Apr 26, 2018 - AMICI CURIAE BRIEF OF CHURCH ALLIANCE, ET AL. ... The Church Alliance is a coalition of the chief executi
Case: 18-1277
Document: 26
Filed: 04/26/2018
Pages: 48
Nos. 18-1277 and 18-1280
In the
United States Court of Appeals for the Seventh Circuit
ANNIE L. GAYLOR, et al., Plaintiffs-Appellees, v. STEVEN T. MNUCHIN, et al., Defendants, and EDWARD PEECHER, et al., Intervening Defendants-Appellants. _______________________________________ Appeal from the United States District Court for the Western District of Wisconsin, No. 3:16-cv-00215-bbc The Honorable Barbara B. Crabb Presiding.
AMICI CURIAE BRIEF OF CHURCH ALLIANCE, ET AL. IN SUPPORT OF DEFENDANTS-APPELLANTS AND REVERSAL
LAURENCE A. HANSEN HUGH S. BALSAM LOCKE LORD LLP 111 South Wacker Drive Chicago, Illinois 60606 (312) 443-0456
MICHAEL W. MCCONNELL KIRKLAND & ELLIS LLP 655 Fifteenth Street, N.W. Washington, DC 20005 (202) 879-5200 Counsel for Church Alliance
Counsel for Church Alliance and additional Amici
COUNSEL PRESS ∙ (866) 703-9373
PRINTED ON RECYCLED PAPER
Case: 18-1277
Document: 26
Filed: 04/26/2018
Pages: 48
APPEARANCE & CIRCUIT RULE 26.1 DISCLOSURE STATEMENT
Appellate Court No: 18-1277; 18-1250 Short Caption: Annie Gaylor, et al. v. Edward Peechen et al. To enable the judges to determine whether recusal is necessary or appropriate, an attorney for a non-governmental party or amicus curiae, or a private attorney representing a government party, must furnish a disclosure statement providing the following information in compliance with Circuit Rule 26.1 and Fed. R. App. P. 26.1. The Court prefers that the disclosure statement be filed immediately following docketing; but, the disclosure statement must be filed within 21 days of docketing or upon the filing of a motion, response, petition, or answer in this court, whichever occurs first. Attorneys are required to file an amended statement to reflect any material changes in the required information. The text of the statement must also be included in front of the table of contents of the party's main brief. Counsel is required to
complete the entire statement and to use N/A for any information that is not applicable if this form is used. PLEASE CHECK HERE IF ANY INFORMATION ON THIS FORM IS NEW OR REVISED AND INDICATE WHICH INFORMATION IS NEW OR REVISED. ( 1) The full name of every party that the attorney represents in the case (if the party is a corporation, you must provide the corporate disclosure information required by Fed. R. App. P 26.1 by completing item #3): See attached addendum.
(2) The names of all law firms whose partners or associates have appeared for the party in the case (including proceedings in the district court or before an administrative agency) or are expected to appear for the party in this court: Locke Lord LLP; Kirkland & Ellis LLP
(3) If the party or amicus is a corporation: i) Identify all its parent corporations, if any; and None. ii) list any publicly held company that owns 10% or more of the party's or amicus' stock: None.
Attorney's Signature:
s/ L_a_u_r_e_n_c_e_A_._H_a_n_s_e_n____________
Date:
April 26, 2018
Attorney's Printed Name: _L_a_u_r_e_n_ce_A_._H_a_n_s_e_n_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ Please indicate if you are Counsel of Record for the above listed parties pursuant to Circuit Rule 3(d). Address:
Yes
X
No
Locke Lord LLP 111 South Wacker Drive, Chicago, IL 60606
Phone Number:
312-443-0456
E-Mail Address:
[email protected]
Fax Number:
312-896-6456
rev. 01/ 15 GA
Case: 18-1277
Document: 26
Filed: 04/26/2018
Pages: 48
PARTIES REPRESENTED BY LOCKE LORD LLP The Church Alliance is a coalition of the chief executive officers of nearly 40 denominational benefit programs, covering ministers affiliated with these sponsoring denominations who are eligible for a housing allowance under section 107(2) of the Internal Revenue Code of 1986: American Baptist Churches in the U.S.A., Association of Unity Churches, Christian Churches, Church of God (Anderson, IN), Church of God (Cleveland, TN), Churches of Christ, Church of the Brethren, Church of the Nazarene, Churches of God, General Conference, Converge Worldwide (Baptist General Conference), Episcopal Church, Evangelical Covenant Church, Evangelical Lutheran Church in America, Free Methodist Church- USA, Jewish Conservative Movement, Jewish Reform Movement, Lutheran Church-Missouri Synod, Presbyterian Church (U.S.A.), Southern Baptist Convention, Unitarian Universalist Association, United Church of Christ, United Methodist Church, The Wesleyan Church, Wisconsin Evangelical Lutheran Synod, and other denominations. The following churches, associations or conventions of churches, or other religious organizations are additional amici represented by Locke Lord LLP in this matter. American Baptist Churches in the U.S.A. American Conference of Cantors* Association of Unity Churches Cantors Assembly** Central Conference of American Rabbis* Church of God (Anderson, IN) Church of God (Cleveland, TN) The Church of Jesus Christ of Latter-day Saints Church of the Brethren Church of the Nazarene The Church Pension Fund (affiliated with the Episcopal Church) Churches of God, General Conference Converge Worldwide (Baptist General Conference) Evangelical Covenant Church
Case: 18-1277
Document: 26
Filed: 04/26/2018
Pages: 48
Evangelical Lutheran Church in America General Council on Finance and Administration of The United Methodist Church Guide Stone Financial Resources of the Southern Baptist Convention Hebrew Union College - Jewish Institute of Religion* Jewish Educators Assembly** Jewish Theological Seminary of America** Moravian Church in America North American Association of Synagogue Executives** The Pension Boards-United Church of Christ, Inc. Rabbinical Assembly** Reform Pension Board* The Salvation Army National Corporation Southern Baptist Ethics & Religious Liberty Commission Union for Reform Judaism* Unitarian Universalist Association Unitarian Universalist Ministers Association United Church of Christ United States Conference of Catholic Bishops United Synagogue of Conservative Judaism** The Wesleyan Church Wisconsin Council of Churches Wisconsin Evangelical Lutheran Synod * = an organization affiliated with the Jewish Reform Movement
Case: 18-1277
Document: 26
Filed: 04/26/2018
**= an organization affiliated with the Jewish Conservative Movement
Pages: 48
Case: 18-1277
Document: 26
Filed: 04/26/2018
Pages: 48
APPEARANCE & CIRCUIT RULE 26.1 DISCLOSURE STATEMENT
Appellate Court No: 18-1277; 18-1250 Short Caption: Annie Gaylor, et al. v. Edward Peechen et al. To enable the judges to determine whether recusal is necessary or appropriate, an attorney for a non-governmental party or amicus curiae, or a private attorney representing a government party, must furnish a disclosure statement providing the following information in compliance with Circuit Rule 26.1 and Fed. R. App. P. 26.1. The Court prefers that the disclosure statement be filed immediately following docketing; but, the disclosure statement must be filed within 21 days of docketing or upon the filing of a motion, response, petition, or answer in this court, whichever occurs first. Attorneys are required to file an amended statement to reflect any material changes in the required information. The text of the statement must also be included in front of the table of contents of the party's main brief. Counsel is required to complete the entire statement and to use N/ A for any information that is not applicable if this form is used.
[
]
PLEASE CHECK HERE IF ANY INFORMATION ON THIS FORM IS NEW OR REVISED AND INDICATE WHICH INFORMATION IS NEW OR REVISED.
(1) The full name of every party that the attorney represents in the case (if the party is a corporation, you must provide the corporate disclosure information required by Fed. R. App. P 26.1 by completing item #3): See attached addendum.
(2) The names of all law firms whose partners or associates have appeared for the party in the case (including proceedings in the district court or before an administrative agency) or are expected to appear for the party in this court: Locke Lord LLP; Kirkland & Ellis LLP
(3) If the party or amicus is a corporation: i) Identify all its parent corporations, if any; and None. ii) list any publicly held company that owns 10% or more of the party's or amicus' stock: None.
Attorney's Signature:
s/ Hugh S. Balsam
Date:
April 26, 2018
Attorney's Printed Name: _H_u_g_h_S_._B_a_ls_a_m_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ Please indicate if you are Counsel of Record for the above listed parties pursuant to Circuit Rule 3( d). Address:
Yes
No
X
Locke Lord LLP 111 South Wacker Drive, Chicago, IL 60606
Phone Number: _3_1_2_-_44_3_-_0_4_0_3_ _ _ _ _ _ _ _ __ E-Mail Address:
Fax Number:
312-896-6403
[email protected] rev. 01/15 GA
Case: 18-1277
Document: 26
Filed: 04/26/2018
Pages: 48
PARTIES REPRESENTED BY LOCKE LORD LLP The Church Alliance is a coalition of the chief executive officers of nearly 40 denominational benefit programs, covering ministers affiliated with these sponsoring denominations who are eligible for a housing allowance under section 107(2) of the Internal Revenue Code of 1986: American Baptist Churches in the U.S.A., Association of Unity Churches, Christian Churches, Church of God (Anderson, IN), Church of God (Cleveland, TN), Churches of Christ, Church of the Brethren, Church of the Nazarene, Churches of God, General Conference, Converge Worldwide (Baptist General Conference), Episcopal Church, Evangelical Covenant Church, Evangelical Lutheran Church in America, Free Methodist Church- USA, Jewish Conservative Movement, Jewish Reform Movement, Lutheran Church-Missouri Synod, Presbyterian Church (U.S.A.), Southern Baptist Convention, Unitarian Universalist Association, United Church of Christ, United Methodist Church, The Wesleyan Church, Wisconsin Evangelical Lutheran Synod, and other denominations. The following churches, associations or conventions of churches, or other religious organizations are additional amici represented by Locke Lord LLP in this matter. American Baptist Churches in the U.S.A. American Conference of Cantors* Association of Unity Churches Cantors Assembly** Central Conference of American Rabbis* Church of God (Anderson, IN) Church of God (Cleveland, TN) The Church of Jesus Christ of Latter-day Saints Church of the Brethren Church of the Nazarene The Church Pension Fund (affiliated with the Episcopal Church) Churches of God, General Conference Converge Worldwide (Baptist General Conference) Evangelical Covenant Church
Case: 18-1277
Document: 26
Filed: 04/26/2018
Pages: 48
Evangelical Lutheran Church in America General Council on Finance and Administration of The United Methodist Church Guide Stone Financial Resources of the Southern Baptist Convention Hebrew Union College - Jewish Institute of Religion* Jewish Educators Assembly** Jewish Theological Seminary of America** Moravian Church in America North American Association of Synagogue Executives** The Pension Boards-United Church of Christ, Inc. Rabbinical Assembly** Reform Pension Board* The Salvation Army National Corporation Southern Baptist Ethics & Religious Liberty Commission Union for Reform Judaism* Unitarian Universalist Association Unitarian Universalist Ministers Association United Church of Christ United States Conference of Catholic Bishops United Synagogue of Conservative Judaism** The Wesleyan Church Wisconsin Council of Churches Wisconsin Evangelical Lutheran Synod * = an organization affiliated with the Jewish Reform Movement
Case: 18-1277
Document: 26
Filed: 04/26/2018
**= an organization affiliated with the Jewish Conservative Movement
Pages: 48
Document: 26 Filed: 04/26/2018 Pages: 48 0112030452ÿ7ÿ89
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