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Chiles v. Salazar · ¶121

Again, what distinguished NIFLA from Casey was the fact that Pennsylvania's speech-related mandate was aimed at regulating the provision of medical treatments to patients; the fact that the particular medical treatment at issue in Casey involved a physical (instead of a verbal) act was of no moment. NIFLA, 585 U. S., at 769–770. The reading of NIFLA the United States favors—which the majority appears to endorse in part, see ante, at 649–650—is irrational because, for purposes of the State's regulation of harmful professional conduct, treatments administered through words versus treatments administered through acts are not meaningfully different.
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