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United States Court of Appeals for the Ninth Circuit Case: 17-17522, 02/20/2018, ID: 10769525, DktEntry: 6, Page 1 of 87 RECORD NO. 17-17522 In The United States Court Of Appeals For The Ninth Circuit BENJAMIN W. ESPINOSA; AMERICAN HUMANIST ASSOCIATION, Plaintiffs-Appellants, v. JAMES DZURENDA, in his official capacity as Director of the Nevada Department of Corrections; JAMES STOGNER, in his official capacity as Head Chaplain of LCC, Defendants-Appellees. ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT COURT FOR NEVADA, RENO NO. 3:16-CV-00141-RCJ-WGC (HONORABLE ROBERT CLIVE JONES) ______________ APPELLANTS’ OPENING BRIEF ______________ Monica L. Miller Kevin Benson American Humanist Association Allison MacKenzie 1821 Jefferson Place NW 402 N. Division Street Washington, DC 20036 Carson City, NV 89703 Telephone: 202-238-9088 x120 Telephone: 775-687-0202 [email protected] [email protected] Counsel for Appellants Counsel for Appellants GibsonMoore Appellate Services, LLC 206 East Cary Street ♦ P.O. Box 1460 (23218) ♦ Richmond, VA 23219 804-249-7770 ♦ www.gibsonmoore.net Case: 17-17522, 02/20/2018, ID: 10769525, DktEntry: 6, Page 2 of 87 CORPORATE DISCLOSURE STATEMENT Pursuant to Federal Rule of Appellate Procedure 26.1 and Ninth Circuit Rule 26.1, Appellant American Humanist Association makes the following disclosures: The American Humanist Association is a non-profit corporation, exempt from taxation under 26 U.S.C. § 501(c)(3). It has no parent or publicly held company owning ten percent or more of the corporation. Date: February 20, 2018 /s/ Monica L. Miller Monica L. Miller American Humanist Association 1821 Jefferson Place NW Washington, DC 20036 Telephone: 202-238-9088 x120 [email protected] Attorney for Appellants i Case: 17-17522, 02/20/2018, ID: 10769525, DktEntry: 6, Page 3 of 87 TABLE OF CONTENTS Page: CORPORATE DISCLOSURE STATEMENT .......................................................... i TABLE OF CONTENTS .......................................................................................... ii TABLE OF AUTHORITIES .................................................................................... iv JURISDICTIONAL STATEMENT .......................................................................... 1 INTRODUCTION AND ISSUES PRESENTED ..................................................... 2 STATEMENT OF THE CASE .................................................................................. 4 1. Nature of the case .................................................................................. 4 2. Parties .............................................................................................. 4 3. Humanism Overview ........................................................................ 6 4. NDOC Faith Group policies ................................................................ 11 5. NDOC’s Refusal to Recognize Humanism ......................................... 14 6. Procedural History ......................................................................... 17 SUMMARY OF THE ARGUMENT ...................................................................... 20 ARGUMENT ........................................................................................................... 23 I. Standard of Review ............................................................................. 23 II. The District Court’s decision contravenes binding precedent holding that Humanism is a religion for Establishment Clause purposes, that belief in a supreme being is not necessary, and that the government cannot favor religion over nonreligion ............... 23 A. Overview ................................................................................... 23 ii Case: 17-17522, 02/20/2018, ID: 10769525, DktEntry: 6, Page 4 of 87 B. Humanism constitutes a religion for Establishment Clause purposes ......................................................................... 25 C. The Establishment Clause prohibits the disparate treatment of Humanists regardless of whether Humanism is a “religion.” ........................................................................... 36 D. The few cases the District Court relied upon are inapposite .................................................................................. 41 III. NDOC’s discrimination against Humanists violates the Establishment Clause .......................................................................... 45 A. NDOC’s disparate treatment of Humanists fails strict scrutiny ...................................................................................... 45 B. NDOC’s disparate treatment of Humanists also fails the Lemon test .................................................................................... 48 IV. The District Court disregarded the Equal Protection Clause, which separately prohibits discrimination against Humanists and Atheists ......................................................................................... 52 A. The District Court dismissed the Equal Protection Clause claim without any rationale ....................................................... 52 B. NDOC’s disparate treatment of Humanists violates the Equal Protection Clause ............................................................ 54 CONCLUSION ........................................................................................................ 60 STATEMENT OF RELATED CASES ................................................................... 62 STATEMENT CONCERNING ORAL ARGUMENT ........................................... 63 CERTIFICATE OF COMPLIANCE ....................................................................... 64 CERTIFICATE OF FILING AND SERVICE ........................................................ 65 iii Case: 17-17522, 02/20/2018, ID: 10769525, DktEntry: 6, Page 5 of 87 TABLE OF AUTHORITIES Page(s): Cases: Abdulhaseeb v. Calbone, 600 F.3d 1301 (10th Cir. 2010) ..................................................................... 58 Abdulhaseeb v. Saffle, 65 F. App'x 667 (10th Cir. 2003) ............................................................... 54 Abington Sch. Dist. v. Schempp, 374 U.S. 203 (1963)................................................................................. 36, 37 ACLU v. City of Plattsmouth, 358 F.3d 1020 (8th Cir. 2004) ....................................................................... 34 ACLU v. Eckels, 589 F. Supp. 222 (S.D. Tex. 1984) ................................................................ 34 Africa v. Pennsylvania, 662 F.2d 1025 (3d Cir. 1981) ...................................................... 41, 42, 43, 44 Allegheny v. ACLU, 492 U.S. 573 (1989) ................................................................................... passim Alvarado v. City of San Jose, 94 F.3d 1223 (9th Cir. 1996) ................................................................... 41, 44 Am. Humanist Ass'n v. Perry, 2017 U.S. Dist. LEXIS 38600 (E.D.N.C. Mar. 17, 2017) ....................... 24, 33 Am. Humanist Ass'n v. United States, 63 F. Supp. 3d 1274 (D. Or. 2014) (“AHA”) ..........................................passim Ashker v. California Dep’t of Corr., 350 F.3d 917 (9th Cir. 2003) ......................................................................... 59 Ass'n of Christian Schs. Int'l v. Stearns, 362 Fed. App'x 640 (9th Cir. 2010) ............................................................... 58 iv Case: 17-17522, 02/20/2018, ID: 10769525, DktEntry: 6, Page 6 of 87 Awad v. Ziriax, 670 F.3d 1111 (10th Cir. 2012) ......................................................... 45, 46, 48 Ball v. Massanari, 254 F.3d 817 (9th Cir. 2001) ......................................................................... 58 Barnes-Wallace v. Boy Scouts of Am., 275 F. Supp. 2d 1259 (S.D. Cal. 2003), aff'd in part, rev'd in part on other grounds, 704 F.3d 1067 (9th Cir. 2012) ....................................................................... 31 Bates v. Commander, First Coast Guard Dist., 413 F.2d 475 (1st Cir. 1969) .......................................................................... 32 Bd. of Educ. v. Grumet, 512 U.S. 687 (1994)....................................................................................... 26 Benjamin v. Coughlin, 905 F.2d 571 (2d Cir. 1990) .......................................................................... 59 Blue Lake Rancheria v. United States, 2010 WL 144989 (N.D. Cal. Jan. 8, 2010) ...................................................... 4 Brown v. Johnson, 743 F.2d 408 (6th Cir. 1984) ...................................................................... 56 Brown v. Livingston, 17 F. Supp. 3d 616 (S.D. Tex. 2014) ................................................. 24, 45, 50 Buchanan v. Burbury, 2006 U.S. Dist. LEXIS 48244 (N.D. Ohio 2006) ......................................... 24 Bud Antle, Inc. v. United States, 593 F.2d 865 (9th Cir. 1979) ...................................................................... 53 Burke v. N.D. Dep't of Corr. & Rehab., 2007 U.S. Dist. LEXIS 35733 (D.N.D. May 16, 2007) ................................ 57 C.F. v. Capistrano Unified Sch. Dist., 654 F.3d 975 (9th Cir. 2011) ...................................................................... 50 v Case: 17-17522, 02/20/2018, ID: 10769525, DktEntry: 6, Page 7 of 87 Caruso v. Zenon, 2005 U.S. Dist. LEXIS 45904 (D. Colo. 2005) ............................................. 45 Catholic League v. City & Cnty. of San Francisco, 624 F.3d 1043 (9th Cir. 2009) ...................................................................
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