21A244 081 Jan 06 2022 Main Document 20220106142119366 Osha Amicus Final (U.S.)

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Nos. 21A243, 21A244, 21A245, 21A246, 21A247, 21A248, 21A249, and 21A250  
 
 
In the Supreme Court of the United States 
 
 
IN RE: MCP NO. 165, OCCUPATIONAL SAFETY AND HEALTH 
ADMINISTRATION, INTERIM FINAL RULE: COVID-19 
VACCINATION AND TESTING; EMERGENCY TEMPORARY 
STANDARD 86 FED. REG. 61402, ISSUED ON NOVEMBER 4, 2021 
 
 
 
On Applications for Stays of Injunctions Issued by the United States District Courts 
for the Western District of Louisiana and Eastern District of Missouri Pending 
Appeals to the United States Courts of Appeals for the Fifth and Eighth Circuits 
 
 
MOTION OF 400 PHYSICIANS, SURGEONS, NURSES, AND MEDICAL 
PROFESSIONALS OPPOSING OSHA’S UNCONSTITUTIONAL 
OVERREACH LEAVE TO FILE ATTACHED BRIEF AS AMICUS CURIAE IN 
SUPPORT OF APPLICANTS 
 
 
 
 
 
WILLIAM WAGNER 
   Counsel of Record 
 
 
ERIN ELIZABETH MERSINO 
GREAT LAKES JUSTICE CENTER 
5600 W. Mount Hope Hwy 
Lansing, MI 48917 
(517) 322-3207 
prof.wwjd@gmail.com 
 
 
 
Counsel for Amicus Curiae 
 
 
 
January 6, 2022 
 
 

i 
MOTION FOR LEAVE 
 
Over 400 Physicians, Surgeons, Nurses, and Medical Professionals Opposing 
OSHA’s Unconstitutional Overreach (“Amicus Curiae”) respectfully moves under 
Supreme Court Rule 37.2 for leave (1) to file the attached brief as Amicus Curiae in 
support of the Emergency Applications filed on December 17-21, 2021, seeking a 
stay or injunction pending review of the Sixth Circuit’s decision to dissolve a stay of 
the Occupational Safety and Health Administration (“OSHA”) Emergency 
Temporary Standard (“ETS”) on Coronavirus Disease of 2019 (“COVID-19”).   
Amicus sought consent from the parties to file a brief in support of the 
emergency applications and provided notice of this filing on December 21, 2021. 
Counsel for the Applicants consented to the filing.  Counsel for the Department of 
Justice took no position.  
Amicus Curiae is an organization devoted to medical decisions only being made 
within the bounds of the Constitution and based upon reliable scientific and medical 
principles.  Amicus Curiae cares deeply about the impact of a governmental agency 
improperly usurping an individual’s control over his/her sincerely held religious and 
moral convictions and personal medical decisions.  Indeed, the physicians, surgeons, 
nurses, and medical professionals have faced the loss of their careers, unpaid 
suspensions from work, and the denial of religious exemptions—not based on the 
sincerity of their religious convictions, but due to categorical denials of any religious 
exemptions at their places of work.  Many support their families with their 
paychecks and fear if they will be able to earn a living due to being publicly 

ii 
ostracized by their government and their employers for following their sincerely 
held religious convictions.  Many have experienced their employers sharing 
confidential medical information with their co-workers.  Many have faced rigorous 
and inappropriate interrogation and insults from their employers regarding their 
religious beliefs.  All have faced unjust persecution.   
The Over 400 Physicians, Surgeons, Nurses, and Medical Professionals Opposing 
OSHA’s Unconstitutional Overreach worked on the front lines during the beginning 
of the COVID-19 pandemic, frequently working overtime in unsafe conditions.  They 
willingly sacrificed their own health to serve others; the majority have already 
contracted COVID-19 and presently have the antibodies against the illness.   
Amicus Curiae has worked from the beginning of the pandemic, almost two 
years ago, without vaccination and without placing others in danger.  Amicus 
Curiae willingly follows health and safety protocol to avoid transmission of COVID-
19.  They just cannot do so when such a protocol, like forced vaccination, violates 
their sincerely held religious beliefs.   
Amicus Curiae has personally felt the backlash of the President’s “Emergency” 
vaccination mandate.  Due to Amicus Curiae’s unique position and experience, the 
organization would provide a helpful perspective for the Court and ask that their 
motion for leave be granted. 

iii 
Respectfully submitted, 
 
GREAT LAKES JUSTICE CENTER 
 
 
 
  
 
 
 
WILLIAM WAGNER 
 
 
 
 Counsel of Record 
 
 
 
 
 
 
 
ERIN ELIZABETH MERSINO 
 
 
 
5600 W. Mount Hope Hwy 
 
 
 
Lansing, MI 48917 
 
 
 
(517) 322-3207 
 
 
 
prof.wwjd@gmail.com 
 
 
 
 
 
 
Counsel for Amicus Curiae 
 
 
 

iv 
QUESTIONS PRESENTED 
 
The questions presented are: 
 
1. 
Whether 
OSHA’s 
private-employer 
mandate 
is 
an 
unlawful 
exercise of  constitutional or statutory authority. 
2. 
Whether OSHA’s private-employer mandate violates the Religious 
Freedom Restoration Act or the First Amendment. 

v 
TABLE OF CONTENTS 
 
QUESTIONS PRESENTED ......................................................................................... iv 
 
TABLE OF AUTHORITIES ......................................................................................... vi 
 
STATEMENT OF IDENTITY AND INTERESTS OF AMICUS CURIAE ................. 1 
 
SUMMARY OF THE ARGUMENT .............................................................................. 3 
 
ARGUMENT .................................................................................................................. 4 
 
I. 
NEITHER THE CONSTITUTION NOR ANY CONGRESSIONAL STATUTE 
AUTHORIZES OSHA’S OVERREACHING MANDATE ...................................... 4 
 
II. OSHA’S MANDATE SQUARELY VIOLATES THE RELIGIOUS FREEDOM 
RESTORATION ACT .............................................................................................. 8 
 
CONCLUSION ............................................................................................................. 10 

vi 
TABLE OF AUTHORITIES 
 
Cases 
 
Burwell v. Hobby Lobby,  
 134 S. Ct. 2751 (2013) ................................................................................................ 8 
 
City of Boerne v. Flores,  
 521 U.S. 507 (1997) .................................................................................................... 4 
 
Free Enterprise Fund v. Public Company Accounting Oversight Bd.,  
 561 U.S. 477 (2010) .................................................................................................... 7 
 
Gibbons v. Ogden,  
 9 Wheat. 1, 6 L.Ed. 23 (1824) .................................................................................... 5 
 
Gonzales v. O Centro Espirita Beneficente Uniao Do Vegetal,  
 546 U.S. 418 (2006) .................................................................................................... 9 
 
Marbury v. Madison,  
 1 Cranch 137, 2 L.Ed. 60 (1803) ................................................................................ 7 
 
McCulloch v. Maryland,  
 17 U.S. 316 (1819) ...................................................................................................... 5 
 
Nat'l Fed'n of Indep. Bus. v. Sebelius,  
 132 S. Ct. 2566 (2012) .................................................................................... 3, 5, 6, 7 
 
Thomas v. Rev. Bd. of Ind. Emp't Sec. Div.,  
 450 U.S. 707 (1981) .................................................................................................... 8 
 
United States v. Morrison,  
 120 S. Ct. 1740 (2000) ................................................................................................ 7 
 
Constitution and Statutes 
 
U.S. Const., art. I § 8 ..................................................................................................... 5 
 
29 U.S.C. §§ 651-678 (1970) .......................................................................................... 5 
 
29 U.S.C. § 651 ............................................................................................................... 5 
 
29 U.S.C. § 655 ............................................................................................................... 5 
 

vii 
29 C.F.R. § 1910.501 ...................................................................................................... 5 
 
42 U.S.C. § 2000bb-(1)(a)-(b) ......................................................................................... 8 
 
42 U.S.C. § 2000bb-2(4) ................................................................................................. 8 
 
42 U.S.C. § 2000cc-5(7)(A) ............................................................................................. 8 
 
Rules 
 
Supreme Court Rule 37 ................................................................................................. 1 
 
Regulations 
 
86 Fed. Reg. 61402 (Nov. 5, 2021) ................................................................................. 5 
 
Other Authority 
 
https://www.cdc.gov/coronavirus/2019-ncov/variants/omicron-variant.html .............. 9 
 
https://www.federalregister.gov/d/2021-23643/p-64 ..................................................... 6 
 
https://www.federalregister.gov/d/2021-23643/p-1117 ................................................. 5 
 
https://www.whitehouse.gov/briefing-room/speeches-remarks/2021/09/09/remarks-
by-president-biden-on-fighting-the-COVID-19-pandemic-3/ .................................... 2 
 
 
 
 
 
 
 

1 
STATEMENT OF IDENTITY AND INTERESTS OF AMICUS CURIAE 
 
Pursuant to Supreme Court Rule 37, Amicus Curiae, Over 400 Physicians, 
Surgeons, Nurses, and Medical Professionals Opposing OSHA’s Unconstitutional 
Overreach, submits this brief.1  Amicus Curiae is an organization devoted to 
medical decisions only being made within the bounds of the Constitution and based 
upon reliable scientific and medical principles.  Amicus Curiae cares deeply about 
the impact of a governmental agency improperly usurping an individual’s control 
over his/her sincerely held religious and moral convictions and personal medical 
decisions.  Indeed, the physicians, surgeons, nurses, and medical professionals have 
faced the loss of their careers, unpaid suspensions from work, and the denial of 
religious exemptions—not based on the sincerity of their religious convictions, but 
due to categorical denials of any religious exemptions at their places of work.  Many 
support their families with their paychecks and fear if they will be able to earn a 
living due to being publicly ostracized by their government and their employers for 
following their sincerely held religious convictions.  Many have experienced their 
employers sharing confidential medical information with their co-workers.  Many 
have faced rigorous and inappropriate questioning and insults from their employers 
regarding their religious beliefs.  All have faced unjust persecution.   
 
1 On December 21, 2021, Amicus Curiae sought consent from the parties and provided notice of this 
filing.  Amicus Curiae received consent from the Applicants, and Counsel for the Department of 
Justice took no position.  Amicus Curiae further states that no counsel for any 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 or entity, other than the Great Lakes Justice 
Center, made a monetary contribution to the preparation or submission of this Amicus Curiae brief.   

2 
The Over 400 Physicians, Surgeons, Nurses, and Medical Professionals Opposing 
OSHA’s Unconstitutional Overreach worked on the front lines during the beginning 
of the COVID-19 pandemic, frequently working overtime in unsafe conditions.  They 
willingly sacrificed their own health to serve others; the majority have already 
contracted COVID-19 and presently have the antibodies against the illness.   
Amicus Curiae has worked from the beginning of the pandemic, almost two 
years ago, without vaccination and without placing others in danger.  Amicus 
Curiae willingly follows health and safety protocol to avoid transmission of COVID-
19.  They just cannot do so when such a protocol, like forced vaccination, violates 
their sincerely held religious beliefs.   
Amicus Curiae has personally felt the backlash of the President’s “Emergency” 
vaccination mandate and its political theater.  In its roll-out, the President 
explained that the purpose of the mandate is “to protect vaccinated workers from 
unvaccinated 
coworkers.” 
 
https://www.whitehouse.gov/briefing-room/speeches-
remarks/2021/09/09/remarks-by-president-biden-on-fighting-the-COVID-19-
pandemic-3/, last visited Jan. 5, 2022.  The polarization, on a national level, of 
Amicus Curiae’s sincerely held religious beliefs has exacerbated the discrimination 
and hardship they have faced and continue to face.   Ironically, it is Amicus Curiae’s 
religious beliefs that drew them to careers of service in the medical field and inspire 
them to care for sick individuals despite the potential risk doing so could pose to 
themselves and their families.   

3 
Amicus Curiae has undergone rigorous schooling, boards, residencies, and have 
significant debt to pay for their schooling.  Yet, due to forced vaccination mandates, 
face the inability to earn an income.   Amicus Curiae oppose the villainization of 
unvaccinated individuals.  First, doing so minimizes the importance of religious 
liberty and welcomes religious discrimination.  Indeed, Amicus have experienced 
this firsthand and are living it presently.  Second, the fighting words upon which 
this mandate are based, such as “protecting vaccinated workers from unvaccinated 
coworkers” forwards a serious falsehood about what the presently available COVID-
19 vaccinations do, and what the effect of vaccination is.   
Amicus Curiae files this brief to encourage this Honorable Court to not justify 
the President’s OSHA mandate.  It is unconstitutional and, undoubtedly, catalyzes 
religious discrimination. 
SUMMARY OF THE ARGUMENT 
 
OSHA asserts that its Mandate is authorized under the Commerce Clause.  It is 
not.  The Commerce Clause has never been used to force businesses, nationwide, to 
purchase, procure, and regulate vaccination, facial coverings, and weekly testing for 
communicable disease for all of their employees.  OSHA wants this Court to 
improperly interpret the Commerce Clause more broadly than it has ever been 
interpreted in the history of our nation.  See, e,g., Nat’l Fed’n of Indep. Bus. v. 
Sebelius, 132 S. Ct. 2566, 2577 (2012).  Pursuant to the principles and constructs of 
the Constitution, this Court must abstain from doing so.   

4 
Amicus Curiae additionally urges this Court that OSHA’s Mandate violates the 
Religious Freedom Restoration Act.  Amicus Curiae has personally faced religious 
persecution due to the announcement and beginning implementation of OSHA’s 
Mandate.  OSHA’s mandate requires individuals with sincerely held religious 
beliefs to divulge those beliefs to their employer, subject to scrutiny and backlash, 
and then publicly identify themselves as unvaccinated by wearing a facial 
covering—that is a substantial burden that triggers strict scrutiny review.  OSHA’s 
mandate falls short of satisfying the “most demanding test known to constitutional 
law.”  City of Boerne v. Flores, 521 U.S. 507, 534 (1997). 
ARGUMENT 
 
I. 
NEITHER 
THE 
CONSTITUTION 
NOR 
ANY 
CONGRESSIONAL 
STATUTE AUTHORIZES OSHA’S OVERREACHING MANDATE. 
 
The United States was founded on the ideal that the federal government cannot 
control every aspect of a person’s life—especially regarding matters of religious 
exercise and livelihood.   
OSHA’s Mandate aggrandizes the power of a federal agency in a manner never 
upheld before by this Court.   
The Federal Government “is acknowledged by all, to be one of 
enumerated powers.”  That is, rather than granting general authority 
to perform all the conceivable functions of government, the 
Constitution 
lists, 
or 
enumerates, 
the 
Federal 
Government’s 
powers. . . . 
 
The enumeration of powers is also a limitation of powers, because 
“[t]he enumeration presupposes something not enumerated.”  The 
Constitution’s express conferral of some powers makes clear that it 
does not grant others. And the Federal Government “can exercise only 
the powers granted to it.” 

5 
Nat’l Fed’n of Indep. Bus. v. Sebelius, 132 S. Ct. 2566, 2577 (2012) (internal 
citations omitted) (quoting McCulloch v. Maryland, 17 U.S. 316, 404, 405 (1819)); 
U.S. Const., art. I § 8, cls. 5, 7, 12; Gibbons v. Ogden, 9 Wheat. 1, 194-95, 6 L.Ed. 23 
(1824).  Congress never delegated OSHA authority to force all employers with over 
100 employees the power to require vaccination of their employees or to clearly 
designate who is unvaccinated by forcing a facial coverings mandate.   
 
Congress expressly delegated OSHA the power to enact an ETS—limited by its 
power to regulate interstate commerce.  29 U.S.C. §§ 651–678 (1970).  OSHA 
published its ETS for employers with 100 or more employees on November 5, 2021, 
29 C.F.R. § 1910.501, 86 Fed. Reg. 61402 (Nov. 5, 2021) – almost a year after 
Pfizer’s COVID-19 vaccine became publicly available.2  And OSHA admits that it 
relies upon “Congress’s Commerce Clause authority” as the constitutional power 
source for its Mandate.  https://www.federalregister.gov/d/2021-23643/p-1117, last 
visited Jan. 5, 2022.  This, in and of itself, is fatal for OSHA.   
 
The Commerce Clause does not grant the power to force employers or employees 
to “become active in commerce by purchasing a product, on the ground that their 
failure to do so affects interstate commerce.”  Sebelius, 567 U.S. at 520-21.  Forcing 
employers or employees to obtain vaccinations, weekly testing COVID-19 testing, 
and facial coverings does not regulate existing interstate commerce, but requires 
 
2 The Occupational Safety and Health Act (“OSH Act’) requires substantial evidence that an ETS is 
necessary to protect employees from grave occupational risks, and the Act is only “applicable to 
businesses affecting interstate commerce.” 29 U.S.C. §§ 651, 655. Yet, the 100-employee line was not 
based on interstate-commerce considerations, OSHA admits the line was not based on a difference in 
occupational risk, and OSHA placed the burden on employers to impose the mandate while stating 
employees may need to bear the costs of testing, an agency first. 
 
 

6 
the purchase and procurement of these measures.  By definition, OSHA’s Mandate 
does not regulate interstate commerce under Art. I, § 8, cl. 3.  It forces employers 
and employees to become active where they are not presently.   
 
OSHA’s mandate explains that it “stops short of requiring the full suite of 
workplace controls against SARS-CoV-2 transmission recommended by OSHA and 
the 
CDC, 
including 
distancing, 
barriers, 
ventilation, 
and 
sanitation.”  
https://www.federalregister.gov/d/2021-23643/p-64, last visited Jan. 5, 2022.  
However, if this Court were to allow OSHA’s mandate to be implemented under the 
Commerce Clause, under the reasoning OSHA is forwarding, nothing would stop 
OSHA from requiring every employer with over 100 employees from purchasing 
those items if OSHA decides to require it.   
 
This Court previously held that the Commerce Clause did not extend to federal 
regulation that required additional activity of employers and employees, instead of 
regulating ongoing interstate commerce.  This Court reasoned that, 
Construing the Commerce Clause to permit Congress to regulate 
individuals precisely because they are doing nothing would open a new 
and potentially vast domain to congressional authority. Every day 
individuals do not do an infinite number of things. In some cases, they 
decide not to do something; in others they simply fail to do it. Allowing 
Congress to justify federal regulation by pointing to the effect of 
inaction on commerce would bring countless decisions an individual 
could potentially make within the scope of federal regulation, and—
under the Government's theory—empower Congress to make those 
decisions for him. 
 
Sebelius, 567 U.S. at 552. 
 
 
Since the Constitution was ratified in 1788, never has a federal agency 
mandated such expansive action as OSHA attempts here in the form of its 

7 
unilaterally crafted and imposed ETS.  As this Court warned in Sebelius, 
“sometimes ‘the most telling indication of [a] severe constitutional problem ... is the 
lack of historical precedent’” 567 U.S. at 549 (quoting Free Enterprise Fund v. 
Public Company Accounting Oversight Bd., 561 U.S. 477, 505).   
 
Allowing OSHA’s mandate would desecrate our nation’s constitutional system of 
limited federal power.  This Court has warned “that those limits may not be 
mistaken, or forgotten.”  Marbury v. Madison, 1 Cranch 137, 176, 2 L.Ed. 60 (1803).  
While the scope of OSHA’s mandate is unprecedented, the problem it brings to this 
Court is not.  The Commerce Clause has been inappropriately invoked for a number 
of worthy causes, such as the deterrence of violence against women.  United States 
v. Morrison, 120 S. Ct. 1740 (2000).  And such regulations, albeit based on worthy 
goals, had to be struck down as unconstitutional—not because the intentions behind 
the regulations were misguided but because safeguarding the constructs of our 
Constitution and the separation of powers is vital to good governance under the 
Rule of Law.   
 
To allow OSHA’s mandate to go into effect pursuant to its Commerce Clause 
authority, because one agrees with the goal of the regulation, abandons the very 
principles of our constitutional republic.  OSHA’s Mandate far exceeds its 
constitutional authority under the Commerce Clause.  “The Commerce Clause is not 
a general license to regulate an individual from cradle to grave.”  Sebelius, 567 U.S. 
at 557.  Amicus Curiae urges this Court not to turn it into one. 
 

8 
II. OSHA’S 
MANDATE 
SQUARELY 
VIOLATES 
THE 
RELIGIOUS 
FREEDOM RESTORATION ACT. 
 
 
Under the Religious Freedom Restoration Act, the Government may only 
substantially burden the free exercise of religion, if the challenged regulation: “(1) is 
in furtherance of a compelling governmental interest; and (2) is the least restrictive 
means of furthering that compelling interest.”  42 U.S.C. § 2000bb-(1)(a)-(b).  
“[E]xercise of religion” is broadly defined as “any exercise of religion, whether or not 
compelled by, or central to, a system of religious belief.” 42 U.S.C. § 2000bb-2(4) 
(referencing 42 U.S.C. § 2000cc-5(7)(A)).  See also Burwell v. Hobby Lobby, 134 S. 
Ct. 2751, 2770, 2778; see also Thomas v. Rev. Bd. of Ind. Emp’t Sec. Div., 450 U.S. 
707, 713, 717-18 (1981) (holding that by denying employment benefits because the 
employee refused, on religious grounds, to work in a plant that produced 
armaments, the government imposed a substantial burden on the employee’s 
exercise of religion by “putting substantial pressure on an adherent to modify his 
behavior and to violate his beliefs,” noting that “[w]hile the compulsion may be 
indirect, the infringement upon free exercise is nonetheless substantial”). 
 
Amicus Curiae oppose forced vaccination pursuant to the tenets of their faiths 
and pursuant to their sincerely held religious beliefs.  OSHA’s mandate invites 
employers to judge the sincerity of their employees’ religious beliefs and 
substantially burden them.  OSHA Mandate requires employers to determine 
whether an employees’ sincerely held religious belief merits an exemption.  If the 
employer deems it does, then the employee must publicly wear a facial covering 
designating to everyone in their workplace that he/she is unvaccinated and also 

9 
submit to weekly COVID-19 testing.  Such Scarlett Letter treatment imposes 
“substantial pressure” on employees establishing a substantial burden on religious 
exercise, and OSHA’s Mandate falls short of strict scrutiny. 
 
Under the Religious Freedom Restoration Act, OSHA must justify its Mandate 
under strict scrutiny. Gonzales v. O Centro Espirita Beneficente Uniao Do Vegetal, 
546 U.S. 418, 430-31 (2006).  This is not a general test, but one that “requires the 
Government to demonstrate that the compelling interest test is satisfied through 
application of the challenged law ‘to the person’— the particular claimant whose 
sincere exercise of religion is being substantially burdened.”  Id. (emphasis added).  
OSHA’s Mandate that applies to every employer with more than 100 employees, 
and every employee at each of those companies, across the entire country, not based 
on risk or need, could never satisfy this constitutional test.  The mandate casts the 
widest net, not based upon any person’s risk of transmission; it is the antithesis of 
narrowly tailored.   
 
OSHA’s mandate has not proven, within the bounds of reliable science, that 
vaccination even stops COVID-19 transmission in the workplace.  Indeed, the “CDC 
expects that anyone with Omicron infection can spread the virus to others, even if 
they 
are 
vaccinated 
or 
don’t 
have 
symptoms.”  
https://www.cdc.gov/coronavirus/2019-ncov/variants/omicron-variant.html, 
last 
visited Jan. 5, 2022.  If OSHA cannot establish this basic premise behind its 
mandate, how could it ever be able to satisfy strict scrutiny review?  It does not.   

10 
 
Instead, OSHA’s mandate creates two classes of people, the vaccinated and the 
unvaccinated.  The unvaccinated must divulge their personal religious beliefs to 
those in positions of power, who may deny them religious exemptions at whim.  
Then, the exemption still requires those with sincerely held religious beliefs to 
openly identify as unvaccinated by wearing facial coverings further opening them to 
disparate treatment in the workplace.  Such a construct imposes the substantial 
burden that the Religious Freedom Restoration Act was enacted to protect.  OSHA, 
however, has not and cannot prove that its regulation of every employer in America 
with over 100 employees satisfies this standard, nor have they even proven that 
vaccinated individuals cannot contract or transmit COVID-19 to establish its theory 
that unvaccinated individuals pose a grave danger, or that the vaccinated do not.   
CONCLUSION 
OSHA enacted its mandate without constitutional authority, and it perpetuates 
religious discrimination and violates the Religious Freedom Restoration Act.  This 
Honorable Court should, therefore, reverse the decision of the Sixth Circuit and stop 
its implementation.  

11 
Respectfully submitted, 
 
GREAT LAKES JUSTICE CENTER 
 
 
 
  
WILLIAM WAGNER 
 Counsel of Record 
 
 
 
 
ERIN ELIZABETH MERSINO 
5600 W. Mount Hope Hwy 
Lansing, MI 48917 
(517) 322-3207 
 
 
 
 
 
prof.wwjd@gmail.com 
 
 
 
Counsel for Amicus Curiae

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