In Masterpiece Cakeshop, Ltd. v. Colorado Civil Rights Comm’n, U.S. Supreme Court Associate Justice Neil Gorsuch cites Model Penal Code §§ 1.13 and 2.02(2)(a)(i) and Restatement Second of Torts § 8A in his concurring opinion discussing the distinction between intended and knowingly accepted effects of the bakers’ conduct.