Reply Brief for Petitioners Zhang Zingrong, et al.

Details

Author(s):
Publish Date:
August 31, 2022
Format:
Brief
Citation(s):
  • James A. Sonne, Michael W. McConnell & Terri E. Marsh, Reply Brief for Petitioners Zhang Zingrong, et al., No. 21-1429 in the Suprreme Court of the United States (Aug. 31, 2022).
Related Organization(s):

Abstract

The Freedom of Access to Clinic Entrances Act (FACEA) prohibits violence against persons exercising their right to religious freedom at a “place of religious worship.” 18 U.S.C. § 248(a)(2). Although FACEA does not modify the term, the Second Circuit held that “place of religious worship” should reach only places “religious adherents collectively recognize
or religious leadership designates as a place primarily to gather for or hold religious worship activities.”

The question presented is:

Whether the statutory text and First Amendment permit FACEA’s protection from violence at a “place of religious worship” to apply only to places religious adherents collectively recognize or religious leadership designates as a place primarily to gather for or hold religious worship activities.