Keeton v. Anderson-Wiley

Jennifer Keeton (plaintiff), a Christian student in Augusta State University's counselor education master's program, told professors and classmates that she believed gay, lesbian, bisexual, transgender, and queer/questioning (GLBTQ) clients suffered from identity confusion, and said she planned to try to convert GLBTQ clients to heterosexuality and tell them being gay is morally wrong. The University (defendant) required Keeton to complete a remediation plan addressing her ability to serve as a multiculturally competent counselor before participating in the program's clinical practicum, based on the American Counseling Association's Code of Ethics, which barred counselors from imposing personal values on clients and required respecting client dignity and diversity — a code the University had to teach to maintain its accreditation. Keeton sued, alleging violations of her free-speech and free-exercise rights and retaliation, and sought a preliminary injunction to prevent dismissal if she didn't complete the plan. The district court denied the injunction, and Keeton appealed.