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AI Essay Writer

AI Essay Writer by Editpad is a free essay generator that helps you write narrative, persuasive, argumentative and descriptive essays online in seconds.

How to use AI Essay Writer by Editpad?

To use Editpad's AI Essay Writer, you need to follow these simple steps below:

• Type or paste your essay topic or requirements in the input box provided.
• Select the required essay length and writing tone.
• You can also select the " Add References " option if required.
• Click on " Write My Essay " button.
• After that, our essay generator will automatically generate your essay and provide results in the output box.

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AI Essay Writer with Academic Citations

Customize outline, trusted by students and professionals across the world, see what samwell can do.

Example of essays and research papers written with Samwell AI

Analysis of Marketing Mix Strategies for Wal-Mart Company

Performance Evaluation of Portfolio Managers of Mutual and Hedge Funds

Continuity and Change in USA 1950’s to Present

Write, Cite, Learn

Samwell makes writing and researching for essays easy, fast, and fun while delivering the best results

Guided Papers

Get a guided and optimal overview of your research paper.

Citation mode

Switch References

Need a reference that better aligns with your essay's requirements? Samwell AI provides a variety of citation choices for each paragraph, ensuring your references are tailored and diverse

Academic Integrity

Samwell AI champions academic integrity, offering suggestions that inspire true creativity within academic standards. Our tool simplifies information access and writing with AI, while keeping the focus on learning - the heart of our mission.

Overview mode

Personalized Research

Discover insights into how the highlights of your new research paper connect with your existing knowledge.

A million empowered writers

Samwell has written over 1.2 billion words from essays to market analysis to blog posts.

Samwell is the app I would have DREAM of when I was in high school, bachelor, master and PhD. So fast and intuitive. We can learn about 10 topics in a day now.

In a world where writing doesn't mean much anymore, Samwell AI offers academics and students what really matters today: quick access to information, references, overview. Introducing it to my students right away.

I considered ChatGPT to be a helpful writing assistant. However, upon discovering Samwell AI, I was amazed. Its capabilities exceeded my expectations by tenfold.

What’s the point to write with AI, now that AI writes for you. Samwell AI is the smartest AI I’ve see, it helps to learn faster and have access to information in a second. No bullshit of you writing, this isn't the point anymore

Samwell provide the best references on the market, the longer essay too (up to 50 pages). Everything in a second and (finally) design friendly. Big up!

A big thank you to Samwell Ai for genuinely saving my life. 🙏❤️

Samwell AI is truly astounding as it generates the entire first draft of your master's thesis or any research paper instantaneously. Furthermore, it provides various options for references and in-text citations, along with a guided tour of the paper. It's absolutely mind-blowing!

Samwell, the AI-driven helper for academic research, has recently improved and become perfect.

Samwell AI is a dream, it guide you through the research paper, you have access to the best accurate sources, it recommend Youtube videos to highlight some important topic. It’s huge!! Congrats!

You’re in control

Choose the package that suits you best. You can switch anytime.

1,000 words

15,000 words per month

90,000 words per month

200,000 words per month

Start Writing Your Free Essay!

More about samwell.

Have a question that needs answering? Our team is here to help! Get in touch with us via email at [email protected]

Advanced AI Essay Writer

20,000 AI-powered essays generated daily

Write unique, high-quality essays in seconds

See it for yourself: get a free essay by describing it in 5 words or more, instantly generate any essay type.

Get your content after just few words , or go step by step.

Full control of each step

Check the references

Edit your references using popular reference types like APA or MLA

How Smodin makes Essay Writing Easy

Generate different types of essays with smodin, instantly find sources for any sentence.

Our AI research tool in the essay editor interface makes it easy to find a source or fact check any piece of text on the web. It will find you the most relevant or related piece of information and the source it came from. You can quickly add that reference to your document references with just a click of a button. We also provide other modes for research such as “find support statistics”, “find supporting arguments”, “find useful information”, and other research methods to make finding the information you need a breeze. Make essay writing and research easy with our AI research assistant.

Easily Cite References

Our essay generator makes citing references in MLA and APA styles for web sources and references an easy task. The essay writer works by first identifying the primary elements in each source, such as the author, title, publication date, and URL, and then organizing them in the correct format required by the chosen citation style. This ensures that the references are accurate, complete, and consistent. The product provides helpful tools to generate citations and bibliographies in the appropriate style, making it easier for you to document your sources and avoid plagiarism. Whether you’re a student or a professional writer, our essay generator saves you time and effort in the citation process, allowing you to focus on the content of your work.

Produce Better Essays than ChatGPT

Our essay generator is designed to produce the best possible essays, with several tools available to assist in improving the essay, such as editing outlines, title improvements, tips and tricks, length control, and AI-assisted research. Unlike ChatGPT, our AI writer can find sources and assist in researching for the essay, which ensures that the essay is backed by credible and relevant information. Our essay generator offers editing assistance and outlines to improve the structure and flow of the essay. This feature is especially useful for students who may struggle with essay organization and require guidance on how to present their ideas coherently. Another advantage of our AI essay writer over ChatGPT is that it is designed explicitly for essay writing, ensuring that the output is of high quality and meets the expectations of the instructor or professor. While ChatGPT may be able to generate essays, there is no guarantee that the content will be relevant, accurate or meet the requirements of the assignment.

Easily Avoid Plagiarism

Our AI generated essays are 100% unique and plagiarism free. Worried about AI detection? Worry no more, use our AI Detection Remover to remove any AI Plagiarism produced from the essay generator.

Testimonials

Millions of users love Smodin's AI Writing Features

Smodin.io is an exceptional app that offers a range of outstanding features designed to help users with their research and content creation needs. One of the app's most impressive features is the Article 2.0, which generates high-quality articles and provides references for further study. The app's ChatIn feature and Research Paper generator are also incredibly unique, allowing users to conduct thorough research on the internet and find genuine paraphrased papers. One of the most impressive aspects of Smodin.io is its customer service team. The team is highly responsive, always available to help, and goes the extra mile to understand users' issues and offer solutions. This level of commitment to customer satisfaction is commendable and sets Smodin.io apart from its competitors. Another notable feature of Smodin.io is its continuous improvement. Every time you use the app, you'll notice new features that have been added based on feedback and recommendations. This level of attention to user feedback is remarkable, and it shows the app's developers' commitment to ensuring that Smodin.io remains the best in the market. I highly recommend Smodin.io to anyone looking for a reliable and efficient research and content creation tool.

I like this app. This app is useful mainly for student

Nice product

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• AI Essay Writer
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• Outline Generator

Looking for the All-in-One AI Essay Writer?

Reliable and secure platform for your essay needs.

• Original draft in minutes Generate unique drafts with ideas and arguments to save time for important things. Read more Our AI essay generator creates complete academic drafts based on your instructions with a few clicks that can be edited. Close
• Plagiarism-free content Get 100% unique drafts that are customized according to your expectations. Read more Textero.ai is a plagiarism-free platform ensuring the academic integrity of all papers and caring about your data safety. Close
• Real academic references Expand your research, find credible sources, add them to your library, and format your paper in two clicks. Read more The AI finds only real academic sources to support your essay writer and formats the work according to the selected citation format automatically. Close
• Advanced Customization Customize draft generation settings for ultimate personalization. Read more Our AI essay writer allows you to generate titles and descriptions, select essay type, set a word count up to 20,000 words, and add your custom sources to the draft. Close
• Multilingual Capabilities Generate drafts in different languages and remove language barriers. Read more Textero.ai essay writer supports generation in Chinese, Czech, English, Filipino, French, German, Italian, Polish, Portuguese, Spanish, Turkish, Ukrainian, and other custom languages. Close
• Customizable Essay Types Select different essay types for deeper generation customization.. Read more Our AI essay generator allows you to pick an essay type: argumentative essay, research paper, literature review, expository essay, or case study analysis. Close

The Revolution in Essay Writer

AI is taking education by storm, and AI essay writer tools are becoming more popular than ever among students. They use advanced algorithms and natural language processing models to generate complete essays quickly. Combined with access to academic databases with papers from reputable authors, Textero AI is tailored to generate the highest-quality essays for any academic discipline, streamlining the essay writing process.

Trusted by Top University Students

Benefits of Textero AI Essay Maker

Students use our AI essay writer to simplify the essay-writing process by boosting productivity through quick generation of essays and research papers. This saves time and allows students to stay focused on the topic.

We use advanced natural language processing algorithms to ensure that content is error-free. Generated content has consistent grammar, tone, and adjustable style.

Our free AI essay generator guarantees plagiarism-free essays. It generates accurate citations for APA and MLA styles, ensuring that your research papers are adhering to the highest academic standards.

Essay writing tool ensures top quality of essays through access to an academic database with 215+ million papers. A combination of consistent tone, style, and coherence results in professional essays that adhere to academic standards.

With customizable settings for the generator, our essay writer tool offers unprecedented personalization to students. Provide the assistant with the details of your essay or outline to generate required paper.

Our AI essay writer tool gathers scientific sources from open scholarly bases with reputable articles. It also features an AI-powered assistant to improve the research process.

How Textero AI Essay Writer Works?

• Start writing for free

Your Personal AI Writing Coach

Write your essays faster with our AI essay maker and generator.

Find inspiration for your writer with Textero essay writing tool.

Polish your writing style by simplifying, expanding, shortening, or paraphrasing your text.

Find articles from reputable authors, generate citations, and conduct research.

Build compelling outlines with AI to streamline your writing process.

Upload your documents and texts to receive comprehensive summaries.

1M+ Users Review Textero AI Essay Writer

Jan 12, 2023

"As a student who struggles with planning papers and meeting deadlines, Textero AI was a life saver! The automatic outline and bibliography builder kept me structured, while the quick generation of introductions and conclusions accelerated my writing process. I finished two days early!"

Nov 21, 2022

"Facing a tight deadline for a major thesis paper, I used Textero's rapid generation of related evidence and rephrasing of my arguments to produce a well-cited, coherent paper in just a few days! It helped me synthesize tons of research efficiently."

Sep 15, 2023

"Textero essay writing tool quick brainstorming helped cure my writer’s block by sparking unique ideas I never considered. Seeing essay samples on various topics then effortlessly crafting an intriguing opening paragraph gave me creative confidence I've missed for years!"

Dec 1, 2022

"As a non-native speaker, Textero AI was a revelation. It offered vocabulary enhancements that made my essays sound natural. The Advanced Grammar and Style Corrections improved my writing dramatically, boosting my grades and confidence. Highly recommended for anyone seeking fluency in their academic writing!"

Aug 19, 2023

"Facing a tight deadline, I turned to Textero AI Essay Witing. Its quick essay generation feature produced quality content fast. It relieved my stress and helped me submit my assignment on time, with confidence. It's an invaluable tool for any student in a time crunch."

Oct 28, 2022

"Textero vocabulary suggestions enriched my academic essays, making them more articulate and impactful. The tool's ease of use and efficient features saved me countless hours, allowing me to focus on research. It's a fantastic aid for any academic writer."

• Intelligent Outlining Module – AI essay writer uses advanced algorithms to ensure coherent structure of generated texts. Resulting essays have a logical flow that expands on research topics.
• Dynamic Research Engine – our essay writing tool has access to academic research databases that are constantly updated. It prioritizes most recent sources to use in generated essays.
• Adaptive Writing Assistant – our AI assistant was trained on more than 215 million academic papers to provide suggestions to users’ content. It can be used to edit and revise generated texts.
• Multi-Format Citation Engine – users can select MLA and APA citation styles for their essays. AI essay writer will format sources according to the preferred citation style.
• Ask AI Function – look for academic sources relevant to your topic while working with the document. Users can ask AI a question and receive a detailed answer with relevant citations.
• Extensive Academic Database Access – Textero AI has direct access to the academic research paper database that is constantly updated. Sources used in generated essays adhere to academic standards.
• Contextualized Content Generation – AI essay writer tool generates contextually relevant essays and research papers based on the topic and instructions provided by the user.
• Anti-Plagiarism Shield – content generated by Textero AI is 100% plagiarism-free. It uses advanced algorithms to detect and eliminate plagiarism, ensuring that your assignments are credible.
• Narrative – narration of a story through events, often from the author’s perspective;
• Persuasive – the use of logical and reasonable arguments aimed at persuading readers to adopt the author’s point of view;
• Argumentative – presentation of a topic from several perspectives, favoring one side with evidence and reasoning;
• Expository – presentation of a topic in a straightforward manner by using facts and examples;
• Compare and contrast – description of similarities and differences between subjects to provide a nuanced perspective on the topic;
• Cause and effect – description of relationships between events to explain how different factors lead to a particular outcome;
• Definition – explanation of a idea, concept, or term with exploration of its interpretations;
• Expository – explanation of a topic in an unbiased manner through factual information and analysis.

Are you ready to write top-quality essay with Textero.ai?

Boost Your Essay Writing Skills and Achievements with Textero AI

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Improve Your Academic Writing Skills and Performance With Textero AI. Discover your ultimate go-to assistant for academic writing. Use the power of AI to overcome writer’s block, find new ideas, and elevate your writing experience with Textero.ai.

© 2023 Textero.ai, Inc. All rights reserved.

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Don't stress about deadlines. Write better with Yomu and simplify your academic life.

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Step into the future of the academic writing with Yomu

Never get stuck at writing your essay

Use an intelligent Document Assistant to help write entire sections and give you feedback.

Your personal essay copilot

Elevate your essay writing with an AI autocomplete that completes your sentences and paragraphs.

Edit your paper like a pro

Leverage AI to brainstorm and refine your paper: paraphrase, expand, shorten, summarize, and transform bullet points into detailed text.

Cite papers with ease

Easily find, include, and format citations in your paper with our AI-powered citation tool powered by Sourcely .

Ensure your work is original and uphold academic integrity.

Evaluate your work with an advanced plagiarism checker and gain insights on how to maintain originality and authenticity ( Ethics Statement ).

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Power your academic writing with yomu ai.

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Authentic, original, genuine.

Get ahead of AI detectors and ensure your work is original and authentic.

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Edit, brainstorm, and write with our powerful AI commands.

Yomu lets you easily add, caption and reference figures in the text.

Grammar & text improvements

Write flawlessly with the help of our grammar & text improvement checker.

Yomu lets you easily create, modify, caption and reference tables in the text.

Submit desired features

We are not stopping here, review our roadmap, frequently asked questions.

Yomu is an AI-powered writing assistant that helps you write better essays, papers, and academic writing. Simply start typing and Yomu will generate suggestions for you to use in your writing. You can also use Yomu to generate entire paragraphs or sections. Yomu also helps find citations, references, and sources for you to use in your writing. You can make sure that your writing is plagiarism-free by using Yomu's plagiarism checker.

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Make your essays with smart ai, what do you want to write essay about.

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Writing essays can be a boring and time-consuming task, but what if there was a tool that could make the process easier and more efficient?

Introducing Toolbaz AI Essay Writer - a creative writing tool that uses artificial intelligence (AI) to help you craft high-quality essays with minimal effort.

What’s more,

Toolbaz's AI Essay Writer is also changing the way people write and making it easier than ever to generate professional-grade essays. Get ready to elevate your writing skills with the power of AI!

Let’s discuss it briefly!

Image by storyset on Freepik

What is an AI Essay Writer?

An AI essay writer is a type of artificial intelligence that is specifically designed to write academic essays. These AI tools use advanced algorithms and machine learning techniques to analyze the topic and generate a well-written essay based on the given prompt.

Furthermore,

AI essay writers are becoming increasingly popular among students and professionals as they can save time and effort while creating high-quality essays.

But it's important to remember that while AI essay writers can be helpful, they shouldn't be used as the only source of academic work because they can't think critically and analyze as well as a human writer can.

How Does Toolbaz AI Essay Writer Work?

This tool's primary goal is to help students with their writing assignments or essays by automatically generating them from scratch.

Simply put, it creates essays on your behalf. You can choose from a variety of topics, and the essay will be generated depending on your selection. It is completely customizable, so if you don't like the way it looks or sounds, just change it!

Our tool helps to:

• Prepare academic assignments
• Generate college essays
• Quality content from scratch
• Create blogs

How AI Essay Writer Helps In Writing Articles?

The AI Essay Writer is a tool for creating the best and most creative essays possible. Our essay typer is integrated with artificial intelligence technology, which allows it to generate original and distinctive content for you.

This tool's AI technology is so powerful that it can even write an essay on your behalf! It will use its own algorithms to examine your text and other web texts before generating a very unique essay.

You may also edit the essay's content before submitting it to our experienced editors for evaluation.

The content created can be used for any purpose, including:

• To provide an unique essay that will assist you with your homework or research assignment.
• To compose an essay on a topic of your selection.
• To create a blog post on any topic that interests you.

What does essay generator AI allow you to do?

You can either write a new essay or edit an old one. You can also get assistance with essay writing. You may use an essay generator (AI) to learn how to write essays and enhance your English abilities.

It is very simple; just enter the text you desire to change and click the “write” button. The tool will do everything for you!

How do I use Toolbaz AI essay writer online?

You can use our essay generator to create a custom essay. Here's how to get started!

Just enter the topic in the input area like.

After entering the topic!

Make sure to tick the “Recaptcha” box to verify that you’re not a robot. This will enable the tool to examine your input and generate unique, quality content for you!

How does Toolbaz help me write better essays?

Toolbaz's AI essay writer engine will provide you with a custom-written essay tailored to your individual needs.

The AI will analyze your prompt, automatically generate high-quality content, provide insights and editing tips to improve the quality of your writing, and suggest topics and ideas for further exploration. With Toolbaz on your side, you'll be able to write top-notch essays in just seconds.

What types of essays does Toolbaz write?

Are you tired of struggling to come up with ideas for your essays? Let Toolbaz take the burden off your shoulders!

Our advanced writing tool is capable of generating a wide range of essay types, including:

• Argumentative
• Narrative and more!

Whether you need to persuade your reader to take a certain action or simply inform them about a particular topic, Toolbaz has you covered.

With its intuitive interface and vast library of resources, Toolbaz makes it easy to write quality essays that are sure to impress your teachers and peers.

How can I improve my essay writing skills?

There are several ways you can improve your essay writing skills:

Practice writing regularly:

The more you write, the more comfortable you will become with the writing process and the better you will become at expressing your thoughts and ideas on paper.

Read widely:

Reading helps to expand your vocabulary and exposes you to different writing styles and techniques, which you can then incorporate into your own writing.

Get feedback:

Ask a friend, family member, or teacher to read your essays and provide constructive feedback.

Use writing tools:

Toolbaz is a highly effective writing tool that can help you improve your skills and generate top-quality essays.

Among the various writing resources available, it stands out for its comprehensive features and user-friendly interface.

Are the essays generated by Toolbaz original and free of plagiarism?

Yes, the essays generated by Toolbaz are original and free of plagiarism.

We understand the importance of submitting unique and original work, and our tool is designed specifically to assist students in generating original ideas and thoughts.

All of the essays generated by our tool are completely original and written from scratch, ensuring that they are completely free of plagiarism.

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The whole purpose of writing tools is to make monotonous, tedious, and routine tasks obsolete.

Why do the same thing over and over again when you can easily automate the whole process, giving you tons of free time, less stress, and notably better results? After all, it’s not like you’re learning anything new by doing the same time-consuming tasks!

Writing tools allow students to spend their time focusing on things that really matter.

Hours Upon Hours of Saved Time

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And that’s just to name a few things! The actual possibilities are endless.

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Writing assignments tend to pile up, along with many other tasks. And unfortunately there’s no way to add more hours to the day to complete everything on time.

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With the help of writing tools, this nightmare is easy to avoid. You’ll be able to deal with all your routines more effectively and even meet multiple deadlines at once.

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Conduct, Content, and the Supreme Court

By Katrina Fay

Published: June 06, 2024

On December 5th, 2022, the Supreme Court of the United States heard the case of 303 Creative LLC. v. Elenis , a case that was marketed as pitting free speech against LBGTQ rights. [1] In this case, Lorie Smith, the sole owner and creator of 303 Creative LLC., wanted to create wedding websites; she was afraid, however, that the Colorado Anti-Discrimination Act (CADA) would compel her to create websites for the weddings of same-sex couples, which goes against her sincerely held religious beliefs. She sought an injunction from the Colorado courts that would allow her not only to refuse to create such content but allow her to post a notice saying she was not willing to provide that kind of service. [2]

Justice Gorsuch and the majority of the Supreme Court ruled in favor of Smith (6-3), as stated by Gorsuch in his Opinion of the Court. Primarily, they held that the public accommodation laws against discrimination were secondary to Smith’s First Amendment rights to expressive speech and that Smith’s business was not entitled equally to everyone as a public service under these laws. Additionally, they believed that forcing her to comply with CADA would create “compelled speech” which would infringe on her First Amendment rights. While I agree with Gorsuch’s theory and understanding of the law, I believe that the Court errs in its application of the law at hand. In his opinion, Gorsuch creates an incomplete picture of public accommodation laws by not including the proper context of their importance, failing to consider fundamental principles of public accommodation laws and ignoring critical precedents of the Court that have protected classes from similar claimed exemptions before. Additionally, he misleads by relying on three legal precedents whose situations are different from the case at hand in substantial ways. I will, however, focus on his specific claim of “compelled speech.” I believe that Justice Gorsuch misrepresents the issue as one of “compelled speech” as opposed to conduct, disregarding the instances when expressive activities are regulated by the government as well as the complexities involved when “content” and “characteristic” are inherently connected.

To begin, Gorsuch held that forcing Smith to comply with Colorado’s Anti-Discrimination Act would create “compelled speech” by the government which would infringe on her First Amendment rights. The core of the First Amendment’s right to freedom of speech is that individuals have the right to believe what they want to believe and that they have a right to express those beliefs. One of the ways the government can infringe upon this right is if it compels an individual to espouse or create speech that goes against their beliefs. Smith’s claim, supported by the Court, is that enforcing CADA, compelling her to create content she does not agree with, goes against her First Amendment right. Any expressive action or activities relating to these beliefs are considered expressive action or expressive speech, and this expressive element is a point that Gorsuch holds onto as the cornerstone of the case: Smith is engaging in expressive speech; the right to expressive speech cannot be taken away from her. [3]

Up to this point, I agree. Contrary to Gorsuch’s opinion, however, the speech and its expressivity are not the critical point in this case; the conduct relating to expressive activity is. There is no debate, among the majority and the dissenting judges, that speech is being created and that Smith has a right to express what she believes. While her speech in and of itself may be free, “The First Amendment does not prevent restrictions directed at commerce or conduct from imposing incidental burdens on speech.” [4] Gorsuch’s claim that the government protects expressive speech and association is true, [5] but there are certain important caveats. In United States v. O’Brien (1968) , the Court ruled against David O’Brien after he protested the Vietnam war by burning his draft card. Although his actions were expressive, the government was not regulating the law against burning draft cards to suppress expression. Thus, the statutes of the O’Brien precedent were born, whereby if the law’s regulation of conduct is unrelated to the suppression of expression and carries out a government interest that cannot be done in a more effective way, the law is considered to not be in contradiction with First Amendment rights. [6] Efficacy in this case is much intertwined with the importance and substantiality of the government’s interests. In O’Brien , the Court ruled that since the draft cards served many purposes and mutilating the cards prevented them from serving the government’s interest, individuals found breaking the law would be penalized; the “efficacy” was weighed based on a governmental system’s smooth and proper functioning. Any burden on expressive speech in these cases is “incidental,” proving expressive speech can be regulated as conduct. Gorsuch never mentions O’Brien but disagrees that the burden of enforcing CADA would be “incidental,” as he claims that enforcing CADA, thus compelling Smith to speech, goes against her rights. [7]

First, Gorsuch focuses his attention on the “content” element, whereas O’Brien indicates that the “conduct” element is a more important factor in this case. CADA meets the O’Brien statutes, as it is not aimed at suppressing speech and is an effective law in the state of Colorado for fighting discrimination. The law does not dictate the content of any business or individual’s speech at all. An individual or business is only “compelled” if, and to the extent, that the company offers speech in a discriminatory manner. In this case, Colorado is not forcing Smith to speak any message of the State. She could provide only quotes and templates on her website that adhere to her moral beliefs, and the government would not compel her to say anything different; “All the company has to do is offer its services without regard to customers’ protected characteristics.” [8] [9] Several legal precedents also indicate that public accommodation laws have conflicted with “compelled speech” before. In Runyon v. McCrary (1976) , the Court ruled that “[a private] school’s “practice” of denying educational services to [racial] minorities was not shielded by the First Amendment.” [10] The Court clarified that “[r]equiring the schools to abide by anti-discrimination law was not the same thing as compelling the schools to express teachings contrary to their sincerely held belief that racial segregation is desirable.” [11] Gorsuch mentions nothing of Runyon , a case that Sotomayor says “the majority studiously avoids.” [12] The efficacy of the O’Brien statutes has been used before in other cases as well. Its standards were upheld most notably in Tinker v. Des Moines Independent Community School District .

Secondly, Gorsuch misrepresents the case at hand by drawing a clear line between characteristics and content that in reality is more complicated. Smith claims she is not discriminating based on any characteristic; she simply refuses to create content against her beliefs. She objects not to the person but to the speech that providing the service would create. Gorsuch defends this argument on the grounds that the First Amendment’s “protections belong to all, including to speakers whose motives others may find misinformed or offensive.” [13]

The issue in this case, however, is not the right to free speech, as Gorsuch claims. The issue is that characteristic and content overlap in a way that Gorsuch does not touch on. There is no dispute that the content of the website can convey whatever speech Smith wishes, but as a business owner, she must be willing to offer everyone this speech. She cannot refuse to provide LGBTQ couples with an identical service she provides for heterosexual couples. Smith makes the argument that she would be willing to provide LGBTQ members with other types of websites, just not wedding ones, but that harkens back to Katzenbach v. McClung (1964) : serving one class a different array of services, or a limited menu, is still discrimination as it denotes that one class is deserving of different treatment because of a characteristic. Additionally, the services provided (wedding website design) lead to expressive action of some kind (a wedding website), [14] and objecting to the content inherently objects, in this case, to the protected characteristic of the couple; in refusing to create a website for a same-sex wedding, Smith is refusing to provide her services for a same-sex couple based on a protected characteristic. Sotomayor discusses this in her dissent, referring to characteristic as “status” and content as “message.” She says, “The majority insists that petitioners discriminate based on message, not status. The company, says the majority, will not sell same-sex wedding websites to anyone. It will sell only opposite-sex wedding websites; that is its service. Petitioners, however, cannot define their service as “opposite-sex wedding [websites]” any more than a hotel can recast its services as “whites-only lodgings.” [15] If a business such as Smith is offering a public service, they cannot refuse to serve someone simply because it produces speech they do not like.

While I agree with the Court’s definitions, and I acknowledge that the First Amendment right to freedom of speech is important, I believe that Court came to the wrong conclusion. Gorsuch misrepresents the issue as one of “compelled speech” as opposed to one of conduct and denial of service, disregarding the instances when expressive activities are regulated by the government, as well as the complexities involved when “content” and “characteristic” are inherently connected. While this case may seem like just another public accommodation law case, the implications of the Court’s decision to rule in Smith’s favor could create new loopholes for discriminatory behavior. Professor Theo Myhre from the University of Washington described the impact of the case, saying, “​​This case creates an exception under the First Amendment free speech provision — or for people engaged in expressive activities — when they disagree with the message being sent in that activity. So now businesses that are open to the public, under public accommodations law, have a free speech exception and are able to discriminate against LGBTQ people, if they disagree with the message in the expressive activity.” [16]

[1] “Supreme Court hears arguments on Colorado case pitting free speech against LGBTQ

rights | full audio,” Youtube video, 2:24:10, streamed live by “CBS News” on December 5, 2022, accessed 8 October 2023, https://www.youtube.com/watch?v=6elYU3fqkDM .

[2] 303 Creative v. Elenis, 143 S. Ct 2298, 2334.

[3] 303 Creative v. Elenis, 143 S. Ct 2298, 2312.

[4] 303 Creative v. Elenis, 143 S. Ct 2298, 2334.

[5] 303 Creative v. Elenis, 143 S. Ct 2298, 2312.

[6] 303 Creative v. Elenis, 143 S. Ct 2298, 2335.

[7] 303 Creative v. Elenis, 143 S. Ct 2298, 2318.

[8] 303 Creative v. Elenis, 143 S. Ct 2298, 2336.

[9] Smith also does not need to be a business that serves the public “at large”; she could instead be a private business. Many artists are not regulated by law because they are not public-facing. Smith can still create and produce whatever speech or creative expression she likes, but it must be available to everyone.

[10] 303 Creative v. Elenis, 143 S. Ct 2298, 2332.

[11] 303 Creative v. Elenis, 143 S. Ct 2298, 2332.

[12] 303 Creative v. Elenis, 143 S. Ct 2298, 2332.

[13] 303 Creative v. Elenis, 143 S. Ct 2298, 2317.

[14] 303 Creative v. Elenis, 143 S. Ct 2298, 2337.

[15] 303 Creative v. Elenis, 143 S. Ct 2298, 2339.

[16] Theo Myhre, “Three-Minute Legal Talks: The 303 Creative Case Explained,” The University of Washington School of Law, July 24, 2023, accessed 9 October 2023, https://www.law.uw.edu/news-events/news/2023/303-creative-case .

Works Cited

Camp, Tanner B. “Employers Beware: The Potential Employment-Related Impacts of 303 Creative LLC v. Elenis.” The National Law Review , 31 July 2023, www.natlawreview.com/article/employers-beware-potential-employment-related-impacts-303-creative-llc-v-elenis , accessed 10 October 2023.

Myhre, Theo. “Three-Minute Legal Talks: The 303 Creative Case Explained.” The University of

Washington School of Law, 24 July 2023, www.law.uw.edu/newsevents/news/2023/303creative-case , accessed 9 October 2023.

Oyez . Cornell Law School, Chicago-Kent College of Law, Justia Supreme Court Center, and Legal Information Institute, www.oyez.org .

“Supreme Court hears arguments on Colorado case pitting free speech against LGBTQ rights | full audio.” YouTube , streamed live by CBS News, 5 December 2022,  www.youtube.com/watch?v=6elYU3fqkDM , accessed 8 October 2023.

303 Creative LLC v. Elenis, 143 S. Ct. 2298, 600 U.S.___ (2023). No. 21-476.

“303 Creative LLC v. Elenis.” American Bar Association, 7 December 2022, www.americanbar.org/groups/public_education/publications/preview_home/303-creative-v-elenis/ , accessed 10 October 2023.

Katrina Fay

Katrina Fay, class of 2027, is from South Bend, IN. She is studying political science, economics, and theology. Inspired by her love for legal research and passion for social justice, her essay, “Conduct, Content, and the Supreme Court,” takes a deep dive into the majority opinion of a 2023 Supreme Court case that pitted freedom of speech against LGBTQ+ rights. After college, Katrina intends to pursue a law degree, focusing on either constitutional or international law. Katrina would like to thank Lauryn Sparger, a Hesburgh librarian and law student who helped her access and correctly cite the case, but, most especially, she would like to thank Dr. Ian Gerdon for all his critiques, support, and encouragement throughout the writing process.