Olympus Spa v. Armstrong

138 F.4th 1204 (9th Cir. 2025) · United States Court of Appeals for the Ninth Circuit · March 12, 2026 · No. 23-4031

Summary

The Ninth Circuit amended its opinion affirming dismissal of Olympus Spa’s First Amendment challenge to enforcement of the Washington Law Against Discrimination against the spa’s policy excluding preoperative transgender women. The court held that the enforcement action did not impermissibly burden the spa’s rights to free speech, free exercise, or expressive association. The accompanying order denied panel rehearing and rehearing en banc.

Court
United States Court of Appeals for the Ninth Circuit
Writing for the Court
M. Margaret McKeown; Ronald M. Gould; Kenneth K. Lee
Jurisdiction
United States Court of Appeals for the Ninth Circuit
Decision date
March 12, 2026
Docket number
23-4031
Procedural posture
Appeal from dismissal with prejudice under Federal Rule of Civil Procedure 12(b)(6) of a constitutional challenge to enforcement of the Washington Law Against Discrimination.
Standard of review
The court reviewed the Rule 12(b)(6) dismissal de novo. It applied intermediate scrutiny under United States v. O'Brien to the Spa's incidental free-speech claim, rational basis review to its free-exercise claim because the Washington Law Against Discrimination was neutral and generally applicable and imposed only incidental burdens, and the associational-rights standards governing intimate and expressive association.
Precedential value
published precedential opinion
Parties
Olympus Spa, Myoon Woon Lee, Sun Lee, Jane Doe, patron, Jane Does, employees 1–3 v. Andreta Armstrong, Madison Imiola
Disposition
affirmed

Topics

free speechfree exercise clausestatutory interpretationstandard of reviewappellate procedure

Practice areas

constitutional lawcivil rightsFirst Amendmentpublic accommodationsappellate procedurestatutory interpretation

Questions Presented

  1. Whether enforcement of the Washington Law Against Discrimination impermissibly compelled or restricted the Spa's speech in violation of the First Amendment.
  2. Whether the Washington Law Against Discrimination, as applied to the Spa, violated the Free Exercise Clause because it burdened the Spa's religious beliefs.
  3. Whether the Spa and its patrons constituted an intimate or expressive association protected by the First Amendment.
  4. Whether the Washington Law Against Discrimination applied to the Spa's exclusion of preoperative transgender women.

Holdings

  1. The Washington Law Against Discrimination prohibits discrimination in public accommodations based on sexual orientation, and Washington's statutory definition of sexual orientation expressly includes gender expression or identity. The statute therefore applied to the Spa's exclusion of preoperative transgender women.
  2. WLAD enforcement did not violate the Spa's First Amendment free-speech rights because the required changes to the Spa's written entrance policy were incidental to regulating unlawful discriminatory conduct, not direct regulation of protected expression.
  3. WLAD is neutral and generally applicable and imposes only an incidental burden on religious exercise; its application to the Spa therefore was subject to rational basis review and did not violate the Free Exercise Clause.
  4. The Spa was neither an intimate association nor an expressive association protected by the First Amendment.

Key quotations

But it is also unambiguous, and it applies to the Spa’s entrance policy. (8)
The mandated alterations were “plainly incidental to the [challenged law’s] regulation of conduct. (13)
As applied, the statute does not abridge the Spa’s rights to free speech, free exercise, or free association. (28)

Factual background

Olympus Spa operates two Korean spas in Washington that require nudity for certain services and maintain sex-segregated facilities. The Spa's entrance policy admitted biological women and post-operative transgender women but excluded preoperative transgender women who had not undergone genital surgery. After a complaint, the Washington State Human Rights Commission determined that the policy violated the Washington Law Against Discrimination and obtained a settlement requiring the Spa to remove the biological-women language and adopt a policy affirming equal access without regard to sexual orientation or gender identity. The Spa sued state officials, alleging that enforcement of the statute violated its First Amendment rights to free speech, free exercise of religion, and association.

Procedural history

The Washington State Human Rights Commission investigated Olympus Spa after a transgender woman complained that the Spa denied her access under a biological-women-only entrance policy. The Spa entered a pre-finding settlement agreement requiring compliance with the Washington Law Against Discrimination and removal of the biological-women language from its website, while reserving the right to bring a constitutional challenge. The Western District of Washington dismissed the Spa's amended complaint with prejudice, and the Ninth Circuit affirmed. The Ninth Circuit later denied panel rehearing and rehearing en banc and filed this amended opinion.

Court Document

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