The Indiana Religious Freedom Restoration Act – An Analysis of Its Controversy

I have a posted a follow-up in order to address some, but not all, questions I have received over the past few days.

Also, here is a recent story from ABC Indianapolis regarding these points.

I will preface this post by saying that I am not a supporter of the Indiana Religious Freedom Restoration Act (IRFRA), a/k/a Ind. Code § 34-13-9, et seq. As this post goes on, those reasons will become self-evident but it is mostly because it is so vague and just a poorly written law. However, more than anything, there is a shocking lack of actual analysis of this statute and several arguments are being thrown out there which are rather unfounded. As an Indiana citizen and lawyer, I will do my best to provide insight as to what this bill purports to do and why it has drawn the ire of so many both within and without the borders of this state. So, I invite you, the reader, to take the time to go through this bill and decide for yourself, without prejudice, what you think of this newest piece of legislation (the full text of the law is below beside the titular parallel federal legislation.

Does IRFRA resemble its federal counterpart?

The short answer here is no.

I have seen the point made that federal democrats in 1993 passed a similar bill into law. This is in reference to 42 U.S.C. § 2000bb, which was indeed passed during the Clinton administration. This sound-byte is apparently made to imply that the left cannot complain because they created the blueprint.

Indeed, as Gov. Pence provided in his statement yesterday: “Fortunately, in the 1990s Congress passed, and President Clinton signed, the Religious Freedom Restoration Act—limiting government action that would infringe upon religion to only those that did not substantially burden free exercise of religion absent a compelling state interest and in the least restrictive means.” See Gov. Mike Pence signs ‘religious freedom’ bill in private.

The flaw in this implication is that it is misleading for several reasons. The federal act was deemed inapplicable to state actions. Consequently, several states have copied the federal act or have adopted similar legislation. A fair collection of all religious freedom statutes and court decisions can be found here. (Hats off to Liberty Counsel for making the effort to compile this list and publish it.) Upon my quick scan, Indiana’s version of the bill most resembles a similar law passed in Texas in 1999 but even that bill contains significant limitations that Indiana’s does not.

What is clear is that Indiana has not copied the federal legislation or those passed by other states, but has instead added more expansive language as seen below. The IRFRA adds several clauses which rightly give pause to the endless possibilities of using religion and religious freedom as a sword and a shield.

What are the controversial provisions and why?

Let’s start with Section 5, which reads: “As used in this chapter, ‘exercise of religion’ includes any exercise of religion, whether or not compelled by, or central to, a system of religious belief.” (Emphasis added.)

First, note the lack of any restrictive language in this paragraph. The word “includes” is deliberately used in place of “means.” The latter would at least limit “any exercise of religion” to the predicate definition. “Includes” just means that this is but one example of exercising religion. (Here the law goes beyond its most similar counterparts in Texas and New Mexico which use “means”.) While this language indeed mirrors the federal legislation, proponents of the IRFRA have submitted that Indiana’s constitution protects religious freedom to greater extent than federal law.  Second, religion is not defined. So, “any exercise of religion” is subject to a fairly broad interpretation. Third, any action which may fall under the “exercise of religion” may or not be “compelled by, or central to, a system of religious belief.” In other words, even if the belief is at the fringe of what a religion may or may not hold true, it falls under this definition of exercising one’s religion.

Section 7 then reads:

As used in this chapter, “person” includes the following: (1) An individual. (2) An organization, a religious society, a church, a body of communicants, or a group organized and operated primarily for religious purposes. (3) A partnership, a limited liability company, a corporation, a company, a firm, a society, a joint-stock company, an unincorporated association, or another entity that: (A) may sue and be sued; and (B) exercises practices that are compelled or limited by a system of religious belief held by: (i) an individual; or (ii) the individuals; who have control and substantial ownership of the entity, regardless of whether the entity is organized and operated for profit or nonprofit purposes.

(Emphasis added.) The potential danger in this aspect of the statute is that it may become self-fulfilling. For example, as has been cited before, say a hotel corporation with a religious owner refuses service to an individual based upon his religious beliefs. Now, even if that person had not previously exercised such practices, this Act, which requires no more than two religious practices that fall into this category, would allow a corporation to begin a discriminatory practice in the name of free exercise (and remember now how broadly exercising religion is defined?).

This inevitably leads the reader to Section 9, which reads:

A person whose exercise of religion has been substantially burdened, or is likely to be substantially burdened, by a violation of this chapter may assert the violation or impending violation as a claim or defense in a judicial or administrative proceeding, regardless of whether the state or any other governmental entity is a party to the proceeding. If the relevant governmental entity is not a party to the proceeding, the governmental entity has an unconditional right to intervene in order to respond to the person’s invocation of this chapter.

(Emphasis added.)

In other words, you can defend yourself in a criminal or civil action on the very broad basis of “any exercise of religion.” Where this may apply the most would be a Court’s ability or inability to apply a human rights ordinance against someone with a religious objection. (That we can even have an exercise in religion running directly against a human rights ordinance is cause alone for concern.) Such ordinances typically prohibit the discrimination employment, housing, education and public accommodations on the basis of a person’s sexual orientation or gender identity. The cities and counties in Indiana with these ordinances in effect are the City of Bloomington, the City of Evansville, the City of Indianapolis, Marion County, Monroe County, and the City of South Bend.

What makes this law new and different is its application to disputes between private citizens. That is not to say that such laws could not be used in private matters (in fact, Alabama, Connecticut, Florida, Idaho, New Mexico, Oklahoma, South Carolina, and Texas all have similar prvisions). Indiana’s version of the law, though, goes the extra mile to ensure the matter could remain between private individuals. It is the only one I have seen where the State can explicitly intervene at its discretion.

The timing factor.

Perhaps the most frustrating aspect of this law to its opponents is that it comes right after Indiana’s very public and very unsuccesful bid to ban gay marriage. Our own attorney general went state to state submitting amicus briefs in support of laws that would prevent state-sanctioned gay marriage. The state’s arguments at the 7th Circuit were nearly laughed out of the courtroom and were called out for what they were: discrimination based on personal views. The proponents of the IRFRA seem to gloss over this aspect even though the proponents of this bill were the same who had tried to ban gay marriage through Indiana’s Constitution. The exasperation could probably summed up as: “Look, if you hate the LGBT community, so be it . . . but don’t act like this law has nothing to do with it.”

What to make of it all?

As usual, it seems the truth lies somewhere in the middle.

Those against the bill may cite that 1) it may be applied more broadly than any of its predecessors at the state and federal level; 2) if properly based on religious grounds, it will override human rights ordinances that had protected LGBT rights; and 3) it coincidentally comes on the heals of Indiana’s effort to combat gay marriage.

Those in favor of the bill may argue that its predecessors, particularly those found in Texas and New Mexico have been around, constitutionally applied, and that the ire felt by the State is mere propaganda in light of the fact that these laws have been in existence elsewhere for some time. The principal legal argument in favor the law can be found here.

The law itself though tests the limits that previous versions have not. While it may be constitutional, it certainly is trying to push the envelope on the reach of free exercise of religion.

Addendum: Re-reviewing Section 9.

In light of some comments both received by email and online, it has been brought to my attention that Section 9 of IRFRA, was written so as to allow for the application of the law in a lawsuit without the intervention of the government agency who drafted the legislation or ordinance whose application would be limited by IRFRA. Some may be wondering why does this matter.

To begin, New Mexico’s version of Section 9 largely resembles those found in the other states that have a similar provision allowing for their respective religious freedom legislations to be applied as a defense in a judicial or administrative proceeding. “A person whose free exercise of religion has been restricted by a violation of the New Mexico Religious Freedom Restoration Act may assert that violation as a claim or defense in a judicial proceeding and obtain appropriate relief against a government agency . . .” NM ST § 28-22-1-4. The decision in Elane Photography, LLC v. Willock, 2013-NMSC-040, 309 P.3d 53 cert. denied, 134 S. Ct. 1787, 188 L. Ed. 2d 757 (2014) stated that the government was a necessary party in order to be exempt from the law the religious freedom act. This rationale would likely apply to similarly drafted acts in the other states mentioned above.

As has been graciously pointed out to me, Section 9 as written in the IRFRA obviates the requirement that the government be a party to a proceeding.

By way of background, typically a challenge in the application of law is done by requesting declaratory relief at the state or federal level asking the court to clarify how and should to apply a certain law, given that the person making the request has standing (i.e. is affected by the law) to do so. Thus, the government agency may respond and take a position to articulate how its law should be applied. In the same vein, the government can defend the constitutionality of the law if that is raised in the lawsuit as well. The overall point is that the government who drafted the affected law has an opportunity to come in a defend its application.

This matters because Section 9 would allow a challenge to a law or ordinance between two parties without making the government a necessary party. To use a contemporary hypothetical, if a South Bend patron sued a hotel  for discriminatory treatment under South Bend’s human rights ordinance and the hotel claimed as a defense that it was asserting its religious right to refuse service to that patron, that lawsuit would typically and necessarily involve the City of South Bend as a party so it could advocate for or against the application of IRFRA to its local ordinance. And while a Court could not prevent the City from intervening in the case, my opinion is that the legislation would bypass the need to have South Bend in such a case to defend the application of its own ordinance.

This is but another way in how IRFRA is more broadly written than its federal and state predecessors. While I would agree with the notion that its not an outright license to discriminate in and of itself (a court ruling would have to decide that), it does allow the path of least resistance among its species to have a court adjudicate it in a manner that could ultimately be used to discriminate against those protected in Indiana by human rights ordinances.

Indiana version

Sec. 1. This chapter applies to all governmental entity statutes, ordinances, resolutions, executive or administrative orders, regulations, customs, and usages, including the implementation or application thereof, regardless of whether they were enacted, adopted, or initiated before, on, or after July 1, 2015.Sec. 2. A governmental entity statute, ordinance, resolution, executive or administrative order, regulation, custom, or usage may not be construed to be exempt from the application of this chapter unless a state statute expressly exempts the statute, ordinance, resolution, executive or administrative order, regulation, custom, or usage from the application of this chapter by citation to this chapter.Sec. 3. (a) The following definitions apply throughout this section:(1) “Establishment Clause” refers to the part of the First Amendment of the Constitution of the United States or the Constitution of the State of Indiana prohibiting laws respecting the establishment of religion.(2) “Granting”, used with respect to government funding, benefits, or exemptions, does not include the denial of government funding, benefits, or exemptions.

(b) This chapter may not be construed to affect, interpret, or in any way address the Establishment Clause.

(c) Granting government funding, benefits, or exemptions, to the extent permissible under the Establishment Clause, does not constitute a violation of this chapter.

Sec. 4. As used in this chapter, “demonstrates” means meets the burdens of going forward with the evidence and of persuasion.

Sec. 5. As used in this chapter, “exercise of religion” includes any exercise of religion, whether or not compelled by, or central to, a system of religious belief.

Sec. 6. As used in this chapter, “governmental entity” includes the whole or any part of a branch, department, agency, instrumentality, official, or other individual or entity acting under color of law of any of the following:

(1) State government.

(2) A political subdivision (as defined in IC 36-1-2-13).

(3) An instrumentality of a governmental entity described in

subdivision (1) or (2), including a state educational institution, a body politic, a body corporate and politic, or any other similar entity established by law.

Sec. 7. As used in this chapter, “person” includes the following:

(1) An individual.

(2) An organization, a religious society, a church, a body of communicants, or a group organized and operated primarily for religious purposes.

(3) A partnership, a limited liability company, a corporation, a company, a firm, a society, a joint-stock company, an unincorporated association, or another entity that:

(A) may sue and be sued; and

(B) exercises practices that are compelled or limited by a

system of religious belief held by:

(i) an individual; or

(ii) the individuals;

who have control and substantial ownership of the entity, regardless of whether the entity is organized and operated for profit or nonprofit purposes.

Sec. 8. (a) Except as provided in subsection (b), a governmental entity may not substantially burden a person’s exercise of religion, even if the burden results from a rule of general applicability.

(b) A governmental entity may substantially burden a person’s exercise of religion only if the governmental entity demonstrates that application of the burden to the person:

(1) is in furtherance of a compelling governmental interest; and

(2) is the least restrictive means of furthering that compelling governmental interest.

Sec. 9. A person whose exercise of religion has been substantially burdened, or is likely to be substantially burdened, by a violation of this chapter may assert the violation or impending violation as a claim or defense in a judicial or administrative proceeding, regardless of whether the state or any other governmental entity is a party to the proceeding. If the relevant governmental entity is not a party to the proceeding, the governmental entity has an unconditional right to intervene in order to respond to the person’s invocation of this chapter.

Sec. 10. (a) If a court or other tribunal in which a violation of this chapter is asserted in conformity with section 9 of this chapter determines that:

(1) the person’s exercise of religion has been substantially burdened, or is likely to be substantially burdened; and

(2) the governmental entity imposing the burden has not demonstrated that application of the burden to the person:

(A) is in furtherance of a compelling governmental interest; and

(B) is the least restrictive means of furthering that compelling governmental interest;

the court or other tribunal shall allow a defense against any party and shall grant appropriate relief against the governmental entity.

(b) Relief against the governmental entity may include any of the following:

(1) Declaratory relief or an injunction or mandate that prevents, restrains, corrects, or abates the violation of this chapter.

(2) Compensatory damages.

(c) In the appropriate case, the court or other tribunal also may award all or part of the costs of litigation, including reasonable attorney’s fees, to a person that prevails against the governmental entity under this chapter.

Sec. 11. This chapter is not intended to, and shall not be construed or interpreted to, create a claim or private cause of action against any private employer by any applicant, employee, or former employee.

Federal Law

Sec. 1(a) In generalGovernment shall not substantially burden a person’s exercise of religion even if the burden results from a rule of general applicability, except as provided in subsection (b) of this section.(b) ExceptionGovernment may substantially burden a person’s exercise of religion only if it demonstrates that application of the burden to the person–

(1) is in furtherance of a compelling governmental interest; and

(2) is the least restrictive means of furthering that compelling governmental interest.

(c) Judicial relief

A person whose religious exercise has been burdened in violation of this section may assert that violation as a claim or defense in a judicial proceeding and obtain appropriate relief against a government. Standing to assert a claim or defense under this section shall be governed by the general rules of standing under article III of the Constitution.

Sec. 2

As used in this chapter–

(1) the term “government” includes a branch, department, agency, instrumentality, and official (or other person acting under color of law) of the United States, or of a covered entity;

(2) the term “covered entity” means the District of Columbia, the Commonwealth of Puerto Rico, and each territory and possession of the United States;

(3) the term “demonstrates” means meets the burdens of going forward with the evidence and of persuasion; and

(4) the term “exercise of religion” means religious exercise, as defined in section 2000cc-5 of this title.

Sec. 3

(a) In general

This chapter applies to all Federal law, and the implementation of that law, whether statutory or otherwise, and whether adopted before or after November 16, 1993.

(b) Rule of construction

Federal statutory law adopted after November 16, 1993 is subject to this chapter unless such law explicitly excludes such application by reference to this chapter.

(c) Religious belief unaffected

Nothing in this chapter shall be construed to authorize any government to burden any religious belief.

Sec. 4

Nothing in this chapter shall be construed to affect, interpret, or in any way address that portion of the First Amendment prohibiting laws respecting the establishment of religion (referred to in this section as the “Establishment Clause”). Granting government funding, benefits, or exemptions, to the extent permissible under the Establishment Clause, shall not constitute a violation of this chapter. As used in this section, the term “granting”, used with respect to government funding, benefits, or exemptions, does not include the denial of government funding, benefits, or exemptions.

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About Matt Anderson

I am civil trial attorney in South Bend, Indiana and have practiced on both sides of insurance and personal injury law in Illinois and Indiana for the better part of ten years. I created this blog as a way for other Indiana civil litigation and trial attorneys to get meaningful updates on cases ad issues that affect their practice. (I'll admit that there is some self-interest involved since it's also a handy way to summarize and file my own research.)

149 responses to “The Indiana Religious Freedom Restoration Act – An Analysis of Its Controversy”

  1. fleetwoodray says :

    Here is what bothers me with these types of bills. How can you tell if someone is a Democrat/Republican, white collar/blue collar, Christian/Muslim/Atheist rapist/pedophile etc. unless you advertise it in some way or fashion whether verbally or visually. When doing any kind of secular interaction, most people could care less.
    But, when you specialize in something, you should be able to exercise your right to that specialization. Our laws can be so much simpler if we individually respect one another and follow what is considered reasonable. Semper Fi

    Like

  2. Bill Baker says :

    Thank you so much for this addition to the debate. I saw the interview on ABC News with Gov. Pence. Indiana residents elected him and they who where he stood on these issues. Conservatives in this country aren’t even attempting to hide their bigotry and racism. As a liberal, I’m glad they’re showing their stripes for all to see.
    I travel around the world and read, monitor local politics, policies while I’m in different countries. If everyone would ‘pull back’ to see the macro picture they would discover that the equilibrium, homeostasis of the workd is always thrown off by right wing conservatism. They are called different things in different countries (tea party, evangelicals, and more broadly, republicans in the US) but the aim is the same. They divide, they live in and by fear and thirst for war.

    Like

  3. Jeremy Rosenthal Denver says :

    Great blog! Is your theme custom made or did you download it
    from somewhere? A theme like yours with a few simple tweeks
    would really make my blog jump out. Please let me know where you got
    your theme. Thank you

    Like

  4. megan says :

    OK help me out. After IRFRA goes into effect, in order to use your “exercise of religion” as a defense in any proceeding (private action, goverment, or otherwise), doesn’t the defendant STILL have to demonstrate that the goverment is “SUBSTANTIALLY burdening” the defendant’s exercise of reliegion?

    If so, wouldn’t the entire effectiveness of this law depend solely upon a judge’s interpretation of what constitutes a “substantial burden” to the the exercise of religion in the context of public accomodations?

    Like

    • pdgpa says :

      Not the “entire effectiveness,” but that is an important issue. Unfortunately the word “substantial” is one of the most ambiguous in the law. In fact, that term can mean either of two almost opposite things: it can either mean “weighty,” that is, “significant” (as you are assuming) or “not insubstantial,” that is, having any substance at all, even slight.

      Like

  5. Peter Pablo says :

    Why is everyone overlooking the fact that federal courts would never ultimately allow for discrimination on the basis of this law?

    Like

    • pdgpa says :

      Because that is not a “fact” at all, Peter, that’s why. Not all discrimination is unlawful. Most of the discrimination encouraged by INRFRA is, under state and federal law, not unlawful at present. The category of people that it principally targets (LGBTQ) is not protected by most state or federal anti-discrimination laws.

      Like

      • Peter Pablo says :

        Perhaps I am misunderstanding this whole situation, but I thought that the non-existence of federal and state anti-discrimination statutes don’t matter in the long run, because the court can rest its hat on constitutional arguments. It seems to me that this statute presents a fact pattern in which SCOTUS can finally expand the application of the equal protection clause OR can find that discriminating against members of the LGBT community doesn’t fall within conduct protected by the RFRA.

        Is my understanding of this incorrect?

        Like

      • wefijewoif says :

        So then this really this law has no impact on whether or not gays and lesbians can be discriminated against in Indiana counties that haven’t enacted ordinances prohibiting discrimination? The LGBT community can be discriminated against anyway in Indiana, because they have no cause of action to allege against private business owners for discriminating against them. The RFRA would not be needed by the discriminating party to defend against discrimination claims, as there is no cause of action for the LGBT community protecting them from this discrimination.

        I mean, this law is an affirmative defense to otherwise unlawful conduct. If there is no claim that currently exists that would implicate this affirmative defense in that jurisdiction, then it can’t really be said to enable discrimination can it?

        That’s besides the point. I don’t believe that in jurisdictions where this protection exists this law could be used to trump that law.

        Like

      • Matt Anderson says :

        You are correct in the sense that RFRA can only go so far as it is in conflict with government action, including laws. No local human rights ordinances means RFRA could not used as a defense to a violation of those ordinances. I think the conflict has arisen because a Court is going to one day balance Indiana’s recognition of religious freedom against whether a local human rights ordinance furthers a compelling government interest. In other words, would a state with little history of recognizing gay rights find a city’s human rights ordinance to be that compelling. If that finding goes in favor of such discrimination, what would then prevent other states from emulating Indiana?

        Like

    • Mike McNally says :

      It depends on whether a claim stems from a state vs. a federal law.

      Like

  6. Bob Patterson says :

    Although the IRFRA doesn’t target anyone specifically, it clearly is so broadly written that despite it’s obvious target, the LGBT community, it could easily be employed to discriminate against anyone prediciated upon the loosely applied “religious” interpretations. There is absolutely nothing in the Indiana law that intones that its provisions could not and would not be applied to anyone for whatever frivious reasons. Whomever it might be practiced against would suffer the burden of proof to show that they ahve been discriminated against should they elect to to bring suit. Way too broad and out of line with the federal code and most other state’s similar laws.

    Like

    • Peter Pablo says :

      Bob,

      I understand what you are saying. I hope you don’t mind if I ask more questions- I am trying to understand how this statute would be interpreted by courts to give it meaning in absence of language within the statute itself limiting its provisions.

      Wouldn’t this statute be interpreted with an eye on both the expressed intent of the Indiana legislature as written in the legislative history, and how similar acts in other states/the federal act are interpreted for guidance? Wouldn’t that serve to give meaning to the otherwise ambiguous provisions of this statute?

      Also, even if a case concerning this is brought between two private entities in state court, wouldn’t the RFRA still be interpreted using this method? And if it ultimately ended up before the federal courts, wouldn’t those courts do the same?

      Like

    • Ray says :

      Why would religious protection under Title VII of the CRA not already apply to a business owner, who in the hypothetical case of a Denver patisserie chef, was sued by a same-sex couple for refusal to cater their wedding and lost… Problem is, the chef was Christian and the marriage a religious event by Christian standards.

      (1) Does this NOT violate the chef’s civil rights? [and] (2) If the double-standard were addressed, wouldn’t Pence’s defense of the IRFRA fall apart?…

      Like

      • David Henderson-Rinehart says :

        The couple wanted to purchase a cake, not to have their wedding catered, in the Lakewood bakery case you mention. Both the couple and the baker agreed on these facts:

        “4. On July 19, 2012, Complainants Charlie Craig and David Mullins entered Masterpiece Cakeshop in the company of Mr. Craig’s mother, Deborah Munn.
        “5. Complainants sat down with [Jack] Phillips[, owner of Masterpiece Cakeshop] at the cake consulting table. They introduced themselves as ‘David’ and ‘Charlie’ and said that they wanted a wedding cake for ‘our wedding.’
        “6. Phillips informed Complainants that he does not create wedding cakes for same-sex weddings. Phillips told the men, ‘I’ll make you birthday cakes, shower cakes, sell you cookies and brownies, I just don’t make cakes for same-sex weddings.'”

        Liked by 1 person

      • pdgpa says :

        David H-R: I honestly cannot tell what point you are trying to make, although it seems you think it is obvious. If LGBTQ people are a protected class under the pertinent state’s public-accommodations civil rights law, and the state has no religious-scruples exception to that law (such as a state-level RFRA), then the baker in the Colorado situation would seem to be in violation for refusing to make and sell the cake. If the state does have a RFRA-type law, he may have a defense; that is, he may be entitled to refuse the couple any particular kind of service that violates his personal religious beliefs to provide. (Ray is confused about title VII, a federal law which protects individuals from discrimination in employment on various bases, including religion, by employers of more than 15 persons. The gay couple was not the “employer” of the baker, and he certainly wasn’t one of at least 15 such employees; they were trying to be his customers, not hiring him to work for them as an employee in their business. Title VII therefore doesn’t apply at all.)

        Like

      • David Henderson-Rinehart says :

        I wasn’t expressing an opinion on the question of how the law applies to specific facts, just correcting an inaccuracy in the facts as Ray had described them.

        Like

  7. wefijewoif says :

    Matt-

    For some reason I can’t respond directly to your last comment, so all I can do is hope you will see this.

    Wouldn’t the decision to allow discrimination based on this statute then go to the Federal courts, specifically the Supreme Court, on appeal? Do you believe that there is strong precedent there to uphold the decision to allow this sort of discrimination?

    I’m anxious that I am misinterpreting the statute itself. It doesn’t explicitly preempt those local laws- it just makes them subject to the RFRA, correct? Is that different from other RFRA in other states? Do they allow for express exemptions?

    Like

  8. zmilne27 says :

    Reblogged this on RedWhiteandBlurred and commented:
    Really great read. I question some of the rationale, but it’s refreshing to see such a relatively un-biased opinion of such a volatile issue.

    Like

  9. Noah Levin says :

    I was wondering if this law could be applied to birth control or morning after contraception. Could a religious pharmacist deny dispensing birth control because of his religious beliefs? Please reply via email if possible. Thank you for your detailed legal analysis.

    Like

  10. H. Alicea says :

    This post is to say some things make me entirely grossed out. Boys kissing boys, girls kissing girls, junkies and the flag of colors for boys that like boys and women liking women. Now I’m Christian and I wish people weren’t stupid but the fact is our society is very poisoned and people have to find the good path. You can change and our society needs better protection from people breathing toxic and not even knowing it. The side effects are stupidity, sickness and reversal of healing just for toxic. Crystal meth is far worse but includes those. Look, many are so expressive of something so gross and of people just controlled themselves better they wouldn’t be disgusting to those who were brought up better. Let’s face it, we need change but I don’t care of change when it’s letting the freaks go to the front stage hogging all the news. There is atrocities happening but the media love the anarchy of lies rather than truth. Okay, we heard, now talk about something else. So the business owner doesn’t want to throw up or have a sick face because this crude person is acting horrible. So many people are stupid and how can you trust people in your place of business who are so loud and obstreperous due to a bad living environment they are coming from. Let’s have a change okay. Let’s do the census bureau to find out what everyone thinks instead of just the freaks and the business owners. Oh, simple questions like, do you like seeing boys kids or do you like loud people talking near you so much. So many actually to find out what the majority have to say because people don’t vote and write their congressmen and senators enough but we all deserve to be heard. Let’s stop encouraging that which so many of us, hopefully the majority of us think is a bit too crazy. Change, we voted for it, now let’s not be a country of hypocrites and do it right!

    Like

    • H. Alicea says :

      I use Swype so asome mistakes like where it says of is supposed to be if and where it says kids is so posed to say kiss… Frustrating but reading what I wrote is not as important. I’m just dying to voice because maybe what I wrote matters for change. With brain loss, I can smell toxic and I wish you all could. Absolutely terrible smell that always brings pain. I wish I was in a better environment but hey, I’m still waiting for research to verify my ability to smell toxic so I can be the new sheriff on town. I know things not many do and I know for a fact we need change. God bless and good day!

      Like

    • Matt Anderson says :

      Hector:
      I have let all but one comment stand. I am allowing yours to stand just to let you know that in the same way you appear to find homosexuality stupid, several people would feel the same about your prejudice. Also, I believe the census you are proposing came back and most people said they hated discrimination laws more than anything.

      Like

  11. religious freedom laws says :

    this was a great breakdown. thanks for posting it. very informative

    Like

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  14. Tom Cotton Suggests Critics Of Indiana Law Should Be Grateful State Doesn't Execute Gays (VIDEO) - April 2, 2015
  15. The Indiana RFRA Is Different from Every Other RFRA in the Country | Equality Louisiana - April 2, 2015
  16. New Developments For IRFRA | Amusing Nonsense - April 2, 2015
  17. Brothers At Arms 004 RFRA and Christian Fakery – Open Eyes Network - April 23, 2015
  18. What You Need to Know about Indiana’s RFRA | Brynn Tannehill - June 12, 2015
  19. An Open Letter to the Governor of Indiana - September 28, 2015
  20. The Religious Freedom Restoration Act (RFRA) and Wage and Hour Law | Wage & Hour Insights - January 7, 2016

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