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«No. 12-144 ================================================================ In The Supreme Court of the United States -DENNIS HOLLINGSWORTH, et ...»

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No. 12-144


In The

Supreme Court of the United States

-----------------------------------------------------------------DENNIS HOLLINGSWORTH, et al.,





-----------------------------------------------------------------On Writ Of Certiorari To The

United States Court Of Appeals

For The Ninth Circuit

-----------------------------------------------------------------BRIEF OF WESTBORO BAPTIST CHURCH



-----------------------------------------------------------------MARGIE J. PHELPS, ESQ.

Counsel of Record ================================================================ COCKLE LAW BRIEF PRINTING CO. (800) 225-6964 OR CALL COLLECT (402) 342-2831 i










Page CASES Church of the Holy Trinity v. United States, 143 U.S. 457, 12 S. Ct. 511, 36 L. Ed. 226 (1892).........22 Lawrence v. Texas, 539 U.S. 558, 123 S. Ct.

2472, 156 L. Ed. 2d 508 (2003)

Lynch v. Donnelly, 465 U.S. 668, 79 L. Ed. 2d 604, 104 S. Ct. 1355 (1984)

Metropolitan Life Ins. Co. v. Massachusetts, 471 U.S. 724, 105 S. Ct. 2380, 85 L. Ed. 2d 728 (1985)

Perry v. Brown, 681 F.3d 1065 (9th Cir. 2012), cert. granted by Hollingsworthv. Perry, 2012 U.S. LEXIS 9416 (Dec. 7, 2012)

United Haulers Association v. Oneida-Herkimer Solid Waste Management Authority, 550 U.S.

330, 127 S. Ct. 1786, 167 L. Ed. 2d 655 (2007).........4 Van Orden v. Perry, 545 U.S. 677, 125 S. Ct.

2584, 162 L. Ed. 2d 607 (2005)

Zorach v. Clauson, 343 U.S. 306, 96 L. Ed. 954, 72 S. Ct. 679 (1952)


A Spiritual and Ethical Compendium to the Torah and Talmud, by Rabbi Arthur Segal with Frank Dunne, Jr., 2008

Acts 10:35, Holy Bible

iii TABLE OF AUTHORITIES – Continued Page Alexis de Tocqueville, Democracy in America, 3rd ed., David Campbell Publishers Ltd., 1994

Alfred M. Rehwinkel, The Flood in the Light of the Bible, Geology and Archaeology, Concordia Publishing House, St. Louis, 8th ed., 1962

“Back to the Beginning,” “Noah’s Biblical Flood:

New Evidence Suggests It Happened,” ABC News Special

Berg, Colby, Esbeck & Garnett, “Religious Freedom, Church-State Separation, and the Ministerial Exception,” 106 Nw. U. L. Rev.

Colloquy 175 (2011)

“Brief Amicus Curiae of Mother Teresa of Calcutta, in Support of Petitioners’ Petitions for a Writ of Certiorari,” Human Life Review, Spring, 2001, Vol. 27, Issue 2

Commentary by Adam Clarke on Psalm 9:17.............6 Commentary by Charles Haddon Spurgeon on Psalm 82:1

Commentary by Dr. John Gill on Psalm 82:1............17 Commentary by Dr. John Gill on Luke 17:32............12 Commentary by Jamieson, Fausset and Brown on Luke 17:32

Commentary by Matthew Henry on Nahum 1:1.......21 1 Corinthians 7:39, Holy Bible

iv TABLE OF AUTHORITIES – Continued Page Deuteronomy 11:26-28, Holy Bible

Deuteronomy 32:35, Holy Bible

Ephesians 5:23, Holy Bible

Ephesians 5:31-32, Holy Bible

Genesis 7:11-23, Holy Bible

Genesis 18:32, Holy Bible

Genesis 19:1-28, Holy Bible

Gallup Values and Beliefs survey, 2008

Hebrews 13:4, Holy Bible

Henry Thatcher Fowler, “Influence of the Bible in American Democracy,” Christian Education, Vol. 3, No. 1, October 1919

Hershey H. Friedman, Ph.D., and James Lynch, J.D., “Preventing the Decline and Fall of America: Messages from the Bible,” Journal of Business Systems, Governance and Ethics, Vol. 7, No. 1 (August 2012)


John W. Welch, “Biblical Law in America: Historical Perspectives and Potentials for Reform,” 2002 Brigham Young University Law Review 611

Jonah 3:4, Holy Bible

Jonah 3:6-9, Holy Bible

Jonah 3:10, Holy Bible

v TABLE OF AUTHORITIES – Continued Page Jude 1:7, Holy Bible

Judges, chapters 19-21, Holy Bible

Letter to the editor, Topeka Capital Journal, December 15, 2009

Leviticus 18:22, Holy Bible

Leviticus 20:13, Holy Bible

Luke 17:27, Holy Bible

Luke 17:32, Holy Bible

Malachi 2:16, Holy Bible

Mark 10:11, Holy Bible

Matthew 7:6, Holy Bible

Matthew 19:3-8, Holy Bible

Nahum 1:1, Holy Bible

2 Peter 2:7-12, Holy Bible

Philippians 3:2, Holy Bible

Proverbs 14:34, Holy Bible

Proverbs 18:22, Holy Bible

Proverbs 31:10, Holy Bible

Psalm 9:17, Holy Bible

Psalm 33:12-15, Holy Bible

Psalm 82:1, Holy Bible

Revelation 19:7, Holy Bible

Revelation 22:15, Holy Bible

vi TABLE OF AUTHORITIES – Continued Page Robert N. Bellah, “Biblical Religion and Civil Religion in America,” Journal of the American Academy of Arts and Sciences, Winter, 1967, Vol. 96, No. 1

Romans 1:21-31, 32 Holy Bible

Romans 7:2, Holy Bible

Sanford Hoadley Cobb, The Rise of Religious Liberty in America

“Sinners in the Hands of an Angry God,” sermon by Jonathan Edwards

Tracy Fessenden, “The Nineteenth-Century Bible Wars and the Separation of Church and State,” Church History, Vol. 74, No. 4 (Dec. 2005)

The Westboro Baptist Church of Topeka, Kansas, respectfully submits this amicus curiae brief in support of no party, but in favor of reversal.

-----------------------------------------------------------------STATEMENT OF INTEREST


The Westboro Baptist Church (WBC) is a small nondenominational independent Bible-believing flock in Topeka, Kansas (since 1955), which has engaged this nation in a robust debate about its policies of sin and the consequence of such pervasive proud sin to the country and its people. WBC began picketing over 20 years ago, warning that homosexuality was going to be the destruction of America. After the tragic events of September 11, 2001, WBC increased its street and social-media ministry, urging Americans to put away policies of proud sin, mourn, repent, and obey God. Today the number one moral issue facing

this nation is same-sex marriage. Westboro has testified to the world about this issue:

The Westboro Baptists may be on the right track after all, although gay marriage, Pursuant to S. Ct. R. 37.6, the amicus states that no counsel for a party authored this brief in whole or in part, and no counsel or party made a monetary contribution intended to fund the preparation or submission of this brief. No person other than amicus curiae, its members, or its counsel made a monetary contribution to its preparation or submission. The parties have consented to the filing of this brief.

not just homosexuality, could be the catalyst for the consummation.

With several states ratifying gay marriage and movements afoot to extend it elsewhere, it could become general. The Babylonian Talmud reveals that until now only one society in all of history practiced it, the Antediluvian.

The Babylonian Talmud also says the practice was the reason for Noah’s flood. The risk of retribution is real.

Interestingly, Jesus said the time of his coming would resemble those far off days. He even mentioned “marriage and giving in marriage.” We in Australia have just had our first such wedding. It’s a worry.

Ken Hood, Clifton, Australia As this Honorable Court sets out to consider whether to protect same-sex marriage – to give the imprimatur of the government to marriages between same-sex couples – WBC has a vested interest in speaking up. WBC members have toiled in the American vineyard, entreating Americans to get right with God. Like every citizen of this land, WBC members have an everlasting and non-delegable duty to warn our fellow citizens – and especially our leaders – of Letter to the editor, Topeka Capital Journal, December 15, 2009, available Online at http://bit.ly/13fPkhi.

the consequence of continuing down this path toward same-sex marriage as a permanent fixture in the culture and mores of the United States.

-----------------------------------------------------------------SUMMARY OF THE ARGUMENT The government has responsibility to protect the health, safety and welfare of the people. Of all the harms that a society can face, none are worse than incurring the wrath of God by a blatant policy of defiance of and disobedience to His plain standard.

This nation was founded on Bible principles, and the laws of America arose from Scriptural precepts.

America has erred in making fornication, adultery, divorce, remarriage, abortion-for-convenience-on-demand and sodomy, standard fare in this country. It is time to reverse that course, and for this Court to squarely hold that the governments of America have a compelling interest in upholding traditional opposite-sex marriage, and further in protecting the people from the devastating effects of same-sex marriage. Separation of church and state, while prohibiting government from interfering in issues of doctrine or church governance, does not prohibit the government from promulgating laws that institute the standards of God on moral issues. Just as the government is empowered to outlaw murder, the government is empowered to outlaw same-sex marriage. This nation that God blessed and built into a super power is going to perish if this Court and the governments of this land bless same-sex marriage through government license. WBC pleads for reversal.






“[G]overnment is vested with the responsibility of protecting the health, safety, and welfare of its citizens. See Metropolitan Life Ins. Co. v. Massachusetts, 471 U.S. 724, 756, 105 S. Ct. 2380, 85 L. Ed. 2d 728 (1985) (‘The States traditionally have had great latitude under their police powers to legislate as to the protection of the lives, limbs, health, comfort, and quiet of all persons’ (internal quotation marks omitted)),” United Haulers Association v. OneidaHerkimer Solid Waste Management Authority, 550 U.S.

330, 342-343, 127 S. Ct. 1786, 1795, 167 L. Ed. 2d 655, 667 (2007).

Sister Teresa of Calcutta once addressed this Court, urging it not to make abortion the law of the land, and told the Court: “A nation founded on these principles [of the Declaration of Independence] holds a sacred trust: to stand as an example to the rest of the world... ” and that “America has kept faith.” “Brief Amicus Curiae of Mother Teresa of Calcutta, in Support of Petitioners’ Petitions for a Writ of Certiorari,” Human (Continued on following page) The whole world is now watching to see if the Highest Court in the Land – truly the most powerful court in the world – referred to as the conscience of the nation – is going to set in motion the most ruinous of all sins, to the great harm and detriment of the citizens of this land.

Nothing is more harmful to the health and welfare than sin. In his best known sermon, “Sinners in the Hands of an Angry God,” expounding Deuteronomy 32:35, Holy Bible, “Their foot shall slide in due time,” American theologian Jonathan Edwards said


Sin is the ruin and misery of the soul; it is destructive in its nature; and if God should leave it without restraint, there would need nothing else to make the soul perfectly miserable. The corruption of the heart of man is a thing that is immoderate and boundless in its fury; and while wicked men live here, it is like fire pent up by God’s restraints, whereas if it were let loose it would set on fire the course of nature; and as the heart is now a sink of sin, so, if sin was not restrained, it would immediately turn the soul into a fiery oven, or a furnace of fire and brimstone.4 Life Review, Spring, 2001, Vol. 27, Issue 2, pp. 97-100, found Online at http://bit.ly/Wl1wHv.

This sermon can be found Online at http://bit.ly/Secdkc.

Jonathan Edwards’ (1703-1758) biography can also be found Online at http://bit.ly/VEhsIW, as part of a full collection of information and sermons at the Online Jonathan Edwards Center at (Continued on following page) Nothing is more destructive to a nation than wholesale rejection of the plain standard of God.

“The wicked shall be turned into hell, and all the nations that forget God.”5 Adam Clarke: “They will not live in his fear. There are both nations and individuals who, though they know God, forget him, that is, are unmindful of him, do not acknowledge him in their designs, ways, and works. These are all to be thrust down into hell” (emphasis in original).6 Yale University. This revivalist, theologian, pastor, philosopher and (briefly before his death) president of the College of New Jersey (later Princeton University), represents the kind of preacher found in this nation over two hundred years ago. Such preaching was observed by Alexis de Tocqueville when he toured America in 1831, and reported back to France.

[B]ut there is no country in the whole world in which the Christian religion retains a greater influence over the souls of men than in America; and there can be no greater proof of its utility, and of its conformity to human nature, than that its influence is most powerfully felt over the most enlightened and free nation of the earth.

Alexis de Tocqueville, Democracy in America, 3rd ed., David Campbell Publishers Ltd., 1994, at 303-304. President Dwight D. Eisenhower characterized Tocqueville’s words in a campaign

address in Boston, Massachusetts on November 3, 1952, thusly:

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