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IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION

INTERVARSITY CHRISTIAN
FELLOWSHIP/USA, et al.,

Civil Action No. 1:18-cv-00231

Plaintiffs,
v.
BOARD OF GOVERNORS OF WAYNE
STATE UNIVERSITY, et al.,

REPLY IN SUPPORT OF
INTERVARSITY’S MOTION FOR
PARTIAL SUMMARY JUDGMENT
AND A PERMANENT INJUNCTION

Defendants.

Daniel P. Dalton
Dalton & Tomich PLC
The Chrysler House
719 Griswold Street, Suite 270
Detroit, Michigan 48226
Tel.: (313) 859-6000
Fax: (313) 859-8888
ddalton@daltontomich.com

Lori H. Windham
Eric C. Rassbach
Daniel H. Blomberg
Daniel Ortner
The Becket Fund for Religious Liberty
1200 New Hampshire Ave. NW, Suite 700
Washington, DC, 20036
Tel.: (202) 955-0095
Fax: (202) 955-0090
lwindham@becketlaw.org
Counsel for Plaintiffs

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TABLE OF CONTENTS
TABLE OF AUTHORITIES .......................................................................................................... ii
INTRODUCTION ...........................................................................................................................1
I. InterVarsity is entitled to summary judgment on its Religion Clause claims............................1
II. InterVarsity is entitled to summary judgment on its Free Exercise claims ...............................3
III. InterVarsity is entitled to summary judgment on its Free Speech claim ...................................5
A. Wayne State’s policy is unconstitutional on its face ...........................................................5
B. Wayne State cannot defend the arbitrary application of its policy here ..............................7
IV. InterVarsity is entitled to summary judgment on its expressive association claim ...................8
V. Wayne State’s actions cannot survive strict scrutiny .................................................................9
CONCLUSION ..............................................................................................................................10

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TABLE OF AUTHORITIES
Page(s)
Cases
Alpha Delta Chi-Delta Chapter v. Reed,
648 F.3d 790 (9th Cir. 2011) .....................................................................................................6
CEF of Minn. v. Minneapolis Special Sch. Dist.,
690 F.3d 996 (8th Cir. 2012) .....................................................................................................9
Christian Legal Soc’y v. Walker,
453 F.3d 853 (7th Cir. 2006) .....................................................................................................2
Christian Legal Soc’y v. Martinez,
561 U.S. 661 (2010) ..................................................................................................... 5, 6, 9-10
Church of Lukumi Babalu Aye, Inc. v. City of Hialeah,
508 U.S. 520 (1993) .................................................................................................................10
Conlon v. InterVarsity Christian Fellowship/USA,
777 F.3d 829 (2015) ...............................................................................................................1, 2
Fraternal Order of Police v. City of Newark,
170 F.3d 359 (1999) ...................................................................................................................4
Gonzales v. O Centro Espirita Beneficente Uniao do Vegetal,
546 U.S. 418 (2006) ...................................................................................................................9
Healy v. James,
408 U.S. 169 (1972) ...................................................................................................................9
Hollins v. Methodist Healthcare, Inc.,
474 F.3d 223 (6th Cir. 2007) .....................................................................................................3
Holt v. Hobbs,
135 S. Ct. 853 (2015) ...............................................................................................................10
Hosanna-Tabor Evangelical Lutheran Church and Sch. v. EEOC,
565 U.S. 171 (2012) ......................................................................................................... passim
Hurley v. Irish-Am. Gay, Lesbian & Bisexual Grp. of Boston,
515 U.S. 558 (1995) ...................................................................................................................7
Masterpiece Cakeshop Ltd. v. Colo. Civil Rights Comm’n,
No. 16-111, 584 U.S. __ (June 4, 2018) ....................................................................................5

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McAllen Grace Brethren Church v. Salazar,
764 F.3d 465 (5th Cir. 2014) ...................................................................................................10
Midrash Sephardi v. Town of Surfside,
366 F.3d 1214 (11th Cir. 2004) .................................................................................................4
Reed v. Town of Gilbert, Ariz.,
135 S. Ct. 2218 (2015) ...............................................................................................................7
Stryker Corp. v. XL Ins. Am., Inc.,
No. 1:05-cv-51, 2013 WL 3276408
(W.D. Mich. June 27, 2013) ....................................................................................................10
Trinity Lutheran Church of Columbia, Inc. v. Comer,
137 S. Ct. 2012 (2017) ...............................................................................................................5
United States v. Virginia,
518 U.S. 515 (1996) ...................................................................................................................8
Statutes
42 U.S.C. § 2000bb ..........................................................................................................................8
Other Authorities
Dean of Students Office, List of student organizations,
https://doso.wayne.edu/org-services/listing ...............................................................................4
Wayne State University Code 2.28.01.010-20.................................................................................5

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INTRODUCTION
InterVarsity wants to continue its religious association on campus, as it has for 75 years. It has
shown that Wayne State’s abrupt actions to terminate that association violate the First Amendment.
In response, Wayne State is once again heavy on the invective and light on the law. It relies upon
inapplicable cases while struggling to explain the inexplicable: its decision to penalize
InterVarsity’s religious leadership decisions while ignoring the leadership and membership
decisions of dozens of other groups. Wayne State’s concessions, both in its summary judgment
response and its motion to dismiss, make clear that its actions here must face strict scrutiny, which
they cannot hope to pass. Wayne State wants this Court to dismiss the case and authorize Wayne
State to interfere with InterVarsity’s religious leadership selection in unconstitutional ways. But it
is InterVarsity that is entitled to both summary judgment in its favor and an injunction permanently
prohibiting Wayne State from resuming its unconstitutional behavior. 1
I. InterVarsity is entitled to summary judgment on its Religion Clause claims.
Wayne State admits or does not contest all of the elements necessary to grant summary
judgment to InterVarsity on Counts I and II. Under the Religion Clauses, government is forbidden
from “interfer[ing] with the internal governance” of a religious organization, particularly by
“dictat[ing] to a religious organization who its spiritual leaders would be.” Conlon v. InterVarsity
Christian Fellowship/USA, 777 F.3d 829, 835-36 (2015). Accordingly, if (1) a “religious group,”
(2) is selecting “one of the group’s ministers,” (3) the government may not “interfer[e] with the
freedom of [the] religious group[ ]” to make that selection. Hosanna-Tabor Evangelical Lutheran
Church and Sch. v. EEOC, 565 U.S. 171, 177, 184 (2012).
Here, the facts establishing the first two prongs are undisputed. Wayne State does not contest
1

Wayne State asks to defer any decision on this motion and for oral argument on this and on its
motion to dismiss. If the Court believes oral argument would be helpful, InterVarsity requests that
both motions be considered and set for argument concurrently.
1

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that InterVarsity has a “religious mission” to “establish and advance . . . witnessing communities
of students and faculty who follow Jesus as Savior and Lord.” Dkt. 21 at 4. Nor does it contest that
InterVarsity’s leaders must “exemplify Christ-like character, conduct, and leadership,” affirm
InterVarsity USA’s statement of faith, perform “important religious functions,” and have a
“religious leadership title.” Id.; Dkt. 16-1 at 11-13. It also does not contest the evidence showing
that InterVarsity’s leaders hold important religious roles and receive significant religious training.
Dkt. 16-1 at 13. Together, these uncontested facts show that the ministerial exception “clearly
applies” to protect InterVarsity’s leadership selection. InterVarsity, 777 F.3d at 834-35.
And the last prong is conceded: Wayne State admits that it interprets its policy to “provide[] a
bright-line rule” against InterVarsity asking its leaders to believe in the God they pray to. Dkt. 21
at 21. That absolute rule is the kind of interference in “religious leadership” decisions that the First
Amendment “categorically prohibits.” InterVarsity, 777 F.3d at 836. Nor could it be otherwise:
Wayne State’s bright-line “intrusion into the internal structure [and] affairs” of InterVarsity would,
if allowed to stand, “cause the group . . . to cease to exist.” Christian Legal Soc’y v. Walker, 453
F.3d 853, 861, 863 (7th Cir. 2006).
Wayne State offers three defenses. First, that the Religion Clauses’ protection for internal
leadership selection decisions “operates solely as a defense.” Dkt. 21 at 18. But that unprecedented
and impoverished vision of the Religion Clauses is wrong, as InterVarsity explains in its Response
to Wayne State’s motion to dismiss. Dkt. 25 at 11-15.
Second, Wayne State worries that allowing religious groups to select their own leaders will
raise Establishment Clause problems. Dkt. 21 at 20. But it is Wayne State’s effort to entangle itself
in leadership selection that raises such problems. Moreover, courts have enforced the right of
religious groups to select their leaders for decades without violating the Establishment Clause.

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And should Wayne State fear it cannot follow their nuanced example, it could always simply adopt
as a general rule its recent commitment that it “will not intervene in [InterVarsity’s] leadership
selection.” Dkt. 16-1 at 7. That worked well for the last 75 years.
Third, Wayne State argues that the ministerial exception’s protections are limited to situations
where a “government actor” takes over as a group’s minister. Dkt. 21 at 19. But that misses the
point. The ministerial exception is a complete structural bar on any government interference in
ministerial selection, not just interference the government might consider substantial. Hence the
Supreme Court’s ruling that any “penalty” or “punish[ment]” on leadership selection is forbidden,
since it would pressure a religious organization to select “an unwanted minister.” Hosanna-Tabor,
565 U.S. at 194, 188. Thus, courts have protected religious groups from many different types of
attempts to use governmental pressure to influence ministerial decisions. See Hollins v. Methodist
Healthcare, Inc., 474 F.3d 223, 225 (6th Cir. 2007) (listing anti-discrimination, contract, and tort
claims). Rejecting such pressure, the First Amendment has “struck the balance” to protect a
religious group’s selection of “who will guide it on its way.” Hosanna-Tabor, 565 U.S. at 196.
In sum, this Court can and should grant summary judgment to InterVarsity.
II. InterVarsity is entitled to summary judgment on its Free Exercise claims.
Wayne State has likewise conceded or failed to rebut all of the facts necessary to enter
judgment for InterVarsity on its Free Exercise Claims, Counts III and IV. Some of this has been
covered in InterVarsity’s Response to Wayne State’s motion to dismiss, Dkt. 25 at 15-20, but
Wayne State’s summary judgment response brief makes the Constitutional analysis even clearer.2
Wayne State admits that it has “exempt[ions] from the nondiscrimination policy” for categories

Due to a scrivener’s error, the Free Exercise Counts III and IV were not listed in the motion,
but have been briefed by both parties. See Dkt. 16-1 at 21, Dkt. 21 at 20-22. Wayne State argues
the court could grant it summary judgment on all counts. Id. at 6. Therefore the Court may grant
summary judgment to InterVarsity on Counts III and IV.
2

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of secular groups, exemptions that it does not allow to religious groups. Dkt. 21 at 12. When the
government “creates a categorical exemption for individuals with a secular objection [to a policy]
but not for individuals with a religious objection,” that categorical distinction indicates an
impermissible “value judgment” against religious motivations and “is sufficiently suggestive of
discriminatory intent so as to trigger heightened scrutiny.” Fraternal Order of Police v. City of
Newark, 170 F.3d 359, 365 (1999). Courts have found that just one categorical exemption is
sufficient. Id. at 366; accord Midrash Sephardi v. Town of Surfside, 366 F.3d 1214, 1235 (11th
Cir. 2004) (same). Wayne State admits to several. For instance, Wayne State admits that, “[a]s a
matter of policy,” it “does not apply the gender component of the nondiscrimination policy to club
sports.” Dkt. 21 at 3. Wayne State says that the reason for this is “obvious” and “based on . . .
health, safety and welfare.” Id. at 3, 12. But it is far from obvious that those concerns required
granting an automatic, categorical exemption to clubs that might not even want it, such as Wayne
State’s two ping-pong clubs, its billiards club, or the Quidditch club. See Dean of Students Office,
List of student organizations, https://doso.wayne.edu/org-services/listing (listing club sports).
Wayne State also extends a categorical exemption from the sex-discrimination policy to its 46
fraternities and sororities, some of the largest groups on campus. Dkt. 21 at 12.
These broad, categorical exemptions are “sufficiently suggestive of discriminatory intent so as
to trigger heightened scrutiny.” Fraternal Order of Police, 170 F.3d at 365. But here, there is no
need to rely on suggestion: Wayne State’s anti-religious value judgment is explicit. Wayne State
insists on maintaining categorical exemptions for large, popular secular groups so that those groups
can select both leaders and members based on sex. But Wayne State then insists that it cannot
possibly allow religious groups to select religious leaders because, just maybe, one day a religious
group (unlike InterVarsity) might “hold[] as an article of religious faith that their leaders must be

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. . . male.” Dkt. 21 at 23-24. To Wayne State, actual secular sex discrimination is good while
hypothetical religious sex discrimination is evil. But to the Supreme Court, a “rationale for the
difference in treatment of these two instances cannot be based on the government’s own
assessment of offensiveness.” Masterpiece Cakeshop Ltd. v. Colo. Civil Rights Comm’n, No. 16111, slip op. 16, 584 U.S. __ (June 4, 2018). Thus, Wayne State “cannot act in a manner that passes
judgment upon or presupposes the illegitimacy of religious beliefs and practices.” Id. at 17.
Based on these concessions alone, Wayne State’s religiously discriminatory policy must face
“the strictest scrutiny.” Trinity Lutheran Church of Columbia, Inc. v. Comer, 137 S. Ct. 2012, 2019
(2017). As established below, it cannot pass that scrutiny, and so judgment should be entered in
favor of InterVarsity.
III. InterVarsity is entitled to summary judgment on its Free Speech claim.
InterVarsity demonstrated that Wayne State has violated its Free Speech rights. Dkt. 16-1 at
14-21. Wayne State once again relies upon Martinez and Reed. Dkt. 21 at 9-11. But the facts
demonstrate that its policy is illusory, content-based, and arbitrarily applied.
A. Wayne State’s policy is unconstitutional on its face.
Wayne State relies heavily on the Supreme Court’s decision in Christian Legal Society v.
Martinez, 561 U.S. 661 (2010). But Wayne State’s policy is distinguishable from the policy upheld
in Martinez in three fundamental respects. First, the Court’s decision in Martinez depended heavily
on a university clearly setting “the lawful boundaries” of a limited public forum, and then
“respect[ing] the lawful boundaries it has itself set.” Id. at 685. But Wayne State has no written
policy that addresses discrimination by student organizations. See Code 2.28.01.010-20 (no
mention of student organizations). And Wayne State’s own evidence shows that the University
understands the nondiscrimination requirement to apply to student organization membership, but

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not leadership. See Dkt. 21-2 at 6 (stating “Membership must be open to all currently registered
WSU students (see Anti-Discrimination Policy),” but making no such leadership requirement).
Second, Martinez recognized that limitations on leadership selection raise unique
constitutional problems. The majority said that groups remained free to refuse to elect officer
candidates who are “at odds” with the group’s mission. 561 U.S. at 692-93. And Justice Kennedy’s
concurrence found that even in the face of a true all-comers policy, a student group would have a
“substantial case” if the policy was “used to . . . challenge [group] leadership.” 561 U.S. at 706.
As discussed above, the Court later unanimously agreed on this point, ruling that the government
may not restrict religious groups’ selection of religious leaders. Hosanna-Tabor, 565 U.S. 171.
Third, Martinez is inapplicable to Wayne State’s policy, which it applies selectively only to
certain types of expressive criteria. The deeply divided Martinez Court refused to address policies
that “target solely those groups whose beliefs are based on religion . . . and leave other associations
free to limit membership and leadership to individuals committed to the group’s ideology.” 561
U.S. at 675. And Justice Kennedy’s concurrence emphasized that “the case likely should have a
different outcome” if there was any evidence that if the school’s policy was “content based either
in its formulation or evident purpose.” Id. at 703-04. Wayne State’s policy is content-based in both
its “formulation” and its “evident purpose.” Student groups may select leaders based on a variety
of secular viewpoints, such as political ideology. Dkt. 21 at 12 & n.3 (concession). But religious
groups may not select their leaders based upon religious views. The policy is content-based.
Wayne State also relies heavily on the Ninth Circuit’s decision in Alpha Delta Chi-Delta
Chapter v. Reed, 648 F.3d 790 (9th Cir. 2011). As discussed in InterVarsity’s response to Wayne
State’s motion to dismiss, in Reed the university’s policy survived a facial challenge (and only the
facial challenge) because it had a clear policy which expressly applied to student organizations.

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Dkt. 25 at 6-8. But Wayne State does not have a facial policy to review, since its Code does not
expressly apply to student organizations and has never been understood to apply to them as written.
Id. And the Ninth Circuit’s ruling is merely persuasive authority whose persuasive power is called
into question by Reed v. Town of Gilbert, Ariz., 135 S. Ct. 2218, 2229 (2015).
In Town of Gilbert, the Supreme Court invalidated a sign code which treated political or
ideological speech more favorably than religious speech, holding that such distinctions are subject
to strict scrutiny because their application “depend[s] entirely on the communicative content.” Id.
at 2227. Wayne State’s Code facially treats political association differently than religious
association, as the university admits. Dkt. 21 at 12 & n. 3. Town of Gilbert also addresses situations
where, as here, “the purpose and justification for the law are content based.” 135 S. Ct. at 2228.
Here, Wayne State admits that the purpose of the policy is to ensure that groups cannot “make
second-class citizens of students who refuse to accept their religious pledge.” Dkt. 18 at 17. Since
the purpose and justification for the policy governing student organizations is content-based, it
must face strict scrutiny.3
B. Wayne State cannot defend the arbitrary application of its policy here.
Wayne State’s policy is also viewpoint discriminatory as applied. Dkt. 16-1 at 18-20. Wayne
State acknowledges that its policy does not apply consistently to all groups, but claims it merely
employs “a few limited exceptions.” Dkt. 21 at 3. The record shows otherwise.
Wayne State concedes that it grants an “exemption from the gender discrimination aspect of
the policy,” Dkt. 18 at 14 n.7, to sports clubs and to fraternities and sororities. Its defense is that

3

Wayne State also argues that its actions are constitutional because they govern conduct, not
speech. Dkt. 21 at 11. But the selection of a group’s speaker is an inherently expressive act. See
Hurley v. Irish-Am. Gay, Lesbian & Bisexual Grp. of Boston, 515 U.S. 558, 570 (1995) (“[t]he
election of contingents to make a parade” was expressive); Hosanna-Tabor, 565 U.S. at 201 (Alito,
J., concurring) (“When it comes to the expression . . . of religious doctrine, there can be no doubt
that . . . the content and credibility of a religion’s message depend vitally upon” the messenger).
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federal law has an exemption for fraternities and sororities in Title IX. Dkt. 21 at 12. But Title IX
does not compel Wayne State to adopt that same exemption, which Wayne State admits. Id.
Moreover, federal law also provides exemptions for religious organizations. See, e.g., 42 U.S.C.
§ 2000bb. Wayne State offers an even flimsier justification for its exemption of club sports, relying
solely on what it labels as “obvious reasons” of “health, safety and welfare.” Dkt. 21 at 3, 12. This
rationale based on sex-based stereotypes is constitutionally suspect. See United States v. Virginia,
518 U.S. 515, 541 (1996) (refusing to credit similar justifications offered in favor of single-gender
military academies). These admissions alone are sufficient to trigger strict scrutiny.
InterVarsity also adduced evidence that Wayne State’s policy is haphazardly conceived and
unevenly applied. InterVarsity collected direct quotations from the websites of ninety student
groups indicating that they discriminate in violation of the Code, or that they are permitted to
discriminate according to ideology and identity. Dkt.16-2 Ex 1. Wayne State dismisses this
evidence as attorney opinion, but it is a list of quotations and citations available on Wayne State’s
own website, and on the student organization sites linked from there. Wayne State’s other
argument for disregarding what is plain from its own website is that the student groups’
constitutions are necessary to determine whether the groups are truly discriminating. Dkt. 21 at
12-13. But Wayne State’s sweeping Code surely applies to discriminatory actions, not merely
discriminatory constitutions. Wayne State’s own website contains evidence that groups limit
leadership and membership in prohibited ways. It cannot ignore that while penalizing InterVarsity.
IV. InterVarsity is entitled to summary judgment on its expressive association claim.
The University’s actions also violate InterVarsity’s right to expressive association. 4 Dkt. 16-1

4

Relying on Martinez, Wayne State argues that only limited public forum analysis applies. Dkt.
21 at 8. In Martinez, CLS conceded its “expressive-association claim” was “auxiliary to speech’s

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at 20-21. Wayne State claims InterVarsity suffered no harm because the group could still meet on
campus at its own expense, and simply accept the penalties of non-recognition. Dkt. 21 at 17. But
in Healy v. James, the Supreme Court found that the student group’s associational rights were
harmed by “denial of access to the customary media for communication with the administration,
faculty members, and other students,” and even “more subtle governmental interference.” 408 U.S.
169, 181-82 (1972). InterVarsity suffered the same penalties. Dkt. 16-1 at 6. The Supreme Court
has since made clear that the denial of contracts, grants, and benefits based upon speech or religious
character is just as unconstitutional as a direct penalty. See Dkt. 16-1 at 16; see also CEF of Minn.
v. Minneapolis Special Sch. Dist., 690 F.3d 996, 1001-02 (8th Cir. 2012). Wayne State’s other
argument—that no “non-Christians have attempted to take leadership roles,” Dkt. 21 at 17—is
unsupported and irrelevant. Wayne State is arguing for a catch-22: InterVarsity might have the
right to reject a particular leadership candidate, but only if it first waives that right.
V. Wayne State’s actions cannot survive strict scrutiny.
As discussed above, strict scrutiny applies to InterVarsity’s freedom of speech, freedom of
association, and free exercise claims. 5 Wayne State asserts that it “has a compelling interest in
preventing discrimination on its campus.” Dkt. 21 at 17-18. But it makes no attempt to bear its
burden of proof to explain why it must penalize InterVarsity, but not others. See Gonzales v. O
Centro Espirita Beneficente Uniao do Vegetal, 546 U.S. 418, 431 (2006) (strict scrutiny requires
“scrutiniz[ing] the asserted harm of granting specific exemptions to particular religious
claimants.”). Wayne State also claims (without citation) that “ A compelling interest allows the

starring role,” and the Court treated the two analyses together because a blanket policy defining
the scope of the forum, not individual application, was at issue. 561 U.S. at 680-81.
5
Wayne State objects to InterVarsity’s reference to strict scrutiny as an “affirmative defense.”
Dkt. 21 at 8 n.2. But Wayne State acknowledges that strict scrutiny “heightens the government’s
burden.” Id. That is the point—this is an issue on which Defendants bear the burden of proof.
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government to act—but does not require it.” Dkt. 21 at 24-25. This is precisely backwards: “Where
government . . . fails to enact feasible measures to restrict other conduct producing substantial
harm or alleged harm of the same sort, the interest given . . . is not compelling.” Church of Lukumi
Babalu Aye, Inc. v. City of Hialeah, 508 U.S. 520, 546-47 (1993). Wayne State has granted
numerous exceptions to its nondiscrimination policy. See supra III.B. It cannot claim a compelling
interest in excluding InterVarsity.
Even if Wayne State’s interest in combating discrimination were compelling, it has not pursued
that interest using the least restrictive means. The least-restrictive-means standard is
“exceptionally demanding[.]” Holt v. Hobbs, 135 S. Ct. 853, 864 (2015). This is particularly true
where, as here, other exceptions exist: if the government’s “proffered objectives are not pursued
with respect to analogous nonreligious conduct,” that suggests “those interests could be achieved
by narrower [policies] that burdened religion to a far lesser degree.” Id. at 866 (quoting Lukumi,
508 U.S. at 546); accord McAllen Grace Brethren Church v. Salazar, 764 F.3d 465, 475–76 (5th
Cir. 2014). Wayne State has two less restrictive alternatives at hand: First, to do what it is doing
today and recognize InterVarsity.6 Second, it can do what its student organization application
suggests: apply its policy to student organization membership, but not leadership. See Dkt. 21-2 at
6 (student organization application). Wayne State offers no proof that either option is unworkable.
CONCLUSION
For all these reasons, the Court should grant InterVarsity’s motion for partial summary
judgment and issue permanent injunctive relief protecting InterVarsity’s constitutional rights.

6

Wayne State cites no precedent supporting its argument that Federal Rule of Evidence 408 bars
consideration of a decision Wayne State announced via the media. Rule 408 is intended to
safeguard private negotiations, not press releases. See, e.g., Stryker Corp. v. XL Ins. Am., Inc., No.
1:05-cv-51, 2013 WL 3276408, at * 2 (W.D. Mich. June 27, 2013) (Rule 408 did not apply to a
communication that “was not secret” because the party “had made [its] position known” publicly).

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Date: June 5, 2018

Respectfully submitted,
/s/ Lori Windham
Lori Windham
Eric Rassbach
Daniel Blomberg
Daniel Ortner
The Becket Fund for Religious Liberty
1200 New Hampshire Ave. NW, Suite 700
Washington, DC, 20036
Tel.: (202) 955-0095
Fax: (202) 955-0090
lwindham@becketlaw.org
Daniel P. Dalton
Dalton & Tomich PLC
The Chrysler House
719 Griswold St., Suite 270
Detroit, MI 48226
Tel.: 313.859.6000
Fax: 313.859.8888
ddalton@daltontomich.com
Counsel for Plaintiffs

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