When a plaintiff alleges denial of a governmental benefit based on beliefs/thoughts and the benefit is conditioned on adopting government-approved beliefs/thoughts, is he/she required to allege and prove suppression of speech is a motivating factor to state a First Amendment claim?

QUESTION(S) PRESENTED 1) When a plaintiff alleges that he or She was denied a valuable governmental benefit based on his or her beliefs and thoughts and that the receipt of that benefit is conditioned on adopting, internalizing, and voicing government approved ones, is he or she also required to additionally allege and prove that suppression of speech is a motivating factor of the government to state a clain upon which relief may be qranted under the First Amendment? , 2) When the aim of a governmental practice is to inhibit and coerce belief and thought, is not that the same as an aim to suppress speech? 3) Is a Turner v. Safley, 482 U.S. 78 (1987) test, as is, appropriate for a challenge of parole suitability determination regulations where the regulations are used to penalize, inhibit, and coerce parole candidate beliefs and thoughts; where day-to-day operation of a prison are not involved; and where there are no institutional safety and security concerns? 4) Was an adverse ruling using the Turner test premature in this case before plaintiff had an opportunity to fully develop the record and were the first and second parts of the test correctly used? . 5) Are parole suitability determination regulations allowed to be challenged facially under the Due Process Clause? 6) Is the Turner test appropriate for a facial challenge of regulations under . the pue Process Clause? : 7) Did the appellate court error by not permitting an Opening Brief to be filed on the ground that the questions raised were "too insubstantial"? ii