“…272 In the aftermath of Hobby Lobby, Terri Day, Leticia Diaz, and Danielle Weatherby argue that Elane Photography and numerous cases filed since represent a "growing trend in which for-profit businesses are invoking their deeply held religious beliefs to excuse themselves from serving gay and lesbian customers" as well as an example of the potential slippery slope for the religious exercise protections the Supreme Court recognized in Hobby Lobby. 273 This trend even extends to government employees. For example, in September 2015, County Clerk Kim Davis, of Rowan, Kentucky, cited her religious beliefs when she refused to issue marriage licenses to same-sex couples.…”