It Shouldn’t Be Illegal to Sell Flowers Without a License in Louisiana
The Story
After the tragic loss of her daughter, Angele Mixson found solace and a renewed sense of purpose in the art of floristry. What began as a personal project to adorn her daughter’s gravesite blossomed into a passion and a potential career path. Angele, self-taught and skilled in flower arranging, aspired to turn this passion into a profession. However, she encountered an unexpected obstacle: Louisiana’s unique and restrictive florist licensing laws. As the only state in the U.S. that requires florists to obtain a license through a costly and challenging examination, Louisiana placed a significant barrier between Angele and her dream.
Determined to challenge these arbitrary restrictions, Angele partnered with the Pelican Institute for Public Policy to file a lawsuit against the Louisiana Horticulture Commission, aiming to defend her right to earn a living through floristry and, by extension, challenge the state’s approach to occupational licensing. This legal action contends that the requirements infringe upon constitutional rights, including those protected by the Due Process, Equal Protection, and Privileges or Immunities Clauses of the Fourteenth Amendment. The case highlights the broader issues of economic freedom, the right to engage in one’s chosen profession, and the significance of artistic expression in the face of restrictive occupational licensing laws.
This case is emblematic of a larger fight for economic freedom and the right to pursue one’s passion and profession without unnecessary governmental interference. Angele Mixson’s journey from grieving mother to advocate for floristry freedom underscores the importance of challenging occupational licensing laws that serve as barriers to entry in professions where such stringent requirements are unwarranted.
The Latest
Victory! On April 30, 2025, the Court granted the joint stipulation and dismissed the case without prejudice, allowing Pelican to declare victory after legislative changes addressed the unconstitutional licensing requirements that prompted the lawsuit.
The Timeline
Complaint. On February 14, 2024, the Pelican Institute filed a Complaint on behalf of Angele challenging the Louisiana florist licensing regime – including an Exhibit that featured many of her skillfully crafted floral creations.
Legislative Victory. On June 11, 2024, Louisiana Governor signed House Bill 933, authored by Rep. Mike Bayham, eliminating the florist licensing and testing requirements and replacing them with a simple operating permit, making Louisiana no longer the only state requiring a license to arrange flowers.
Joint Stipulation of Dismissal. On April 24, 2025, all parties filed a joint stipulation of dismissal without prejudice.
Victory Through Dismissal. On April 30, 2025, the Court granted the joint stipulation and dismissed the case without prejudice, allowing Pelican to declare victory after legislative changes addressed the unconstitutional licensing requirements that prompted the lawsuit.
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