheme, the people are limited in what progress they can have. That's a very different scenario than we are currently facing where people would be permitted, but not forced to discriminate.

Michael C. Dorf said...

I agree with Keith Kaplan that there is a non-frivolous argument for relying on social and private economic pressure, rather than the law, to achieve the goals of public accommodations law. But that's a policy question of whether to have public accommodations law, or perhaps a policy question of whether to have particular legislative exceptions thereto. The argument of the challengers is that the First Amendment writes this policy view into the Constitution.

Keith K said...

The decision in Elane is troubling to me on that score as well. It seems to indicate that otherwise protected first amendment acts lose their first amendment protections when sold on the open market.

"Elane Photography argues that because the service it provides is photography, and because photography is expressive, “some of [the] images will inevitably express the messages inherent in [the] event.” (decision at 34).

When talking about first amendment issues, it's important to identify what the speech is and how it's being infringed. The Judge admits as much: "It may be that Elane Photography expresses its clients’ messages in its photographs, but only because it is hired to do so."

So, even the Judge admits that it's expressive speech - but it still can be regulated because they chose to sell their work to the public? It does not strike me as correct that protected speech can lose first amendment protections because the speaker engages in commerce.

Am I missing something here?

Keith K said...

I took the quotes from the decision here:,687.pdf

David Ricardo said...

In his comment to a reply Mr. Dorf seems to have nailed the issue here. He is arguing that as a point of law the New Mexico decision is correct and consistent. His opposite side, Mr. Epstein seems to be arguing that as a matter of public policy the law is incorrect, or not needed.

These are obviously two different things. So one could easily take both sides, that as a matter of law the New Mexico decision is correct but as a matter of public policy the law is not good public policy. Ultimately the public attitudes towards minorities, women, the gay community and others who require legal protection against discrimination may make that legal protection redundant. But no one should argue that this is currently the situation.

As for the argument that wedding photography is somehow protected because it is a first amendment expression, that is just not credible. No one is arguing that if a person is taking and exhibiting photographs for artistic purposes that they must somehow take pictures of gay and lesbian couples.

The photography in this situation is commercial activity, plain and simple. It is not art, it is not speech, it is commerce and even if it has some artistic content that does not make it art or speech. And we have made the policy decision in this country that commerce must operate in a non-discriminatory manner, and as Mr. Dorf has so correctly documented, that policy is Constitutional and does not a violation of the First Amendment.

Keith K said...

Photographers are hired to tell the story of a wedding. They make thousands of dollars for doing so and are far more than simple automated cameras at pre-arranged locations.

Therefore, I disagree that it lacks protections under the first amendment.

But even if it did, it's not as if it's difficult to imagine a scenario (as CATO does in their Amicus on this case) in which there is a very sound first amendment claim. Maybe the commerce is a singer that makes songs about the couple's courtship to sing at a wedding.

What do you do in that scenario? What must be sacrificed? As the Court said in Wooley v. Maynard, you can't force a message into someone's mouth.

Anonymous said...

As a matter of policy I'm somewhere in between. I think that corporations--being wholly legal entities--have no rights whatsoever because rights endow only to natural born persons. So for me the entire case hinges on the fact that Elane is a business. She has sought the benefits of that form of ownership and one of the costs is that she gives up her rights. If she were doing the wedding as a sole proprietorship, she's win in my view.

One of the aspects of this case that commentators fail to appreciate is that New Mexico is one of those states that allows an individual to effectively incorporate themselves. One can form a corporation with one person holding all the offices. So for me the case hinges on whether her business was an "alter ego" of the person or not. Since it was not an alter ego under New Mexico law, she loses. If it were an alter ego under NM law, I'd argue she should win.

David Ricardo said...

With respect to Keith I agree, photographers are hired to tell a story, and I would also agree that there are aspects of art to the process. But the key thing here is his phrase, “hired to tell story”. This makes the activity commerce. Furthermore if one is going to adopt the position that any commercial activity that contains creativity or art or expression is totally protected under the first amendment, than all commercial activity is speech and protected. One can find expression in any commercial endeavor.

For example how I lay out and decorate my restaurant is partly creative art, and so my restaurant is an expression covered under the first amendment and exempt from anti-discrimination regulation. My business has a website, which is very artistic and creative and contains expression. Therefore my business is protected under the first amendment and exempt from anti-discrimination regulation. My garbage business has trucks which are artistically decorated and therefore I can discriminate and not pick up the garbage of same sex couples.

If commerce, that is offering goods and services in the marketplace to all comers, is the primary driving force of the activity then it is commerce, not art, not expression, not creativity. And this nation says NO, you cannot discriminate in marketplace. This position also renders the legal form of the business irrelevant. It doesn’t matter if you operate as a corporation or a sole proprietorship (which is an extension of the individual) or whatever.

The government has the right, but not the obligation to exempt a commercial activity from discrimination laws and other regulations. Of course this may change with the Hobby case in which case the nation starts down the path of theocracy. And really, that of course is what many, not Keith and not all, but what many really want. Substitute “Christian Law” for “Sharia Law” and you have no difference between much of the religious right and the radical Muslim community. And legal discussion and First Amendment questions aside, that is really the issue here. To pretend otherwise is folly.

Keith K said...

The argument of the challengers is that the First Amendment writes this policy view into the Constitution.

I agree with Prof. Dorf that this can be seen as an issue of policy vs. law. But I'm not sure that's all it can be.

We are talking about tension between a right and a legislative priority.

If one of those has to give, I'd hope it's the legislation and not the Constitution. All the more so, when it's not necessary (there are hundreds of photographers in Albuquerque and the record shows that the couple didn't have any issue finding another one.

But that doesn't make it absolute. In a Jim Crow like situation, I can see how legislation could meet such a threshold of necessity. If the facts were different, it could change the calculus.

David Ricardo:

Wow, that devolved rather quickly. On a side note, I think that one can protect a space for the exercise of religion without giving in to a Christian version of Sharia. There's a big difference between allowing religion and forcing others to practice it.

That being said...

One can find expression in any commercial endeavor.

When I posed this issue on my blog and said I'd find the case completely different had it been a wedding cake instead of a wedding album, Professor Adam Winkler made a similar claim to yours. He tweeted: "why isn't the cake expressive? Wedding cakes highly artistic. May not be copyright but lots of protected expression not copyright"

Let me ask you this way: Can the government go in and say that decorated garbage trucks are forbidden? Can they ban cakes from being baked? Other than violating my distaste for broad readings of the commerce clause, I don't see why not (insert Scalia's 'stupid, but Constitutional' rule here).

But can a government ban taking of photographs? I don't think that's possible. Taking photos is explicitly protected.

In other words, the difference is built into the act, it's historical record and its relationship with the alleged infraction.

Taking a photo IS what the photographer is being asked to do. Telling a gay wedding story IS what the photographer is being paid to create.

There is no such thing as gay garbage. There is no such thing as a gay menu.

Stuart McPhail said...

I'm not so certain you can cleanly distinguish cake baking and photography (or wedding singing).

The distinction seems to hinge how likely the activity is going to involve involuntary compelled speech, or merely the provision of speech one has already uttered. For example, I would have a first amendment right not to write an article advocating some particular view. But once I've written that article, I would not have a first amendment right to refuse to give/sell that article to someone.

So a baker likely has some set of predetermined cake designs. If the baker has no objection to baking that cake, but only objects to selling it to a gay couple, then there would be no first amendment claim.

A wedding photographer, however, does not have a preset selection of wedding photos you can choose from. But one could imagine a photographer selling prints - such a photographer would have no first amendment right to refuse to sell a print to a gay couple.

There may be bakers, however, who are more like wedding photographers - they come up with a cake design after meeting the couple and use the design to express something about the wedding. That would be a much stronger claim.

Nor does it seem relevant that the government could bar the underlying activity. Government can bar flag burning if there was a non-speech related reason to bar it (say its drought conditions in California and any open flame is banned). The salient fact would be whether Government is banning the cake-baking because it wanted to stop such baked-good expressions or some other reason (though talk about political suicide).

Of course, on the flip side, merely because an act has an expressive sub element does not mean that there's a first amendment right to engage in it and any related activity. My expression in restaurant decoration doesn't immunize activities beyond the decoration (nor would it immunize the decoration if it interfered with the enforcement of a non-speech targeting law.)

But this leaves me sympathetic to Prof. Dorf's argument - although it might not have the breadth Prof. Dorf imagines. An artisan barrista may creatively decorate the foam in a coffee, but unless that expression is contingent on the customer, then compelling service to that customer would not impact the creative element. The wedding photographer case is hard because the very subject of the creative element - the wedding photos - is contingent on the customer being served.

So to take Kinko's - it would have a hard time arguing that it cannot serve gay individuals if the nature of the print is materially indistinguishable from prints for straight individuals. (Though query whether wedding invitations to a gay wedding are materially indistinguishable from invitations to a straight wedding.)

Keith K said...

I was trying (and clearly failed) to make a comparison to Smith where the Court agreed that the legislature can ban peyote.

I agree and like your analogy about ore-made cakes and it meshes with the facts in this case.

Elane photography does studio pictures which are staged ahead of time and more like the "pre-made cake" analogy. As per the lower court record, they serve gay couples equally for studio photos as any other couple. It's only weddings where they drew the line.

David Ricardo said...

Notice the contortions that those who would support the right of wedding photographers and other so-called ‘artists’ to discriminate against various customer classes. (Studio photos are subject to the law, going to the wedding and taking pictures is not?)

And notice that no one has an ironclad rule about how to distinguish which businesses can discriminate because they are involved in ‘expression’ and thus protected by the Constitution and those that are not. The position of allowing some but not all businesses (or some activities of a business but not all activities) to be free of anti-discrimination laws is not workable. And compare that with the simple position that if you engage in commerce you are subject to the laws of commerce and the laws against discrimination.

Finally, as a last word, there is this. If you are opposed to same sex marriage (and no I don’t think those who support the rights of the photographers here on this Forum are), if you think same sex marriage is a horrible evil, if you think same sex marriage will result in eternal damnation, if you think that same sex marriage is the worst thing people can do then there is a simple solution. Don’t marry someone of the same sex.

Joe said...

I am supportive as a whole of Prof. Volokh's broad view of free speech which underlines for me the problems with the sort of line-drawing that is made to make this a special free speech sort of case.

The line drawing will ultimately be artificial and that is a core problem with today's Hobby Lobby case too. The arguments are broad. It isn't limited to one belief system or issue.

I do disagree with one comment made. If you oppose SSM, or eating animals for that matter, not doing the act itself is not all you should do. There is a range of things to do to avoid what you deem immoral.

All the same, when you have a for-profit secular business, particularly a corporation in a public accommodation, it is no longer truly "private" in various ways. This includes the allowance of certain equal access rules.

Scott said...

I think David's on to something with the "hired to tell a story" point. There seems to me to be a point of distinction between an *existing* expressive work that you sell, wherein the impetus for the work comes from the artist and the consumer is choosing to buy *that work* after the fact, and the artist-for-hire situation where the initial impetus for the creative work comes from the *client*, who then engages the artist to realize it. In the former case, the "public accommodation" is the sale of the *work*; in the latter, it's the sale of the *service*. In the case of a bakery, then, the First Amendment expressive rights of the bakers cannot be infringed by the government in terms of pre-made cakes sold in the bakery, or in "stock" designs offered as choices to clients. The minute that the bakers say "we take commissions," though, they've chosen to offer their creative *services* as a public accommodation, and must abide by the relevant statutes. Ditto photographers: you're free to choose your subjects for photos that you hope to sell *after the fact*, but if you're selling photography *as a service*, you're subject to public accommodations laws.

Stuart McPhail said...

Agree that the "hired to tell a story" point has some intuitive appeal. After all, a hired gun isn't really expressing themselves, but expressing the views of their boss (or client).

But does it prove too much? A journalist is paid to write about certain topics by a newspaper (for how much longer, who knows). Does that mean the journalist has no first amendment rights to refuse to write a story the government requests?

Further, its likely both the hired journalist and photographer are adding their own expressive elements in completing there tasks, so the speech doesn't entirely belong to the boss/client.

I raise these questions not because I think Elana should win - actually not sure about it.

Also - to revisit my post yesterday - have been thinking about the distinction of objecting to a certain form of expression and objecting to a iteration of a non-objectionable expression. It seems much easier to find a violation in the first instance.

If, for example, one objects to saluting the flag because one objects to the expression it conveys of support for the country, there is a pretty clear first amendment violation if the government compels you to salute. But, what if someone did not object to saluting the flag or expressing support, but refused to do so in this instance for reasons unrelated to the actual expression (the student really dislikes the teacher and wants to stick it to him) and would happily salute in other situations. Would it still violate the first amendment to compel the student to salute? After all, its still compelling speech, and perhaps we have a first amendment right to refuse to engage any *act* of speech, regardless of the nature of our objection (with a caveat that the government can compel speech about facts, e.g., tax returns and subpoenas). Or perhaps we only have a first amendment right to refuse to lend our support to a certain expression. Actually uncertain if the case law recognizes any such distinction or, if it did, how it would come out.

Scott said...

"Further, its likely both the hired journalist and photographer are adding their own expressive elements in completing there tasks, so the speech doesn't entirely belong to the boss/client."

Under the work-for-hire provisions of US copyright law, if the journalist is paid a regular salary by the newspaper, her work does in fact belong to the paper and not to her. It's less clear that this applies to a wedding photographer without a specific work-for-hire provision in the contract, but I think that by analogy to the newspaper-reporter relationship (the employer/client sets the task for the expressive employee/contractor), the presumption of First Amendment freedom from interference for the photographer is unwarranted. This also voids your hypothetical about the reporter refusing to write an article that the government requests: presuming that the government wants an article to appear in the newspaper, the First Amendment tension there is actually between the government and the newspaper, not the reporter. See Professor Dorf's post about bakers for a similar scenario.

Keith K said...

I'm not sure how it fits into the analysis, but it's my understanding that the wedding photographer keeps the right of copyright to the photos, while the newspaper owns the copyright on the work for hire if the employer.

Sam Rickless said...

I'm coming to this discussion pretty late, for which I apologize. I enjoyed the podcast (Jeff, if you're reading this, great job!), and wanted to add a few words about the underpinnings of economic citizenship, with the aim of deepening the point made both in the blog post and in the podcast.

Prof. Epstein thinks that economic activity is merely a matter of association, so that if I am free to associate with whom I please, it follows that I am free to sell to whom I please. But economic activity implicates government as a guarantor of economic rights in a way that non-economic association does not. If A sells X to B, delivers X to B, and then B refuses to pay (or gives A a bad check, or engages in some other form of fraud), then government is needed to interfere in order to protect A. Without coercive governmental threats against those who refuse to play by the rules of economic exchange, the entire economic system falls apart. The rules themselves are unjust unless they work to the benefit of all. It strikes me as morally wrong for a business to demand that government guarantee its economic rights without thereby allowing government to have a significant say in the rules that determine the contours of these rights, especially when this say is designed to broaden (rather than to restrict) access to products and services. Indeed, it strikes me as a form of pragmatic hypocrisy: "Hey, society, protect me against those who refuse to play by the economic rules you've laid down, but allow me exemptions from those rules when I really really want them."

The main point is that we as a society agree to create, maintain, and enforce a system of economic exchange (money for goods/services). In the absence of rules that define the system, there is no such thing as an economic right. Whereas a good case can be made that I have a right antecedent to government that you not kill me or maim me, the case for *economic* rights antecedent to government is exceedingly weak.

No one is forcing the owners of Hobby Lobby or Elane Photography to enter the marketplace. But once they make the decision to do so, then they are bound by the (just) rules that we as a society determine as governing marketplace interactions. Those rules are just when they promote equal economic citizenship. So the owners of Hobby Lobby and Elane Photography have no leg to stand on. The complaint that government is forcing them to associate with people with whom they do not wish to associate is laughable, given that, by virtue of incorporating, they have thereby agreed to abide by the rules that govern economic transactions, including applicable (and just) anti-discrimination laws.

Michael C. Dorf said...

Sam: I very much share your basic orientation towards these questions. Let me add a caveat and an observation. The caveat is that, as you say, govt may condition its protection of market transactions on various other "just" rules. Presumably, the argument of those seeking exemptions is that failure to include the particular exemptions they seek makes a rule unjust. That may or may not be true in any particular case, but I would acknowledge that in certain circumstances a rule with an "unless" clause could be just, whereas the same rule without the "unless" clause would be unjust.

The observation is that Prof. Epstein and other libertarians will appear to concede the legal realist point that market exchange depends on government, but they then tend to "naturalize" a minimal version of the common law. So Prof. Epstein will say that govt's role is to ensure that exchanges are not the product of force, fraud or monopoly, but that's it. I think this is wrong as a historical and practical matter. The "free" market requires many more legal rules, about all sorts of things--e.g., when is a contract enforceable, what are the remedies for breach, what counts as breach, etc.--so that it's just wrong to think that one can derive all of these rules from first principles. That was the very Langdellian view that legal realism overthrew. But once we recognize that the market is constructed from myriad policy choices, there is no good reason to say that such policy choices cannot include rules restricting discrimination.

Keith K said...

I appreciate Sam's comment, but I think it's lacking something important. To many advocating a "hands-off" approach to public accommodations law, there is clearly a hint (to put it mildly) of contempt for others they disagree with, be it gays, blacks or any other group. However, it seems as if Prof. Epstein (as well as Volokh in the CATO brief submitted in the Elane photography case) are not doing so at all.

What they are are saying is that there may be more than one way to lead towards an ideal situation of everyone being served by every business.

Much in the same way that Ted Olson was maligned by some pro-gay rights organizations for pushing to issue too far, too fast and creating a backlash that worked against equality happening faster -- there's an argument that public accomodation laws change behavior of people, but not their thoughts and beliefs. By merely forcing them, with the full force of government )as opposed to social pressure) to comply, you foment hostility.

Contrast that to a situation like that in Marlboro, NJ, where Hobby Lobby was forced by social pressure to carry Jewish iconography without any legislation or court interference, and you get a sense of the power of the market forces at play.

If it's possible that equality can be achieved faster through markets than public accommodation laws, wouldn't it be a better POLICY alternative to use?

That is not to say that it's illegal to use such laws under a compelling interest test... just that some may have something else in mind than hate to move this along.

Cicy said...

the presumption of First Amendment freedom from interference for the photographer is unwarranted. This also voids your hypothetical about the reporter refusing to write an article that the government requests: presuming that the government wants an article to appear in the newspaper, the First Amendment tension there is actually between the government and the newspaper, not the reporter. See Professor Dorf's post about bakers for a similar scenario.

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