Filed Date: Dec. 19, 2025
Case Ongoing
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This case is a First Amendment constitutional challenge to a State Commission on Judicial Conduct who disciplined a Texas justice of the peace who refused to officiate marriage ceremonies for same-sex couples.
On December 19, 2025, a Texas justice of the peace filed this lawsuit in the United States District Court for the Western District of Texas. The plaintiff, represented by Mitchell Law PLLC, sued the State Commission on Judicial Conduct seeking declaratory and injunctive relief, as well as damages, under 42 U.S. § 1983. According to the complaint, the justice of the peace refused to officiate weddings for same-sex couples on account of her religion. In 2019, the State Commission consequently investigated her, resulting in a public warning and a finding that she violated Canon 4A(1) of the Texas Code of Judicial Conduct. Despite the Texas Supreme Court adopting a comment in October 2025 stating it's not a violation for judges to refrain from performing weddings based on sincere religious belief, the Commission allegedly continues to threaten discipline if she performs opposite-sex weddings while refusing same-sex ones. The plaintiff alleged this violated her First Amendment rights and urged the courts to overrule Obergefell v. Hodges, 576 U.S. 644 (2015), which recognized a constitutional right to marry for same-sex couples. The case was assigned to District Judge Leon Schydlower.
As of February 22, 2026, this case is ongoing.
Summary Authors
Haleigh Knowles (2/22/2026)
Geoffrey Moseley (2/25/2026)
For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/72061951/parties/hensley-v-steel/
Albright, Alan D. (Texas)
Schydlower, Leon (Texas)
Mitchell, Jonathan F. (Texas)
See docket on RECAP: https://www.courtlistener.com/docket/72061951/hensley-v-steel/
Last updated Feb. 22, 2026, 7:12 p.m.
State / Territory:
Case Type(s):
Key Dates
Filing Date: Dec. 19, 2025
Case Ongoing: Yes
Plaintiffs
Plaintiff Description:
Texas justice of the peace
Plaintiff Type(s):
Public Interest Lawyer: No
Filed Pro Se: No
Class Action Sought: No
Class Action Outcome: Not sought
Defendants
State
State Commission on Judicial Conduct
Case Details
Causes of Action:
Constitutional Clause(s):
Other Dockets:
Western District of Texas 6:25-cv-00595
Available Documents:
Outcome
Prevailing Party: None Yet / None
Relief Sought:
Relief Granted:
Source of Relief:
Issues
General/Misc.:
LGBTQ+:
Case Summary of Hensley v. Steel, Civil Rights Litig. Clearinghouse, https://clearinghouse.net/case/47541/ (last updated 2/25/2026).