Amicus Curiae Brief — Am. Legion v. Am. Humanist Ass'n, 139 S. Ct. 451 (2018) (No. 17-1717)

Nos. 17-1717, 18-18

In The Supreme Court of the Anited States

AMERICAN LEGION, et. ai.,

Petitioners,

v.

AMERICAN HUMANIST ASS’N, et. ai.,

Respondents.

MARYLAND-NATIONAL CAPITAL PARK AND PLANNING

COMMISSION,

Petitioner,

Vv.

AMERICAN HUMANIST ASS’N, et. ai.,

Respondents.

On Writs of Certiorari

to the U.S. Court of Appeals for the Fourth Circuit

BRIEF AMICI CURIAE FOR THE MILITARY

RELIGIOUS FREEDOM FOUNDATION AND

SIXTEEN HIGH-RANKING MILITARY OFFICIALS

AND VETERANS IN SUPPORT OF RESPONDENTS

SARAH M. SHALF

Counsel of Record

Emory Law School

Supreme Court Advocacy Program

1301 Clifton Road

Atlanta, GA 30322

(404) 712-4652

edu

Counsel for Amici Curiae

TABLE OF CONTENTS

accessories i

A ii

INTERESTS OF AMICI CURIAE .............<.00c0ecceeeeeseeeeeees 1

SUMMARY OF THE ARGUMENT..................000ccccceeeeenees 4

EEE Ee 5

L THE UNITED STATES MILITARY IS A

HIGHLY DIVERSE INSTITUTION, WITH

SERVICEMEMBERS WHOSE RELIGIOUS

DIVERSITY MIRRORS THAT OF THE

Il. RELIGIOUSLY-FUELED TENSION HAS

iil. THE BLADENSBURG CROSS'’S RELIGIOUS

HISTORY AND EXCLUSION OF JEWISH

SERVICEMEN SERVES TO MEMORIALIZE

RELIGIOUS PREFERENCE, AND LEADS

TO THE PERCEPTION THAT OUR

GOVERNMENT ENDORSES SUCH

ENE SE EE ea 22

EE ET A LER Oe a a la

il

TABLE OF A

CASES

Supreme Court Cases

Pleasant Grove City v. Summum, 129 S.Ct 1125

Salazar v. Buono, 559 U.S. 700 (2010).................000. 6

Other Cases

American Humanist Ass'n v. Maryland-National

Gea iiildrinciinsinceledinisteniendaitnentnutnmatcaninnmbdentgantitinds 18

EXECUTIVE ORDERS

Exec. Order No. $061 (194G)......ccccccccccccccccscccccscccsess s]

OTHER AUTHORITIES

Air Force Instruction 1-1, Sec. 2.12 (2012)..............+. 6

Alan Cooperman, Air Force to Probe Religious Climate

Anna Mulrine, Too Much Religion at Military

Academies? West Point Cadet Revives Charge,

CHRISTIAN SCIENCE MONITOR (2012) ................0000e 11

Brief of Former High-Ranking Military Officials,

Salazar v. Buono, 559 U.S. 700 (2010).............. 4,6,7

Cavalry Cross to Honor Dead, WASHINGTON HERALD

GE naredieetenctannsenmsseectendeiedntenninnemibanbeneetinmn 17

Dave Philipps, Muslims in the Military: The Few, the

Proud, the Welcome, N.Y. TIMES (2016)............... 9,12

Department of Defense Directive 1350.2 §4.2............ 3

Drew Miller, Inside the Military’s Campaign to Make

Its Soldiers Christian, MIC (2013)... ..........cc<ceee00 14

For Liberty: American Jewish Experience in WWI,

National World War I Museum and Memorial........ 10

From Representation to Inclusion: Diversity

Leadership for the 2Ist-Century Military, US.

Military Leadership Diversity Commission (2017).....9

Jacqueline Zoller, Who Cares If Jesus Loves Nukes?:

The Constitutionality of the Christian Just War Theory

Taught to the Air Force Missile Launch Officers, 14

RUTGERS J. L. RELIGION 425 (2012).................. 13, 14

Joseph Rhee, Tahman Bradley & Brian Ross, U.S.

Military Weapons Inscribed with Secret ‘Jesus’ Bible

ee SIE inicnindasernenensnaunanemanaceseacses 15

Kristy Kamarck, Diversity, Inclusion, and Equal

Opportunity in the Armed Services: Background and

Issues for Congress, Cong. R. Service

iv

Mariam Khan, More than 5,000 Muslims Serving in

the U.S. Military, Pentagon Says, ABC News

Memorandum from the Off. Of the Assistant Secretary

of Defense on Faith And Belief Codes (2017)............. 9

Michael Rugel, Over There: Zac Morton Kaiz, National!

Museum of American Jewish Military History

ieee hciensuesevanvinempnainesempecaieesdnumuuineeidhbinnaiitinetias 20

Neela Banerjee, Soldier Sues Army, Saying His

Atheism Led to Threats, N.Y. TIMES (2008).............. 14

Peace Cross, Maryland National Register............... 16

Prince Georges Plans War Memorial Cross, EVENING

TI TTIT inssinicickichicihiaeiendcneehceinianbeialeniastaiabiinicaaiineteaienasiRdiens 18

Religious Diversity in the U.S. Military, U.S. Military

Leadership Diversity Commission (2010)................. 8

Robert Asahina, Just Americans: How Japanese

Americans Won a War at Home and Abroad (2007)....9

Saw Lt. Rosenfeld’s Body, BALTIMORE SUN (1918)....19

Sergt. Isaac Morris, BALTIMORE SUN (1918)............ 19

Seeks Word of Private Balser, BALTIMORE SUN

Seymour Brody, 350 Year Commemoration of Jews in

America’s Military (2004)...............ccccccecceeeeeeeeeeees 10

Sonny Hernandez, Christian Service Memvers: Avoid

Supporting or Accommodating Evil, BARBWIRE

INTERESTS OF AMICI CURIAE'

The Military Religious Freedom Foundation

(MRFF) is dedicated to ensuring that all members of

the United States Armed Forces fully receive the

Constitutional guarantees of religious freedom to

which they and all Americans are entitled by virtue of

the Establishment Clause of the First Amendment.

MRFF currently represents approximately 61,000

clients, including active duty U.S. marines, sailors,

soldiers, airmen, cadets, midshipmen, National

Guard, reservists and veterans, including matters

involving high school JROTC. Approximately 95% of

MRFP’s clients self-identify as practicing Christians.

MRFF recognizes that military life requires

individual adherence to shared patriotic principles.

MRFF also recognizes the need for military personnel

to at times temporarily’ relinquish some

Constitutionally granted personal freedoms for the

sake of military discipline and objectives. MRFF

believes that religious faith is a Constitutionally

guaranteed freedom that must never be compromised,

except in the most limited of military circumstances,

because of its fundamental importance to the

preservation of the American nation and the American

' Pursuant to Supreme Court Rule 37.6, amici curiae affirm

that no counsel for a party authored this brief in whole or in part,

that no counsel or a party made a monetary contribution

intended to the preparation or submission of this brief and no

person other than amici curiae, their members, or their counsels

made a monetary contribution to its preparation or submission.

Both Petitioner and Respondent filed blanket consent to the filing

of amicus curiae briefs, both of which are on file with the clerk.

2

way of life. MRFF adheres strongly to the principle

that religious faith is a deeply personal matter, and

that no American has the right to question another

American’s beliefs as long as they do not unwontedly

intrude on the public space or the privacy or safety of

another individual.

“**

The Army and Air Force officials and veterans

signing this brief are committed to maintaining the

cohesiveness of the United States military by

preserving the right of all servicemembers to exercise

their religious beliefs without fear of discrimination,

persecution, or harassment by military officials. The

Army and Air Force officials and veterans who have

signed this brief include:

Michael “Mikey” Weinstein, President and Founder,

Military Religious Freedom Foundation

Robert Muller, Founder, Vietnam Veterans of America;

Co-Founder, International Campaign to Ban

Landmines, Nobel Peace Prize (1997); MRFF Advisory

Board Member

Richard G. Harding, Lieutenant General; 1 6th Judge

Advocate General, United States Air Force (ret.)

William T. “Bill” Lord, Lieutenant General; Former

Chief Information Officer, United States Air Force

(ret.)

Irving “Irv” Halter, Major General, United States Air

Force (ret.)

3

John Compere, Judge, Brigadier General, United

States Air Force (ret.); MRFF Advisory Board Member

Martin France, Brigadier General, United States Air

Force (ret.); MRFF Advisory Board Member

Andrew E. Salas, Brigadier General, United States Air

Force

Vincent R. Lindenmeyer, Colonel, Ph.D., United

States Army (ret.)

Richard L. Klass, Colonel, United States Air Force

(ret.)

Quentin D. Collins, Colonel, United States Air Force

(ret.); MRFF Advisory Board Member

Lawrence “Larry” Wilkerson, Colonel, United States

Army (ret.); MRFF Advisory Board Member

Rabbi Joel Schwartzman, Colonel, United States Air

Force (ret.)

David Antoon, Colonel, United States Air Force (ret.)

Gregory J. Petrequin, Colonel, United States Army

(ret.)

Cynthia R. Lindenmeyer, Reverend Doctor Chaplain,

American Public University System (ret.),

commissioned as a U.S. Army officer

Full biographies for each signee can be found in

Appendix I.

4

*s

Amici submit this brief to illustrate how the

dissolution of military cohesiveness is not only

harmful to individual servicemembers, but also

dangerous to our national security. Amici emphasize

that the United States military cannot fulfill its

mission of preserving national security and protecting

citizens if government officials are engaging in actions

that promote religious favoritism, encourage exclusion

and create an environment where servicemembers are

subject to harassment while in service to this country.

SUMMARY OF THE ARGUMENT

The Department of Defense has long recognized

that “discrimination against persons or groups based

on ... religion ... is contrary to good order and

discipline and is counterproductive to combat

readiness and mission accomplishment.” Department

of Defense Directive 1350.2 §4.2 (Aug. 18, 1995).

Religious preference, harassment, and discrimination

are examples of the kinds of divisiveness that can

threaten military functions, and that were brought

before this Court in Salazar v. Buono:

Nothing is more important to military

functioning than internal cohesion.

When soldiers trust one another and feel

a common sense of patriotism and

purpose, the military is able to function

effectively and achieve its many

challenging aims...[bjut military

cohesion can be easily imperiled by

5

discrimination, prejudice, and subtler

exclusionary practices.

Brief of Former High-Ranking Military Officials

Colonel David Antoon, Brigadier General Israel

Drazin, Vice Admiral Bernard Kauderer, Colonel

Richard L. Klass, Brigadier General A.A. “Tony”

Verrengia, and Colonel Lawrence B. Wilkerson,

Salazar v. Buono, 559 U.S. 700 (2010) (No 08-472) at

18-19.

This Brief presents three arguments to show

that permitting the Bladensburg cross to stand as a

state-sponsored memorial to fallen servicemembers

harms military cohesion: (1) the military is a

religiously diverse institution; (2) servicemembers

who do not identify as Christian have been ostracized

by fellow servicemembers as well as military leaders

who impermissibly promote the Christian faith over

others; and (3) the history of excluding non-Christians

from the Bladensburg cross leads to the impermissible

and damaging perception that our government

endorses such exclusion and preferential treatment.

ARGUMENT

Every branch of the United States Military has

a provision allowing for the free practice of religion,

and requiring military leaders to balance the free

practice of religion with the prohibition against

government exercise of religion. For example, the Air

Force’s provision reads as follows:

6

Leaders at all levels must balance

constitutional protections for their own

free exercise of religion, including

individual expressions of religious

beliefs, and the constitutional

prohibition against governmental

establishment of religion. They must

ensure their words and actions cannot

reasonably be construed to be officially

endorsing or disapproving of, or

extending preferential treatment for any

faith, belief, or absence of belief.

Air Force Instruction 1-1, Sec. 2.12 (2012). However,

the United States military has been plagued by a

history of excluding, ostracizing, humiliating, and

harassing servicemembers who do not practice the

Christian faith. Many of these instances have been

fueled by military leadership. Approximately 30% of

servicemembers do not identify themselves as

Christian, leaving nearly one-third of servicemembers

vulnerable to acts of religious intolerance, and

threatening the ability for our milit»ry to act as a

cohesive unit.

In Salazar v. Buono, justices of this Court

raised the issue as to whether a land transfer

involving a cross-shaped military memorial would

“project a message of government endorsement [of

religion] to a reasonable observer.” Salazar v. Buono,

559 U.S. 700, 744 (2010) (Stevens, J. dissenting). At

the time, several military officials acting as amici

raised the concern that the perception that the

government was honoring Christian servicemembers

7

over those of other faiths would be impermissibly

damaging:

The message that the military values the

sacrifices of Christian war dead over

those of servicemembers from other faith

traditions...that is not only a clear

constitutional violation, but is also

harmful to the military as an institution,

adding to social divisiveness in the very

way that the Establishment Clause is

intended to avoid.

Brief of Former High-Ranking Military Officials

Colonel David Antoon, Brigadier General Israel

Drazin, Vice Admiral Bernard Kauderer, Colonel

Richard L. Klass, Brigadier General A.A. “Tony”

Verrengia, and Colonel Lawrence B. Wilkerson,

Salazar v. Buono, 559 U.S. 700 (2010) (No 08-472) at

4.

This case raises the same concerns. The

Bladensburg cross lists the names of Christian

servicemen from Prince George’s County and

Baltimore, Maryland, and Washington, D.C. who died

during World War I, but excludes the names of Jewish

servicemen from the same region who similarly gave

their lives for their country. Those Jewish servicemen

are not honored in any other way in the region.

Further, the religiously-themed dedication of the

cross, and the Christian services that have taken place

featuring this cross, bring into question whether the

cross really serves as a secular monument that honors

all servicemen who gave their lives.

8

L THE UNITED STATES MILITARY IS A

HIGHLY DIVERSE INSTITUTION, WITH

SERVICEMEMBERS WHOSE RELIGIOUS

DIVERSITY MIRRORS THAT OF THE

UNITED STATES.

The United States military is a strikingly

religiously diverse institution. In 2017, 30% of U.S.

military personnel did not identify themselves as

Christian. Kristy Kamarck, Diversity, Inclusion, and

Equal Opportunity in the Armed Services: Background

and Issues for Congress, CONG. R. SERVICE No. 7-5700

40-43 (2017). Because the military is such a religiously

diverse organization, it is important not to show a

preference for one religion over another, or to

discriminate against certain religions.

The millennial generation, which constitutes

the focus of the military's current recruiting and

retention efforts, is the most ethnically and racially

diverse cohort in the nation’s history. Its diverse

religious beliefs and practices may differ from those

commonly understood and accepted by the military's

majority culture, and it demonstrates gradually

increasing tolerance of religious difference. U.S.

Military Leadership Diversity Commission. (2010,

June). Religious Diversity in the U.S. Military. {Issue

Paper #2]. Arlington, VA: Military Leadership

Diversity Commission, 22.

Given its young demographic, the military

appears to reflect the religious diversity of the United

States in terms of identification with minority faiths,

identification with possessing no religious preference,

and identification with groups traditionally

considered outside the religious mainstream (e.g.,

9

Pagan, Eastern, Humanistic, and others). U.S.

Military Leadership Diversity Commission. (2010,

June). Religious Diversity in the U.S. Military. (Issue

Paper #2]. Arlington, VA: Military Leadership

Diversity Commission, 22. Religious diversity in the

military reflects the civilian population, including the

greater religious diversity of its youth. Jd.

The United States military has played a pivotal

role in the United States’ pursuit of equality of

opportunity for all citizens. In 1948, after the end of

World War II, President Harry S. Truman issued

historic Executive Order 9981. This order called for

the desegregation of the military by providing

“equality of treatment and opportunity for all persons

in the armed services.” Exec. Order No. 9981, 13 Fed.

Reg. §4313 (1948). Since then, the U.S. military has

become a groundbreaking institution that is dedicated

to the ideal that individual servicemembers should be

rewarded for their performance and dedication, no

matter their gender, skin color, ethnic background, or

religion. U.S. Military Leadership Diversity

Commission. (2011, March). From Representation to

Inclusion: Diversity Leadership for the 21st-Century

Military. [Final Report]. Arlington, VA: Military

Leadership Diversity Commission.

Today, we see the military continue to recognize

its religious diversity. In 2017, the Department of

Defense announced a near doubling of its list of

recognized religions. See Memorandum from the Off.

of the Assistant Secretary of Def. on Faith and Belief

Codes for Reporting Personnel Data of Service

Members. (Mar. 27, 2017) (changing DoDI 1336.05

“Faith Group Codes”, now titled “Faith and Belief

Code,” from listing just over 100 religions to 221.) This

10

change highlights the government's intentions to

respect the rights of all service personnel by

recognizing the ever-growing religious diversity in the

military. Id.

Various religious minorities have provided

distinguished and honorable service. The most

decorated unit in American military history was

composed of 4,500 Japanese-Americans who

subscribed to faiths including Buddhism and

Shintoism as well as Christianity. Robert Asahina,

Just Americans: How Japanese Americans Won a War

at Home and Abroad (2007). This unit, the 100th

Infantry Battalion, fought eight major campaigns

during World War II and played an instrumental role

in liberating the Dachau Concentration Camp. /d.

Muslim servicemembers have fought in every

U.S. war since at least the Civil War. Dave Philipps,

Muslims in the Military: The Few, the Proud, the

Welcome. N.Y. TIMES (2016), https://

www.nytimes.com/20 16/08/03/us/muslims-us-

military.html. Currently, there are an estimated 4,000

to 6,000 servicemembers in the U.S. military who

identify as Muslim. Jd; see also Mariam Khan, More

than 5,000 Muslims Serving in the U.S. Military,

Pentagon Says, ABC News (2015), https://

abcnews.go.com/US/5000-muslims-serving-us-

Jewish servicemembers have fought for the

United States in every major conflict in history.

Seymour Brody, 350 Year Commemoration of Jews in

America’s Military (2004), available at

http://seymourbrody.com/military/brody_military.pdf.

During the Revolutionary War, many Jewish soldiers

were in General George Washington’s Continental

Army. /d. During the Civil War, six Jewish soldiers in

the Union Army were recipients of the prestigious

Medal of Honor. Jd. There were more than 250,000

Jewish soldiers who fought in World War I, of whom

over 3,500 were killed, 12,000 were wounded, and

1,100 received decorations for bravery. Id. Nearly

250,000 Jews served in the American Expeditionary

Forces, which totaled 4.8 million and women.

Eighteen percent were foreign born. National World

War I Museum and Memorial, For Liberty: American

Jewish Experience in WWI, 13 Nov 2018,

https://www.theworldwar.org/explore/exhibitions/past

-exhibitions/liberty-american-jewish-experience-wwi.

However, despite the strides that the military

has taken in recent years to become more inclusive,

non-Christian servicemembers have been, and

continue to be, subject to _religiously-fueled

discrimination and humiliation. Such actions devalue

the contributions of non-Christian servicemembers

and disintegrate the unity that the military needs to

achieve in order to carry out its duties.

Il. RELIGIOUSLY-FUELED TENSION HAS

LONG PLAGUED US. MILITARY

BRANCHES, OSTRACIZING MEN AND

WOMEN WHO DO NOT IDENTIFY AS

CHRISTIAN.

Despite the Department of Defense’s position

discussed above, the United States military has long

suffered from religious tension, discrimination, and

harassment that has impacted numerous

servicemembers who did not share those religious

views.

12

In 2012, a cadet at the United States Military

Academy West Point, Blake Page, publicly withdrew

from the academy due to the “overt evangelism” that

permeated campus. In a letter he wrote, Page said that

he did not “wish to be in any way associated with an

institution which willfully disregards the Constitution

of the United States by enforcing policies which run

counter to the same.” Anna Mulrine, Too Much

Religion at Military Academies? West Point Cadet

Revives Charge, CHRISTIAN SCIENCE MONITOR (Dec. 7,

2012), https://www.csmonitor.com/USA/Military/

2012/1207/Too-much-religion-at-military-academies-

West-Point-cadet-revives-charge. Those policies

included prayers at mandatory events and regular

religious events that made non-Christian students

feel ostracized. Most shockingly, Page also

experienced individual instances of harassment at

West Point for not sharing his classmates’ evangelical

religious views. Id.

Page is not the only cadet to experience

discrimination because of his views, nor is West Point

the only military institution to play host to religious

discrimination. Ai the Air Force Academy, cadets who

chose not to go to chapel after dinners would be

marched to their dormitories in a “Heathen Flight,”

forcing Air Force leadership to create a “task force” to

evaluate whether “faculty and staff have pressured

cadets into converting to evangelical Christianity.”

Alan Cooperman, Air Force to Probe Religious Climate

at Colorado Academy, Washington Post, May 4, 2005),

http://www. washingtonpost.com/wp-

dyn/content/article/2005/05/03/AR200505030 1 499 ht

mil.

13

Despite their longstanding history of military

service, Muslim servicemembers shared that they had

encountered “knuckleheaded comments equating

them with terrorists.” In the months leading up to the

2016 election, Khizr and Ghazala Khan, the parents of

Army Captain Humayun Khan, who was killed in Iraq

in 2004, were subject to an endless stream of

disparaging comments. Dave Philipps, Muslims in the

Military: The Few, the Proud, the Welcome. N.Y.

TIMES (2016), http://www.nytimes.com/2016/08/03/us/

muslims-us-military.html.

Some of this discrimination has even been

perpetuated by military religious leadership. Captain

Sonny Hernandez, an Air Force Reserve chaplain,

wrote an article in which he explained his view that

only Christians should be able to serve as military

chaplains. He wrote, “Christian service members who

openly profess and support the rights of Muslims,

Buddhists, and all other anti-Christian worldviews to

practice their religions—because the language in the

Constitution permits it—are grossly in error, and

deceived.” Sonny Hernandez, Christian Service

Members: Avoid supporting or Accommodating Evil’,

BarbWire, (Sept. 12, 2017), https://barbwire.com/

christian-service-members-avoid-supporting-

accommodating-evil/. Captain Hernandez continued

with statements such as, “[I|s it wrong for a professing

Christian service member to say, ‘I support the rights

of all Americans to practice their faith since the

Constitution protects their rights?” Absolutely!” Jd.

For twenty years, chaplains at the Vandenburg

Air Force Base in California taught a mandatory

course titled “Christian Just War Theory,” which

subjected servicemembers to Biblical justifications for

14

atomic warfare, should such drastic actions be needed

in the future. Jacqueline Zoller, Who Cares If Jesus

Loves Nukes?: The Constitutionality of the Christian

Just War Theory Taught to the Air Force Missile

Launch Officers, 14 RUTGERS J. L. RELIGION 425, 449

(2012). Among other lessons, the course featured a

PowerPoint presentation with several passages from

the Old Testament and the New Testament. /d. at 430-

432. This course was discontinued only after thirty-

one nuclear missile launch officers complained to Air

Force officials that the course was inappropriate. Jd. A

memorandum sent to Air Force officials warned that

proselytizing could lead to the “degradation of the

unit’s morale, good order, and discipline” if only

certain religions were emphasized. /d. at 433.

Another Air Force chaplain, Major Warren

Watties told cadets that if they were not “born again”

they would “burn in the fires of hell.” Drew Miller,

Inside the Military’s Campaign to Make Its Soldiers

Christian, Mic, (Sept. 4 2013), https://mic.com/

articles/61629/inside-the-military-s-campaign-to-

make-its-soldiers-christian#.TGqhO4iWy.

Non-Christian members of the military have

had to face discrimination by their peers and

superiors. Specialist Jeremy Hall founded a chapter of

the Military Association of Atheists and Freethinkers

at Camp Speicher in Tikrit, Iraq. Neela Banerjee,

Soldier Sues Army, Saying His Atheism Led to

Threats, N.Y. ‘TIMES (April 26, 2008),

https://www.nytimes.com/

2008/04/26/us/26atheist. html. In July 2007, a major

came to the meeting, during which he told the soldiers

there that “people like you are not holding up the

Constitution and are going against what the founding

15

fathers, who were Christians, wanted for America.” /d.

After this incident, Specialist Hall said he did not

trust his officers. Eventually, after threats from other

soldiers, the military sent him home early. /d.

However, once he returned to base in the United

States, Specialist Hall continued to experience

discrimination for his beliefs. /d.

Not all instances of preferential treatment

towards Christianity have been explicit — certain

actions are more subtle, but still as damaging. In Iraq

and Afghanistan, members of the U.S. Military used

rifle sights made by Trijicon with inscriptions on them

referring to Bible verses, transforming their weapons

into what became known among the troops as “Jesus

rifles.” Joseph Rhee, Tahman Bradley, & Brian Ross,

U.S. Military Weapons Inscribed with Secret ‘Jesus’

Bible Codes, ABC News (Jan. 18, 2010),

https://abcnews.go.com/Blotter/us-military-weapons-

inscribed-secret-jesus-bible-codes/story?id=9575794.

These inscriptions read “2COR4:6” referring to Second

Corinthians 4:6: “For God, who commanded the light

to shine out of darkness, hath shines in our hearts, to

give the light of the knowledge of the glory of God in

the face of Jesus Christ.” Id.

Against this background of the military's

struggles to respect the religious diversity of its

members, the Bladensburg Cross stands owt as a

government imprimatur on religious exclusion,

emboldening the leaders and members who would

engage in acts such as those described above, and

leading to further division amongst our nation’s

military.

16

iil. THE BLADENSBURG CROSS’S RELIGIOUS

HISTORY AND EXCLUSION OF JEWISH

SERVICEMEN SERVES TO MEMORIALIZE

RELIGIOUS PREFERENCE, AND LEADS

TO THE PERCEPTION THAT OUR

GOVERNMENT ENDORSES SUCH

EXCLUSION.

The history of the Bladensburg Cross shows

that it stands to commemorate Christian servicemen

from Prince George’s County and the surrounding

area, while excluding Jewish servicemen who — like

their Christian counterparts — made the ultimate

sacrifice for their country during World War |. That

the memorial is shaped like a cross is not the extent of

the issue in this case. The Bladensburg Cross stands

as a memorial to religious-based exclusion, as the

cross excludes Jewish servicemen from the greater

Washington and Baltimore area. That this cross

stands on public land carries with it the impermissible

and dangerous perception that a state government

condones religious preference and endorses religious-

based exclusion.

This Court has previously stated that

memorials constitute a_ significant means of

communication from the government to the general

public. “Governments have long used monuments to

speak to the public... .Triumphal arches, columns, and

other monuments have been built to commemorate

military victories and sacrifices and other events of

civic importance.” Pleasant Grove City v. Summum,

129 S. Ct. 1125, 1132-33 (2009) (discussing that the

purpose of monuments is typically “to convey some

17

thought or instill some feeling in those who see the

structure”).

The memorial, formally labeled as the Peace

Memorial, is a forty-foot concrete cross in the town of

Bladensburg in Prince George’s County, Maryland.

The cross was erected at the junction of the National

Defense Highway and Washington-Baltimore

Boulevard, the road from Baltimore to Washington

that would have been travelled by families, friends,

and comrades of the dozens of Jewish servicemen from

the nearby Baltimore area who lost their lives in the

war. From 1919 to 1925, the cross was constructed

with the purpose of honoring men from the area who

perished in World War I. Peace Cross, Maryland’s

Nat'l Register Props., https://mht.maryland.gov/

nr/NRDetail.aspx?NRID=1644 (last visited January

14, 2019). In total, forty-nine men are listed on the

cross with an inscription above their names that

reads: “This memorial cross is dedicated to the heroes

of Prince George’s County, Maryland who lost their

lives in the Great War for the liberty of the world.”

According to their draft registration cards and other

sources, nearly a third of these forty-nine names were

actually from towns outside of Prince George’s County,

and even other states outside of Maryland, with some

not having even the slightest connection to the county.

This includes a number of Christian veterans from the

greater Baltimore area, a city that has historically

been home to a vibrant Jewish community. Draft

registration cards (copies on file with fold.3com

Military Records).

In 1925, during the dedication ceremony of the

monument which was attended by both governmental

officials and members of the Christian clergy, the

18

keynote speaker of the event, Maryland

Representative Stephen Gambrill, proclaimed, “By the

token of this cross, symbolic of Mount Cavalry, let us

keep fresh the memory of our boys who died for our

righteous cause.” Joint Appendix at 55a-56a.

At the time the cross was built, local news

sources described the memorial as “a mammoth cross,

the likeness of Mount Calvary on which Christ died,

will be built to perpetuate the memory of the heroes

who died to save the country. ... Many towns and

counties throughout the United States have selected

the Calvary Cross as the most appropriate

monument.” Calvary Cross To Honor Dead,

WASHINGTON HERALD, May 25, 1919, at 16.

Christian chaplains provided sermons and

speeches at the cross’s dedication ceremony, including

Rev. F.C. Reynolds, who served as chaplain in the

115“ Infantry unit, and Rev. A.J. Carey, who was the

pastor of St. Jerome’s Catholic Church in Hyattsville

(Prince George’s County). War Dead Honored by

Prince Georges, WASHINGTON Post, May 3, 1929, at 3.

It is significant that no representatives of other

minority religions or cultures were present to offer

dedications at the ceremony. Am. Humanist Ass'n v.

Maryland-Natl Capital Park & Planning Comm'n,

874 F.3d 195, 200-01 (4% Cir. 2017).

News sources at the time the cross was erected

were clear in their description of the cross as a

religious monument. When raising funds for the cross,

school-children were asked to make the following

pledge:

We, the school children of Maryland,

trusting in God, the supreme ruler of the

universe, pledge faith in our brothers

19

who gave their all in the world war to

make the world safe for democracy. Their

mortal bodies have turned to dust, but

their spirit lives to guide us through life

in the way of Godliness, justice and

liberty. With our motto, ‘One God, One

country and One flag,’ we contribute to

this memorial cross commemorating the

memory of those who have not died in

vain.

Prince Georges Plans War Memorial Cross. EVENING

STAR, Washington, D.C., June 2, 1919, at 21.

Therefore, these sources from the time the cross

was erected show that this cross was not intended to

be a secular memorial commemorating all soldiers

from the region. The cross is clearly intended to be a

Christian memorial, for Christian soldiers, dedicated

in a ceremony that was attended by government

officials, and standing on government land.

Furthermore, the forty-nine names listed on the

memorial exclude the names of Jewish servicemen

from the region who gave their lives during World War

1. Some of the Jewish servicemen served in the same

regiment as the men whose names are listed on the

cross.

Sgt. Isaac “Ike” Morris, a Jewish serviceman,

was killed in action in France and later eulogized in

the Baltimore Sun by his friend Ben Blumenthal, yet

his name is missing from the forty-nine listed on the

cross. In a letter to the Sun’s editor, Blumenthal!

stated that Sgt. Morris was “brave to the core,

intensely patriotic, and a sincere and loyal friend of

humanity, it became his great privilege to put his

heart and soul in America’s call for men to make the

20

world a better place to live.” Ben Blumenthal, Sergt.

Isaac Morris., BALTIMORE SUN, December 11, 1918, at

6.

Lieutenant Merrill Rosenfeld, a Baltimore

native who served in the same regiment as many of

the names memorialized on the cross, was killed in

October 1918 in France while leading a group of men

in a charge against an enemy machine gun nest.

Although he was awarded the Distinguished Service

Medal for his heroic actions during World War I, his

name was left off the cross. See Saw Lt. Rosenfeld’s

Body, BALTIMORE SUN, Nov. 25, 1918, at 12.

Another absent name is that of PFC Zadoc

Morton Katz, a Baltimore native who was shot and

killed after leading reinforcements into battle at

Montfaucon. In a letter, PFC Katz wrote about how

the Jewish servicemen celebrated Rosh Hashanah

without any provisions or services from the military:

I don’t think any of the 250 Jewish boys

assembled in the “Y” hut last Saturday

morning to celebrate ‘Rosh Hashona’

could have been more profoundly moved

than I. With no one to officiate but the

boys themselves, and no complete prayer

book of the service, the orthodox service

was chanted through.... The services

concluded about 11 A. M. with the

singing of ‘America’, and | reported to my

platoon for duty, feeling a pride in my co-

religionists and a surety that after the

war the epithet ‘Coward’ cannot be

hurled at us.

Michael Rugel, Over There: Zac Morton Katz, Nationa!

Museum of American Jewish Military History,

21

https://nmajmh.org/2017/06/over-there-zadoc-morton-

katz/ (lun 28, 2017).

Private Louis Balser, who served in Company D

of the 115th Infantry — the same regiment whose

chaplain presided over the dedication ceremony at the

cross — died in October 1918 in France. Information

about his service comes from letters his brother

published in local newspapers, seeking information

about Pvt. Balser’s whereabouts. Although many of

his Christian comrades from the 115th Infantry unit

were honored on the cross, his name was left off. Seeks

Word of Private Balser, BALTIMORE SUN, Dec. 21, 1919,

at 16.

The fact that some of these unlisted veterans

were not originally from Prince George’s County is of

no import because many of the forty-nine men named

on the cross were also from Baltimore and other

communities in Maryland. See Draft registration

cards (copies on file with fold3.com Military Records).

Given that the names of these veterans were not

honored on the monument despite their acts of

courage and selfless leads to the conclusion that such

an honor was conferred prescriptively to Christians

rather than uniformly to all the men who lost their

lives.

The history of the Bladensburg cross clearly

shows that the memorial was intended only for

Christian servicemen, and conspicuously excluded

Jewish servicemen, many of whom served alongside

those who were included among the forty-nine men

listed on the cross. If this memorial is permitted to

stand on government land, it will stand not as a

monument for all veterans, as the petitioners argue it

22

does in modern day, but as a monument of

government-sponsored religious exclusion.

CONCLUSION

The United States military is religiously

diverse, and servicemembers of all religious

backgrounds have honorably and valiantly served this

country — some making the ultimate sacrifice. Military

memorials, particularly those standing on public land,

should honor and celebrate this diversity by not

showing a preference of one religion over another.

To be effective, the military must be able to

respond to dangerous situations as a singular unit.

Instances of discrimination, religious favoritism, and

any actions that cause a significant percentage of the

military’s members to feel excluded chip away at this

cohesiveness and, in turn, make the military less

effective and its members disconnected.

Amici respectfully ask this Court to affirm the

district of the Fourth Circuit.

Respectfully Submitted,

SARAH M. SHALF

Counsel of Record

Emory Law School Supreme

Court Advocacy Program

1301 Clifton Road

Atlanta, GA 30322

(404) 712-4652

sarah.shalf@emory.edu

Counsel for Amici Curiae

APPENDIX I

List of Amici

Michael “Mikey” Wei =——

Mikey Weinstein is the Founder and the

President of the Military Religious Freedom

Foundation. Weinstein is a 1977 Honor Graduate of

the United States Air Force Academy. Mikey served

as the first General Counsel to Texas billionaire and

two-time Presidential candidate H. Ross Perot and

Perot Systems Corporation. A registered Republican,

he also spent over three years working in, and for, the

West Wing of the Reagan Administration as legal

counsel in the White House. [n his final position there,

Mikey was named the Committee Management

Officer of the much-publicized Iran-Contra

Investigation in his capacity as Assistant General

Counsel of The White House Office of Administration,

Executive Office of the President of the United States.

Robert Muller

Nobel Peace Prize, Co-Founder, International

Campaign to Ban Landmines, (1997); MRFF Advisory

Board Member

Robert Muller, a MRFF Advisory Board

Member, served as a Marine Infantry Officer in

Vietnam in 1968-69. While leading an assault on an

enemy-held hill, he was shot through the chest,

leaving him permanently paralyzed from the chest

down. Upon returning to the States, he spent a year

in a VA hospital in New York City. His ward was the

basis of a cover story in Life magazine that shocked

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Americans when the horrible conditions of the

treatment and facilities were revealed. It was the

second largest selling issue Life magazine ever

published and triggered a national scandal concerning

the treatment that at least some veterans had to

endure. There were congressional hearings and a lot

of national media coverage. Muller was the

spokesman for the veterans. He later started a

veteran’s advocacy group, Vietnam Veterans of

America (VVA) and led the organization for nine

years. The group was granted a congressional charter

in 1986 and remains the only national organization for

Vietnam veterans.

He also led the first group of veterans to return

to Vietnam in 1981 to begin a process of normalizing

relations between Vietnam and the USA. He worked

cooperatively with Vietnam on issues of mutual

concern from the war including: Agent Orange and its

health effects on those who served; a better accounting

of those listed as missing from the war; the issue of

American children; and how to assist in recovery from

the war. His continuing efforts over the years led to

millions of dollars being contributed by the US

government to help clean up hot spots of Agent

Orange, assistance in clearance of unexploded

ordnance and landmines, as well as _ broader

rehabilitation programs for civilian war victims.

After stepping down as president of VVA, he

continued working with a companion organization he

has also set up called Vietnam Veterans of America

Foundation that focused on humanitarian programs

principally targeting civilian casualties. The

organization wound up establishing rehabilitation

programs in Vietnam, Cambodia and numerous other

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war-torn countries around the world. The

organization's efforts initially focused on landmine

victims since Cambodia had the highest number of

amputees per capita in the world. Gaining a better

understanding of how pervasive and damaging

landmines have been, he co-founded an international

campaign to ban the weapon. His organization

managed the campaign and the International

Campaign to Ban Landmines was awarded the Nobel

Peace Prize in 1997.

Several years later. Muller changed the name of

the organization to Veterans For America to be

inclusive of service members and veterans of our wars

in Afghanistan and lLraq. Veterans for America was

the leading voice for several years in calling attention

to the plight of this younger group who endured

multiple deployments, extensions of deployments and

the reduction of time between deployments which

eventually led to a Blue Ribbon DOD Commission that

recognized these policies as knowingly compounding

injuries to those who serve. Veterans For America

conducted base visits to highlight the many problems

returning service members were confronted with and

helped promote the national scandal that focused on

poor treatment at Walter Reed hospital in the nation’s

capital.

Richard C. Hardi

Lieutenant General, United States Air Force (ret.)

Lt. Gen. Richard C. Harding (USAF, retired)

was nominated in 2009 by the President, confirmed in

2010 by the United States Senate, and served as the

16th Judge Advocate General (TJAG) of the United

States Air Force. In that capacity and until his

4a

retirement in 2014 at the expiration of his statutory

tour, General Harding served as the legal adviser to

the Secretary of the Air Force and all officers and

agencies of the Department of the Air Force. He

directed all Air Force attorneys in the performance of

their duties and was responsible for the professional

oversight of more than 2,200 judge advocates, 350

civilian attorneys, 1,400 enlisted paralegals and 500

civilians in the Air Force Judge Advocate General's

Corps worldwide. While serving as the Air Force

TJAG, General Harding also served as Senator

(R/SCyYColonel Lindsey Graham's Aijir _ Force

supervisor.

General Harding was the principal architect

and drafter of Air Force Instruction 1-1, entitled “Air

Force Standards,” which remains in effect today and

which includes an instruction on “Government

Neutrality Regarding Religion.” He also created the

Department of Defense’s Special Victim Counsel

(SVC) program, which provides legal services to

military survivors of sexual assault. The SVC

program was recognized by a Department of Justice

award, enacted into law by Congress, and has reduced

sexual assault in the Department of Defense.

General Harding, the son of an Air Force officer

and grandson of a Naval officer, entered the Air Force

with a direct commission in 1980. Following his

commissioning, he served in a variety of assignments

as a judge advocate to include serving six assignments

as a staff judge advocate at the unified command,

major command, numbered air force and wing levels.

Prior to assuming his position as The Judge Advocate

General, he served as the Commander, Air Force

Legal Operations Agency, Bolling Air Force Base, D.C.

Sa

General Harding received a Bachelor of Science

degree from the University of Arkansas in 1975 and a

law degree also from the University of Arkansas in

1979. General Harding is a graduate of the Air Force

Squadron Officer School, Air Command and Staff

College, and Air War College.

His assignments in chronological order include:

Bitburg Air Base, West Germany; deputy Staff Judge

Advocate at Dyess AFB, Texas; Chief, Executive

Services Division, Office of The Judge Advocate

General, Headquarters U.S. Air Force, the Pentagon,

Washington, D.C; Chief of the Special Law Branch

and Chief of the Information and Privacy Law

Branch, General Law Division, Headquarters U.S. Air

Force, the Pentagon, Washington, D.C.; Chief of

Officer Assignments, Judge Advocate General

Professional Development Division, Headquarters

U.S. Air Force, the Pentagon, Washington, D.C.; Staff

Judge Advocate, Randolph AFB, Texas; Staff Judge

Advocate, Elmendorf AFB, Alaska; Deputy Chief

Counsel, U.S. Transportation Command, Scott AFB,

Ill.; Staff Judge Advocate, U.S. Strategic Command,

Offutt AFB, Neb.; Staff Judge Advocate,

Headquarters 8th Air Force, Barksdale AFB, La.;

Staff Judge Advocate, Headquarters Air Force Space

Command, Peterson AFB, Colo.; Staff Judge

Advocate, Headquarters Air Combat Command,

Langley AFB, Va.; Commander, Air Force Legal

Operations Agency, Bolling AFB, D.C., and The Judge

Advocate General, Headquarters U.S. Air Force, the

Pentagon, Washington, D.C.

General Harding’s decorations include: two

Distinguished Service Medals, two Defense Superior

6a

Service medals, two Legion of Merit Medals, and six

Meritorious Service awards.

William T. “Bill” Lord

Lieutenant General, United States Air Force (ret.)

General Lord was the USAF Chief Information

Officer and Chief of War Fighting Integration from

2009 until his retirement in 2012. He was responsible

for 30,000 personnel providing information technology

services for the entire USAF with a budget of $8

billion. Prior to that, he was the Commander of the

USAF Cyber Command (provisional) establishing

cyberspace as a USAF operating domain. He has been

a commander six times and at every organizational

level in the USAF. He was named the best USAF Wing

commander year for the leadership of his 16,000

personnel at Keesler Air Force Base, Biloxi, MS,

through Hurricane Katrina. A graduate of the US Air

Force Academy, Chapman University, and the

Industrial College of the Armed Forces he holds a

Bachelor of Science, Master of Business

Administration, and Master of Science in National

Resource Strategy (Telecommunications). His

assignments included tours of duty in Europe and the

White House. General Lord has lectured by invitation

at UC Berkley, Stanford, Harvard Law, Princeton,

Temple, Univ. of PA, Univ. of North Carolina, AF

Academy, US Military Academy West Point,

Dartmouth Univ., Louisiana State Univ., Norwich

Univ., and the Nat'l War College. He is the recipient

of over 20 industry awards for his leadership in the

information technology area. He is currently a cyber

and information technology system and _ services

consultant.

7a

Irving “Irv” Halter

Major General, United States Air Force (ret.)

Maj. Gen. (Ret.) Irving Halter is a veteran of

over 32 years in the United States Air Force. Irv

graduated from the Air Force Academy in 1977, and

his career took him around the globe with over 14

years of overseas assignments, culminating in senior

positions at the Academy, the National

Reconnaissance Office, and Joint Staff in Washington,

DC. His final assignment was Vice Director for

Operations, J3, where he advised and facilitated

global operations for the Chairman, Joint Chiefs of

Staff, Secretary of Defense, and other senior DoD and

national security leaders.

During his Air Force career, Irv commanded five

different operational units including a fighter

squadron, operations group, two fighter wings, and a

numbered air force. In his final command, 19th Air

Force, Irv was responsible for all basic and advanced

Air Force (flying training, directing 30,000

professionals at 18 bases across the United States

while executing 500,000 flying hours a year. He also

served as the senior Air Force officer in Afghanistan

during early combat operations in 2002. Irv was a

highly-experienced fighter pilot, flying over 3200

hours in jet aircraft, including 180 combat hours over

[rag and Afghanistan.

John Compere

Judge, Brigadier General, United States Army (ret.);

MRFF Advisory Board Member

Brigadier General John Compere, Judge

Advocate General's Corps, US Army (Retired)

graduated from Texas Tech University (B.A.,

8a

Government) and the University of Texas (J.D., Law).

Army ROTC commissioned, he volunteered and

entered active duty in January 1967 as a 10Ist

Airborne Division paratrooper and prosecutor, served

in CONUS, Thailand, Vietnam, Honduras, and

Panama, and retired as a Disabled American Veteran

(Vietnam). He is the former Chief Judge of the US

Army Court of Military Review (a tenured US judicial

position nominated by President George H.W. Bush

and confirmed by Congress). Compere was also the

owner of a San Antonio law firm and a board-certified

civil trial lawyer, mediator, and arbitrator in federal

and state courts. As an author and lecturer for the

State Bar of Texas, 74 of his legal articles were

copyrighted and published. In January 2007, he

retired and returned to the family ranch in Texas with

his wife Dolores.

Martin France

Brigadier General, United States Air Force (ret.);

MRFF Advisory Board Member

Brigadier General Martin E.B. France (USAF

retired) is a graduate of the United States Air Force

Academy (B.S.), Stanford University (M.S.) and

Virginia Tech (Ph.D.), as well as a distinguished

graduate of the National War College. His 41-year Air

Force career culminated in 13 years of service as the

Permanent Professor and Department Head of for

Astronautics at the US Air Force Academy, including

a term as the Chief of the Engineering Division

(civilian College of Engineering Dean equivalent). His

professional experience includes research and

development assignments with the Air Force Research

Lab working on high energy laser systems, as the Air

9a

Force Exchange Engineer to France, assigned to

Toulouse, France, and as a program manager at the

Defense Advanced Research Projects Agency

(DARPA). He served as the Chief Scientist of the Joint

Improvised Explosive Device Defeat Organization

(JIEDDO) and earlier as an instructor, associate

professor, and executive officer in the Department of

Astronautics, USAF Academy. General France also

served as a staff officer at Air Force Space Command,

the Air Staff, and on the Joint Chiefs of Staff, writing

long-range mission area plans for space forces, in a

variety of requirements positions for space support,

force enhancement, space superiority, intelligence,

and special access programs, and in key support roles

within the Pentagon during Operations NOBLE

EAGLE and ENDURING FREEDOM. He was

awarded a Fulbright Fellowship in 2014 and served as

a visiting scholar to Nanyang Technological

University (Singapore) during the fall of that year. In

2017, he was invited to serve on the foundational

cadre of the President's National Space Council. He

has published technical, policy, and strategy papers in

several refereed journals, and was a fully qualified

Foreign Area Officer (fluent in French), a Joint

Specialty Officer, and a Level III Certified Acquisition

Professional. His awards include the Legion of Merit,

Joint Meritorious Service Medal, the Meritorious

Service Medal with five oak leave clusters and the

Military Religious Freedom Foundation's Jefferson

Award. He lives with his wife of 37-plus years, Becky,

in Colorado Springs and is currently a senior technical

analyst with Integrity Applications, Inc.

10a

Andrew E. Salas

Brigadier General, United States Air Force

Brigadier General Andrew E. Salas is the

Special Assistant to the Chief, National Guard

Bureau, Diversity and Inclusion. His role is to ensure

that America’s rich diversity is reflected and

welcomed in the National Guard’s ranks. He has

served as New Mexico's Adjutant General, in

command of the 332nd Expeditionary Support Group

In Operation lIragi Freedom, as Vice Wing

Commander for the 150th Special Operations Wing,

and with the Executive Office of the President, Drug

Control Policy. He also served at Headquarters,

United States Air Force as Director of Ground Safety

and as the Air National Guard liaison to 12th Air

Force (AF Southern).

Vincent R. Lindenmeyer

Colonel, Ph.D., United States Army (ret.)

Colonel Vincent Ray Lindenmeyer, Ph.D., USA,

Retired is a veteran of Operation IRAQI FREEDOM

and Operation ENDURING FREEDOM with overseas

assignments to Korea, Qatar, Egypt, and Iraq.

Colonel Lindenmeyer culminated his 26-year

active duty career as a Battle Watch Commander for

the United States Strategic Command

(USSTRATCOM) overseeing the country’s most

sensitive missions across the nuclear, space and cyber

domains. He is also an expert in collaborative

operations and future operations planning teams,

having served in the J3, USSTRATCOM. During his

service in Iraq, Colonel Lindenmeyer served as the

Senior Strategist, Advisor, and Lead, Professional

Military Education, Office of Security Cooperation—

lla

Iraq, Baghdad. He moved the Iraq National Defense

University and lraq War College to a US-funded $14M

new campus in the International Zone, created a

strategic framework for curriculum development, and

planned and organized a first-ever Iraq National

Security Conference, JUN12, receiving the Bronze

Star Medal.

Highlights of Colonel Lindenmeyer’s career

include commanding a company in the 82d Airborne

Division, Ft. Bragg, North Carolina, (1998-2000);

serving as Executive Officer for the Ist Support

Battalion, Multinational Force & Observers (MFO),

Sinai, Egypt, (2004-2005), commanding the Combat

Support Coordination Team in Korea (1996-1997); and

serving as a Tactical Officer at the United States

Corps of Cadets, United States Military (2000-2004).

Colonel Lindenmeyer is a graduate of the US

Army Ranger School, US Army Airborne School, US

Army Jumpmaster School (with 45 Airborne jumps),

and earned the Expert Infantryman’s Badge and

Senior Parachutists Badge. Colonel Lindenmeyer

awards include the Bronze Star Medal, Defense

Meritorious Service Medal, Meritorious Service Medal

with Silver oak leaf cluster, Joint Service

Commendation, Army Commendation Medal with two

Bronze oak leaf clusters, Army Achievement Medal,

National Defense Service Medal with Bronze Star,

Iraq Campaign Medal, Global War on Terrorism

Expeditionary Medal, Global War on Terrorism

Service Medal, Korea Defense Service Medal,

Outstanding Volunteer Service Medal, Army Service

Ribbon, Army Overseas Service Ribbon with Numeral

2, and the Multi-national Force and Observers Medal

Ribbon with Numeral 2.

12a

Colonel Lindenmeyer’s civilian education

includes a Ph.D. in Education, Northcentral

University, Prescott, Arizona, 2013; Master of

Strategic Studies, United States Army War College,

2011; Master of Science in Education, Long Island

University, CW Post, 2001; Master of Science in

Management, University of Central Texas, 1995;

Bachelor of Science, United States Military Academy,

1991; and Certificate of Completion, United States

Military Academy Preparatory School, 1987. From his

initial oath to his retirement from active duty, Colonel

Lindenmeyer served a total of 30 years to support and

defend the Constitution of the United States of

America.

Colonel Lindenmeyer is married to the

Reverend (Doctor) Cynthia Ramirez Lindenmeyer and

ordained minister in the United Church of Christ.

Colonel Lindenmeyer and Reverend (Doctor)

Lindenmeyer stand together as fierce advocates for

the disenfranchised, underrepresented, and those

without a voice, today and always.

Richard L. Klass

Colonel, United States Air Force (ret.)

Colonel Richard L. Klass (USAF retired) is a

distinguished graduate of the United States Air Force

Academy and the National War College. He received

an M.A. (First Class) and MLitt degrees from Oxford

University, attending as a Rhodes Scholar. He also

served for two years in the Executive Office of the

President as a White House Fellow.

His military assignments include over 200

combat missions as a Forward Air Controller in

Southeast Asia, teaching at the Air Force Academy,

l3a

and tours in Germany and the Pentagon. His awards

include the Silver Star, Distinguished Flying Cross,

Legion of Merit and Purple Heart. He lives with his

wife, Liz, in Arlington, Virginia.

Quentin D. Collins

Colonel, United States Air Force (ret.); MRFF Advisory

Board Member

Quentin D. Collins, a MRFF Advisory Board

Member, enlisted in the US Air Force on February 6,

1976. After serving one four-year stint, he went on to

college and upon graduation enlisted in the US Army

and was selected for Officers Basic Course for

commissioning. He became a Company Commander

in the 1st Infantry Division as well as completing US

Army’s Ranger Qualification Course and Sniper

School. Upon separation, he went on and received

Master's Degrees in Religion, Divinity § and

Information Systems.

As a member of an _ Evangelical, Non-

Denominational Church he was feeling compelled to

become a Chaplain in the US Military. This was

fulfilled when he was appointed as an Air Force

Chaplain in February 2000. In September 2001, he

was activated from his position in the Air Force

National Guard to support both Operation Enduring

Freedom and Operation Iraqi Freedom. Having been

wounded in Action in December 2004 he was awarded

both a Purple Heart and a Bronze Star with Combat

V for actions taken in the Mosul, Iraq Suicide Bombing

at the dining facility. Following 16 months of

rehabilitation, he became a US Army Chaplain and

deployed for his fourth and final combat deployment

in 2007 to Iraq. Being an Engineer Brigades

l4a

Chaplain, he traveled extensively to eleven provinces

of the 18 in Iraq. He drove over an Improvised

Explosive Device while driving in Al Baquoba, Iraq on

April 8, 2008. Though the injuries seemed minimal,

he was awarded another Purple Heart and a Bronze

Star for helping make the “Surge” winnable.

When he returned to the United States, the

injuries eventually ended his 33 years of service with

a Medical Retirement on November 13, 2015. Prior to

his retirement he tirelessly trained junior Chaplains

of the importance of interpretation of the Ist

Amendment clause of the Freedom of a Religion

includes all faiths or non-faith of the Service Members

they were serving. He created the Joining Community

Forces Initiative which became the Joining Forces

Program under the Obama Administration. He is

sought out as a Subject Matter Expert on issues of

Freedom of Religion and Reintegration issues for

Military Veterans, Active Duty, and Their Families.

He tirelessly continues this effort in his role of

Founder and Director of the FRAME Initiative.

Lawrence “Larry” Wilkerson

Colonel, United States Army (ret.); MRFF Advisory

Board Member

Lawrence Wilkerson, a MRFF Advisory Board

Member, served 31 years in the US Army. His last

military assignments were as Special Assistant to

General Colin L. Powell, chairman of the Joint Chiefs

of Staff (1989-1993) and as Deputy Director and

Director of the U.S. Marine Corps War College (1993-

1997). Upon retirement, Wilkerson served as a private

consultant to General Powell (1997-2000) and then,

when Powell became secretary of state, he served first

lSa

on his departmental policy planning staff (2001-2002)

and then as his chief of staff (2002-2005). After

departing the Department of State, Wilkerson joined

the faculties of the George Washington University and

the College of William & Mary. Today, he still teaches

national security affairs at William & Mary as well as

writes and speaks extensively across the country and

the world.

Joel Schwartzman

Colonel, United States Air Force (ret.)

Rabbi Joel Schwartzman entered the United

States Air Force as a member of the first Chaplain

Candidate Program, Class 73B, in 1975. During the

course of his military career, he was stationed in

Biloxi, MS; San Antonio, TX; Newport News, VA; and

Denver, CO. He served two tours overseas at both

Ramstein AB, Germany, and at Hellenikon AB in

Athens, Greece. He also served a tour as a Jewish

Chaplain at the United States Air Force Academy in

Colorado Springs, CO. There, he renovated the Jewish

chapel in the iconic and renowned Cadet chapel. He

commissioned and installed nine paintings in that

chapel that are now worth over a million dollars. He

led the Professional Division as he helped create the

Command Chaplain’s function at the newly formed

Air Combat command. He was director of the Chaplain

Individual Reserve Program at Air Reserve Personnel

Headquarters, and was Senior Chaplain at the 11th

Wing, Bolling Air Force Base in Washington, DC.

His military awards and decorations include the

Legion of Merit, Meritorious Service Medal,

Humanitarian Service Medal, Ajir _ Force

Commendation Medal, Outstanding Unit Citation, Air

l6a

Force Organizational Excellence Medal, and Air Force

Overseas Long Tour of Duty, and the Air Force

Longevity Service Award.

He is a graduate of the Air Command and Staff

College and the Air War College. In 1995, he was

selected as Chaplain of the Year by the Association of

Jewish Chaplains. In 1997, he had the honor of giving

the Memorial Day Invocation and Benediction at

Arlington Cemetery before the American people and

the President of the United States. More recently, as

a civilian rabbi, he invoked at President Obama's

signing of the Recovery Act bill in Denver, CO.

After more than twenty-three years of military

service, he retired at the rnnk of Colonel in September

1998.

David Antoon

Colonel, United States Air Force (ret.)

Colonel David Antoon obtained degrees from the

US Air Force Academy (BS), Air Force Institute of

Technology (MS), and Trinity University (MBA), and

is a graduate of the Air War College. He served 29

years in the US Air Force including two tours in

Vietnam as a C-130 Instructor Pilot, Flight Test

Squadron Operations Officer, Test Wing Chief Of

Standardization/Evaluation, and Deputy Director of

the Test Wing Aircraft Modification Center. His

awards include the Distinguished Flying Cross and

Legion of Merit. Following his military career, Colonel

Antoon was a United Airlines pilot for 20 years. He

has since served as a Patient Safety Advocate with

Consumer Reports and Healthwatch USA.

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Gregory J. Petrequin

Colonel, United States Air Force (ret.)

Gregory J. Petrequin is a retired Colonel and

Master Navigator, from the United States Air Force.

During his twenty-seven years on active duty,

he served in a variety of positions, including KC-135

navigator, KC-135 instructor navigator, Combat Crew

Training School Instructor Navigator, Theater Airlift

Liaison Officer, Aide de Camp (to an Army 4-Star

General), Squadron Operations Officer, Squadron

Commander, Deputy Program Manager, Group

Commander and Division Chief, as well as in

numerous other staff positions.

Colonel Petrequin flew 34 sorties (in 42 days), in

the KC-135A during Operation DESERT STORM, and

led a 7-man airfield opening team, into Iraq, on the

first night of Operation IRAQI FREEDOM, assessing

and then opening Tallil Airfield and Baghdad

International Airport, for U.S. and Coalition

operations. He also commanded a combat search and

rescue group, during Operation ENDURING

FREEDOM, in the Horn of Africa, where his group

conducted the first combat rescue and first civilian sea

rescue, in the history of the group.

Colonel Petrequin earned his Bachelor of Arts

Degree, with honors, from San Francisco State

University and has completed three Master’s Degrees,

in Aeronautical Science, Military Operational Art, and

Science and Strategic Studies, from Embry-Riddle

Aeronautical University and Air University.

Colonel Petrequin was awarded the Defense

Superior Service Medal, the Legion of Merit, the

Bronze Star, the Meritorious Service Medal, the Air

Medal, Joint Service Commendation and Achievement

8a

medals and the Air Force Commendation and

Achievement medals, as well as other campaign

medals and ribbons.

Upon retirement from the Air Force, Colonel

Petrequin served as a Production Manager for Cintas

Corporation, managing a 68,000 square foot, multi-

shift, industrial laundry plant, and two branch

locations. He led a team of 50 production partners,

including four supervisors, who processed over 88,000

rental uniforms and thousands of pounds of bulk

product per week. He was the Cintas Midwest Group's

Plant Manager of the year for 2012-2013.

Colonel Petrequin and his fiancée, an

emergency room registered nurse, now make their

home on a family farm in central California, where he

is retired and starting a small business as well as

serving as an advocate and volunteer writer and

speaker for the Military Religious Freedom

Foundation.

thia R. Li er

Reverend, Dr., Chaplain, American Public University

System (ret.), commissioned as a U.S. Army officer

Lindenmeyer is an ordained minister in the United

Church of Christ currently serving as the American

Public University System (APUS) Chaplain and

Pastor at First United Methodist Church in Omaha,

Nebraska. Her doctoral thesis from Princeton

Theological University focused on social online

dynamics for soldiers deployed supporting the Global

War on Terror.

Commissioned into the Signal Corps, she served

on active duty for seven years following graduation

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from the United States Military Academy in 1990 with

a B.S. in Electrical Engineering and area of study in

Middle Eastern History. Throughout her military

career, Cynthia served as the first woman platoon

leader in the 199th Infantry Motorized Regiment and

Signal Platoon leader in the 2nd Armored Cavalry

Regiment (ACR). Serving as an operations officer and

minority admissions officer for West Point, Cynthia

served as a distinguished company commander in

Wonju, Korea in the First Signal Brigade. Cynthia

resigned her Army commission to attend Duke

Divinity School and graduated with a Masters of

Divinity in 2000. Cynthia returned to the Army as a

military chaplain and was the Distinguished Honor

Graduate from the Army Chaplain School. She then

served seven years as Associate Academy Chaplain at

the United States Military Academy. During that

time, she graduated from the Blanton Peale Institute

with a Pastoral Counseling degree.

Cynthia was selected to serve as representative

to the Defense Advisory Committee on Women in the

Services (DACOWITS) advocating to end the combat

exclusion policy for women.