Here is the beginning.  I can send the rest if anyone is interested.

 

Stan Shepp

 

 

 

No. _________

================================================================

In The

Supreme Court of the United States

--------------------------------- ---------------------------------

RODNEY HANS HOLM,

Petitioner,

v.

STATE OF UTAH,

Respondent.

--------------------------------- ---------------------------------

On Petition For Writ Of Certiorari

To The Supreme Court

Of The State Of Utah

--------------------------------- ---------------------------------

PETITION FOR WRIT OF CERTIORARI

--------------------------------- ---------------------------------

RODNEY R. PARKER*

FREDERICK MARK GEDICKS

SNOW, CHRISTENSEN & MARTINEAU

10 Exchange Place, 11th Floor

Post Office Box 45000

Salt Lake City, Utah 84145

Telephone: (801) 521-9000

RAYMOND SCOTT BERRY

Post Office Box 58027

Salt Lake City, Utah 84158

Telephone: (801) 359-6160

October 13, 2006 *Counsel of Record

================================================================

COCKLE LAW BRIEF PRINTING CO. (800) 225-6964

OR CALL COLLECT (402) 342-2831

i

 

 

QUESTIONS PRESENTED

 

1. Does Reynolds v. United States, 98 U.S. 145

(1879), preclude extension of modern liberty rights to

religious polygamists who do not seek legal recognition of

their relationships?

 

2. Does state criminalization of private polygamous

relationships between consenting adults violate the liberty

protected by the Due Process Clause of the Fourteenth

Amendment?

 

3. Does Utah’s bigamy law target religion, in violation

of the Free Exercise Clause of the First Amendment

and the Equal Protection Clause of the Fourteenth

Amendment, by making participation in a private religious

ceremony an element of the crime?

 

4. Were Petitioner’s constitutional rights of due

process and confrontation violated when the State failed to

prove the jurisdictional elements of the crime, and when

the trial court sustained the State’s objection to Petitioner’s

effort to prove that the alleged acts took place

outside the State of Utah?

 

 

 

Let me know if you want the entire file posted here.

 

Thanks!

 

Stan Shepp

Somewhere in the West

Center of the Universe

[EMAIL PROTECTED]

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