Petition for Writ of Certiorari: Table of Contents

The content of this petition may be viewed on-line by using the links below or the entire document may be downloaded as a (very large) pdf file.



Questions Presented

  1. Is the Commissioner of Internal Revenue entitled to a blanket exemption from the application of the Religious Freedom Restoration Act of 1993 (“RFRA”), 42 U.S.C. § 2000bb, et seq., despite the absence of any such exemption in the statute and this Court's determination that blanket exceptions to RFRA should be neither inferred nor accepted on the basis of the government's generalized invocation of a need for uniformity in the administration of a federal program?
  2. Can Ninth Amendment rights “retained by the people” be identified by examining liberties clearly existent at the time of the adoption of the Constitution and the Bill of Rights, as reflected in, for example, colonial and early state constitutions and legislation, so as to guarantee the right of conscientious objection to compelled participation in warfare that was well-established at the founding of this nation?

Table of Contents