A body of state and federal law allows persons and institutions in the healthcare industry to assert conscience-based refusals to provide patient services. While early healthcare refusal laws focused on the conscience claims of professionals opposed to performing certain procedures, over time refusal laws expanded through concepts of complicity to cover an increasing number of persons and institutions in healthcare services. The complicity-based conscience claims in Hobby Lobby resemble and perhaps descended from these legislated exemptions, popularly termed healthcare refusal laws or conscience clauses.