Is a church a place of public accommodation and if so – are congregations required to follow anti-discrimination laws regarding gender and sexual orientation?

That’s the issue raised by a brochure published by the Iowa Civil Rights Commission. They contend that any church that opens its doors to the public would be required to comply with sexual orientation and gender identity laws.

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It’s unclear when the Commission’s brochure was published, but it clearly outlines their interpretation of the 2007 Iowa Civil Rights Act – known as Iowa Code Chapter 216.

First Liberty Institute is representing Cornerstone World Outreach, a Sioux City church that fears it may be in violation of the statute.

Hiram Sasser, the law firm’s director of litigation, said the Commission’s brochure means churches would be required to let transgender individuals use the bathrooms of their choice.

“It further compels our client to use specific pronouns when referring to certain ‘gender identities’ and prohibits our client from even teaching its religious beliefs,” Sasser said.

 “Cornerstone World Outreach cannot be made to open its restrooms for use by individuals in accordance with their gender identities, rather than their sex assigned at birth,” Sasser said.

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The law firm fired off a demand letter to the Iowa Civil Rights Commission calling for them to amend its published policy to clarify that it will not apply Iowa Code 216 against churches and they must also acknowledge that Cornerstone World Outreach is exempt from enforcement.

I reached out to the Iowa Civil Rights Commission for clarification on their interpretation of the law – but so far they have not returned my correspondence.

Chelsey Youman, First Liberty’s chief of staff, told me the ramifications of Iowa’s policy cannot be overstated.

“This is an unprecedented move by a government agency to mandate that anytime a church opens its doors to the public that it automatically qualifies as a place of public accommodation,” Youman said. “And this is just the tip of the iceberg.”

Pastor Cary Gordon accused the Iowa Civil Rights Commission of “acting like a First Amendment Gestapo – to hunt down and harass churches and local businesses trying to live out their Christian convictions.”

“Based on what they are saying, orthodox Christianity is in violation of the state law of Iowa,” the pastor told me.

The brochure on sexual orientation and gender identity has a section titled, “Does this law apply to churches?”

Just so liberals won’t accuse me of taking this out of context – I’m going to provide you with the entire answer:

“Does this law apply to churches? Sometimes.  Iowa law provides that these protections do not apply to religious institutions with respect to any religion-based qualifications when such qualifications are related to bona fide religious purpose. Where qualifications are not related to a bona fide religious purpose, churches are still subject to the law’s provisions. (e.g. a child care facility operated at a church or a church service open to the public.”

A few thoughts here, folks:

Does that mean churches must allow men who identify as women to use the bathrooms of their choice during Wednesday night church suppers? Are congregations required to let transgender folks play on the church softball teams of their choice? What about church-related sporting events for children? Are those events covered under the law?

And which government agency decides what is and what is not a “bona fide religious purpose”?

“Such emphasis highlights the Commission’s intention to not only heavily scrutinize the validity and sincerity (of the) religious doctrines of our client and other religious institutions, but also the very legitimacy of the church as a religious body,” reads the First Liberty letter to the Civil Rights Commission.

But the most concerning part of the policy involves the public accommodation clause. The Commission states that churches that open their services to the public would have to comply with the law.

Well, that covers just about every church in the state – because that’s the point of Sunday services. Churches want everyone to attend their services – saints and sinners.

Attorney Youman tells me if the rules are enforced, it could lead to significant trouble for people of faith.

“The state claims it has the power to regulate what the church even teaches – what they are allowed to say from the pulpit – in addition to how they operate regarding matters of gender and sexuality,” she said. “If the church has a doctrine or theology that is at odds with the state and they speak out about that – they can have the full weight of the law brought down against them.”

To be clear – no church in Iowa has been accused of violating the law – but Pastor Gordon only believes it’s a matter of time before an activist files a complaint.

“It’s a harbinger of more trouble to come if we don’t address it right now and hold them accountable to what they are saying,” he said.

Todd Starnes is host of Fox News & Commentary, heard on hundreds of radio stations. His latest book is "God Less America: Real Stories From the Front Lines of the Attack on Traditional Values." Follow Todd on Twitter @ToddStarnes and find him on Facebook.