State Religious Freedom Restoration Acts

{{Short description|1993 state laws in the United States}}

{{Use mdy dates|date=May 2025}}

[[File:Map of US states that have State Religious Freedom Restoration Acts - with Bills pending.svg|thumb|300px|{{legend|#00aad4|20 states had existing RFRA laws prior to their 2015 legislative session.{{cite web|url=http://www.ncsl.org/research/civil-and-criminal-justice/state-rfra-statutes.aspx|title=State Religious Freedom Restoration Acts|date=March 30, 2015|publisher=National Conference of State Legislatures}}}}

{{legend|#c8ab37|16 states had RFRA legislation proposed during the 2015 legislative season. Only two, Indiana and Arkansas, passed.{{cite web|url=http://www.ncsl.org/research/civil-and-criminal-justice/2015-state-rfra-legislation.aspx|title=2015 State Religious Freedom Restoration Legislation|date=March 30, 2015|publisher=National Conference of State Legislatures}}}}]]

State Religious Freedom Restoration Acts are state laws based on the Religious Freedom Restoration Act (RFRA), a federal law that was passed almost unanimously{{cite web|url=http://www.volokh.com/2013/12/02/1a-religious-freedom-restoration-act/|title=1A. What Is the Religious Freedom Restoration Act?|work=The Volokh Conspiracy|date=December 2, 2013}}{{cite web| url = http://www.weeklystandard.com/blogs/indianas-religious-freedom-restoration-act-explained_900641.html| url-status = dead| archive-url = https://web.archive.org/web/20150328133644/http://www.weeklystandard.com/blogs/indianas-religious-freedom-restoration-act-explained_900641.html| archive-date = March 28, 2015| title = Indiana's Religious Freedom Restoration Act, Explained}} by the U.S. Congress in 1993 and signed into law by President Bill Clinton.{{cite web |url=http://religiousfreedom.lib.virginia.edu/sacred/RFRA1993.html |title=Full Text of the Religious Freedom Restoraction Act |website=religiousfreedom.lib.virginia.edu |access-date=January 12, 2022 |archive-url=https://web.archive.org/web/20010525124428/http://religiousfreedom.lib.virginia.edu/sacred/RFRA1993.html |archive-date=May 25, 2001 |url-status=dead}}{{cite web|url=http://www.volokh.com/2013/12/02/1a-religious-freedom-restoration-act/|title=1A. What Is the Religious Freedom Restoration Act?|work=The Volokh Conspiracy|date=December 2, 2013|accessdate=October 10, 2014}} The laws mandate that religious liberty of individuals can only be limited by the "least restrictive means of furthering a compelling government interest".{{cite web|url=https://money.cnn.com/2015/03/27/news/companies/businesses-fight-indiana-gay-discrimination/|title=Apple's Tim Cook 'deeply disappointed' in Indiana's anti-gay law|work=CNN Money|date=March 27, 2015}} The federal law was originally intended to apply to federal, state, and local governments. In 1997, the U.S. Supreme Court in City of Boerne v. Flores held that the Religious Freedom Restoration Act only applies to the federal government but not states or municipalities. As a result, 21 states have passed their own RFRAs that apply to their state and local governments.

Pre ''Hobby Lobby''

The Religious Freedom Restoration Act of 1993, Pub. L. No. 103-141, 107 Stat. 1488 (November 16, 1993), codified at {{USC|42|2000bb}} through {{USC|42|2000bb-4}} (also known as RFRA), is a 1993 United States federal law that "ensures that interests in religious freedom are protected."{{cite web |title=Burwell v. Hobby Lobby Stores, Inc. (slip opinion), Concurring opinion by judge Anthony Kennedy at page 1 of that concurring opinion respectively page 56 of 95 of the slip opinion in general |url=https://www.supremecourt.gov/opinions/13pdf/13-354_olp1.pdf |publisher=United States Supreme Court |accessdate=June 25, 2020 |date=June 30, 2014}} The bill was introduced by Congressman Chuck Schumer (D-NY) on March 11, 1993. A companion bill was introduced in the Senate by Ted Kennedy (D-MA) the same day. A unanimous U.S. House and a nearly unanimous U.S. Senate—three senators voted against passage—passed the bill, and President Bill Clinton signed it into law.

The federal RFRA was held unconstitutional as applied to the states in the City of Boerne v. Flores decision in 1997, which ruled that the RFRA is not a proper exercise of Congress's enforcement power. However, it continues to be applied to the federal government—for instance, in Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal—because Congress has broad authority to carve out exemptions from federal laws and regulations that it itself has authorized. In response to City of Boerne v. Flores and other related RFRA issues, twenty-one individual states have passed State Religious Freedom Restoration Acts that apply to state governments and local municipalities.{{cite web|url=http://www.ncsl.org/research/civil-and-criminal-justice/state-rfra-statutes.aspx|title=State Religious Freedom Acts|work=National Conference of State Legislatures|archive-url=https://web.archive.org/web/20201206155803/https://www.ncsl.org/research/civil-and-criminal-justice/state-rfra-statutes.aspx|archive-date=December 6, 2020|date=May 5, 2017}}

State RFRA laws require the Sherbert Test, which was set forth by Sherbert v. Verner, and Wisconsin v. Yoder, mandating that strict scrutiny be used when determining whether the Free Exercise Clause of the First Amendment to the United States Constitution, guaranteeing religious freedom, has been violated. In the federal Religious Freedom Restoration Act, which usually serves as a model for state RFRAs, Congress states in its findings that a religiously neutral law can burden a religion just as much as one that was intended to interfere with religion;Religious Freedom Restoration Act full text at http://www.prop1.org/rainbow/rfra.htm therefore the act states that the "Government shall not substantially burden a person's exercise of religion even if the burden results from a rule of general applicability."{{cite book |last1=Utter |first1=Jack |year=2001 |title=American Indians: Answers to Today's Questions |page=159 |publisher=University of Oklahoma Press |isbn=0-8061-3309-0}}

The federal RFRA provided an exception if two conditions are both met. First, the burden must be necessary for the "furtherance of a compelling government interest". Under strict scrutiny, a government interest is compelling when it is more than routine and does more than simply improve government efficiency. A compelling interest relates directly with core constitutional issues.{{cite book |last1=Ross |first1=Susan |year=2004 |title=Deciding communication law: key cases in context |location=New Jersey |publisher=Lawrence Erlbaum Associates |isbn=0-8058-4698-0}}{{page needed|date=November 2013}} The second condition is that the rule must be the least restrictive way in which to further the government interest.

Post ''Hobby Lobby''

In 2014, the United States Supreme Court handed down a landmark decision in Burwell v. Hobby Lobby Stores, Inc. recognizing a for-profit corporation's claim of religious belief.{{cite web|quote=social conservatives have been re-energized in their push for "religious freedom" laws after the Supreme Court's decision in a health care-related case that allowed Hobby Lobby and other businesses to opt not to provide insurance coverage for contraception.|url=http://www.cnn.com/2015/03/25/politics/mike-pence-religious-freedom-bill-gay-rights/|title=NCAA 'concerned' over Indiana law that allows biz to reject gays|work=CNN|date=March 26, 2015}} Nineteen members of Congress who signed the original RFRA stated in a submission to the Supreme Court that they "could not have anticipated, and did not intend, such a broad and unprecedented expansion of RFRA".{{cite web |author1=Katherine Franke, Kara Loewentheil, Jennifer Drobac, Rob Katz, Fran Quigley, Florence Wagman Roisman, Lea Shaver, Deborah Widiss , Susan H. Williams, Carwina Weng, Jeannine Bell, Aviva Orenstein, Shawn Marie Boyne, Jeffrey O. Cooper, Ira C. Lupu, Nelson Tebbe, Robert W. Tuttle, Ariela Gross, Naomi Mezey, Caroline Mala Corbin, Richard C. Schragger, Micah J. Schwartzman, Steven K. Green, Nomi Stolzenberg, Sarah Barringer Gordon, Frederick Mark Gedicks, Claudia E. Haupt, Marci A. Hamilton, Laura S. Underkuffl and Carlos A. Ball |date=February 27, 2015 |title=Letter to Representative Ed DeLaney (Indiana House of Representatives) |url=http://web.law.columbia.edu/sites/default/files/microsites/gender-sexuality/law_professors_letter_on_indiana_rfra.pdf |publisher=Columbia University in the City of New York |quote="Nineteen members of Congress who voted for the passage of the law in 1993 have now withdrawn their support for the federal RFRA given that it has been interpreted by the courts in ways that were not intended by the Congress at the time of the law's passage. See Brief For United States Senators Murray, Baucus, Boxer, Brown, Cantwell, Cardin, Durbin, Feinstein, Harkin, Johnson, Leahy, Levin, Markey, Menendez, Mikulski, Reid, Sanders, Schumer, And Wyden As Amici Curiae In Support Of Hobby Lobby Petitioners And Conestoga Respondents, Burwell v. Hobby Lobby Inc., 134. U.S. 2751 (2014) ('[We] could not have anticipated, and did not intend, such a broad and unprecedented expansion of RFRA.')." |accessdate=July 11, 2015}} The United States government stated a similar position in a brief for the case submitted before the U.S. Supreme Court handed down its decision in Burwell v. Hobby Lobby, writing that "Congress could not have anticipated, and did not intend, such a broad and unprecedented expansion of RFRA. ... The test Congress reinstated through RFRA ... extended free-exercise rights only to individuals and to religious, non-profit organizations. No Supreme Court precedent had extended free-exercise rights to secular, for-profit corporations."{{cite news|last1=Mott|first1=Ronni|title=Hobby Lobby Wages War on Birth Control|publisher=The Jackson Free Press}}{{Full citation needed|date=January 2021}}

Following the Burwell v. Hobby Lobby decision, many states have proposed expanding state RFRA laws to include for-profit corporations,{{cite news|url=http://www.thedailybeast.com/articles/2014/11/16/rfra-madness-what-s-next-for-anti-democratic-religious-exemptions.html|title=RFRA Madness: What's Next for Anti-Democratic 'Religious Exemptions'|newspaper=The Daily Beast|date=November 16, 2014|last1=Michaelson|first1=Jay}}{{cite news|url=https://www.washingtonpost.com/news/morning-mix/wp/2015/03/27/indianas-religious-freedom-bill-and-the-ghost-of-hobby-lobby/|title=How Hobby Lobby paved the way for Indiana's 'religious freedom' bill|newspaper=Washington Post|date=March 27, 2015|author=How Hobby Lobby paved the way for Indiana's 'religious freedom' bill}} including in Arizona where SB 1062 passed by in Arizona but vetoed by Jan Brewer in 2014.{{cite web|url=https://edition.cnn.com/2014/02/26/politics/arizona-brewer-bill/|title=Arizona Gov. Jan Brewer vetoes controversial bill, SB 1062|publisher=CNN|date=February 27, 2015|author=Catherine E. Shoichet}}{{cite web|url=http://america.aljazeera.com/articles/2014/2/26/brewer-gay-law.html|title=Arizona gov. vetoes controversial 'religious freedom' bill|date=February 26, 2015|publisher=Aljazeera}} Indiana SB 101 defines a "person" as "a partnership, a limited liability company, a corporation, a company, a firm, a society, a joint-stock company, an unincorporated association" or another entity driven by religious belief that can sue and be sued, "regardless of whether the entity is organized and operated for profit or nonprofit purposes".{{cite web|url=http://www.politifact.com/truth-o-meter/statements/2015/mar/29/mike-pence/did-barack-obama-vote-religious-freedom-restoratio/|title=Did Barack Obama vote for Religious Freedom Restoration Act with 'very same' wording as Indiana's?|work=Politifact|date=March 29, 2015}} Indiana Democrats proposed an amendment that would not permit businesses to discriminate and the amendment was voted down.{{cite web|url=https://www.theatlantic.com/politics/archive/2015/03/what-makes-indianas-religious-freedom-law-different/388997/|title=What Makes Indiana's Religious-Freedom Law Different?|work=The Atlantic|date=March 30, 2015}}

An RFRA bill in Georgia has stalled, with constituents expressing concern to Georgia lawmakers about the financial impacts of such a bill.{{cite web|url=http://politics.blog.ajc.com/2015/03/26/religious-liberty-bill-takes-a-sharp-rightward-turn-convention-industry-says-15-million-in-business-could-be-lost/|title='Religious liberty' bill takes a sharp rightward turn, convention industry says $15 million in business at risk|work=The Atlanta Journal-Constitution (blog)|date=March 26, 2015}}{{cite web|title=Georgia House Committee Tables 'Religious Liberty' Bill|url=http://wabe.org/post/georgia-house-committee-tables-religious-liberty-bill|date=March 26, 2015|publisher=90.1 FM WABE}}{{cite web|url=http://www.rawstory.com/rs/2015/03/lgbt-rights-amendment-proves-to-be-poison-pill-for-georgias-religious-freedom-bill/|title=LGBT rights amendment proves to be 'poison pill' for Georgia's 'religious freedom' bill|work=Raw Story|date=March 27, 2015}} Stacey Evans proposed an amendment to change references of "persons" to "individuals", which would have eliminated closely held for-profit corporations from the proposed law, but the amendment was rejected because it would not give protections to closely held corporations to practice religious freedoms granted by the Supreme Court in the Hobby Lobby case.

Some commentators believe that the existence of a state-level RFRA bill in Washington could have affected the outcome of the Arlene's Flowers lawsuit.{{cite web|url=http://www.cnn.com/2015/02/20/living/stutzman-florist-gay/|title=The Christian conscience of Barronelle Stutzman|first=Denny|last=Burk|date=February 20, 2015|work=CNN}}{{cite web|url=http://www.christianpost.com/news/analysis-indiana-religious-freedom-law-is-not-anti-gay-136496/|title=Analysis Indiana Religious Freedom Law is not Anti-Gay|work=Christian Post|date=March 27, 2015}}

Politifact reports that "Conservatives in Indiana and elsewhere see the Religious Freedom Restoration Act as a vehicle for fighting back against the legalization of same-sex marriage."{{cite web|author1=Lauren Carroll, Katie Sanders, Aaron Sharockman|title=Fact-checking the March 29 news shows|url=http://www.politifact.com/punditfact/article/2015/mar/29/fact-checking-march-29-news-shows/|website=Politifact|accessdate=July 11, 2015|date=March 29, 2015}} Despite being of intense interest to religious groups, state RFRAs have never been successfully used to defend discrimination against gay people—and have rarely been used at all.{{cite news|author1=Rachel Zoll and David Crary|title=Religious freedom laws not used against gays in the past|url=http://bigstory.ap.org/article/ee8b2d9fc11c462eaa204dbee5e7253d/religious-freedom-laws-not-used-against-gays-past|accessdate=July 11, 2015|agency=The Associated Press|date=March 31, 2015}} The New York Times noted in March 2015 that state RFRAs became so controversial is due to their timing, context and substance following the Hobby Lobby decision.

Several law professors from Indiana stated that State Religious Freedom Restoration Acts like "Indiana SB 101" are in conflict with the U.S. Supreme Court's Free Exercise Clause jurisprudence under that "neither the government nor the law may accommodate religious belief by lifting burdens on religious actors if doing so shifts those burdens to third parties. [...] The Supreme Court has consistently held that the government may not accommodate religious belief by lifting burdens on religious actors if that means shifting meaningful burdens to third parties. This principle protects against the possibility that the government could impose the beliefs of some citizens on other citizens, thereby taking sides in religious disputes among private parties. Avoiding that kind of official bias on questions as charged as religious ones is a core norm of the First Amendment."{{cite web|author1=Katherine Franke, Kara Loewentheil, Jennifer Drobac, Rob Katz, Fran Quigley, Florence Wagman Roisman, Lea Shaver, Deborah Widiss , Susan H. Williams, Carwina Weng, Jeannine Bell, Aviva Orenstein, Shawn Marie Boyne, Jeffrey O. Cooper, Ira C. Lupu, Nelson Tebbe, Robert W. Tuttle, Ariela Gross, Naomi Mezey, Caroline Mala Corbin, Richard C. Schragger, Micah J. Schwartzman, Steven K. Green, Nomi Stolzenberg, Sarah Barringer Gordon, Frederick Mark Gedicks, Claudia E. Haupt, Marci A. Hamilton, Laura S. Underkuffl and Carlos A. Ball|title=Letter to Representative Ed DeLaney (Indiana House of Representatives)|url=http://web.law.columbia.edu/sites/default/files/microsites/gender-sexuality/law_professors_letter_on_indiana_rfra.pdf|publisher=Columbia University in the City of New York|accessdate=July 11, 2015|date=February 27, 2015|archive-url=https://web.archive.org/web/20200515115630/https://web.law.columbia.edu/sites/default/files/microsites/gender-sexuality/law_professors_letter_on_indiana_rfra.pdf|archive-date=May 15, 2020}} The Supreme Court for example stated in Estate of Thornton v. Caldor, Inc. (1985): "The First Amendment ... gives no one the right to insist that, in pursuit of their own interests others must conform their conduct to his own religious necessities.'" Relying on that statement they point that the U.S. Constitution allows special exemptions for religious actors, but only when they don't work to impose costs on others. Insisting on "the constitutional importance of avoiding burdenshifting to third parties when considering accommodations for religion" they point out the case of United States v. Lee (1982). Here the court stated:

{{blockquote|Congress and the courts have been sensitive to the needs flowing from the Free Exercise Clause, but every person cannot be shielded from all the burdens incident to exercising every aspect of the right to practice religious beliefs. When followers of a particular sect enter into commercial activity as a matter of choice, the limits they accept on their own conduct as a matter of conscience and faith are not to be superimposed on the statutory schemes which are binding on others in that activity. Granting an exemption from social security taxes to an employer operates to impose the employer's religious faith on the employees.United States v. Lee (1982)|United States v. Lee, {{ussc|455|252|1982}}}}

Effects of RFRAs on state court cases

Mandates courts use the following when considering religious liberty cases:

  1. Strict scrutiny
  2. Religious liberty can only be limited for a compelling government interest
  3. If religious liberty is to be limited, it must be done in the least restrictive manner possible

States with RFRAs

=By legislature=

Legislatures of 29 states have enacted versions of the Religious Freedom Restoration Act:

{{Div col|colwidth=20em}}

  • Alabama (state constitution amendment){{cite web|title=State Religious Freedom Restoration Acts|url=http://www.churchstatelaw.com/statestatutes/religiousfreedom.asp|website=www.churchstatelaw.com|publisher=Lewis Roca Rothgerber Religious Institutions Group|accessdate=July 11, 2015}}
  • Arizona
  • Arkansas{{cite news|title=Context for the Debate on 'Religious Freedom' Measures in Indiana and Arkansas|url=https://www.nytimes.com/2015/04/01/us/politics/context-for-the-debate-on-religious-freedom-measures-in-indiana-and-arkansas.html|accessdate=July 11, 2015|work=The New York Times|date=March 31, 2015}}{{cite news|author1=Campbell Robertson and Richard Péres-Pena|title=Bills on 'Religious Freedom' Upset Capitols in Arkansas and Indiana|work=The New York Times |url=https://www.nytimes.com/2015/04/01/us/religious-freedom-restoration-act-arkansas-indiana.html?_r=0|accessdate=July 11, 2015|date=March 31, 2015}}
  • Connecticut{{cite web |url=http://www.ncsl.org/research/civil-and-criminal-justice/state-rfra-statutes.aspx |title=State Religious Freedom Restoration Acts |publisher=National Conference of State Legislatures |access-date=June 11, 2015|date=July 6, 2015}}
  • Florida
  • Georgia{{Cite web |last=Homan |first=Maya |date=April 4, 2025 |title=Religious Freedom Bill Is Now Law In Georgia |url=https://thegeorgiasun.com/government/religious-freedom-bill-is-now-law-in-georgia/ |access-date=May 1, 2025 |language=en-US}}
  • Idaho
  • Illinois
  • Indiana{{cite news|last1=Cook|first1=Tony|title=Gov. Mike Pence signs 'religious freedom' bill in private|url=http://www.indystar.com/story/news/politics/2015/03/25/gov-mike-pence-sign-religious-freedom-bill-thursday/70448858/|accessdate=July 23, 2015|publisher=The Indy Star|date=April 2, 2015}}{{cite web|title=Gov. Mike Pence signs 'religious freedom' bill in private|url=http://www.indystar.com/story/news/politics/2015/03/25/gov-mike-pence-sign-religious-freedom-bill-thursday/70448858/|website=indystar.com|publisher=Indy Star|accessdate=March 26, 2015}}{{cite news|title=Here it is: The text of Indiana's 'religious freedom' law|url=http://www.indystar.com/story/news/politics/2015/03/27/text-indianas-religious-freedom-law/70539772/|accessdate=July 23, 2015|publisher=The Indy Star|date=April 2, 2015}}{{cite news|author1=Tony Cook, Tom LoBianco and Brian Eason|title=Gov. Mike Pence signs RFRA fix|url=http://www.indystar.com/story/news/politics/2015/04/01/indiana-rfra-deal-sets-limited-protections-for-lgbt/70766920/|accessdate=July 23, 2015|publisher=The Indy Star|date=April 2, 2015}}{{cite news|title=Read the text of proposed RFRA changes|url=http://www.indystar.com/story/news/politics/2015/04/02/read-text-proposed-rfra-changes/70823550/|accessdate=July 23, 2015|publisher=The Indy Star|date=April 2, 2015}}{{cite web|title=Conference Committee Report Digest for ESB 50; Citations Affected. IC 34-13-9|url=https://www.documentcloud.org/documents/1699997-read-the-updated-indiana-religious-freedom.html|website=documentcloud.org|accessdate=July 23, 2015}}
  • Iowa {{cite web | url=https://www.thegazette.com/staff-columnists/is-iowas-new-religious-freedom-restoration-act-a-license-to-discriminate/ | title=Opinion: Is Iowa's new Religious Freedom Restoration Act a license to discriminate? }}
  • Kansas
  • Kentucky{{cite web|title=HB279 13RS|url=http://www.lrc.ky.gov/record/13RS/HB279.htm|website=www.lrc.ky.gov|publisher=Kentucky Legislative Research Commission|accessdate=July 13, 2014}}
  • Louisiana
  • Mississippi{{cite news|last1=Rogers|first1=Alex|title=Mississippi Governor Signs Controversial Religious Freedom Bill|url=https://time.com/49682/mississippi-phil-bryant-religious-freedom/|access-date=July 23, 2015|publisher=Time Magazine|date=April 4, 2015}}{{cite web|title=The Mississippi Religious Freedom Restoration Act (Senate Bill No. 2681)|url=http://billstatus.ls.state.ms.us/documents/2014/pdf/SB/2600-2699/SB2681PS.pdf|website=billstatus.ls.state.ms.us|accessdate=July 23, 2015}}
  • Missouri
  • Montana
  • Nebraska{{cite web | url=https://legiscan.com/NE/text/LB43/2023 | title=Nebraska LB43 | 2023-2024 | 108th Legislature }}
  • New Mexico
  • North Dakota
  • Oklahoma
  • Pennsylvania
  • Rhode Island
  • South Carolina
  • South Dakota {{cite web|title=An Act to provide protections for the exercise of religious freedom.|url=https://sdlegislature.gov/Session/Bill/22127|publisher=South Dakota Legislature|date=March 10, 2021 |accessdate=May 31, 2021}}
  • Tennessee
  • Texas
  • Utah{{cite web | url=https://utahnewsdispatch.com/2024/01/29/utah-religious-freedom-bill-rfra-lgbtq/ | title=Utah 'religious freedom' bill advances to Senate • Utah News Dispatch | date=January 30, 2024 }}
  • Virginia
  • West Virginia {{cite web | url=https://apnews.com/article/lgbtq-discrimination-religious-freedom-west-virginia-1301d525c95eb4b826dd38c05f62b65b | title=West Virginia GOP governor signs 'religious freedom' bill | website=Associated Press News | date=March 9, 2023 }}
  • Wyoming

{{div col end}}

=By state court decision=

An additional 9 states have RFRA-like provisions that were provided by state court decisions rather than via legislation:{{cite news|last1=Eilperin|first1=Juliet|title=31 states have heightened religious freedom protections|url=https://www.washingtonpost.com/blogs/the-fix/wp/2014/03/01/where-in-the-u-s-are-there-heightened-protections-for-religious-freedom/|accessdate=July 23, 2015|newspaper=The Washington Post|date=March 1, 2014}}{{cite web|author1=Eugene Volokh|title=1A. What Is the Religious Freedom Restoration Act?|website=The Volokh Conspiracy|url=http://volokh.com/2013/12/02/1a-religious-freedom-restoration-act/|accessdate=July 23, 2015|date=December 2, 2013}}

{{Div col|colwidth=20em}}

  • Alaska
  • Hawaii
  • Ohio
  • Maine
  • Massachusetts
  • Michigan
  • Minnesota
  • Washington
  • Wisconsin

{{div col end}}

=Reversals=

Some states have had legislation withdrawn or vetoed. Arizona's bill SB 1062 was vetoed by Governor Jan Brewer. Bills 1161 and 1171 have been vetoed by a Colorado committee.{{cite news|last1=Moreno|first1=Ivan|date=March 9, 2015|title=Lawmakers wrestle with religious rights and nondiscrimination laws|url=http://www.washingtontimes.com/news/2015/mar/9/religious-freedom-gay-rights-debated-at-colorado-c/?page=all|accessdate=July 23, 2015|agency=The Associated Press|publisher=The Washington Times}}{{cite news|last1=Schrader|first1=Megan|title=Klingenschmitt bill to amend Colorado anti-discrimination bill shot down|url=http://gazette.com/klingenschmitt-bill-to-amend-colorado-anti-discrimination-bill-shot-down/article/1547623|accessdate=July 23, 2015|publisher=The Gazette|date=March 10, 2015}}{{cite web|author1=Hope Errico Wisneski|title=Colorado Victory: Discriminatory Legislation Does Not Progress in Legislature|url=http://www.hrc.org/blog/entry/colorado-victory-discriminatory-legislation-does-not-progress-in-legislatur|archive-url=https://web.archive.org/web/20150310171445/http://www.hrc.org/blog/entry/colorado-victory-discriminatory-legislation-does-not-progress-in-legislatur|url-status=dead|archive-date=March 10, 2015|website=The Human Rights Campaign|accessdate=July 23, 2015|date=March 10, 2014}}

Additional details on specific state laws

=Arkansas=

In April 2015, the governor of Arkansas, Asa Hutchinson, signed a religious freedom bill into law. The version of the bill he signed was more narrow in scope than the original version, which would have required state and local governments to demonstrate a compelling governmental interest to be able to infringe on someone's religious beliefs.{{cite web | url=https://www.usatoday.com/story/news/politics/2015/04/02/arkansas-religious-freedom-bill/70831330/ | title=Arkansas governor signs new 'religious freedom' bill | work=USA Today | date=April 2, 2015 | accessdate=March 28, 2016 | author=Trager, Kevin}}

=Georgia=

In March 2016, the Georgia State Senate and the Georgia House of Representatives passed a religious freedom bill.{{cite web | url=http://www.cnn.com/2016/03/17/politics/georgia-religious-freedom-bill-passed/ | title=Ga. governor cites Jesus in signaling 'religious freedom' bill opposition | work=CNN | date=March 17, 2016 | accessdate=March 28, 2016 | author=Botehlo, Greg}} On March 28, Georgia's governor, Nathan Deal, vetoed the bill after multiple Hollywood figures, as well as the Walt Disney Company threatened to pull future productions from the state if the bill became law.{{cite news | url=https://www.washingtonpost.com/news/post-nation/wp/2016/03/28/georgia-governor-to-veto-religious-freedom-bill-criticized-as-anti-gay/ | title=Georgia governor vetoes religious freedom bill criticized as anti-gay | newspaper=Washington Post | date=March 28, 2016 | accessdate=March 28, 2016 | author=Somashekhar, Sandhya}} Many other companies had also been opposed to the bill, including the National Football League, Salesforce, the Coca-Cola Company, and Unilever.{{cite web | url=https://www.bbc.com/news/world-us-canada-35912227 | title=Governor of Georgia vetoes religious freedom bill | work=BBC News | date=March 28, 2016 | accessdate=March 28, 2016}}{{cite web | url=https://money.cnn.com/2016/03/25/news/companies/georgia-religious-freedom-bill/ | title=Georgia's 'anti-LGBT' bill: These companies are speaking out the loudest | work=CNN | date=March 25, 2016 | accessdate=March 28, 2016 | author=Wattles, Jackie}}

=Indiana=

{{main|Religious Freedom Restoration Act (Indiana)}}

In March 2015, Gov. Mike Pence signed the Religious Freedom Restoration Act, allowing business owners who object to same-sex couples on religious grounds to opt out of providing them services.{{cite web | url=https://www.npr.org/sections/thetwo-way/2015/03/26/395583706/indianas-governor-signs-religious-freedom-bill | title=Indiana's Governor Signs 'Religious Freedom' Bill | work=NPR | date=March 26, 2015 | accessdate=March 28, 2016 | author=Neuman, Scott}}

=Mississippi=

{{main|Religious Liberty Accommodations Act}}

In April 2016, Phil Bryant, the governor of Mississippi, signed into law a bill that protects people from government punishment if they refuse to serve others on the basis of their own religious objection to same-sex marriage, transgender people, or extramarital sex.{{cite web | url=https://www.npr.org/sections/thetwo-way/2016/04/05/473107959/mississippi-governor-signs-religious-freedom-bill-into-law | title=Mississippi Governor Signs 'Religious Freedom' Bill Into Law | work=NPR | date=April 5, 2016 | accessdate=April 9, 2016 | author=Domonoske, Camila}} The sponsors of "Project Blitz," a coalition of conservative Christian organizations supporting dozens of "religious liberty" bills at the state level across the United States, see Mississippi's law as model legislation.{{cite news|last1=Stewart|first1=Katherine|title=A Christian Nationalist Blitz|url=https://www.nytimes.com/2018/05/26/opinion/project-blitz-christian-nationalists.html|accessdate=May 27, 2018|work=New York Times|date=May 26, 2018}}

=Missouri=

On March 9, 2016, the Missouri State Senate passed a religious freedom bill. Senate Democrats tried to stop the bill with a 39-hour filibuster, but Republicans responded by forcing a vote using a rarely used procedural maneuver, which resulted in the bill passing.{{cite web | url=http://www.cnn.com/2016/03/09/politics/missouri-religious-freedom-bill/ | title=Missouri 'religious freedom bill' passes as 39-hour filibuster ends | work=CNN | date=March 9, 2016 | accessdate=March 28, 2016 | author=Botehlo, Greg}} In April, it was defeated 6-6 in a Missouri House of Representatives committee vote, with three Republicans joining three Democrats in voting against the bill.{{cite web | url=https://www.npr.org/sections/thetwo-way/2016/04/27/475925476/missouri-religious-freedom-bill-defeated-in-house-committee-vote | title=Missouri 'Religious Freedom' Bill Defeated In House Committee Vote | work=NPR | date=April 27, 2016 | accessdate=June 9, 2016 | author=Farrington, Dara}}

=South Dakota=

On March 10, 2017, Dennis Daugaard, the governor of South Dakota, signed into law SB 149, which allows taxpayer-funded adoption agencies to deny services under circumstances that conflict with religious beliefs.{{cite web | url=https://www.washingtonblade.com/2017/03/10/s-d-governors-signs-first-anti-lgbt-law-2017/ | title=South Dakota governor signs first anti-LGBT law of 2017 | work=Washington Blade | date=March 10, 2017 | accessdate=March 11, 2017 | author=Johnson, Chris}}

= Texas =

On May 20, 2019, the Texas House passed a version of Senate Bill 1978 which prohibits the government from penalizing anyone for “membership in, affiliation with, or contribution...to a religious organization.” The bill was expected to pass the Senate again rapidly and to be signed by the governor.{{Cite web|url=https://www.texastribune.org/2019/05/20/texas-religious-liberty-bill-passes-lgbtq-caucus-fear-hateful-rhetoric/|title=Texas House passes religious liberty bill amid LGBTQ Caucus' objections|last=Platoff|first=Emma|date=May 20, 2019|website=The Texas Tribune|language=en|access-date=May 22, 2019}} On June 10, 2019, the governor signed the bill officially into law and it took effect immediately.{{cite web | url=https://legiscan.com/TX/bill/SB1978/2019 | title=Texas SB1978 | 2019-2020 | 86th Legislature }} Some have called it the "Save Chick-fil-A" law, given that the fast-food chain Chick-fil-A has been criticized for its donations to anti-LGBT causes.{{Cite web|url=https://www.lgbtqnation.com/2019/05/texas-get-save-chick-fil-law-legalizes-anti-lgbtq-discrimination/|title=Texas is about to get a 'Save Chick-fil-A' law that legalizes anti-LGBTQ discrimination|last=Bollinger|first=Alex|date=May 21, 2019|website=lgbtqnation.com|access-date=May 22, 2019}}

References