No.
IN THE
Supreme Court of the United States
C
HURCH OF
S
CIENTOLOGY
I
NTERNATIONAL
,
Petitioner
,—v.—L
AURA
A
NN
D
ECRESCENZO
,
Respondent
.
ON PETITION FOR A WRIT OF CERTIORARI TO THE SUPERIOR COURT OF THE STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
PETITION FOR WRIT OF CERTIORARI
E
RIC
M. L
IEBERMAN
Counsel of Record
D
AVID
B. G
OLDSTEIN
R
ABINOWITZ
, B
OUDIN
, S
TANDARD
,K
RINSKY
, & L
IEBERMAN
, P.C.45 Broadway, Suite 1700New York, New York 10006(212) 254-1111elieberman@rbskl.comB
ERT
H. D
EIXLER
L
AURA
B
RILL
N
ICHOLAS
F. D
AUM
K
ENDALL
B
RILL
& K
LIEGER
LLP10100 Santa Monica Blvd.,Suite 1725Los Angeles, California 90067(310) 556-2700
d
Attorneys for Petitioner Church of Scientology International
QUESTIONS PRESENTED FOR REVIEW
1.Whether California’s penitent-clergy privi-lege statute, Cal. Evid. Code §§1030-34, asauthoritatively construed by the California courts,effects a denominational preference in violation of the Establishment Clause of the First Amendmentbecause it protects only confidential penitentialcommunications made to a single clergy personwho may never further disclose such communica-tions to other clergy—a practice typical of onlysome denominations—but does not protect confi-dential penitential communications that, pursuantto the religious doctrine of petitioner and numer-ous other denominations, are made to more thanone clergy or to a clergy person who must furtherdisclose that communication to another clergy per-son who also must maintain the confidentiality of the communication?2.Whether California’s penitent-clergy privi-lege statute, as authoritatively construed by theCalifornia courts, effects a denominational pref-erence that impermissibly burdens the religiouspractices of only some religions, in violation of theFree Exercise Clause of the First Amendment,because it protects only confidential penitentialcommunications made to a single clergy personwho may never further disclose such communica-tions to other clergy—a practice typical of onlysome denominations—but does not protect confi-dential penitential communications that, pursuantto the religious doctrine of petitioner and numer-ous other denominations, are made to more thanone clergy or to a clergy person who must furtherdisclose that communication to another clergy per-son who also must maintain the confidentiality of the communication?i
35237 Rabinowitz: Scientology • USSC (revised 12-1-08) • LJB 6/21/13 6:30
PARTIES TO THE PROCEEDINGS BELOW AND RULE 29.6 STATEMENT
The names of all the parties to the proceedingsin the Superior Court of California, Los AngelesCounty, the court whose order is sought to bereviewed, are Petitioner Church of ScientologyInternational; Respondent Laura DeCrescenzo;and Religious Technology Center, which is adefendant in the proceedings in the Los AngelesCounty Superior Court, but is not a party to thedispute raised in this Petition. Church of Scientology International and Religious Technology Center are not-for-profitreligious corporations, have no parent corporation,and do not have any owners or issue any stock.ii
35237 • Rabinowitz: Scientology • USSC (revised 12-1-08) • LJB 6/21/13 6:30