"In the sexual orientation context, complicity-based conscience claims, which are beginning to proliferate, have been modeled on healthcare refusals. As religious groups opposing same-sex marriage suffer losses in politics and litigation, critics of same-sex marriage, including the Manhattan Declaration’s Robert George, encourage them to look to the abortion context for a model for long-term change. The abortion example illustrates how to resist legal settlement of conflict. As Ryan Anderson wrote in National Review, “we must . . . make clear that court-imposed same-sex marriage via a Roe-style decision will not settle the marriage debate any more than it has settled the abortion debate.” He immediately pivoted to religious freedom: “What-ever the Court does will cause less damage if we . . . highlight the importance of religious liberty. Even if the Court were to redefine marriage, government should not require third parties to recognize a same-sex relationship as a marriage.” It is not accidental that at the very moment general arguments for “traditional marriage” are failing, Anderson urges claims on religious liberty. As Anderson emphasizes, the abortion context illustrates how creative advocacy can adapt to conditions of loss. Unsurprisingly, then, conscience clauses secured in the abortion domain have become an aspiration for same-sex marriage opponents."