Analysis Law and Policy

‘Hobby Lobby’ Is Just the Beginning: A Flood of Corporate Religious Objections Is Coming

Jessica Mason Pieklo

Thanks to the conservatives on the Supreme Court, corporations now have a whole new basis for objecting to government regulations.

Read more of our coverage on the Hobby Lobby and Conestoga Wood cases here.

The Roberts Court does nothing in small measures, so when Justice Samuel Alito, writing for the majority in Burwell v. Hobby Lobby, insists the decision granting closely held corporations religious objection rights under the Religious Freedom Restoration Act (RFRA) is limited only to the birth control benefit in the Affordable Care Act, don’t believe him. It’s not.

Like the Court’s decision in McCullen v. Coakley and Town of Greece v. Galloway, which also greatly advanced conservative causes but under the guise of “limited” First Amendment opinions, the decision in Hobby Lobby is an exercise in radical incrementalism. The 5-4 majority decision did not strike altogether the birth control benefit, nor did the decision rule broadly that corporations have First Amendment religious rights independent of the RFRA—but it set the path for future courts to do so.

Take first the issue of whether or not secular, for-profit corporations are “people” under the RFRA. As Justice Alito notes, the legal fiction of corporate “personhood” exists largely to provide protections to their individuals. What Justice Alito doesn’t note is that protections have never before been used to burden the rights of employees to the benefit of corporate owners.

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Alito writes:

When rights, whether constitutional or statutory, are extended to corporations, the purpose is to protect the rights of these people. For example, extending Fourth Amendment protections to corporations protects the privacy interests of employees and others associated with the company. Protecting corporations from government seizure of their property without just compensation protects all those who have a stake in the corporations’ financial well being. And protecting the free-exercise rights of corporations like Hobby Lobby, Conestoga and Mardel protects the religious liberty of the humans who own and control those companies.

In order to find corporations can exercise religious beliefs, Alito must conflate two very different scenarios. The first involves cases where the legal interests of employers and employees are largely aligned against those of the government; the second includes cases like Hobby Lobby, where corporate interests are trying to hide behind constitutional protections to deprive their employees of their rights. It’s a quick, but important, conflation that makes it possible for Alito to continue in the rest of his opinion to ignore the interests Hobby Lobby employees have in being free from religious discrimination by their employer.

With that judicial sleight-of-hand accomplished, Alito moves on to the larger question of just how a corporation can exercise these newly found religious rights. As it turns out, corporations practicing religious beliefs is remarkably simple, and just because a corporation seeks to maximize profit doesn’t mean it can’t do so in the name of religion:

While it is certainly true that a central objective of for-profit corporations is to make money, modern corporate law does not require for-profit corporations to pursue profit at the expense of everything else, and many do not do so. For-profit corporations, with ownership approval, support a wide variety of charitable causes, and it is not at all uncommon for such corporations to further humanitarian and other altruistic objectives. … If for-profit corporations may pursue such worthy objectives, there is no apparent reason why they may not further religious objectives as well.

Did you catch that? If some corporations can support charitable causes, Justice Alito reasons, why not allow others to pursue religious causes such as avoiding complying with federal law?

As if sensing the alarm bells ringing in the wake of just proclaiming the existence of corporate religious rights, Justice Alito is quick to point out that because both Hobby Lobby and Conestoga Wood Specialties Corporation are “closely held corporations,” the Court’s order is limited to similar businesses. Justice Alito doesn’t go so far as to say that the decision actually limits religious objections to those kinds of businesses—it just notes that no publicly traded companies have raised religious objections to the Affordable Care Act (ACA) like Hobby Lobby. Yet.

Having firmly established that closely held corporations (and probably publicly traded ones as well) can assert religious objections under the RFRA, the Court turns its attention to the birth control benefit specifically.

And here is where the Court’s deeply ingrained misogyny shines brightest.

Justice Alito writes that the Hahns and the Greensthe families who, respectively, own Conestoga Wood Specialties and Hobby Lobbyhave a sincere religious belief that life begins at conception and that their religious beliefs provide both that they offer insurance coverage for their employees, but only insurance coverage that conforms to those religious beliefs. Justice Alito takes this as an opportunity to misstate the coverage requirements of the ACA. “Before the advent of the ACA, they were not legally compelled to provide insurance,” wrote Alito, “but they nevertheless did soin part, no doubt, for conventional business reasons but also in part because their religious beliefs govern their relations with their employees.”

Of course, the ACA does not require employers to provide any health insurance coverage for their employees. Instead, the law requires those employers that do provide health insurance coverage offer that coverage equally for both men and women.

This a la carte type of coverage, where employers maintain ultimate veto authority over the scope of employee benefits, is of course the endgame to all these contraception challenges, and by opening the door to religious objections like Hobby Lobby the Court has set the stage for just that. The parties in Hobby Lobby sincerely, and wrongly, believe that emergency contraception and some forms of intrauterine devices (IUDs) act as abortifacients. But according to Alito, it doesn’t matter that the Greens and Hahns are wrong. All that matters is that they sincerely believe they are right.

[I]n these cases, the Hahns and Greens and their companies sincerely believe that providing the insurance coverage demanded by the HHS [U.S. Department of Health and Human Services] regulations lies on the forbidden side of the line, and it is not for us to say that their religious beliefs are mistaken or insubstantial. Instead, our “narrow function … in this context is to determine” whether the line drawn reflects “an honest conviction” and there is no dispute that it does.

The decision is a bad one. So bad, in fact, that Alito spends the rest of his attention in the decision explaining that the Court’s conclusions are not as radical as they appear. “HHS and the principal dissent argue that a ruling in favor of the objecting parties in these cases will lead to a flood of religious objections regarding a wide variety of medical procedures and drugs, such as vaccinations and blood transfusions, but HHS has made no effort to substantiate this prediction,” Alito writes. “HHS points to no evidence that insurance plans in existence prior to the enactment of ACA excluded coverage for such items. Nor has HHS provided evidence that any significant number of employers sought exemption, on religious grounds, from any of ACA’s coverage requirements other than the contraceptive mandate.”

HHS provided none of the evidence Justice Alito asks for because, as Justice Ruth Bader Ginsburg points out in her dissent, “[u]ntil this litigation, no decision of the Court recognized a for-profit corporation’s qualification for a religious exemption from a generally applicable law, whether under the Free Exercise Clause or RFRA.” In other words, that evidence didn’t exist because until this decision no corporation had made those kinds of claims.

Alito must really be concerned that his opinion will be dismissed as radical because his next move is to suggest that what the Obama administration really wants to do is force insurance coverage for abortions. If only!

“It is HHS’s apparent belief that no insurance-coverage mandate would violate RFRA—no matter how significantly it impinges on the religious liberties of employers—that would lead to intolerable consequences,” says Alito. “Under HHS’s view, RFRA would permit the Government to require all employers to provide coverage for any medical procedure allowed by law in the jurisdiction in question—for instance, third-trimester abortions or assisted suicide.”

Alito continues:

In any event, our decision in these cases is concerned solely with the contraceptive mandate. Our decision should not be understood to hold that an insurance-coverage mandate must necessarily fall it if conflicts with an employers’ religious beliefs. Other coverage requirements, such as immunizations, may be supported by different interest (for example, the need to combat the spread of infectious diseases) and may involve different arguments about the least restrictive means of providing them.

In other words, it’s not discrimination if it affects women, and it’s probably not discrimination if it affects the LGBT community either. Oh, and there’s a good chance conservatives will use this opinion to launch a broader attack on civil rights protections in the name of religious liberty even though (wink wink, nudge nudge) the Court is only concerned with the contraceptive mandate.

Not surprisingly, it took Justice Ginsburg more than 30 pages to dispense with that dangerous nonsense in a scathing dissent that simply shreds Alito’s claims that his opinion is a narrow one.

In a decision of startling breadth, the Court holds that commercial enterprises, including corporations, along with partnerships and sole proprietorships, can opt out of any law (saving only tax laws) they judge incompatible with their sincerely held religious beliefs. Compelling government interests in uniform compliance with the law, and disadvantages that religion-based opt-outs impose on others, hold no sway, the Court decides, at least when there is a “less restrictive alternative.” And such an alternative, the Court suggests, there will always be whenever, in lieu of tolling an enterprise claiming a religious-based exemption, the government, i.e., the general public, can pick up the tab.

This is not the first time Justices Alito and Ginsburg have been on opposite sides of a gender employment discrimination case. Last term, while Justice Ginsburg was reading from her dissent in Vance v. Ball State, the case that severely curtailed who is considered a supervisor for purposes of sexual harassment claims, Justice Alito rolled his eyes at claims she made that the decision didn’t reflect the realities of workplace harassment. It was a rare moment of displayed hostility by a sitting justice toward a colleague, but one that perfectly captures the disdain Alito shows for women, and especially women workers.

Like she did in Vance, Ginsburg schools Alito on the workplace barriers women face, and once again it’s clear Alito doesn’t care.

Ginsburg writes:

In the Court’s view, RFRA demands accommodation of a for-profit corporation’s religious beliefs no matter the impact that accommodation may have on third parties who do not share the corporation owners’ religious faith—in these cases, thousands of women employed by Hobby Lobby and Conestoga or dependents of persons those corporations employ.

But just what kind of accommodation will satisfy the conservatives on the Roberts Court remains an open question. Justices Alito and Kennedy suggest accommodating corporate religious beliefs the same way the administration is currently trying to accommodate nonprofit religious beliefs as one possibility. Naturally, the Court withholds judgment on whether it believes the current religious accommodation is actually constitutional, and with cases winding through the appellate courts on that very question, that’s very much a live issue, as is nearly every issue in these cases.

Just how far do corporate religious rights extend? Who knows. Will federal courts be put in a position to pick and choose which religious beliefs are sincerely held and which ones are not? It looks that way. Will the decision be used to enable employers to object to providing other health-care services, like HIV treatments? Seems likely, but we’ll have to wait for the lawsuits.

In fact, it seems Monday’s decision really only answered one question: When given the opportunity, will conservatives on the Court rule against the fundamental humanity of women?

The answer is yes. Every time.

Commentary Politics

On Immigration, Major Political Parties Can’t Seem to Agree on What’s ‘Un-American’

Tina Vasquez

As far as immigration is concerned, neither the Democrats nor Republicans are without their faults, though positions taken at the conventions were clearly more extreme in one case than the other.

Read more of our coverage of the Democratic National Convention here.

Immigration has been one of the country’s most contentious political topics and, not surprisingly, is now a primary focus of this election. But no matter how you feel about the subject, this is a nation of immigrants in search of “el sueño Americano,” as Karla Ortiz reminded us on the first night of the Democratic National Convention (DNC). Ortiz, the 11-year-old daughter of two undocumented parents, appeared in a Hillary Clinton campaign ad earlier this year expressing fear that her parents would be deported. Standing next to her mother on the DNC stage, the young girl told the crowd that she is an American who wants to become a lawyer to help families like hers.

It was a powerful way to kick-start the week, suggesting to viewers Democrats were taking a radically different approach to immigration than the Republican National Convention (RNC). While the RNC made undocumented immigrants the scapegoats for a variety of social ills, from U.S. unemployment to terrorism, the DNC chose to highlight the contributions of immigrants: the U.S. citizen daughter of undocumented parents, the undocumented college graduate, the children of immigrants who went into politics. Yet, even the stories shared at the DNC were too tidy and palatable, focusing on “acceptable” immigrant narratives. There were no mixed-status families discussing their deported parents, for example.

As far as immigration is concerned, neither the Democrats nor Republicans are without their faults, though positions taken at the conventions were clearly more extreme in one case than the other. By the end of two weeks, viewers may not have known whether to blame immigrants for taking their jobs or to befriend their hardworking immigrant neighbors. For the undocumented immigrants watching the conventions, the message, however, was clear: Both parties have a lot of work to do when it comes to humanizing their communities.  

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“No Business Being in This Country”

For context, Republican presidential nominee Donald Trump and his running mate Mike Pence are the decidedly anti-immigrant ticket. From the beginning, Trump’s campaign has been overrun by anti-immigrant rhetoric, from calling Mexicans “rapists” and “killers” to calling for a ban on Muslim immigration. And as of July 24, Trump’s proposed ban now includes people from countries “compromised by terrorism” who will not be allowed to enter the United States, including anyone from France.

So, it should come as no surprise that the first night of the RNC, which had the theme of “Make America Safe Again,” preyed on American fears of the “other.” In this case: undocumented immigrants who, as Julianne Hing wrote for the Nation, “aren’t just drug dealers and rapists anymorenow they’re murderers, too.”

Night one of the RNC featured not one but three speakers whose children were killed by undocumented immigrants. “They’re just three brave representatives of many thousands who have suffered so gravely,” Trump said at the convention. “Of all my travels in this country, nothing has affected me more, nothing even close I have to tell you, than the time I have spent with the mothers and fathers who have lost their children to violence spilling across our borders, which we can solve. We have to solve it.”

Billed as “immigration reform advocates,” grieving parents like Mary Ann Mendoza called her son’s killer, who had resided in the United States for 20 years before the drunk driving accident that ended her police officer son’s life, an “illegal immigrant” who “had no business being in this country.”

It seemed exploitative and felt all too common. Drunk driving deaths are tragically common and have nothing to do with immigration, but it is easier to demonize undocumented immigrants than it is to address the nation’s broken immigration system and the conditions that are separating people from their countries of originconditions to which the United States has contributed. Trump has spent months intentionally and disingenuously pushing narratives that undocumented immigrants are hurting and exploiting the United States, rather than attempting to get to the root of these issues. This was hammered home by Mendoza, who finished her speech saying that we have a system that cares more about “illegals” than Americans, and that a vote for Hillary “puts all of our children’s lives at risk.”

There was also Maricopa County Sheriff Joe Arpaio, a notorious racist whose department made a practice of racially profiling Latinos and was recently found to be in civil contempt of court for “repeatedly and knowingly” disobeying orders to cease policing tactics against Latinos, NPR reported.

Like Mendoza, Arpaio told the RNC crowd that the immigration system “puts the needs of other nations ahead of ours” and that “we are more concerned with the rights of ‘illegal aliens’ and criminals than we are with protecting our own country.” The sheriff asserted that he was at the RNC because he was distinctly qualified to discuss the “dangers of illegal immigration,” as someone who has lived on both sides of the border.

“We have terrorists coming in over our border, infiltrating our communities, and causing massive destruction and mayhem,” Arpaio said. “We have criminals penetrating our weak border security systems and committing serious crimes.”

Broadly, the takeaway from the RNC and the GOP nominee himself is that undocumented immigrants are terrorists who are taking American jobs and lives. “Trump leaned on a tragic story of a young woman’s murder to prop up a generalized depiction of immigrants as menacing, homicidal animals ‘roaming freely to threaten peaceful citizens,’” Hing wrote for the Nation.

When accepting the nomination, Trump highlighted the story of Sarah Root of Nebraska, a 21-year-old who was killed in a drunk-driving accident by a 19-year-old undocumented immigrant.

“To this administration, [the Root family’s] amazing daughter was just one more American life that wasn’t worth protecting,” Trump said. “One more child to sacrifice on the altar of open borders.”

It should be noted that the information related to immigration that Trump provided in his RNC speech, which included the assertion that the federal government enables crime by not deporting more undocumented immigrants (despite deporting more undocumented immigrants than ever before in recent years), came from groups founded by John Tanton, a well-known nativist whom the Southern Poverty Law center referred to as “the racist architect of the modern anti-immigrant movement.”

“The Border Crossed Us”

From the get-go, it seemed the DNC set out to counter the dangerous, anti-immigrant rhetoric pushed at the RNC. Over and over again, Democrats like Congressional Hispanic Caucus Chair Rep. Linda Sánchez (D-CA) hit back hard against Trump, citing him by name and quoting him directly.

“Donald Trump believes that Mexican immigrants are murderers and rapists. But what about my parents, Donald?” Sánchez asked the crowd, standing next to her sister, Rep. Loretta Sánchez (D-CA). “They are the only parents in our nation’s 265-year history to send not one but two daughters to the United States Congress!”

Each speech from a Latino touched on immigration, glossing over the fact that immigration is not just a Latino issue. While the sentiments were positiveillustrating a community that is thriving, and providing a much-needed break from the RNC’s anti-immigrant rhetoricat the core of every speech were messages of assimilation and respectability politics.

Even in gutsier speeches from people like actress Eva Longoria, there was the need to assert that her family is American and that her father is a veteran. The actress said, “My family never crossed a border. The border crossed us.”

Whether intentional or not, the DNC divided immigrants into those who are acceptable, respectable, and worthy of citizenship, and those—invisible at the convention—who are not. “Border crossers” who do not identify as American, who do not learn English, who do not aspire to go to college or become an entrepreneur because basic survival is overwhelming enough, what about them? Do they deserve to be in detention? Do their families deserve to be ripped apart by deportation?

At the convention, Rep. Luis Gutiérrez (D-IL), a champion of immigration reform, said something seemingly innocuous that snapped into focus the problem with the Democrats’ immigration narrative.

“In her heart, Hillary Clinton’s dream for America is one where immigrants are allowed to come out of the shadows, get right with the law, pay their taxes, and not feel fear that their families are going to be ripped apart,” Gutiérrez said.

The Democratic Party is participating in an all-too-convenient erasure of the progress undocumented people have made through sheer force of will. Immigration has become a leading topic not because there are more people crossing the border (there aren’t) or because nativist Donald Trump decided to run for president, but because a segment of the population has been denied basic rights and has been fighting tooth and nail to save themselves, their families, and their communities.

Immigrants have been coming out of the shadows and as a result, are largely responsible for the few forms of relief undocumented communities now have, like Deferred Action for Childhood Arrivals, which allows certain undocumented immigrants who meet specific qualifications to receive a renewable two-year work permit and exemption from deportation. And “getting right with the law” is a joke at this point. The problem isn’t that immigrants are failing to adhere to immigration laws; the problem is immigration laws that are notoriously complicated and convoluted, and the system, which is so backlogged with cases that a judge sometimes has just seven minutes to determine an immigrant’s fate.

Becoming a U.S. citizen is also really expensive. There is a cap on how many people can immigrate from any given country in a year, and as Janell Ross explained at the Washington Post:

There are some countries, including Mexico, from where a worker with no special skills or a relative in the United States can apply and wait 23 years, according to the U.S. government’s own data. That’s right: There are people receiving visas right now in Mexico to immigrate to the United States who applied in 1993.

But getting back to Gutierrez’s quote: Undocumented immigrants do pay taxes, though their ability to contribute to our economy should not be the one point on which Democrats hang their hats in order to attract voters. And actually, undocumented people pay a lot of taxes—some $11.6 billion in state and local taxes last year, according to the Institute on Taxation and Economic Policy—while rarely benefiting from a majority of federal assistance programs since the administration of President Bill Clinton ended “welfare as we know it” in 1996.

If Democrats were being honest at their convention, we would have heard about their failure to end family detention, and they would have addressed that they too have a history of criminalizing undocumented immigrants.

The 1996 Antiterrorism and Effective Death Penalty Act and the 1996 Illegal Immigration Reform and Immigrant Responsibility Act, enacted under former President Clinton, have had the combined effect of dramatically increasing the number of immigrants in detention and expanding mandatory or indefinite detention of noncitizens ordered to be removed to countries that will not accept them, as the American Civil Liberties Union notes on its site. Clinton also passed the North American Free Trade Agreement, which economically devastated Mexican farmers, leading to their mass migration to the United States in search of work.

In 1990, then-Sen. Joe Biden introduced the Violence Against Women Act, which passed in 1994 and specifically excluded undocumented women for the first 19 of the law’s 22 years, and even now is only helpful if the victim of intimate partner abuse is a child, parent, or current/former spouse of a U.S. citizen or a permanent resident.

In addition, President Obama is called by immigrant rights advocates “deporter in chief,” having put into place a “deportation machine” that has sent more than two million migrants back to their country of origin, more than any president in history. New arrivals to the United States, such as the Central American asylum seekers coming to our border escaping gender-based violence, are treated with the same level of prioritization for removal as threats to our national security. The country’s approach to this humanitarian crisis has been raiding homes in the middle of the night and placing migrants in detention centers, which despite being rife with allegations of human rights abuses, are making private prison corporations millions in revenue.

How Are We Defining “Un-American”?

When writing about the Democratic Party, community organizer Rosa Clemente, the 2008 Green Party vice president candidate, said that she is afraid of Trump, “but not enough to be distracted from what we must do, which is to break the two-party system for good.”

This is an election like we’ve never seen before, and it would be disingenuous to imply that the party advocating for the demise of the undocumented population is on equal footing with the party advocating for the rights of certain immigrants whose narratives it finds acceptable. But this is a country where Republicans loudly—and with no consequence—espouse racist, xenophobic, and nativist beliefs while Democrats publicly voice support of migrants while quietly standing by policies that criminalize undocumented communities and lead to record numbers of deportations.

During two weeks of conventions, both sides declared theirs was the party that encapsulated what America was supposed to be, adhering to morals and values handed down from our forefathers. But ours is a country comprised of stolen land and built by slave labor where today, undocumented immigrants, the population most affected by unjust immigration laws and violent anti-immigrant rhetoric, don’t have the right to vote. It is becoming increasingly hard to tell if that is indeed “un-American” or deeply American.

News Law and Policy

Three Crisis Pregnancy Centers Served for Breaking California Law

Nicole Knight Shine

The notices of violation issued this month mark the first time authorities anywhere in the state are enforcing the seven-month-old Reproductive Freedom, Accountability, Comprehensive Care, and Transparency (FACT) Act.

The Los Angeles City Attorney is warning three area fake clinics, commonly known as crisis pregnancy centers (CPCs), that they’re breaking a new state reproductive disclosure law and could face fines of $500 if they don’t comply.

The notices of violation issued this month mark the first time authorities anywhere in the state are enforcing the seven-month-old Reproductive Freedom, Accountability, Comprehensive Care, and Transparency (FACT) Act, advocates and the state Attorney General’s office indicate.

The office of City Attorney Mike Feuer served the notices on July 15 and July 18 to two unlicensed and one licensed clinic, a representative from the office told Rewire. The Los Angeles area facilities are Harbor Pregnancy Help Center, Los Angeles Pregnancy Services, and Pregnancy Counseling Center.

The law requires the state’s licensed pregnancy-related centers to display a brief statement with a number to call for access to free and low-cost birth control and abortion care, and for unlicensed centers to disclose that they are not medical facilities.

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“Our investigation revealed,” one of the letters from the city attorney warns, “that your facility failed to post the required onsite notice anywhere at your facility and that your facility failed to distribute the required notice either through a printed document or digitally.”

The centers have 30 days from the date of the letter to comply or face a $500 fine for an initial offense and $1,000 for subsequent violations.

“I think this is the first instance of a city attorney or any other authority enforcing the FACT Act, and we really admire City Attorney Mike Feuer for taking the lead,” Amy Everitt, state director of NARAL Pro-Choice California, told Rewire on Wednesday.

Feuer in May unveiled a campaign to crack down on violators, announcing that his office was “not going to wait” amid reports that some jurisdictions had chosen not to enforce the law while five separate court challenges brought by multiple fake clinics are pending.

Federal and state courts have denied requests to temporarily block the law, although appeals are pending before U.S. Court of Appeals for the Ninth Circuit.

In April, Rebecca Plevin of the local NPR affiliate KPCC found that six of eight area fake clinics were defying the FACT Act.

Although firm numbers are hard to come by, around 25 fake clinics, or CPCs, operate in Los Angeles County, according to estimates from a representative of NARAL Pro-Choice California. There are upwards of 1,200 CPCs across the country, according to their own accounting.

Last week, Rewire paid visits to the three violators: Harbor Pregnancy Help Center, Los Angeles Pregnancy Services, and Pregnancy Counseling Center.

Christie Kwan, a nurse manager at Pregnancy Counseling Center, declined to discuss the clinic’s noncompliance, but described their opposition to the state law as a “First Amendment concern.”

All three centers referred questions to their legal counsel, Alliance Defending Freedom (ADF), an Arizona-based nonprofit and frequent defender of discriminatory “religious liberty” laws.

Matt Bowman, senior counsel with ADF, said in an email to Rewire that forcing faith-based clinics to “communicate messages or promote ideas they disagree with, especially on life-and-death issues like abortion,” violates their “core beliefs” and threatens their free speech rights.

“The First Amendment protects all Americans, including pro-life people, from being targeted by a government conspiring with pro-abortion activists,” Bowman said.

Rewire found that some clinics are following the law. Claris Health, which was contacted as part of Feuer’s enforcement campaign in May, includes the public notice with patient intake forms, where it’s translated into more than a dozen languages, CEO Talitha Phillips said in an email to Rewire.

Open Arms Pregnancy Center in the San Fernando Valley has posted the public notice in the waiting room.

“To us, it’s a non-issue,” Debi Harvey, the center’s executive director, told Rewire. “We don’t provide abortion, we’re an abortion-alternative organization, we’re very clear on that. But we educate on all options.”

Even so, reports of deceit by 91 percent of fake clinics surveyed by NARAL Pro-Choice California helped spur the passage of the FACT Act last October. Until recently, a person who Googled “abortion clinic” might be directed to a fake clinic, or CPC.

Oakland last week became the second U.S. city to ban false advertising by facilities that city leaders described as “fronts for anti-abortion activists.” San Francisco passed a similar ordinance in 2011.