1. Whether, consistent with the Free Exercise clause (App. B-l) and Due
Process (App. B-3, B-4) (Fifth and Fourteenth Amendments), a State may
compel secular therapy while refusing to credit an equivalent
faith-based program.
2. Whether a state court may deny a probationer religious therapy for
nearly a decade despite sincerely held beliefs and eventual probation
approval.
3. Whether reliance on internal probation rules —and assumptions that
religious treatment is inherently insufficient —instead of statutory
authority violates constitutional guarantees of religious liberty (App.
B-l) and due process (App. B-3, B-4).
4. Whether a State may invoke "separation of church and state " or
funding restrictions to deny credit or vouchers for religious therapy
when federal law places faith-based providers on equal footing with
secular programs.
5. Whether the summary, cursory denials by the Superior Court and
Court of Appeals —grounded in internal policy rather than law; while
systematically ignoring A.R.S. § 13-90 1(E) —(See App. B-6) and ignoring a
completed, probation-approved religious program —constitute an abuse of
discretion and a continuing denial of First Amendment Rights, (App.
B-l) when these Orders Denying Relief were filed within two days
of Petitioner 's filing; compounding the Free Exercise (App. B-l) and
Due Process violations (App. B-3, B-4) and whether prolonged denial of
religious therapy requires immediate termination of probation as an
appropriate remedy.
6. Whether this Petition should properly also be called a Petition for
Redress of Grievances (App. B-2) for wrongs committed under the
constitutional First Amendment (App. B-l) by the State of Arizona
and the Adult Probation Department in Maricopa County against
Petitioner.
Whether a state may compel secular therapy while refusing to credit an equivalent faith-based program under the Free Exercise Clause and Due Process