Chiles v. Salazar

Editor’s note: The following is an adapted version of remarks presented by Kaley Chiles before the Presidential Religious Liberty Commission on March 16, 2026. This statement is provided for non-commercial purposes. 

I became a counselor because I believe in the power of truth to set people free. Learning to understand ourselves, confront pain, and pursue healing through a counseling relationship are tools that do not rust or depreciate with time. They can shape the rest of our lives, and I felt called to offer this kind of service. My own life experiences played a critical role in this calling. During my high school years, there was deep tension in my family, and I longed to learn the skills to resolve conflicts well. Around the same time, I began experiencing grand mal seizures -- sudden seizures with no known cause. I had to give up my driver’s license, and I wasn’t even allowed to be alone for a time in case I passed out. As a 17-year-old, that loss of independence was jarring.

But that season of suffering changed me. It forced me to slow down, to reflect, and ultimately to trust God more than I ever had before. Those experiences also shaped my desire to help others navigate suffering and find hope. In counseling, the client sets the goals, and I walk alongside them as we chart a path forward. This teamwork requires trust, authenticity, and the freedom for us to speak freely.

My first counseling job was in a male prison. Later, I worked at a dual-diagnosis adolescent facility, one level down from young people who are actively suicidal. In both places, I saw the depth of human struggle. But I also witnessed the incredible potential for transformation when people have a chance to talk to someone they trust. I noticed that the explicit reason for someone coming to counseling is often only a surface issue. Addiction, anxiety, anger, or depression may be the presenting struggle, but those are often the ‘fruit’ of something deeper. Counseling is about uncovering the ‘root’ -- the fears, the wounds, the questions underneath the surface. Pulling up those roots can help lead to sustainable change.

In 2022, while reviewing state statutes governing licensed counselors, I discovered that Colorado had passed a law dictating which counseling conversations my clients and I are allowed to have on the topics of sex and gender identity. The law restricted certain viewpoints on those topics -- even if the client desired to discuss those topics and pursue certain goals. 

In my practice, questions about identity and sexuality have often arisen, and those questions can lead to a desire to realign one’s sex with his or her identity or change sexual behaviors. But Colorado’s law prohibited me from having those discussions and my minor clients from pursuing those goals. If those topics came up, I could only respond with silence or encouragement to pursue a different goal, such as a gender transition. I knew I couldn’t stay silent while Colorado inserted itself into my relationship with my clients and prevented them from pursuing their goals. So I filed a lawsuit challenging this law on First Amendment grounds. 

In my view, the law inserted the government into private counseling conversations and attempted to control a client’s goals. The stakes for that intrusion are incredibly high. I believe the risk imposes a deep cost on young people and families affected by these laws. 

The First Amendment is not an abstract principle in a counseling office. It ensures open dialogue and the pursuit of truth. The U.S. Supreme Court heard my challenge to Colorado’s law in the fall of 2025. And in 2026, the Supreme Court agreed that the law conflicted with basic First Amendment principles and affirmed that Colorado was trying to censor conversations because it disagrees with the client’s personal goals and the viewpoint expressed in the conversation.

Young people wrestling with identity deserve counselors who are free to speak, ask questions, listen with compassion, and walk alongside them in their search for hope and restoration.