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Chiles v. Salazar · ¶13

According to Ms. Chiles's verified complaint, she holds a master's degree in clinical mental health and a state counseling license. App. to Pet. for Cert. 212a (App.). Clients seek her help on a wide variety of mental-health issues, including trauma, addiction, “eating disorders, gender dysphoria[,] and sexuality.” Id., at 206a–207a, 215a. Ms. Chiles “does not begin counseling” on any topic “with any predetermined goals.” Id., at 207a. Nor does she seek to “impose her values or beliefs” on clients. Id., at 212a. Instead, she “sits down . . . and talks to them about their goals.” Id., at 207a; see also id., at 213a. Only after clients have identified their own aspirations does Ms. Chiles begin “formulat[ing] methods of counseling that will most benefit” them. Id., at 207a. In any counseling that follows, as well, Ms. Chiles seeks to respect her “clients' fundamental right of self-…
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