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_____
IN THE
Supreme Court of the United States
_________
CONRAAD HOEVER,
Petitioner,
v.
Respondents.
________
On Petition for a Writ of Certiorari to the
United States Court of Appeals for the
Eleventh Circuit
________
PETITION FOR A WRIT OF CERTIORARI
________
DAVID M. SHAPIRO
Counsel of Record
RODERICK & SOLANGE MACARTHUR JUSTICE CENTER
NORTHWESTERN PRITZKER SCHOOL OF LAW
375 E. Chicago Ave.
Chicago, IL 60611
(312) 503-0711
david.shapiro@law.northwestern.edu
Appendices
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3 See also Hernandez v. C.I.R., 490 U.S. 680, 699 (1989) (“It is
not within the judicial ken to question the centrality of particu-
lar beliefs or practices to a faith, or the validity of particular lit-
igants’ interpretations of those creeds.”); Presbyterian Church in
U.S. v. Mary Elizabeth Blue Hull Mem’l Presbyterian Church,
393 U.S. 440, 450 (1969) (“[This] requires the civil court to de-
termine matters at the very core of a religion—the interpreta-
tion of particular church doctrines and the importance of those
doctrines to the religion. Plainly, the First Amendment forbids
civil courts from playing such a role.”).
13
(2015). Since 1815, the New York Bible Society (later
renamed Biblica) has been providing Bibles to prison-
ers.4 When Fyodor Dostoevsky was dispatched to a
Siberian prison camp in 1849, a Bible “became [one]
of his most treasured possessions.”5 More recently, a
former Illinois prisoner named Brian Nelson spent 12
years in solitary confinement. He copied the Bible
word for word with a ballpoint pen.6
Petitioner’s case illustrates a broader, and crucial,
principle of religious liberty. Innumerable forms of
religious exercise, mandatory or not, are important to
practicing one’s faith. The practices at issue in the
cases cited in the previous section underscore the
point: many forms of religious exercise—from study-
ing books and partaking of feasts, to drinking sacra-
mental wine and consuming certain foods—may not
be mandatory, but they are nonetheless significant.
See Shakur, 514 F.3d at 885; Kay, 500 F.3d at 1220;
Ford, 352 F.3d at 593–94; Levitan, 281 F.3d at 1319–
20.
If the Free Exercise Clause protected only manda-
tory religious observances, as the court of appeals
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* Northwestern Law Students Orlando Cosme, Adithi Grama, and
Charlie Hogle contributed to the preparation of this petition.