Gender Ideology is a Religion
Forcing female students to share restrooms with and compete against male students violates the Establishment Clause: Draft Lawsuit
For the past few years, I’ve been hoping to file a lawsuit to establish, as a matter of law and fact, that gender ideology is a “religion” within the meaning of the Establishment Clause of the First Amendment of the United States Constitution and—by forcing biological girls to share intimate spaces with and compete against male students—schools are violating the First Amendment. Notably, I studied the Establishment Clause under Justice Alito of the United States Supreme Court (during my third year of law school), so I know a few things about this area of law. The draft complaint has been sitting on my computer since August of 2023. Since then, I have been blessed to work with Dr. James Lindsay on refining the lawsuit (please note, much of the complaint is the product of his brilliance).
Over the past few years, I have spoken with several parents about filing this suit. Unfortunately, I have been unable to proceed due to a lack of funding. Rather than wait any longer, I am posting the work product (below) for the benefit of the public. My prayer is that by making this draft complaint public, someone with funding will reach out so that I can file this case (or, at the very least, another attorney will see this and use this in one of his or her cases—to set a precedent so that our daughters no longer have to suffer).1
Without further ado, here is the draft complaint (if you want to help fight against this nonsense, please share this post on social media, subscribe, and/or make a tax-deductible gift to The Gavel Project):
Seeking to protect their civil liberties and constitutional rights, _____, on behalf of her minor child JANE DOE, and ____, on behalf of her minor child, ASHLEY DOE (collectively, “Plaintiffs”), for their complaint against ____ Unified School District (“Defendant”), allege as follows:
Nature of Claims
1. This action challenges the constitutionality of the Defendant’s practice, protocol, policy, or custom of allowing students who are biologically male to utilize restroom facilities on its school campuses that have been traditionally designated for exclusive use by students who are biologically female. This action further challenges the constitutionality of Defendant’s practice, protocol, policy, or custom of allowing biologically male students to compete against biologically female students.
2. These practices, policies, protocols and/or customs violate Plaintiffs’ rights secured by Articles II § 8, XX § 1, and XI § 7 of the Arizona Constitution.
3. Such practices, policies, protocols and/or customs also violate the Establishment Clause of the United States Constitution, as applied to Arizona by the Fourteenth Amendment, by amounting to the establishment of a religion, along with the Substantive Due Process Clause of the Fourteenth Amendment by violating Plaintiffs’ right to privacy.
4. Plaintiffs seek mandamus relief pursuant to A.R.S. § 12-2021 against Defendant to redress the violations of the Arizona Constitution, along with recovery of attorney’s fees, expert fees, and costs pursuant to A.R.S. § 12-2030. Plaintiffs further seek declaratory relief pursuant to A.R.S. § 12-1831 to establish that allowing biological males to use private female facilities, such as restrooms violates Plaintiffs’ rights established by Articles II, § 8, XX § 1 and XI § 7 of the Arizona Constitution along with recovery of costs pursuant to A.R.S. § 12-1840.
5. Further, Plaintiffs seek injunctive and declaratory relief under 42 U.S.C. § 1983 against Defendant to redress the Establishment Clause violation, together with recovery of attorney’s fees and costs under 42 U.S.C. § 1988(b).
Jurisdiction and Venue
6. This Court has general jurisdiction over the federal claims in this matter and jurisdiction to issue a writ of mandamus pursuant to A.R.S. §§ 12-123, 12-2021 and Arizona Rule of Special Action Procedure 4 on a “verified complaint of a party beneficially interested to compel, when there is not a plain, adequate and speedy remedy at law, performance of an act which the law specifically imposes as a duty resulting from an office, trust or station,” which is the case here.
7. Additionally, jurisdiction is proper in this Court to issue declaratory relief pursuant to A.R.S. §§ 12-1831 and 12-1832.
8. Venue is proper in this Court pursuant to A.R.S. § 12-401.
Parties
9. Plaintiff ______ is a natural person who resides in Maricopa County. She is also the parent of JANE DOE.
10. Plaintiff JANE DOE (“J.D.”) is a minor children of ___ and resident of Maricopa County. J.D. is also a student at ___ High School (“__HS”), a public school within ______ Unified School District (“__USD”).
11. Plaintiff _______ is a natural person who resides in Maricopa County. She is also the parent of ASHLEY DOE.
12. Plaintiff ASHLEY DOE (“A.D.”) is a minor child and resident of Maricopa County. A.D. is a student at __HS, a public school within __USD.
13. Defendant ____ UNIFIED SCHOOL DISTRICT (“Defendant”) is a school district within the meaning of Ariz. Rev. Stat. § 15-101(23) and a political subdivision of this state located in Maricopa County. Defendant is managed by the ___USD Governing Board (“Governing Board”). The Governing Board, which sets ___USD policies and has final authority over all school district business, is hereby sued pursuant to Ariz. Rev. Stat. § 15-326.
General Allegations
14. J.D. is a ___-year-old, biological female who receives in-person instruction as a duly enrolled high-school student at __HS.
15. A.D. is a ___-year-old, biological female who receives in-person instruction as a duly enrolled high-school student at __HS.
16. __HS, pursuant to protocols, policies, practices, and customs adopted by Defendant, allows biological male students, who ascribe to the religion of gender ideology, to use restroom facilities traditionally designated for biological female students (the “Co-ed Restroom Policy”). Furthermore, __HS, pursuant to protocols, policies, practices, and customs adopted by Defendant, allows biological male students, who ascribe to the religion of gender ideology, to compete against biological female students (the “Sports Policy”). Allowing proponents of gender ideology to use restroom facilities inconsistent with their biological sex and compete against members of the opposite sex in athletic competition amounts to __USD promoting the religious practice of gender ideology in violation of Plaintiffs’ rights secured by Articles XX § 1 and XI § 7 of the Arizona Constitution and the Establishment Clause of the First Amendment of the United States Constitution, which is applicable to state actors such as __USD pursuant to Fourteenth Amendment of the United States Constitution.
17. As a direct and proximate result of __USD’s promotion of gender ideology, since ___ of 202__, J.D. and A.D. have felt unsafe and scared to use the female restroom while attending __HS. This fear has caused A.D. and J.D. to hold their bladders at school for prolonged periods of time causing them to suffer severe discomfort and anxiety. During the same period, J.D. and A.D. have felt unsafe to participate in scholastic athletic competition due to fear of physical injury and humiliation while competing against male students.
18. Despite repeated complaints by J.D., A.D. and their parents, Defendant continues to allow biological male students at its schools to use the girls’ restrooms on its campuses and allows male students to compete on female sports teams.
19. Due to Defendant’s Co-ed Restroom Policy and Sports Policy, J.D., A.D., and other students at __USD schools are compelled to: (1) participate in the religious practice of gender ideology by sharing traditionally sex-segregated facilities and compete against male students; (2) hold their bladders for prolonged periods to avoid participating in the religious ceremony of “social transition” by sharing restroom facilities with members of the opposite sex; (3) compete against members of the opposite sex in athletic competition or forego participation; or (4) seek accommodations to avoid the compelled religious practice that is supported by __USD—all in violation of the Establishment Clauses of the United States and Arizona constitutions.
Gender Ideology is a Religious Practice
20. Gender ideology teaches that one’s sense of “gender identity” ( “inner sense of gender”) supersedes reality such that its adherents should “transition” and live their lives as members of the opposite sex. As such, “gender identity” represents an immaterial aspect of one’s “true” or “authentic” being which, in traditional religions, is recognized as a soul.
21. Some adherents of gender ideology are so dogmatic that they force others, such as Plaintiffs, to play pretend by using the adherents’ “preferred pronouns” or face allegations of sexual harassment and/or bullying.
22. Gender ideology is not based on hard science, rejects reality at the most fundamental (cellular) level, and its theories are not provable in any rational or scientific manner. Indeed, gender ideology—like all religions—is a faith-based dogmatism.
23. Adherents of the religion of gender ideology adopt a “gender identity,” which is treated as a set apart from material reality, question, challenge, or disagreement, satisfying the traditional meaning of the words “holy,” “sacred,” and “sacrosanct.” Adherents to gender ideology sometimes express this explicitly, for instance, in claiming that “trans people are sacred.”
24. As a religion, gender ideology is a dualistic social-spiritual practice that locates “spiritual" activity in the psychological and social aspects of life, granting its adherents primacy over material reality and observable fact.
25. Gender ideology, like all religions, occupies a prime place in the minds and hearts of its adherents and incorporates a set of faith-based beliefs (i.e., beliefs amounting to dogmatism) that manifests as norms governing the most profound aspects of its practitioners’ lives. These norms include the wholesale rejection of biological reality and playing pretend in all facets of its adherents’ lives. Indeed, these norms give rise to discernible duties of conscience to adopt socio-politically queer ways of being and doing in all aspects of one’s life and to disrupt all that is “normal, legitimate, and dominant,” through various practices.
26. Gender ideology further grants its adherents a false sense of entitlement to invade the privacy rights of others, including physical intrusion into intimate spaces traditionally reserved for members of the opposite sex such as restrooms, locker rooms, and overnight field trips (sleeping arrangements), gendered activities such as sports, and other extracurricular activities historically segregated based on biological sex. It also grants them a false sense of entitlement to have their worldview (gender ideology) and its practice deferred to by all members of the school community in a way that constitutes not merely tacit but active and participatory endorsement of that worldview, against the rights of those who don’t belong to it.
27. Gender ideology touches every aspect of its adherents’ lives, seeping into the core of their sense of self, culture, family, chosen life paths, moral decisions (especially including sexual inhibitions and social behaviors, including in public), educational pursuits, and dictates how practitioners are expected to think, dress, act, and define themselves and their reality to conform with the practices of fellow believers. In the same way that the Christian church burned “heretics” throughout the Spanish Inquisition, proponents of gender affirmation metaphysically (and, sometimes, violently) cancel their critics as “transphobes,” “bigots,” “fascists,” etc.
28. Adherents to gender ideology are required to reject their sex, which is a biological fact, intentionally challenging the fact that human beings can only be either male or female (admitting some extremely rare birth defects), and that sex is determined by nature by and through each person’s capacity in potential or actuality during their life phase of healthy sexual maturity to produce small mobile gametes (sperm), if male, and large immobile gametes (ova), if female.
29. A belief in gender ideology is much more than just an “essentially political, sociological, or philosophical view or merely a moral code.” See Welsh v. United States, 398 U.S. 333, 339 (1970). Instead, gender ideology plays the role of a religion and functions as a religion in the lives of those that ascribe to it.
30. Gender ideology is—in fact and as a matter of law—a religion because it is the “ultimate concern” of its adherents and offers a comprehensive system of beliefs and practices that answer fundamental questions about the world and what it means to be human within it—such that gender ideology gives rise to clear duties of conscience. Id.
31. Gender ideology is a religion because it is a “sincere and meaningful belief which occupies in the life of its possessor [a place] that is parallel to that filled by God of those” ascribing to a traditional or parochial concept of religion. Id. (citing United States v. Seeger, 380 U.S. 163, 176 (1965)); Moore v. Cty. Of Chesterfield, 708 F.3d 560, 570–71 (4th Cir. 2013) (a religious belief is a scheme of things that occupies a place in the life of the believer “parallel to that filled by the orthodox belief in God.”).[1]
32. Those that practice gender ideology act out their religion through liturgical forms of protest and, frequently, undergoing a form of ritual rebirth, or being born again, called “gender transition” (i.e., “social transition”) by identifying and living as the sex consistent with their gender identity, including by adopting new names and pronouns and using traditionally sex-segregated facilities in a way that is inconsistent with their biological sex. They even refer to their (unregenerate) birth name and sex-associated pronouns through terminology like “deadname” and “deadself,” indicating the ritualistic nature of death and religious rebirth this process represents.
33. __USD’s implementation and affirmation of gender ideology therefore requires affirmation of the gender-ideological worldview, not merely compelled speech, and deference to, if not participation in, its catechism (Queer Theory and gender ideology) and liturgy (activism, social and medical transition, symbology, creeds, and pronouncements).
34. Defendant’s practice of allowing biological male students to use of the girls’ restrooms at __USD schools forces J.D., A.D., and other students to practice the religion of gender ideology, by “affirming” false identities of their peers and living out their lives based on the new, religious norms.
35. By supporting and encouraging gender ideology, Defendant’s Co-ed Restroom Policy is facially antithetical to the Establishment Clause of the First Amendment of the United States Constitution.
36. Through application of Defendant’s Co-ed Restroom Policy, __USD employees encourage children to adopt and live out the religious ideals of gender ideology. Students who ascribe to this religion at the beckoning of __USD employees directly harm students like J.D. and A.D. Encouraging their peers to use facilities inconsistent with their biological sex in furtherance of religious beliefs compels students like J.D. and A.D. (who were born female) to experience insufferable discomfort and reasonably feel unsafe due to biological males entering restrooms that were traditionally reserved for biological females.
37. Areas like restrooms, locker rooms, showers, sleeping areas during overnight trips, gendered activities (such as sports), and other extracurricular activities have been segregated based on sex throughout this Nation’s history. Furthermore, PUSD’s promotion of gender ideology is inconsistent with this Nation’s traditions.
38. Essentially, Defendant is forcing J.D. and A.D. to engage in a religious practice by affirming the female identity of their biologically male counterparts by sharing restroom and other intimate facilities with and competing against them in athletic competition.
39. Additionally, __USD’s Co-ed Restroom Policy and Sports Policy requires students to give up their right to be free from compelled participation in religious practice because those wishing to opt out are required to seek accommodations.
40. Through the implementation of the Co-ed Restroom Policy and Sports Policy, those practicing gender ideology are granted the unique privilege of acting out their religion and, furthermore, compelling students like J.D. and A.D. to participate in the religious practice of gender ideology or seek accommodations in violation of their constitutional rights.
41. Specifically, Plaintiffs are compelled by Defendant’s Co-ed Restroom Policy and Sports Policy to participate in the religious practice of gender ideology, or face possible punishment, when they are forced to speak in violation of their beliefs by using the chosen names and pronouns of certain students and staff identifying as “transgender” or “gender nonconforming.”
42. Additionally, Plaintiffs are compelled to participate in the religious practice of gender ideology when they are forced to share traditionally sex-segregated facilities (including restrooms, locker-rooms, shower areas, and sleeping quarters on overnight field trips) in violation of their conscience and personal religious views—all to accommodate those that ascribe to gender ideology which is promoted by Defendant through the implementation of its Co-ed Restroom Policy and Sports Policy. To avoid forced participation in the religious practice of gender ideology—Plaintiffs are forced to seek accommodations or altogether forfeit their most basic human rights—such as to safety, hygiene, and privacy.
43. The United States Supreme Court has “long held that government may not, consistent with a historically sensitive understanding of the Establishment Clause, ‘Make a religious observance compulsory.’” Id. at 2429 (quoting Zorach v. Clauson, 343, U.S. 306, 314 (1952).
44. The promotion of gender ideology in public schools serves no pedagogical purpose and is inconsistent with this Nation’s history and traditions. Indeed, the concept of gender ideology did not exist until the latter half of the twentieth century and was founded by individuals such as Alfred Kinsey and John Money and on the basis of Critical Theories of Sex, Gender, and Sexuality (today, Queer Theory) that emerged as recently as the 1990s from the legacies and works of Simone de Beauvior, Michel Foucault, Judith Bulter, Gayle Rubin, Eve Kosofsky Sedgwick, and David Halperin, inter alia, who present an unscientific and describable mystical-religious approach (specifically, Gnostic and Hermetic) to their chosen subjects.
45. As such, Queer Theory arises from a view of the world in which one’s true identity is considered sacrosanct but hidden from individual knowledge (“consciousness”) by evil spiritual forces that do not want it realized. Specifically, it is treated as having been obscured by social-spiritual forces of “oppression” that imprison the true (spiritual) self of the person under society’s norms and expectations, particularly around expressions of maleness/masculinity, femaleness/femininity, and sexuality.
46. Following de Beauvoir and Foucault, it is the quest to identify the sexed or sexual being (woman, or homosexual) “in itself” absent the evil conditioning forces of de facto binary-based oppression (patriarchy or heteronormativity). As Foucault and Butler assert, “the soul is imprisoned by the body,” which is in turn imprisoned by societal expectations put upon that body by dint of a “sex assigned at birth” and normative expectations about that sex.
47. That is, Queer Theory describes a psychosocial Gnosticist religious belief structure in which pure and unsullied souls are taught secret self-knowledge that, through the right practices of purification and transformation, allows them to escape the prison of their being, which is imposed by demonic alien forces with the capacity to contour and control the material aspects of being for that specific purpose. Queer Theory, and consequently gender ideology, is therefore a social-spiritualist practice of self-salvation and transformation based on claims to hidden or revealed truth about the true nature of reality and self.
48. In his book Saint Foucault: Toward a Gay Hagiography, David Halperin summarizes these ideas and states, “Unlike gay identity, which, though deliberately proclaimed in an act of affirmation, is nonetheless rooted in the positive fact of homosexual object-choice, queer identity need not be grounded in any positive truth or in any stable reality. As the very word implies, ‘queer’ does not name some natural kind or refer to some determinate object; it acquires its meaning from its oppositional relation to the norm. Queer is by definition whatever is at odds with the normal, the legitimate, the dominant. There is nothing in particular to which it necessarily refers. It is an identity without an essence.” This statement confirms the points in the checklist outlined in the foregoing paragraphs, including particularly that “queer” is an identity that demands observance and inspires duties of conscience in opposing “the normal, the legitimate, the dominant” while occupying an immaterialist philosophy that “need not be grounded in any positive truth or in any stable reality.”
FIRST CAUSE OF ACTION
ESTABLISHMENT OF RELIGION: GENDER IDEOLOGY
UNITED STATES CONSTITUTION FIRST AMENDMENT & 42 U.S.C. 1983
49. Plaintiffs repeat and reallege each of the foregoing allegations as though fully set forth herein.
50. When state officials act under color and authority of law resulting in the deprivation of certain fundamental rights, privileges, and immunities guaranteed to the People by the United States Constitution by operation of the Fourteenth Amendment, Federal law permits the aggrieved party to initiate a contested proceeding both to secure his or her rights by declaring the wrongful actions constitutionally void. See Title 42 U.S.C. § 1983.
51. Defendant’s employees and administrators act under color and authority of law when they allow biologically male students to utilize facilities traditionally reserved for exclusive use by biological females and allow male students to compete against female students in athletics.
52. By reason of Defendant’s acts and conduct as herein alleged, Plaintiffs have been deprived of their rights, privileges, and immunities secured to them by the Establishment Clause of the First Amendment of the United States Constitution, which is operable against states by adoption of the Fourteenth Amendment and 42 U.S.C. § 1983. Thus, Plaintiffs are entitled to mandamus relief or an order preventing further harm by Defendant through continued implementation of its Co-ed Restroom Policy and Sports Policy.
53. As a result of Defendant’s wrongful conduct as described in this complaint, Plaintiffs have suffered anguish, grief, shock, severe anxiety, alienation, humiliation, and mental trauma from fear of being raped when using the restroom and physically injured and humiliated in athletic competition—all of which was proximately caused by Defendants allowing biological male students to share intimate facilities traditionally reserved for female students and compete on female sports teams—such harm is extensive justifying injunctive and mandamus relief.
SECOND CAUSE OF ACTION
SUBSTANTIVE DUE PROCESS: INVASION OF RIGHT OF PRIVACY
UNITED STATES CONSTITUTION FOURTEENTH AMENDMENT & 42 U.S.C. 1983
54. Plaintiffs repeat and reallege each of the foregoing allegations as though fully set forth herein.
55. Implementation of Defendant’s Co-ed Restroom Policy violates Plaintiffs’ rights secured by the Substantive Due Process Clause of the Fourteenth Amendment of the United States Constitution.
56. Defendants challenged practice does so—“regardless of the underlying reason”—by endorsing the religious practice of certain students and granting them special privileges (under the guise of “tolerance”) to use facilities traditionally reserved to Plaintiffs as biological females which, in turn, infringes upon Plaintiffs’ fundamental right to privacy secured by the Substantive Due Process Clause of the Fourteenth Amendment to the United States Constitution See Eisenstadt v. Baird, 405 U.S. 438, 453 (1972) (“if the right of privacy means anything, it is the right of the individual, . . . to be free from unwarranted governmental intrusions into matters so fundamentally affecting a person as [a child using the restroom without fear].”).
57. The Co-ed Restroom Policy does so by codifying the religious practice of certain students and granting them special privileges (under the guise of “tolerance”) to use facilities traditionally reserved to Plaintiffs as biological females and, thereby, infringing upon Plaintiffs’ fundamental right to privacy.
58. Daily, Plaintiffs’ right of privacy is violated by implementation of the Co-ed Restroom Policy, which requires that they either confront the horror of sharing intimate spaces (traditionally segregated by biological sex) with members of the opposite sex or seeking “alternative arrangements” to avoid such a nightmare.
59. By reason of Defendants’ acts and conduct as herein alleged, Plaintiffs have been deprived of their rights, privileges, and immunities secured to them by the Fourteenth Amendment of the United States Constitution, which is operable against states pursuant to 42 U.S.C. § 1983. Thus, Plaintiffs are entitled to mandamus relief or an order preventing further harm by Defendant through continued implementation of its Co-ed Restroom Policy.
60. As a result of Defendant’s wrongful conduct as described in this complaint, Plaintiffs have suffered anguish, grief, shock, severe anxiety, alienation, humiliation, and mental trauma from fere of being raped when using the restroom—all of which was proximately caused by Defendant’s allowing biological male students to share intimate facilities traditionally reserved for female students—such harm is extensive justifying injunctive and mandamus relief.
THIRD CAUSE OF ACTION
ESTABLISHMENT OF RELIGION: GENDER IDEOLOGY
ARIZONA CONSTITUTION ARTICLES XX § 1 and XI § 7
61. Plaintiffs repeat and reallege each of the foregoing allegations as though fully set forth herein.
62. Article XX § 1 of the Arizona Constitution holds: “Perfect toleration of religious sentiment shall be secured to every inhabitant of this state, and no inhabitant of this state shall ever be molested in person or property on account of his or her religious worship, or lack of the same.”
63. Generally, Arizona courts apply the same standard for analyzing constitutional provisions where there is a corollary provision of the United States Constitution. See e.g., Coleman v. City of Mesa, 230 Ariz. 352, 361 ¶ 39 (2012).
64. For the reasons set forth in paragraphs 20 through 48 of this complaint, gender ideology is a religion.
65. For the reasons set forth in the foregoing paragraphs of this complaint, Plaintiffs have been molested in person on account of their religious beliefs and failure to ascribe to gender ideology in violation of their rights secured by Article XX § 1 of the Arizona Constitution.
66. Article XI § 7 of the Arizona Constitution provides: “No sectarian instruction shall be imparted in any school or state educational institution that may be established under this constitution, and no religious or political test or qualification shall ever be required as a condition of admission into any public educational institution of this state, as a teacher, student, or pupil[.]”
67. Here, the Co-Ed Restroom Policy and Sports Policy compel Plaintiffs to acquiesce to the religious practice of gender ideology as a condition precedent of attending __USD schools.
68. For the reasons set forth in the foregoing paragraphs of this complaint, Plaintiffs have been subject to sectarian instruction in violation of their rights secured by Articles XX § 1 and XI § 7 of the Arizona Constitution.
FOURTH CAUSE OF ACTION
SUBSTANTIVE DUE PROCESS: INVASION OF RIGHT OF PRIVACY
ARIZONA CONSTITUTION ARTICLE II § 8
69. Plaintiffs repeat and reallege each of the foregoing allegations as though fully set forth herein.
70. Implementation of Defendant’s Co-ed Restroom Policy violate Plaintiffs’ right of privacy secured by Article II § 8 of the Arizona Constitution—which provides that “[n]o person shall be disturbed in his private affairs . . . without authority of the law.”
71. Generally, Arizona courts apply the same standard for analyzing constitutional provisions where there is a corollary provision of the United States Constitution. See e.g., Coleman, 230 Ariz. at 361 ¶ 39.
72. For the reasons set forth in the foregoing paragraphs of this complaint, Plaintiffs have been disturbed in their private affairs without authority of law.
REQUEST FOR ATTORNEYS’ FEES
73. Plaintiffs request their reasonable attorneys’ fees pursuant to A.R.S. § 12-2030 and 42 U.S.C. § 1988.
PRAYER AND REQUESTED RELIEF
WHEREFORE, Plaintiffs respectfully request the following relief:
74. Declare impermissible and unlawful Defendant’s implementation of its Co-ed Restroom Policy as violating Plaintiffs’ rights under the Establishment Clause of the United States Constitution and Articles XX § 1 and XI § 7 of the Arizona Constitution. See A.R.S. § 12-1831; 42 U.S.C. § 1983.
75. Order Defendant to pay attorneys’ fees and costs to Plaintiffs. See A.R.S. § 12-2030; 42 U.S.C. § 1988.
76. Grant and impose any other remedy and grant and impose such other and further relief, at law or equity, that this Court deems just and proper in light of the circumstances.
RESPECTFULLY SUBMITTED this XX day of __, 2025.
By: /s/ RYAN L. HEATH
Ryan L. Heath, Esq. (036276)
The Gavel Project
4022 E. Greenway Road, #11-139
Phoenix, Arizona, 85032
ryan.heath@thegavelproject.com
Attorney for Plaintiffs
[1] Even if gender ideology is said to be “purely ethical or moral in source and content[,]” it nevertheless is a religion as a matter of law because it “impose[s] on its adherents a duty of conscience to [act in certain ways and] certainly occup[ies] in the life of [its practitioners] ‘a place parallel to that filled by . . . God’ in traditionally religious persons.” Welsh, 398 U.S. at 340 (quoting Seager, 380 U.S. at 176).
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