# Amicus Curiae Brief — Moore, Chief Justice, Supreme Court of Alabama v. Glassroth

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URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386015_2188%3A3

## Record

- **Collection:** Supreme Court brief
- **Document type:** Amicus Curiae Brief
- **Published:** January 1, 2003
- **Citation:** 540 U.S. 1000

## Text

a
Z) Supreme Court, U S
FILED

OCT 2 1 2003
No. 03-468 OFFICE OF THE CLERK |

In the | |
Supreme Court of the United States

ROY S. MOORE, CHIEF JUSTICE
OF THE ALABAMA SUPREME COURT,

Petitioner,

STEPHEN R. GLASSROTH, MELINDA MADDOX,
AND BEVERLY J. HOWARD,

Respondents.

Petition for a Writ of Certiorari to the
United States Court of Appeals for the Eleventh Circuit

ET EE Oa ret nies
_ Sn cn RARE INCOR aaaeasie semanas

MOTION FOR LEAVE TO FILE AMICUS
CURIAE BRIEF AND AMICUS CURIAE
BRIEF OF THE THOMAS MORE LAW
CENTER IN SUPPORT OF PETITIONER

ceieindaaieaniion
ames

Edward L. White II
Counsel of Record
Thomas More Law Center
3475 Plymouth Rd., Ste. 100
Ann Arbor, MI 48105
734-827-2001 ;
Fax: 734-998-4778
Attorney for Amicus Curiae
Thomas More Law Center

CURRY & TAYLOR @ WASH O.C. ¢ (202) 223-3160 ¢ USSCINFO.cCOM

(2. Ie

MOTION FOR LEAVE TO FILE AMICUS CURIAE
BRIEF AND AMICUS CURIAE BRIEF OF THE
THOMAS MORE LAW CENTER IN SUPPORT OF
PETITIONER

Pursuant to Supreme Court Rule 37.2(b), the Thomas
More Law Center respectfully moves this Court for leave
to file the attached amicus curiae brief in support of the
Petitioner, Chief Justice Roy S. Moore. The consent of
the attorneys for the Petitioner has been obtained. The
consent of the attorneys for the Respondents was
requested but refused.

The Thomas More Law Center is a national, not-for-
profit, public interest law firm based in Ann Arbor,
Michigan. The Thomas More Law Center is dedicated to
defending and promoting the sanctity of human life,
time-honored values, and the religious freedom of
Christians, including the display of the Ten
Commandments on public property. As part of its
litigation efforts, the Thomas More Law Center has
represented government entities in defense of lawsuits
seeking to remove Ten Commandments monuments
from public property, and the Thomas More Law Center
has submitted amicus curiae briefs at the United States
Court-of Appeals level in support of the public display of
such monuments. In particular, the Thomas More Law
Center filed an amicus curiae brief, with the cons.t of
all parties, in the United States Court of Appeals for the
Eleventh Circuit in support of Chief Justice Moore.
Accordingly, the Thomas More Law Center has an
interest and an expertise in this area of the law, which
will be of assistance to this Court in deciding whether to
grant Chief Justice Moore’s petition for a writ of
certiorari.

The Thomas More Law Center’s amicus curiae brief
points out that this case presents not only the
opportunity, as argue * in the Petition, for this Court to
re-examine Lemon v ..zrtzman, 403 U.S. 602 (1971),
but also the opportunity to re-evaluate Stone v. Graham,
449 U.S. 39 (1980) (per curiam), and to clarify for the
lower courts the proper scope and applicability, if any,
of Stone to cases involving the display of the Ten
Commandments in non-public school contexts.

Respectfully submitted,

Edward L. White III
Counsel of Record
Thomas More Law Center
3475 Plymouth Road, Ste. 100
Ann Arbor, MI 48105
734-827-2001
Fax: 734-998-4778
Attorney for Amicus Curiae
Thomas More Law Center

October 21, 2003

i

TABLE OF CONTENTS

MOTION FOR LEAVE TO FILE AMICUS CURIAE
BRIEF AND AMICUS CURIAE BRIEF OF THE
THOMAS MORE LAW CENTER IN SUPPORT OF
PETITIONER

Pe i vccicsesccncssccccoressescccsccconssocoseoces soacsessves

STATEMENT OF IDENTITY AND INTEREST OF

EE

.

TABLE OF AUTHORITIES

CASES

ABINGTON SCH. DIST. V. SCHEMPP, 374 U.S.

203 (1963)...cccceceveeeeeeeees senna ee

ACLU v. City OF PLATTSMOUTH, 186 F. SUPP.

ZD 1024 (D. NEB. 2002) ........ccceccecsscecssesseccesesesees

ACLU v. HAMILTON COUNTY, 202 F. SUPP. 2D

757 (E.D. TENN. 2002) .............rccsescsscesseersesesees

ACLU v. MERCER COUNTY, 219 F. SUPP. 2D

TTT (ED. RY. 2ODZ) q...crcccocensevcccccessscereenseseccsensece

ADLAND V. Russ, 307 F.3D 471 (6TH CIR.
2002), CERT. DENIED, 123 S. CT. 1909

ANDERSON V. SALT LAKE CITY CorP., 475
F.2D 29 (10TH Cir. 1973), CERT. DENIED,

414. U.S. 879 (1973) covvosavnvsenovevcvvvccscsssssssocesseseeee

BOOKS V. CITY OF ELKHART, 235 F.3D 292
(7TH Cir. 2000), CERT. DENIED, 121 S. CT.

ELLA RLEAAOE

CITy OF ELKHART V. BOOKS, 121 S. CT. 2209

COLORADO V. FREEDOM FROM RELIGION
FOUND., 898 P.2p 1013 (CoL. 1995) (EN
BANC), CERT. DENIED, 516 U.S. 1111 (1996)

COUNTY OF ALLEGHENY V. ACLU, 492 U.S.
BE Ce iviecscsnrcrnersnenesnennnesesinscnasiinniicrninbaninamneenees

iii
CROCKETT V. SORENSON, 568 F. Supp. 1422

CD. Ck SE sisccicanes onl 9
EDWARDS V. AGUILLARD, 482 U.S. 578 (1987) ...........:.0000 7,8
ENGEL V. VITALE, 370 U.S. 421 (1962).............scccsccsssssseees 4,5
FREETHOUGHT SOC'Y V. CHESTER COUNTY,

334 F.3D 247 (SD CIR. 20038)..........cccccccsscsssccseseees pecionneeii 11
HOHN V. UNITED STATES, 524 U.S. 236 (1998) ............ceseeeee 6
KIMBLEY V. LAWRENCE COUNTY, 119 F. SUPP.

I i I. ciiccneniniinndl 5
LEE V. WEISMAN, 505 U.S. 577 (1992)...........ccsscsssssssssessseeees q
LEMON V. KURTZMAN, 403 U.S. 602 (1971) ..........cceeeseeeees 2,4
LYNCH V. DONNELLY, 465 U.S. 668 (1984) ..........eseeseeseeeeeee 10

SANTA FE INDEP. SCH. DIST. v. DOE, 530 U.S.
I Ce ierciccnininiinseiciaisvicnaiiaiantiiianinaiianitiiiiaiaitiieaimanedial 4

STONE V. GRAHAM, 449 U.S. 39 (1980) (PER

SUMMUM V. CITY OF OGDEN, 152 F. SUPP. 2D
1286 (D. UTAH 2001) AFF'D IN PART, REV'D

IN PART, 297 F.3D 995 (10™ CIR. 2002) .......seeesssseseesseeeeeees 9
RULES
Bete, Ce, Fh, FIG seieneersnceenenionsacininsinunicanianienianeniaisinmenieaaiainisinns ]
Dem. CR. BE. BEG ccviccnccictnienssnminaniiimnmnnnninaanest Niintineelinsenetiianaeie ]

1

STATEMENT OF IDENTITY AND INTEREST
OF THE AMICUS CURIAE

The Thomas More Law Center is a national, not-for-
profit, public interest law firm based in Ann Arbor,
Michigan. The Thomas More Law Center is dedicated to
defending and promoting the sanctity of human life,
time-honored values, and the religious freedom of
Christians, including the display of the Ten
Commandments on public property. As part of its
litigation efforts, the Thomas More Law Center has
represented government entities in defense of lawsuits
seeking to remove Ten Commandments monuments
from public property, and the Thomas More Law Center
has submitted amicus curiae briefs in the United States
Court of Appeals for the Sixth Circuit, Seventh Circuit,
and the Eleventh Circuit in support of the public display
of such monuments. Accordingly, the Thomas More
Law Center has an interest and an expertise in this area
of the law, which will be of assistance to this Court in
deciding whether to grant Chief Justice Moore’s petition
for a writ of certiorari.

The Thomas More Law Center appears as amicus
curiae in support of Chief Justice Moore and urges this
Court to grant his petition for a writ of certiorari.’

SUMMARY OF THE ARGUMENT
To date, this Court has not decided a case that

involves the display of the Ten Commandments,
whether displayed alone or as part of a broader display,

'‘ No counsel for a party authored this brief in whole or in part,
and no person or entity aside from the Thomas More Law Center
has made a monetary contribution to the preparation or submission
of this brief. Sup. Ct. R. 37.6. The Thomas More Law Center has no
parent corporation and no stock. Sup. Ct. R. 29.6.

=

in a non-public school context. This case presents this
Court with that opportunity.

More than twenty years ago, this Court decided in
summary fashion Stone v. Graham, 449 U.S. 39 (1980)
(per curiam), which involved the mandated display of
the Ten Commandments, by themselves, in public
school classrooms. This Court determined that even
though the Kentucky Legislature had set forth a secular
purpose for the display, the religious nature of the Ten
Commandments overrode that secular purpose and thus
led this Court to conclude that the Establishment Clause
had been violated.

Stone, although squarely a public school case, has
led to a presumption against the display of the Ten
Commandments in non-public school contexts. This
case presents this Court with the opportunity to re-
evaluate Stone and to clarify the proper scope and
applicability of Stone in order to provide lower courts
' with guidance on how to evaluate government displays,
which include the Ten Commandments, in non-public
school contexts.

Such guidance from this Court is especially needed
in light of the mounting litigation over the public display
of the Ten Commandments in non-public school
contexts, litigation that has resulted in contrary results
in this country.

This Court should grant a writ of certiorari in this
case for the reasons stated in this brief, as well as for
the reasons set forth in the Petition, including that this
Court re-examine Lemon v. Kurtzman, 403 U.S. 602
(1971), as a viable precedent. Pet. 11-25.

3
ARGUMENT

At issue in this case is the “moral foundation of law”
display that appeared in the Rotunda of the Alabama
Supreme Court and contained a monument that includes
the text of the Ten Commandments, which has secular
and religious attributes, along with the national motto
“In God We Trust,” and quotations from the Declaration
of Independence, George Mason, and James Madison
among many other quotations that address the moral
foundation of our law. In addition to the monument, the
display includes a plaque with quotations regarding the
moral foundation of law by Martin Luther King, Jr. and
Frederick Douglass. And, the display includes a plaque
inscribed with the Bill of Rights. Pet. App. 47a-50a, 52a,
‘04a-107a, 115a.

This Court has never decided a case that involves the
display of the Ten Commandments, whether alone or in
a broader context, as in the instant case, in a non-public
school context. This case presents this Court with that

opportunity.

More than twenty years ago, in Stone v. Graham, 449
U.S. 39 (1980) (per curiam), this Court considered a
Kentucky statute that required school officials to post a
copy of the Ten Commandments alone on the wall of
each public school classroom in Kentucky. Id. at 39.
This Court summarily struck down the law, holding that
it served no secular purpose, even though the Kentucky
Legislature had required the following statement of
secular purpose to appear at the bottom of each display:
“The secular application of the Ten Commandments is
clearly seen in its adoption as the fundamental legal
code of Western Civilization and the Common Law of
the United States.” Jd. at 41.

4

Despite the Kentucky Legislature’s stated secular
purpose for the display, this Court nevertheless
summarily wrote: “The pre-eminent purpose for posting
the Ten Commandments on schoolroom walls is plainly
religious in nature. The Ten Commandments are
undeniably a sacred text in the Jewish and Christian
faiths, and no legislative recitation of a supposed secular
purpose can blind us to that fact. The Commandments
do not confine themselves to arguably secular matters. .
..” Id. at 41. This Court, therefore, concluded that the
Kentucky statute in question violated the first prong (the
purpose prong) of Lemon v. Kurtzman, 403 U.S. 602
(1971), and consequently violated the Establishment
Clause.” Id. at 42-43.

In reaching its ruling in Stone, apart from referencing
Lemon, this Court relied only on public school prayer
cases, id. at 4043 (citing Abington Sch. Dist. v.
Schempp, 374 U.S. 203 (1963) (Bible reading and Lord’s
Prayer), and Engel v. Vitale, 370 U.S. 421 (1962) (daily
prayer)), thus indicating that this Court viewed Stone as
a public school prayer case in concluding that the
Kentucky Legislature’s requirement that the Ten
Commandments be posted on the classroom walls was
purely a religious admonition along the lines of the
religious practices prohibited in Schempp and Engel.

* Justices of this Court have criticized Lemon, and the time has
come for this Court to re-evaluate Lemon as a viable precedent, as
Chief Justice Moore argues in his Petition. Pet. 11-25; see, e.g.,
Santa Fe Indep. Sch. Dist. v. Doe, 530 U.S. 290, 319-20 (2000)
(Rehnquist, CJ., joined by Scalia and Thomas, JJ., dissenting)
(explaining that “Lemon has had a checkered career in the
decisional law of this Court” and collecting Supreme Court opinions
criticizing Lemon and noting further that this Court has stated that
Lemon is not binding on it).

5

Even though Stone is essentially a public school
prayer case and is limited to the public school context
with regard to the display of the Ten Commandments, as
Chief Justice Moore points out in his petition, “Stone has
become the touchstone of all Ten Commandment
display cases, as it was in the Court of Appeals below.”
Pet. 18 n.4.

In particular, the Court of Appeals relied on Stone in
rejecting Chief Justice Moore’s argument that the Ten
Commandments, which were part of the overall
Rotunda display, depicts the moral foundation of
secular duties. Pet. App. 27a, 30a. The Court of Appeals
stated that as this Court declared in Stone, “(t]he Ten
Commandments are undeniably a sacred text in the
Jewish and Christian faiths, and no legislative recitation
of a supposed secular purpose can blind us to that fact.””
Id. (citing Stone, 449 U.S. at 41). Moreover, the Court of
Appeals. stated that the ‘“[ujse of the Ten
Commandments for a secular purpose . . . does not
change their inherently religious nature. .. .” Id.

The Court of Appeals’ reading of Stone illustrates an
incorrect presumption stemming from Stone that the
display of the Ten Commandments on government
property, even in a non-public school context, violates
the Establishment Clause based on the view that no
secular purpose for displaying the Ten Commandments
can overcome the religious nature of the Decalogue.

* E.g., Adland v. Russ, 307 F.3d 471, 480-81 (6” Cir. 2002), cert.
denied, 123 S. Ct. 1909 (2003); Books v. City of Elkhart, 235 F.3d
292, 302-04 (7" Cir. 2000), cert. denied, 121 S. Ct. 2209 (2001); ACLU
v. Hamilton County, 202 F. Supp. 2d 757, 763 (E.D. Tenn. 2002);
ACLU v. City of Plattsmouth, 186 F. Supp. 2d 1024, 1032 (D. Neb.
2002); Kimbley v. Lawrence County, 119 F. Supp. 2d 856, 865-66
(S.D. Ind. 2000).

6

This Court could hardly have intended such a
presumption when it drafted Stone more than twenty
years ago or intended for Stone to be applied to Ten
Commandments displays in non-public school contexts.
This case presents this Court with the opportunity to re-
evaluate Stone and clarify the proper scope and
applicability of Stone to cases involving the display of
the Ten Commandments in non-public school contexts.’

Indeed, this Court should not feel constrained to
follow Stone, which by its very nature is a weak
precedent, and this Court should be concerned with the
strength the lower courts have given to Stone in non-
public school contexts.’ Stone is a 5to4 per curiam
opinion. It was a “cavalier summary reversal” of the
courts of Kentucky that was done without the benefit of
oral argument, briefing, or plenary consideration by this
Court. Stone, 449 U.S. at 47 (Rehnquist, J., dissenting);
see also id. at 43 (Burger, CJ., joined by Blackmun, J.,
dissenting); id. (Stewart, J., dissenting). This Court has
explained that it is “less constrained to follow precedent
where . . . the opinion was rendered without full briefing
or argument.” Hohn v. United States, 524 U.S. 236, 251
(1998).

Reliance on Stone outside the public school context
has limited, if any, value since the unique and particular
circumstances of the public school context, which led to

* At the time Stone was decided, there was little, if any,
litigation over the public display of the Ten Commandments in non-
public school contexts, and there was only one published federal
circuit court decision on the subject, Anderson v. Salt Lake City
Corp., 475 F.2d 29 (10" Cir. 1973), cert. denied, 414 U.S. 879 (1973),
which the Stone majority did not even reference, further supporting
the conclusion that Stone is intended to be limited to the public
school context.

* See, e.g., n.3, supra.

7

the holding in Stone, do not extend outside that context.
This Court should make that clear to the lower courts.

The public school context in which the Stone
majority considered the display of the Ten
Commandments explains the majority's summary
conclusions about the Decalogue’s religious nature and
its summary rejection of the secular purpose advanced
by the Kentucky Legislature for displaying the Ten
Commandments in those classrooms.

This Court always has been especially concerned
about religious activities in public schools, a heightened
concern that it does not extend beyond the public
school context. See, e.g., Lee v. Weisman, 505 U.S. 577,
592 (1992) (“[T]here are heightened concerns with
protecting freedom of conscience from subtle coercive
pressure in the elementary and secondary public
schools.”); Edwards v. Aguillard, 482 U.S. 578, 583-84
(1987) (“The Cowrt has been particularly vigilant in
monitoring compliance with the Establishment Clause
in elementary and secondary schools.”); see also County
of Allegheny v. ACLU, 492 U.S. 573, 620 n.69 (1989)
(explaining that although a public display of a Christmas
tree and a menorah in a non-public school context was
found to be constitutional, such a display located in a
public school context would raise additional
constitutional considerations since the Establishment
Clause must be applied with a special sensitivity in that
context).

The heightened concerns this Court has about
anything religious in the public school setting, however,
should not be applied to displays of the Ten
Commandments in non-public school settings, where
children are not compelled to be present as they are in a
public school classroom where the Ten Commandments

8

are posted alone as in Stone. See Colorado v. Freedom
from Religion Found., 898 P.2d 1013, 1023 (Col. 1995)
(en banc) (explaining that reliance on Stone is
misplaced in analyzing the display cf the Ten
Commandments except when the Decalogue is
displayed in a public school classroom, where students
are compelled to aitend and are easily influenced), cert.
denied, 516 U.S. 1111 (1996).

Moreover, although originating from a religious text,
the Ten Commandments are not as limited in scope as
the Stone majority suggested. This Court should make it
clear to the lower courts that it did not intend in Stone
to limit the importance of the Ten Commandments to
being just a “sacred text” that lacks secular applications
and that it did not intend to raise the presumption that
the public display of the Ten Commandments violates
the Establishment Clause even in a non-public school
context.”

As has been repeatedly acknowledged, especially
after the issuance of Stone, except by a majority of this
Court, the Ten Commandments undeniably form the
basis of the judicial code of Western Civilization, which
is something that should be acknowledged in public and
which was what the broad display in the Rotunda of the
Alabama Supreme Court conveyed to its viewers. See,
e.g., City of Elkhart v. Books, 121 S. Ct. 2209, 2211
(2001) (Rehnquist, CJ., joined by Scalia and Thomas, JJ.,
dissenting from denial of certiorari) (“Undeniably .. .

* Although in Edwards v. Aguillard, 482 U.S. 578, 593-94 (1987),
a public school case, this Court explained that it did not mean in
Stone that “no use could ever be made of the Ten Commandments,
or that the Ten Commandments played an exclusively religious role
in the history of Western Civilization,” this limitation of Stone needs
to be reiterated by this Court in the context of the display of the
Ten Commandments in a non-public school setting.

9

the [Ten] Commandments have secular significance
[besides being a sacred text] because they have made a
substantial contribution to our secular legal codes.”);
Books v. City of Elkhart, 235 F.3d 292, 302 (7° Cir. 2000)
(“The text of the Ten Commandments no doubt has
played a role in the secular development of our society. .
. .”), cert. denied, 121 S. Ct. 2209 (2001); Anderson v.
Salt Lake City Corp., 475 F.2d 29, 33-34 (10th Cir. 1973)
(noting that the Ten Commandments have religious and
secular attributes), cert. denied, 414 U.S. 879 (1973);
ACLU v. Mercer County, 219 F. Supp. 2d 777, 784 (E.D.
Ky. 2002) (“[FJor good or bad, right or wrong, the Ten
Commandments did have an influence: upon the
development of United States law. . . .”); Summum v.
City of Ogden, 152 F. Supp. 2d 1286, 1294 (D. Utah 2001)
(“The ‘Ten Commandments,’ while a sacred text to some
and an ethical code of conduct to others, is also a
landmark in the history of the development of Western
law.”), aff'd in part, rev’d in part, 297 F.3d 995 (10" Cir.
2002); Crockett v. Sorenson, 568 F. Supp. 1422, 1428
(W.D. Va. 1983) (“[T]he Ten Commandments have had
immeasurable effect on Anglo-American legal
development.”); Colorado v. Freedom from Religion
Found., 898 P.2d 1013, 1024 (Colo. 1995) (en banc)
(noting “the historical fact that the Ten Commandments
has served over time as a basis for our national law”),
cert. denied, 516 U.S. 1111 (1996).

This Court should clearly acknowledge the
contributions the Ten Commandments have made to the
development of our law to ensure that there is no
presumption, as Stone tends to engender, that there can
be no secular purpose for the display of the Ten
Commandments in public, even in a non-public school
context.

19

Along those lines, because Stone pre-dates Lynch v.
Donnelly, 465 U.S. 668 (1984), and County of Allegheny
v. ACLU, 492 U.S. 573 (1989), which are this Court’s two
leading cases that provide the analytical framework for
determining the constitutionality of government displays
of items with religious connotations, this Court should
clarify for the lower courts how Stone should be
weighed, if at all, when analyzing the display of the Ten
Commandments in non-public school contexts in light of
Lynch and Allegheny.

In Lynch and Allegheny, this Court upheld the
government display of religious symbols (the créche and
the menorah) as part of a broader display in a non-
public school context. Lynch, 465 U.S. at 671-72, 687;
Allegheny, 492 U.S. at 581-82, 621. Although in Lynch
and Allegheny religious objects (the créche and the
menorah) were permitted to be included in public
displays, the same result does not generally occur when
the Ten Commandments are involved, even though the
Commandments have both sacred and_ secular
attributes, which can reasonably be attributed to the
presumption in Stone against the public display of the
Ten Commandments, no matter the secular purpose for
the display. If a créche and a menorah, both religious
symbols, may be included in public displays, then the
Ten Commandments, which have both sacred and
secular attributes, should be permitted, especially when
the Ten Commandments are included in a broad display,
as occurred here, to commemorate the foundation of
our laws.

In sum, this case presents this Court with the
opportunity to re-evaluate and clarify Stone and to re-
examine Lemon. In so doing, this Court should give
guidance to the lower courts on how to analyze displays
of the Ten Commandments in non-public school

11

contexts, which is especially needed in light of the
mounting litigation in this area that has produced
contrary results throughout this country. E.g.,
Freethought Soc’y v. Chester County, 334 F.3d 247 (3d
Cir. 2003) (allowing display of Ten Commandments);
Adland v. Russ, 307 F.3d 471 (6" Cir. 2002) (not allowing
display of Ten Commandments), cert. denied, 123 S. Ct.
1909 (2003); Books v. City of Elkhart, 235 F.3d 292 (7°
Cir. 2000) (not allowing display of Ten Commandments),
cert. denied, 121 S. Ct. 2209 (2001); Anderson v. Salt
Lake City Corp., 475 F.2d 29 (10" Cir. 1973) (allowing
display of Ten Commandments), cert. denied, 414 U.S.
879 (1973); Colorado v. Freedom from Religion Found.,
898 P.2d 1013 (Col. 1995) (en banc) (allowing display of
Ten Commandments), cert. denied, 516 U.S. 1111 (1996).

CONCLUSION

This Court should grant a writ of certiorari in this
case for the above-stated reasons, as well as for the
reasons set forth in the Petition.

Respectfully submitted,

Edward L. White III
Counsel of Record
Thomas More Law Center
3475 Plymouth Road, Ste. 100
Ann Arbor, MI 48105
734-827-2001
Fax: 734-998-4778
Attorney for Amicus Curiae
Thomas More Law Center

October 21, 2003

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386015_2188%3A3. Public record. Not legal advice.