Chiles v. Salazar · ¶97

Chiles insists that, although she is a counselor licensed by Colorado, she has a constitutional right to fout Colorado's statute and the standard of care it incorporates if a client asks her to do so. Never mind that medical professionals— including counselors like Chiles—are generally bound to follow medical standards and state licensing requirements when they provide medical care to patients. Chiles wants to offer patients conversion therapy despite the MCTL and the medical consensus it refects. So she has invoked the First Amendment, arguing that, because talk therapy is speech, no State can impose treatment standards like the MCTL on licensed talk therapists without first satisfying heightened scrutiny.

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