1-0 Petition for Review Filed
May 20th, 2020
PETITION FOR REVIEW IN THE NATURE OF A COMPLAINT FOR DECLARATORY RELIEF
Petitioner Ivy Hill Congregation of Jehovah’s Witnesses (“Ivy Hill Congregation”), by and through its undersigned counsel, hereby brings this petition for review seeking a declaration regarding the religious rights afforded to its members and, in support thereof, avers as follows:
1. This action implicates one of the core liberties enshrined in both the Federal and State Constitutions – the right of individuals to worship according to the dictates of their own faith and conscience.
2. The Ivy Hill Congregation consists of adherents to the practices and teachings of Jehovah’s Witnesses.
3. Ivy Hill Congregation’s beliefs and practices are now at issue given recent actual and threatened enforcement actions by the Commonwealth under the Child Protective Services Law (the “CPSL”), see 23 Pa.C.S. §§ 6301, et seq., combined with the peculiar construct of the privilege afforded to clergymen, such as ministers of the gospel, under that statute.
4. In order to redress this harm and ensure that its congregants can worship according to the dictates of their faith, while also complying with the laws of this Commonwealth, the Ivy Hill Congregation seeks declaratory relief concerning the rights and responsibilities of its ministers of the gospel.
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