The Supreme Court just weakened the main legal tool against conversion therapy. Jewish patients facing a parallel ideological harm in the therapist’s chair should be paying attention.
The Supreme Court’s 8-1 decision in Chiles v. Salazar has prompted immediate and understandable alarm.1 By holding that Colorado’s ban on conversion therapy for minors is “presumptively unconstitutional” as applied to talk therapy, the Court has signaled that the First Amendment limits states’ ability to regulate what licensed therapists tell vulnerable patients. Over twenty states passed similar laws banning conversion therapy—debunked practices that claim to alter gender identity and sexual orientation; those bans will now face legal challenges as well.
The concern is justified. But the outrage over Chiles—driven by advocates who rightly see conversion therapy as weaponizing the clinical relationship against a patient’s identity—has obscured a parallel problem. Conversion therapy is not the only ideology being imposed on patients from the therapist’s chair. It is merely the one that progressive institutions have chosen to oppose.
Since October 7, 2023, a different form of ideological capture has taken hold across the mental health field.2 The Decolonizing Therapy Movement has been spreading through clinical training programs, importing a political framework that treats Zionism—and by extension, mainstream Jewish identity—as a form of colonial pathology. In a Decolonizing Therapy social media post, Zionism appears alongside “rape culture” and “genocidal tendencies” as attributes in a diagram of a “colonized mind.”3 Jewish therapists have been blacklisted from referral networks based on presumed political affiliations.4 Jewish patients presenting with trauma related to antisemitism have encountered clinicians who reframe their distress through a lens that treats their identity as complicit in oppression rather than worthy of support.5 The problem has become so widespread that the U.S. House of Representatives Committee on Education and the Workforce has opened a formal investigation into antisemitism at the American Psychological Association (“APA”), the nation’s foremost accreditor for psychological training and continuing-education programs.6
The parallel is hard to miss. Both practices subordinate the patient’s experience to the therapist’s ideology. Conversion therapy tells LGBTQ patients their orientation is disordered and must be corrected. Followers of Decolonizing Therapy tell Jewish patients that their connection to Jewish peoplehood is a colonial artifact—something to be dismantled rather than supported. In both cases, the therapist’s chair becomes a vehicle for ideology, not care.
There is now a case in Texas that highlights these very concerns. In Junger v. DSquared Relationships PLLC,7 currently before a federal court in Texas, two Jewish therapists allege they were fired from a counseling practice after objecting when the clinic selectively restricted discussion of Jewish identity and antisemitism, while other identity-based topics were discussed freely. According to the complaint and deposition record, when a non-Jewish therapist sought guidance from her Jewish colleagues about a Jewish patient presenting with identity-related trauma, the clinic owner intervened, stating that soliciting input from Jewish therapists would yield a “one-sided response.” The Jewish therapists who objected to that characterization were terminated within days.
What the case record reveals is not the overt antisemitism most people picture. The clinic owners did not use slurs. Instead, as alleged, they operated from a subtler framework: Jewish perspectives on Jewish experiences were treated as inherently unreliable; Jewish advocacy was dismissed as performance; and Jewish trauma was recharacterized as political rather than clinical. In depositions and text messages now in the court record, one owner described the terminated therapists as “zealots” whose concerns were “part of the victim story,” while the other stated that the therapists’ emails were changing her views of Jewish people generally to “aggressive.” If proven, this is not hatred as most people understand it. It is bias—the kind that does the most damage precisely because it does not recognize itself as prejudice.
This is where Chiles creates a genuine problem. Justice Gorsuch’s majority opinion emphasizes that the First Amendment prohibits states from using licensing authority to prevent therapists from “sharing particular views with patients.” If conversion therapy bans are presumptively unconstitutional because they regulate the viewpoints therapists express, then state licensing boards will have even less power to address ideological frameworks that target Jewish patients under the guise of clinical practice. The very tool that progressive advocates used to protect LGBTQ youth—regulating what therapists can say—has been weakened in a way that also leaves Jewish patients exposed to a structurally identical harm.
If the principle animating opposition to conversion therapy is that therapists should not weaponize the clinical relationship to undermine a patient’s identity, that principle must apply regardless of which identity is being targeted and regardless of which ideological framework is doing the targeting. A therapist who tells a gay teenager his orientation is sinful is committing the same category of professional violation as a therapist who tells a Jewish patient her connection to Jewish peoplehood is colonial. The political valence is different. The harm is the same.
The Junger case points toward what may now be the more viable legal path. The plaintiffs brought claims under Section 1981 of the Civil Rights Act of 1866—one of the oldest federal anti-discrimination statutes—alleging that singling out Jewish identity in a professional setting constituted race-based discrimination and that firing the therapists who objected was unlawful retaliation. A pending summary judgment motion argues that the defendants effectively admitted in depositions that the therapists were fired for pushing back and should be found liable as a matter of law. If the court agrees, it will send a clear message: treating Jewish identity as uniquely suspect in professional settings carries consequences under federal civil rights law—consequences that do not depend on the state regulatory authority that Chiles has now constrained.
That would matter far beyond one practice in East Texas. It would give legal teeth to a pattern Jewish clinicians and patients have encountered with increasing frequency: the quiet assumption that Jewish perspectives are partisan, Jewish trauma is political, and Jewish advocacy is performance. These assumptions are not confined to fringe practitioners. They are embedded in training materials, supervision, and institutional culture—and they operate through the same mechanism as conversion therapy: the authority of the therapeutic relationship.
The Court’s decision in Chiles may have limited what states can do through professional regulation. It has not limited what federal civil rights law can do through anti-discrimination enforcement. For those who believe the therapeutic relationship should serve patients rather than ideologies, both tools were always necessary. Now one of them is weaker. The other has never been more important.
Disclaimer: The opinions and views expressed in this article are those of the author and not necessarily those of The National Law Review. The author is affiliated with The Lawfare Project, which represents the plaintiffs in Junger v. DSquared Relationships PLLC.
[1] Chiles v. Salazar, 607 U.S. ___, No. 24-539 (2026) (Gorsuch, J.), https://www.supremecourt.gov/opinions/25pdf/24-539_fd9g.pdf.
[2] Miri Bar-Halpern & Jaclyn Wolfman, Traumatic Invalidation in the Jewish Community After October 7, 35 J. Hum. Behav. Soc. Env’t (2025), https://doi.org/10.1080/10911359.2025.2503441.
[3] Decolonizing Therapy Fuels Antisemitism, Jerusalem Post (July 29, 2025) (discussing a “colonized mind” infographic circulated on the Decolonizing Therapy social media page placing Zionism alongside “rape culture” and “genocidal tendencies”), https://www.jpost.com/diaspora/antisemitism/article-862643.
[4] Sally Satel, Inside the Campaign to Blacklist ‘Zionist’ Therapists, The Free Press (Aug. 12, 2024) (documenting an organized effort by members of a Chicago anti-racist therapist group to compile and circulate a blacklist of therapists with “Zionist affiliations”), https://www.thefp.com/p/campaign-to-blacklist-zionist-therapists.
[5] Sally Satel, Anti-Semitism on the Couch, Commentary (Jan. 20, 2026), https://www.commentary.org/articles/sally-satel/antisemitism-american-psychological-association/; see also Daniel Balva, The Abandonment of Jewish Therapists: Antisemitism in the Mental Health Field, ISGAP (July 2, 2025), https://isgap.org/flashpoint/the-abandonment-of-jewish-therapists-antisemitism-in-the-mental-health-field/.
[6] See Letter from Tim Walberg, Chairman, House Comm. on Educ. and the Workforce, to Dr. Debra Kawahara, President, American Psychological Association (Dec. 12, 2025); https://edworkforce.house.gov/uploadedfiles/apa_letter_12.10.2025.pdf).
[7]Junger et al. v. DSquared Relationships PLLC et al., No. 4:25-cv-00650 (E.D. Tex. filed June 18, 2025).
