# Amicus Curiae Brief — Goldman v. Weinberger > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385012_0168%3A11 ## Record - **Collection:** Supreme Court brief - **Document type:** Amicus Curiae Brief - **Published:** January 1, 1986 - **Citation:** 475 U.S. 503 ## Text No. 84-1097 JOSE: P| r LiL JR. — Oe < Supreme Court, U.S. FILED gerp 3 1985 IN THE Supreme Court of the United States OCTOBER TERM, 1985 S. SIMCHA GOLDMAN, Petitioner, Vv. CASPAR W. WEINBERGER, SECRETARY OF DEFENSE, et al., Respondents. On Writ of Certiorari to the United States Court of Appeals for the District of Columbia BRIEF OF THE AMERICAN JEWISH COMMITTEE AND CHRISTIAN LEGAL SOCIETY AS AMICI CURIAE SUPPORTING PETITIONER SAMUEL RABINOVE SAMUEL ERIC HANS ERICSSON RICHARD T. FOLTIN Counsel of Record THE AMERICAN KIMBERLEE W0oD COLBY JEWISH COMMITTEE CHRISTIAN LEGAL SOCIETY 165 E. 56th Street P.O. Box 1492 New York, New York 10022 Springfield, VA 22151 (212) 751-4000 (703) 941-3192 WILSON - Eres PRINTING Co.. Inc. - 789-0096 - WASHINGTON. D.C. 20001 he ie ‘BEST AVAILABLE COPY "4 — ret QUESTION PRESENTED Whether the government may compel a military psy- chologist to violate his deeply held religious convictions by prohibiting his wearing an unobtrusive yarmulke. (i) TABLE OF CONTENTS Page ee i en cssensneanneomseossnnoos iii ae iv INTEREST OF AMICI CURIAE ........................................ 1 ES yee 2 i cntteoemvonanens 3 I. THE CONSTITUTION REQUIRES THAT STATE REGULATORY ACTIVITY ACCOM- MODATE THE FREE EXERCISE OF RE- LIGION, EXCEPT WHERE TO DO SO WOULD BE INCOMPATIBLE WITH SOCI- ETY’S COMPELLING INTERESTS ................. 3 II. THE MILITARY IS REQUIRED BY THE FREE EXERCISE CLAUSE TO MAKE THE NARROW AND MINOR REGULATORY EX- CEPTION SOUGHT BY PETITIONER. ............. 7 i _ sethettinddendnasendinaceenaeeceeses 13 (iii) iv TABLE OF AUTHORITIES CASES: Page Bob Jones University v. United States, 460 U.S. a ccmrtnens 6 Cantwell v. Connecticut, 310 U.S. 296 (1940) ......... 5 Chappell v. Wallace, 462 U.S. 296 (1983) ............ 8 Gillette v. United States, 401 U.S. 487 (1971) ...... 6 Goldman v. Weinberger, 734 F.2d 1531, reh. de- nied, 739 F.2d 657 (D.C. Cir. 1984) -................... 9-13 McDaniel v. Paty, 485 U.S. 618 (1978) .................. Murdock v. Pennsylvania, 319 U.S. 105 (1943) ....... 5 Pierce v. Society of Sisters, 268 U.S. 510 (1925)... 5 Prince v. Massachusetts, 321 U.S. 158 (1944) ......... 6 Reynolds v. United States, 98 U.S. 145 (1878) ....... 3,6 Rostker v. Goldberg, 453 U.S. 57 (1981) —.............. 8,9 School District of Abington Township v. Schempp, ee a cet 4 Schlesinger v. Ballard, 419 U.S. 498 (1975) ........... 8 Sherbert v. Verner, 374 U.S. 398 (1963) ................. 4-7 Thomas V. Review Board, 450 U.S. 707 (1981) ....... 5, 7 Thornton Vv. Caldor, 105 S.Ct. 2914 (1985) ........... 4 Torcaso V. Watkins, 367 U.S. 488 (1961) -................ 5 United States v. Lee, 455 U.S. 252 (1982).............. 6 United States v. Seeger, 380 U.S. 163 (1965)........ 6 Wallace v. Jaffree, 105 S.Ct. 2479 (1985) —............ 5 Welsh v. United States, 398 U.S. 333 (1970) _......... 6 Wisconsin Vv. Yoder, 406 U.S. 205 (1972) —............ 3, 5, 7 Zorach Vv. Clauson, 343 U.S. 306 (1952) .....0.......... 7 CONSTITUTIONAL PROVISIONS: U.S. Const. Amend. I _.............. scdichedeseteadsiiatenatiianbienapiinated passim I scesnsumnntpnenstteaaphintit 7 OTHER AUTHORITIES: L. Tribe, American Constitutional Law (1978)... 4 > IN THE Supreme Court of the United States OCTOBER TERM, 1985 No. 84-1097 S. SIMCHA GOLDMAN, - Petitioner, CASPAR W. WEINBERGER, SECRETARY OF DEFENSE, et al., Respondents. On Writ of Certiorari to the United States Court of Appeals for the District of Columbia BRIEF OF THE AMERICAN JEWISH COMMITTEE AND CHRISTIAN LEGAL SOCIETY AS AMICI CURIAE SUPPORTING PETITIONER INTEREST OF THE AMICI CURIAE The American Jewish Committee (“AJC”), a na- tional organization of approximately 50,000 members, was founded in 1906 to protect the civil and religious rights of Jews. It is the AJC’s conviction that the civil and religious rights of Jews will be secure only when the civil and religious rights of Americans of all faiths are equally secure. To fulfill this aspiration, the Ameri- can Jewish Committee strongly supports the First Amendment principle of separation of religion and gov- ernment, which is encapsulated in both the Establishment Clause and the Free Exercise Clause. One corollary of this principle is that only when justified by the com- 2 pelling interests of society may the state prevent an individual from carrying out a practice dictated by his religious beliefs. The Christian Legal Society is a non-profit profes- sional association of 3,500 Christian judges, attorneys, law professors, and law students, founded in 1961. The Center for Law and Religious Freedom is a division of the Christian Legal Society founded in 1975 to protect and promote the freedom of both Christians and other persons in the exercise of their religious beliefs. The Christian Legal Society believes that accommodation by the state of the individual citizen’s religious beliefs, as required by the First Amendment, strengthens the indi- vidual citizen’s respect for, and allegiance to, our con- stitutional government. SUMMARY OF ARGUMENT Captain Goldman is a clinical psychologist in a mili- tary hospital, whose service record has been excellent. For many years, he has worn an unobtrusive yarmulke while working, in accordance with his deeply held reli- gious convictions as an Orthodox Jew. After several years of meritorious service, he was ordered to remove his yarmulke while working, an order directly contrary to his traditional and sincerely held religious beliefs. The First Amendment requires the state to accom- modate an individual citizen’s sincerely held religious beliefs, unless a compelling state interest exists, un- achievable by less restrictive means. On the facts of this case, in which the wearing of a yarmulke was un- challenged for several years, the military’s interest in enforcement of its regulations, merely for the sake of enforcement, does not constitute a state interest of the necessary magnitude to justify abridgment of a service- man’s free exercise rights. Under the First Amendment, Captain Goldman may serve both his religion and his country. 3 ARGUMENT I. THE CONSTITUTION REQUIRES THAT STATE REGULATORY ACTIVITY ACCOMMODATE THE FREE EXERCISE OF RELIGION, EXCEPT WHERE . TO DO SO WOULD BE INCOMPATIBLE WITH SOCIETY’S COMPELLING INTERESTS. Normally, when government acts within the limits of its powers, it is entitled to expect that its laws will pre- vail over individual beliefs. The “concept of ordered liberty precludes allowing every person to make his own standards on matters of conduct in which society as a whole has important interests.” Wisconsin v. Yoder, 406 U.S. 205, 215-16 (1972). Even religious belief cannot “permit every citizen to become a law unto himself.” Reynolds v. United States, 98 U.S. 145, 167 (1878). However, where an impediment to individual religious activity is traceable to state action, the Court has recog- nized that the Free Exercise Clause often compels the government to remove or mitigate such state-imposed impediments. Because of the high value taat the Fram- ers placed on religious liberties, this Court’s cases have emphasized that “‘only those interests of the highest order and those not otherwise served can overbalance legiti- mate claims to the free exercise of religion.”” Wisconsin v. Yoder, 406 U.S. at 215 (1972). Thus, the principle of “accommodation” has been prop- erly invoked by the Court to resolve the conflict between a state-created program of regulations and an individ- ual’s religious beliefs. Indeed, it is the very fact of that state-created conflict which the Court has relied upon to rebut the argument that “an exception from a gen- eral obligation of citizenship on religious grounds may run afoul of the Establishment Clause.” Wisconsin v. Yoder, 406 U.S. at 220-21. Such accommodation is not contrary to this Court’s recent reaffirmation in Wallace v. Jaffree, 105 S.Ct. 2479, 4 2492 (1985), of “the established principle that the Gov- ernment must pursue a course of complete neutrality to- ward religion.” As one noted commentator has stated, neutrality as understood by the Court is not a “ ‘strict neutrality’ theory, which would hold that ‘government cannct utilize religion as a standard for action or in- action because [the two religion clauses] prohibit classi- fication in terms of religion either to confer a benefit or impose a burden.’” L. Tribe, American Constitutional Law 821 (1978), quoting P. Kurland, Religion and the Law 18 (1962). So to understand the Religion Clauses would ignore an existential reality: a seemingly neutral statute may, under certain circumstances, have an un- necessarily greater negative impact upon a religious than upon a nonreligious person because of the former’s reli- gious obligations. Rather, this Court has affirmed: The fullest realization of true religious liberty re- quires that government neither engage in nor com- pel religious practices, that it effect no favoritism among sects or between religion and nonreligion, and that it work deterrence of no religious belief. School District of Abington Township v. Schempp, 374 U.S. 203, 305 (1963) (Goldberg, J., joined by Harlan, J., concurring). This notion of neutrality—which requires, as an essential element, that state action “‘work deter- rence of no religious belief’—clearly contemplates that there may be times when, in order to ensure that state action is neutral with respect to effect, a religion-con- scious accommodation will be permissible (see Zorach v. Clauson, 343 U.S. 306 (1952)) or, at times, compelled. See Sherbert v. Verner, 374 U.S. 398 (1963). 1 The principle of accommodation is consistent with this Court’s recent holding in Thornton v. Caldor, 105 S.Ct. 2914 (1985), which struck down, as a violation of the Establishment Clause, Connecticut’s statute which provided Sabbath observers with an absolute and unqualified right not to work on their chosen Sabbath. That so-called “accommodation” involved no state action which deterred religious practice. Because it attempted “to lift a burden 5 This Court’s cases have outlined the areas in which a state’s interest is not deemed sufficiently compelling to override a claim to free exercise of religion, so that accommodation of religious practice is required. The state may not engage in regulative activity which has the effect of compelling or prohibiting, regulating, or taxing the expression of religious beliefs, where a more narrowly drawn regulation would suffice to serve the state’s compelling interests. See Cantwell v. Connecticut, 310 U.S. 296 (1940) ; Murdock v. Pennsylvania, 319 U.S. 105 (1943); Torcaso v. Watkins, 367 U.S. 488 (1961). Neither may a state enact a qualification for public serv- ice which, without sufficient connection to a legitimate government objective, deters an individual from engag- ing in activities compelled, or powerfully induced, by his religious beliefs. See, e.g., McDaniel v. Paty, 435 U.S. 618 (1978). Such actions with respect to religion clearly lie outside the government’s ambit of authority. Similarly, where a government-mandated system of com- pulsory education poses obstacles to deeply held religious beliefs, believers are guaranteed an opportunity to send their children to privately financed religious schools or, in certain situations, to refrain from schooling alto- gether. See generally, Pierce v. Society of Sisters, 268 U.S. 510 (1925), and Wisconsin v. Yoder, supra. A pub- lic system of unempioyment compensation that provides no benefits to persons who voluntarily refrain from work may not deny coverage to an employee whose resignation was precipitated by a conflict between work requirements and sincere religious convictions. Thomas v. Review Board, 450 U.S. 707 (1981); Sherbert v. Verner, supra. Thus, this Court has limited governmental regulation of overt acts prompted by religious principles to cases on religious practice . . . imposed by private employers” it was “not the sort of accommodation statute specifically contemplated by the Free Exercise Clause.” Jd. at 2919 (O’Connor, J., con- curring). See Wallace v. Jaffree, 105 S.Ct. at 2497 (O’Connor, J., concurring). 6 where the regulated conduct poses “some substantial threat to public safety, peace or order.” Sherbert Vv. Verner, 374 U.S. at 403 (1963). The cases in which this Court has upheld the claim of governmental author- ity against a free exercise challenge uniformly fit within these narrow categories.” Thus, the interest of the state is not only valid but compelling in matters of health and child welfare, Prince v. Massachusetts, 321 U.S. 158 (1944) (child labor laws enforceable so as to prevent children’s sale of religious literature), or where the duty from which an individual seeks exemption is one of the essential responsibilities of citizenship in our modern society, necessary to preserve peace or the orderly oper- ation of society. See Gillette v. United States, 401 U.S. 437, 461-462 (1971) (no free exercise right to avoid military service based upon religiously-based conscien- tious objection to a particular war) ;* United States v. Lee, 455 U.S. 252 (1982) (no free exercise right to avoid paying taxes) .* 2 An additional category of “morals” is sometimes added. Obvi- ously, this is not taken to mean that government may decide which religions are “moral” or “immoral”. Rather, this category is not altogether distinct from threats to “public order’, in that restric- tions are justifiable only when the conduct in question assaults one of the most fundamental bedrock values of our society or legal order, such as the principle of nondiscrimination embodied in the Fourteenth Amendment or the prohibition of polygamy. Bob Jones University v. United States, 460 U.S. 574 (1983); Reynolds v. United States, 98 U.S. 145 (1878). 3 While there may not be a First Amendment right to avoid military service on religious grounds, this Court has clearly established that the allowance of such accommodation of religious belief (broadly defined) is within Congress’ prerogative. Welsh v. United States, 398 U.S. 333 (1970); United States v. Seeger, 380 U.S. 163 (1965). * The decision in Lee was predicated on the realistic assessment that the sccial security system is not an individual “insurance” system (from which a religious group providing its own system of social and personal insurance might legitimately claim exemp- 7 By way of contrast, this Court has found even com- pelling state interests insufficient to override a claim to exemption from state programs, based upon religious be- lief, where granting the religious claim would cause no harm to others and would involve only de minimis altera- tions of a governmental legislative or regulatory scheme. See, e.g., Wisconsin v. Yoder, supra (state compulsory education laws); Thomas v. Review Board, supra (state unemployment benefits system); Sherbert v. Verner, supra (same). Il. THE MILITARY IS REQUIRED BY THE FREE EXERCISE CLAUSE TO MAKE THE NARROW AND MINOR REGULATORY EXCEPTION SOUGHT BY PETITIONER. Were it not for the military setting in which this case arises, there would be no question whatever, based upon the principles enunciated above, that the precedents of this Court would compel judgment for Captain Goldman. The case at bar involves a claim to a minor exception from governmental rules imposed for the sake of uniform- ity and administrative convenience. The legitimacy and sincerity of the claimant’s religious belief is unchallenged. Captain Goldman asks for no special benefits of a sub- stantive nature; nor does he ask for exemption from fun- damental duties incident to citizenship in the nation, such as payment of taxes, or. availability for military service; nor does the exception sought interfere with any govern- ment rule designed to insure safety, peace, health or pub- lic order. All Captain Goldman asks is that civil govern- ment “accommodate[] the public service to [his] spiritual needs.” Zorach v. Clauson, 343 U.S. at 314 (1952). Not- withstanding the military setting, a fair application of tion), but a system of general taxation and transfer payments and, as such, indistinguishable from the obligation to pay taxes gen- erally. 455 U.S. at 258 (“mandatory participation is indispensable to the fiscal vitality of the social security system”). See U.S. Const. Amend. XVI. 8 the Free Exercise Clause requires that Captain Goldman be granted the narrow, limited exception which he seeks from the dress regulations promulgated by the United States Air Force. This Court has consistently provided more that its usual “customary deference” to a coequal branch of govern- ment in determining the constitutionality of congressional judgments with respect to the national defense and mili- tary matters. See Chappell v. Wallace, 462 U.S. 296, 300 (1983) ; Rostker v. Goldberg, 453 U.S. 57, 64-66 (1981). Nevertheless, the Court explicitly has acknowledged that military matters are subject to constitutional limitations, stating: None of this is to say that Congress is free to dis- regard the Constitution when it acts in the area of military affairs. In that area, as in any other, Con- gress remains subject to the limitations of the Due Process Clause, but the tests and limitations to be applied may differ because of the military context. We of course do not abdicate our ultimate responsi- bility to decide the constitutional question, but sim- ply recognize that the Constitution itself requires such deference to congressional choice. Rostker, 453 U.S. at 67 (citations omitted). In according this deference, however, this Court ex- plicitly declined the Government’s invitation further to refine the applicable tests, where allegations of constitu- tional violations are directed at the military, so as to require only that challenged regulations bear a “rational relation to some legitimate Government purpose”. Zd. at 69. To the contrary, this Court explicitly noted that it had not previously applied “a different equal protection test because of the military context,” id. at 71 (citing Schlesinger v. Ballard, 419 U.S. 498 (1975)), and pro- ceeded to determine whether the challenged “action trans- gressed an explicit guarantee of individual rights”, even in light of the judicial deference to congressional mili- 9 tary expertise. Jd. at 70. Whatever the appropriate stand- ard for examination of a military determination subject to constitutional challenge (whether “strict scrutiny” or an intermediate standard), it is clear, under Rostker, that there is a judicial obligation to determine whether indi- vidual rights guaranteed by the Constitution—be they the right of free exercise or the right to equal protection —have unjustifiably been subject to encroachment. The court below acknowledged its constitutional obliga- tion, consonant with Rostker, to determine whether the Air Force’s refusal to accommodate the requirements of its dress code to Captain Goldman’s religiously compelled requirements to wear a yarmulke served “legitimate mili- tary ends .. . sought to be achieved by means designed to accommodate the individual rigui to an appropriate de- gree.” 734 F.2d 1531, 1536. However, notwithstanding this acknowledgment, the Court of Appeals failed prop- erly to balance “legitimate military ends” against “indi- vidual rights.” Rather, the Court of Appeals abdicated even the limited role which the judiciary must play in the context of the military. This appears evident from the Court of Appeals’ own enumeration and assessment of the Air Force’s justifications for its refusal to accom- modate Captain Goldman’s religious practices. Thus, the Court of Appeals rightly found “unpersua- sive” the Air Force’s argument that one reason for scrupulous uniformity with respect to its dress code is safety, finding that “more narrowly drawn regulations, accommodating religious practices to a greater degree, would satisfy such safety concerns”. 734 F.2d at 1539. The court also noted the potential weakness of the argu- ment that “if members of numerous other religions with distinctive garb flood the Air Force with requests for ex- emptions, . . . severe disruption would result”, by observ- ing that “[t]his argument assumes that substantial num- bers of these sects have enlisted and would be likely to request exemptions. .. .” Id. 10 The Court of Appeals further found “weak” an Air Force argument that “it cannot reasonably distinguish {the relative obtrusiveness] among various religious prac- tices, but must either allow or disallow all requested ex- ceptions.” Jd. In a telling critique of this Air Force ra- tionale, the Court of Appeals stated: [It] appears that the Air Force already distinguishes among practices that may be religious, for the regu- lations permit certain deviations from complete visi- ble uniformity, such as the wearing of rings and bracelets of nonuniform design, see AFR 35-10 § 1- 12(b) (1) (b), and have been interpreted to allow the wearing of nonuniform undergarments and orna- ments, provided they are not visible beneath the re- quired uniform, despite the existence of military- issue undergarments. The Air Force, therefore, does distinguish, for example, Mormons who wear “tem- ple garments” underneath their outer clothing from Orthodox Jews, whose religious garb, though visible, is nearly as unobtrusive. If obtrusiveness is the underlying standard actually employed in making these distinctions, the Air Force arguably should be required to employ it in a more thoroughgoing man- ner, in order to accommodate rights of free exercise to the greatest possible extent. Id. at 1540. Having effectively rebutted the Air Force’s assertion that the challenged regulations were necessarily connected to various purported regulatory purposes, the Court of Appeals nonetheless abruptly concluded that: (T]he peculiar nature of the Air Force’s interest in uniformity renders the strict enforcement of its regu- lation permissible. That interest lies in the enforce- ment of regulations, not for the sake of the regula- tions themselves, but for the sake of enforcement. Its regulations are necessarily arbitrary .... Unlike the states in Wisconsin v. Yoder, Thomas v. Review Board, and Sherbert v. Verner, whose interests in enforcing their rules would not be greatly impaired 11 by making exceptions when enforcement would not serve the purpose underlying the rules, the Air Force has no concrete interest separate from the effect of strict enforcement itself. Id. This finding was premised on the Air Force’s asser- tion that flexibility as to Captain Goldman’s religious claim would breed resentment among other servicemen and thereby adversely affect discipline. Thus, the challenged regulations were, in essence, up- held by the Court of Appeals solely because the military’s need for discipline requires uniform adherence to its rules, no matter how arbitrary and regardless of counter- vailing constitutional considerations. The rationale that uniform application of regulations is necessary for its own sake may be justifiable when fundamental constitu- tional rights are not directly and uncontrovertibly impli- cated. However, when a fundamental constitutional right is undeniably at stake, to uphold governmental regula- tions without further judicial inquiry is to create a stand- ard of inquiry which places virtually any military action beyond review of the courts. Manifestly, any regulation, having otherwise failed of justification, can be justified as necessary not for its own sake, “but for the sake of enforcement.” As Judge Starr, dissenting from the de- nial of the petition for a rehearing en banc, cogently stated : Not a scintilla of evidence in the record suggests that [Petitioner’s] wearing of a yarmulke caused any resentment whatever in others. The claim is con- tradicted by expert testimony, credited by the trial court, that making exceptions to accommodate deeply held religious beliefs would defuse rather than cause resentment. The claim is also at odds with’common sense. Reasonable servicemen would more justly be annoyed with the mechanical enforcement of arbi- trary rules that prevent the wearing of such unob- trusive symbols of religious faith while allowing oth- ers to wear religious rings and bracelets. 12 739 F.2d 657, 659. It should be stressed in this regard that Captain Goldman wore his yarmulke on duty for many years, with no hint of “resentment” among his fellow servicemen. /d. The Air Force’s justification for enforcement of an ad- mittedly arbitrary dress regulation, in the face of Captain Goldman’s religiously-compelled obligation to wear a small skulleap which is neither obtrusive nor displaces military dress, runs counter to expert testimony and common sense. Moreover, it runs counter to the fundamental no- tion that the Free Exercise Clause requires “those in au- thority to accommodate those who wish to exercise their religious liberties, unless the accommodation would prove unduly burdensome.” Jd. Even the appropriately great deference that this Court must allow to the military with respect to determination of its own needs cannot allow the Air Force to sweep aside First Amendment guarantees, with no more than conclusory assertions, contradicted by the record and by common sense. The imperative that the Court diligently pursue its otigation to determine whether the accommodation of religion sought by Captain Goldman “would prove unduly burdensome” is made even more compelling when one con- siders that the Air Force’s mechanical enforcement of an arbitrary dress regulation prevented Captain Goldman’s wearing of an unobtrusive symbol of religious faith even while allowing others to wear, for religious reasons, items of apparel which were not part of the standard uniform. The Court of Appeals itself acknowledged, in rebutting the claim that the prevention of “obtrusiveness” had been the Air Force’s guiding principle, that: [It is} no answer to assert . . . that wearing rings and special undergarments are not exceptions to the uniform requirements, on the ground that the regu- lation specifically allows them, because the reason for the difference in treatment of various nonstand- 13 ardized articles of clothing and ornaments, rather than the fact of the difference, would [then] be at issue. 734 F.2d at 1246. However, the Court of Appeals’ ruling, premised on the military’s assertion that the uniformity imposed by the dress regulation is necessary for the sake of enforcement, raises exactly that issue—the issue of why regulations were enacted allowing one variety of religious observance, while, at the same time, other regulations forbid a practice of another faith which is indistinguish- able in terms of obtrusiveness or interference with duty. Not only free exercise concerns, but also weighty con- cerns of equal protection, are raised when the military may arbitrarily, and without objectively verifiable justifi- cations, ordain that certain religiously-compelled dress requirements are forbidden and others are not. In the absence of any evidence supporting the justi- fications espoused by the Air Force for its failure to ac- commodate Captain Goldman, accommodation is required. In the alternative, at the least, this matter should be re- manded for further evidence with respect to those justifi- cations. CONCLUSION Accordingly, amici curiae urge this Court to reverse the judgment of the court below. Respectfully submitted, SAMUEL RABINOVE SAMUEL ERIC HANS ERICSSON RICHARD T. FOLTIN Counsel of Record THE AMERICAN KIMBERLEE WO0oD COLBY JEWISH COMMITTEE CHRISTIAN LEGAL SOCIETY 165 E. 56th Street P.O. Box 1492 New York, New York 10022 Springfield, VA 22151 (212) 751-4000 (703) 941-3192 --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385012_0168%3A11. Public record. Not legal advice.