3demonize, vilify, and criminalize deeply held religious beliefs that are in opposition to theiragenda.5.
Section 249(a)(2) of the Hate Crimes Act thus promotes another Orwellianconcept: thought crimes. Section § 249(a)(2) criminalizes certain ideas, beliefs, and opinions,and the involvement of such ideas, beliefs, and opinions in a crime will make the crimedeserving of federal prosecution. Consequently, government officials, including Defendant, areclaiming the power to decide which thoughts are criminal under federal law and which are not.6.
Section 249(a)(2) of the Hate Crimes Act is intended to send a government-endorsed message to those persons who oppose the homosexual agenda on the basis of deeplyheld religious beliefs, such as Plaintiffs, that their religious beliefs are disfavored and theequivalent of racist beliefs.7.
Section 249(a)(2) of the Hate Crimes Act is an effort to eradicate religious beliefsopposing the homosexual agenda from the marketplace of ideas by demonizing, vilifying, andcriminalizing such beliefs as a matter of federal law and policy.8.
The enforcement history of similar “hate crimes” legislation, the publicstatements of homosexual activists, and the influence of homosexual activists within the federalgovernment demonstrate that Plaintiffs’ fears of adverse enforcement action under the Act onaccount of their deeply held religious beliefs are credible.9.
In order to secure its passage, the politically-divisive Hate Crimes Act wasincluded in the National Defense Authorization Act for Fiscal Year 2010 (hereinafter referred toas “Defense Authorization Act”), even though the Act is non-germane and non-related todefense. As Senator John McCain stated in the Senate Congressional Record, “It is indeed,
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