T he U.S. Supreme Court's highly anticipated decision in Obergefell v. Hodges recognized federal constitutional protection for same-sex marriage. Although on its face the case addressed only whether states must issue marriage licenses to same-sex couples and recognize marriages legally formed in other states, Obergefell has implicated a number of other legal rights, particularly those related to religious exercise and civil rights. Some religious doctrines include objections to same-sex marriage, leading to questions about the extent to which individuals, businesses, or religious institutions that share such objections must recognize or accommodate couples in same-sex marriages. Because federal law includes both constitutional and statutory protections for religious beliefs that may involve such conflicts, the manner in which these protections may intersect with constitutional protection of same-sex marriage can become complicated. This report will analyze a range of legal issues for which Obergefell has implications. Since states initially began recognizing same-sex marriage, one of the primary questions has been whether recognition of same-sex marriage requires individuals, who officiate at weddings or issue marriage licenses but object to same-sex marriage on religious grounds, to provide those services to same-sex couples. Another conflict has arisen over whether businesses, which are owned by individuals with religious objections to same-sex marriage, would be subject to civil rights laws that prohibit discrimination against same-sex couples. Likewise, it is unclear whether religiously affiliated social service providers who object to same-sex marriage may participate in certain federally funded programs (e.g., adoption services grants). Finally, another potential legal issue that has been raised in light of Obergefell is whether churches and other religious entities could be denied federal tax-exempt status if they act in opposition to same-sex marriage. In its landmark decision, Obergefell v. Hodges , the U.S. Supreme Court struck down state bans on same-sex marriage as unconstitutional under the Fourteenth Amendment of the U.S. Constitution. The issues presented to the Court included whether states were required to permit same-sex couples to marry in their states and whether states were required to recognize same-sex marriages formed in other states, but did not include any issue directly affecting the manner in which such marriages were formed or what legal rights such couples may have beyond the ability to marry itself. Ultimately, the Court ruled that "the State laws challenged ... in these cases are now held invalid to the extent they exclude same-sex couples from civil marriage on the same terms and conditions as opposite-sex couples." The Court characterized the protection of the Due Process Clause of the Fourteenth Amendment as one that "extend[s] to certain personal choices central to individual dignity and autonomy, including intimate choices that define personal identity and beliefs." Examining the evolving history of the institution of marriage, the Court noted a shift in societal perceptions of same-sex relationships over the past century. In particular, the Court acknowledged that it "has long held the right to marry is protected by the Constitution," and cited four principles supporting governmental recognition of marriage rights: individual autonomy; the unique nature of the institution of marriage; the safeguards that legal marriage provides for children and families; and the "keystone" role marriage plays in the nation's social order. Examination of these principles led a majority of the Court to conclude that the reasons for which marriage is a fundamental right apply equally to same-sex couples as they have to opposite-sex couples, and thus same-sex marriages must be afforded the same constitutional protection. Obergefell was decided by a 5-4 vote, with the dissenting justices expressing strong objections to the majority opinion, in part raising arguments regarding religious freedom. Even Justice Kennedy, writing for the majority, acknowledged that recognition of same-sex marriage would not be universally accepted, specifically citing religious objectors: Many who deem same-sex marriage to be wrong reach that conclusion based on decent and honorable religious or philosophical premises, and neither they nor their beliefs are disparaged here. But when that sincere, personal opposition becomes enacted law and public policy, the necessary consequence is to put the imprimatur of the State itself on an exclusion that soon demeans or stigmatizes those whose own liberty is then denied. The Court emphasized the continued First Amendment right of individuals and religious entities to engage in debate regarding expansion of the scope of couples eligible to marry, while distinguishing that the Fourteenth Amendment precluded the government from engaging in unequal treatment of these couples. The First Amendment states that "Congress shall make no law respecting the establishment of religion, or prohibiting the free exercise thereof ...," in what are known respectively as the Establishment and Free Exercise Clauses. Establishment Clause protections apply in circumstances in which a government action may be considered as sanctioning a particular religious practice or point of view. Free Exercise Clause protections generally apply if a government action is directed at interfering with voluntary religious practices of private parties. The Establishment Clause prohibits the government from taking actions that would create an official position related to a religious practice or point of view. The Supreme Court has applied a range of different tests to identify whether a particular government action would violate the Establishment Clause. Under the traditional tripartite Lemon test, a challenged government action would be upheld if it (1) has a secular purpose; (2) has a primary effect that neither advances nor inhibits religion; and (3) does not foster excessive entanglement with religion. When applying that test, the Court has required that laws cannot create a relationship between government and religious entities that would cause one to interfere with the internal affairs of the other. Other tests consider whether the government action may endorse or disapprove a particular religion, or whether the law is neutral between religions and between religion and nonreligion. Under the Free Exercise Clause, the First Amendment also provides protection against the government's interference with voluntary religious exercise. The Court historically had applied heightened scrutiny to government actions that would infringe on religious exercise, requiring the government to show a compelling interest to do so. However, in the 1990 decision Employment Division, Department of Human Resources in Oregon v. Smith , it lowered the constitutional standard to require only that the government not intentionally infringe upon religious exercise. Under the current interpretation, the Court explained that the Free Exercise Clause never "relieve[s] an individual of the obligation to comply with a valid and neutral law of general applicability." However, the Court has emphasized that Congress remains free to consider whether heightened protection would be appropriate through the legislative process. Shortly after the Court adopted the new standard, Congress responded by enacting the Religious Freedom Restoration Act (RFRA), which applies heightened scrutiny to federal government actions that may affect religious exercise. RFRA states that the "[g]overnment shall not substantially burden a person's exercise of religion even if the burden results from a rule of general applicability, except" when the burden furthers a compelling governmental interest and uses the least restrictive means to achieve that interest. Since its enactment, RFRA traditionally has been applied in cases involving alleged burdens on the religious exercise of individuals and nonprofit religious organizations. Although litigation involving RFRA has been extensive in lower courts, the Supreme Court has heard only a few cases requiring it to interpret the substantive provisions of RFRA. In the landmark 2014 case, Burwell v. Hobby Lobby Stores, Inc. , the Court interpreted the scope of applicability of RFRA's protections to include some corporations. In Hobby Lobby , the owners of closely held for-profit corporations challenged a provision of the Affordable Care Act that required employers to provide insurance coverage for certain contraceptives as a burden on their religious exercise under RFRA. The Supreme Court held that RFRA requires the government to accommodate the beliefs of such entities, meaning that RFRA now may be understood to protect individuals, nonprofit religious organizations, and closely held for-profit businesses, that is, those "owned and controlled by members of a single family." Notably, the Court acknowledged, but declined to resolve, the remaining question of whether other businesses (e.g., publicly traded companies) also may be protected. The closely divided Hobby Lobby decision sparked a vigorous debate over the future implications of neutral laws of general applicability that may affect the ability of various entities to exercise their religious beliefs. In a highly critical dissenting opinion, Justice Ginsburg questioned, for example, the extent to which the decision could be read to permit employers with religious objections to various government mandates to avoid compliance. The majority opinion addressed this concern, explaining that it was unfounded because the Hobby Lobby decision reached only the contraceptive coverage requirement at issue in the case. According to the majority, other legal mandates would be subject to a different set of interests and different arguments regarding methods of meeting those interests. However, the majority did not state definitively that other requirements would be beyond the reach of a future RFRA challenge. This response implied that other legal mandates that may be challenged under future RFRA cases would have to be assessed on a case-by-case basis, a point that has generated much debate since the decision was issued. The extent to which individuals and businesses are able to avoid compliance with various legal mandates related to same-sex marriage as a result of RFRA and Hobby Lobby is unclear. Although Hobby Lobby clearly broadened the applicability of RFRA's protections, the decision did not clearly delineate the parameters of how that protection might be used. One outstanding question that appears to be critical to the analysis of balancing legal rights in the context of religious objections to same-sex marriage is what constitutes a substantial burden under RFRA, a term that was not defined by Congress in the statute itself. It is important to note that RFRA applies only to federal government actions that may burden religious exercise. Protection against burdens imposed by state or local governments depends on state law. After the Supreme Court held that the federal RFRA did not constrain the states, many states enacted their own versions of RFRA to prevent burdens on religious exercise at the state and local level.