NO. ________ IN THE Supreme Court of the United States SEATTLE’S UNION GOSPEL MISSION, Petitioner, v. MATTHEW S. WOODS, Respondent. On Petition for Writ of Certiorari to the Supreme Court of Washington PETITION FOR A WRIT OF CERTIORARI NATHANIEL L. TAYLOR KRISTEN K. WAGGONER ABIGAIL J. ST. HILAIRE JOHN J. BURSCH ELLIS, LI & MCKINSTRY Counsel of Record PLLC RORY T. GRAY 1700 Seventh Ave., ALLIANCE DEFENDING Suite 1810 FREEDOM Seattle, WA 98101 440 First Street, N.W. (206) 682-0565 Suite 600 Washington, D.C. 20001 (616) 450-4235
[email protected] Counsel for Petitioner i QUESTIONS PRESENTED Petitioner Seattle’s Union Gospel Mission is a nonprofit that exists to preach the gospel of Jesus Christ. Mission employees—all of whom must share and live out its beliefs—do so by meeting the needs of the homeless and evangelizing to them. One of the Mission’s many ministries is Open Door Legal Services, a legal clinic that assists those in Mission recovery programs and other vulnerable community members. Respondent Matthew Woods applied for an Open Door position with the stated intent of changing the Mission’s religious beliefs and without satisfying the prerequisites of regular church attendance, a pastor’s recommendation, and an explanation of his relationship with Jesus. Woods sued when the Mission hired a coreligionist instead. A state trial court ruled for the Mission, noting that it is exempt from state non-discrimination law. But the Washington Supreme Court held that exemp- tion violated the state constitution as-applied and declared the Mission’s First Amendment rights limi- ted to the ministerial exception, creating a split with six Courts of Appeals.