Elane Photography, LLC, Plaintiff-Petitioner v. Vanessa Willock, Defendant-Respondent

Summary

The Court held that Elane Photography, a public accommodation, violated the New Mexico Human Rights Act by refusing to photograph a same-sex commitment ceremony because of the customer’s sexual orientation. It rejected the company’s compelled-speech and free-exercise challenges, concluding that the Act regulates discriminatory business conduct rather than expression and is a neutral law of general applicability. The Court also held that the New Mexico Religious Freedom Restoration Act does not apply when no government agency is a party, and it affirmed summary judgment for Willock. Justice Bosson, specially concurring, agreed with the result but emphasized that religiously motivated conduct must yield when it infringes others’ legal rights in the commercial marketplace.