Whether the Due Process Clause permits a family court to compel unwanted medical treatment as a condition of allowing a fit parent to maintain contact with his child absent an overriding state interest and consideration of reasonable alternatives

and undersigned counsels’ need for additional time to prepare a petition that will assist this Court in deciding whether to grant certiorari. Specifically, Mr. Woodward respectfully requests additional time to file his petition for certiorari for the following reasons: 1. Mr. Woodward initially sought emergency relief in this Court on August 15, 2023, by filing an application for a stay of the Tennessee trial court’s order. Application for a Stay, No. 23A137 (U.S. Aug. 15, 2023). Mr. Woodward was awaiting preparation of his petition for writ of certiorari until the Court disposed of his stay application. Justice Kavanaugh denied that application on August 18, 2023. An extension of time is warranted to ensure counsel now has sufficient time to prepare a separate petition for writ of certiorari. 2. In addition, pre-existing commitments will limit counsel’s ability to prepare a petition for certiorari on or before September 4, 2023. In particular, Mr. Phillips had a reply brief that was filed on August 18 in the New York Supreme Court, Appellate Division, in IntegrateNYC, Inc. v. New York, No. 2022-02719, and has a response brief due on August 24 in the U.S. District Court for the Western District of Wisconsin in Epic Systems v. Tata Consultancy, No. 3:14-cv-00748. Mr. Phillips also has a previously paid-for vacation in Poland September 1-10. 3. An extension of time is warranted because this case raises an exceptionally important question about when, consistent with the Due Process Clause, family courts may compel medical treatment as a condition of allowing a loving and fit parent to see his child. That question arises frequently, and family courts across the Nation take differing views on its answer. But the answer is clear under this Court’s precedents: Without an overriding state interest and thorough consideration of reasonable alternatives, courts cannot force unwanted medical treatment on a parent, and certainly cannot do so as a condition of parental contact. The Tennessee trial court in this case flouted that rule, and courts across the country would benefit from this Court’s guidance on this recurring and important issue. CONCLUSION For these reasons, Applicant respectfully requests that an order be entered extending the time to file his petition for a writ of certiorari to and including October 4, 2023. Respectfully submitted, /s/ Carter G. Phillips CARTER G. PHILLIPS * JACQUELINE G. COOPER Copy M. AKINS SIDLEY AUSTIN LLP 1501 K Street, N.W. Washington, D.C. 20005 (202) 736-8000 Attorneys for Applicant/ Petitioner * Counsel of Record August 22, 2023 CERTIFICATE OF SERVICE I, Carter G. Phillips, do hereby certify that, on this 22nd day of August, 2023, I caused a copy and an electronic copy of the Application for Extension of Time in the foregoing case to be served by U.S. Mail, postage prepaid, and by email on the following party: Helen S. Rogers Laura S. Blum The Wind in the Willows Mansion 2205 State Street Nashville, TN 37203 (615) 320-0600 /s/ Carter G. Phillips CARTER G. PHILLIPS SIDLEY AUSTIN LLP 1501 K Street, N.W. Washington, D.C. 20005 (202) 736-8000