"As recent litigation illustrates, business owners working in wedding-related fields are asserting complicity-based objections to serving same-sex couples. Jack Phillips, the owner of Denver’s Masterpiece Cakes, turned away same-sex couples because he “believes that the Bible commands him . . . not to encourage sin in any way.” He contended that baking and selling a cake for a same- sex wedding would force him to “participate” in a sinful same-sex relation- ship. Similarly, owners of an Iowa art gallery used as an event space turned away a same-sex couple because “their religious beliefs prevent them from . . . facilitating . . . same-sex wedding ceremonies.” Moreover, through concepts of complicity, these exemption claims move beyond wedding-related services. For example, legislative proposals supported by social conservative advocacy groups would allow some for-profit employers who seek to avoid complicity in their employees’ sinful conduct to refuse to provide health insurance that covers employees’ same-sex spouses."