Summary of the argument: The fundamental argument in this action for permanent injunctive relief is that in view of the sworn testimonies of ex-gays, medical experts, licensed theologians, and persecuted Christians, sexual orientation and gender identity are orthodoxies, ideologies, and doctrines that amount to a series of unproven faith-based assumptions and naked assertions that are implicitly religious and inseparably linked to the religion of secular humanism. The US Supreme Court already established secular humanism is a religion for the purpose of the first amendment in cases like Torcaso v. Watkins; accordingly, for the defendants to introduce and attempt to enact and enforce the Equality Act – and all similar policies – violates the Establishment Clause of the First Amendment because (1) such government action lacks a primary secular purpose, (2) constitutes an indefensible legal weapon against non-observers of the religion of secular humanism, and (3) serves to excessively entangle our government with the religion of secular humanism. We will come at the Biden Administration as hard as possible for good cause explained in the attached verified complaint.
