2013—In a challenge to a California law that prohibits mental-health counselors from engaging in “sexual orientation change efforts” with clients who are minors, a Ninth Circuit panel rules (in Pickup v. Brown) that talk therapy is “professional conduct” that is unprotected by the First Amendment.
Five years later, in its opinion in National Institute of Family Life Advocates v. Becerra, the Supreme Court will criticize Pickup by name for “except[ing] professional speech from the rule that content-based regulations of speech are subject to strict scrutiny.”