We will hear argument first this morning in case 24-539, Childs v. Salazar.

Mr. Campbell.

Thank you, Mr. Chief Justice, and may it please the Court.

Colorado forbids counselors like Kaylee Childs from helping minors pursue state disfavored goals on issues of gender and sexuality.

This law prophylactically bans voluntary conversations,

censoring widely held views on debated moral, religious, and scientific questions.

Aside from this law and recent ones like it,

Colorado hasn't identified any similar viewpoint-based bans on counseling.

These laws are historic outliers. In NIFLA, this Court protected professional speech,

highlighting the dangers of censoring private conversations between professionals and their clients,

and this Court rejected by name two lower court decisions upholding laws like

Colorado's. But the Tenth Circuit gutted NIFL speech protection. Colorado insists that its law is

subject only to rational basis review. Yet that would allow states to silence all kinds of speech

in the counseling room, such as disfavored

views on divorce or abortion. If heightened scrutiny doesn't apply, states can transform

counselors in the mouthpieces for the government. Here, Colorado can't satisfy any level of heightened

scrutiny. It didn't seriously consider any less restrictive

alternatives, and Colorado can't prove harm because it hasn't cited a study focusing on what's

at issue here, voluntary speech between a licensed professional and a minor. Nor can Colorado

deny that many people have experienced life-changing benefits from the

kind of counseling that Ms. Childs wants to provide. The First Amendment doesn't permit Colorado

censorship. I welcome the Court's questions. In its introduction of its brief, Colorado says that

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