Death Doulas Have First Amendment Right to Advise Clients Without Having to Get Funeral Services License

From Judge Ilana Rovner, joined by Judges Candace Jackson-Akiwume and Nancy Maldonado, in yesterday's Richwine v. Matuszak :

Through her business, Death Done Differently, Lauren Richwine offers services as a death doula. In her death doula capacity, Richwine discusses with her clients how they want to be remembered after death, helps clients write letters to loved ones, and provides emotional support to the dying. Richwine teaches families how to support the dying and, after an individual dies, she helps the survivors determine a funeral program, select services at the funeral home of their choice, and, under the supervision of a licensed funeral director, she verbally advises the survivors about the moving, bathing, and dressing of the deceased. She also attends the funeral. In addition