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No. 22-____

IN THE

Supreme Court of the United States

--------

CHURCH OF SCIENTOLOGY INTERNATIONAL, RELIGIOUS TECHNOLOGY CENTER & CHURCH OF SCIENTOLOGY CELEBRITY CENTRE INTERNATIONAL,

Petitioners,

v.

CHRISSIE CARNELL BIXLER, CEDRIC BIXLER-ZAVALA, JANE DOE #1 & JANE DOE #2,

Respondents.

e -------- lin On Petition for a Writ of Certiorari to the

Court of Appeal of California, Second Appellate District, Division Five

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d PETITION FOR WRIT OF CERTIORARI --------

a ROBERT E. MANGELS e MATTHEW D. HINKS

JEFFER MANGELS BUTLER & MITCHELL LLP

D 1900 Ave. of the Stars

WILLIAM H. FORMAN Counsel of Record

MARGARET E. DAYTON WINSTON & STRAWN LLP 333 South Grand Avenue

7th Floor

38th Floor

Los Angeles, CA 90067 Los Angeles, CA 90071

(310) 203-8080

(213) 615-1700

mhinks@

whforman@

Counsel for Petitioner Religious Technology Center

July 19, 2022

Counsel for Petitioners Church of Scientology International and Celebrity Centre International

WILSON-EPES PRINTING CO., INC. ? (202) 789-0096 ? WASHINGTON, D.C. 20002

QUESTIONS PRESENTED Where a parishioner freely executes a religious arbitration agreement with her church, does the First Amendment prohibit enforcement of the agreement if the parishioner leaves the faith? Does the First Amendment restrict the terms on which a Church may accept members into its faith?

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(i)

ii

PARTIES TO THE PROCEEDINGS AND RULE 29.6 STATEMENT

The Church of Scientology International, Church of Scientology Celebrity Centre International, and Religious Technology Center are each a church in the Scientology religion (collectively, "Petitioners" or the "Church Parties"). These entities were each a defendant in the trial court, a real party in interest in the California Court of Appeal and the California Supreme Court, a petitioner in the California Supreme Court, and are a petitioner in this Court.

Chrissie Carnell Bixler, Cedric Bixler-Zavala, Jane

e Doe No. 1 and Jane Doe No. 2 (collectively,

"Respondents") were each a plaintiff in the trial court,

lin a petitioner in the Court of Appeal and the California

Supreme Court, a respondent in the California Supreme Court, and are a respondent in this Court.

The Superior Court for the State of California,

d County of Los Angeles, was a respondent in the

California Court of Appeal and the California Supreme Court.

a Another plaintiff involved in this case, Bobette

Riales, remains a plaintiff in the trial court. She did

e not sign an agreement to arbitrate, and therefore, her

claims were not the subject of the orders at issue in the

D proceedings in the California Court of Appeal or the

California Supreme Court or in this Petition for Writ of Certiorari.

Daniel Masterson, is a defendant in the trial court. He was not named as a real party in interest in the Petition for Writ of Mandate, but joined in the Church Parties' briefing in the California Court of Appeal and the California Supreme Court as a real party in interest.

iii

David Miscavige, is named as a defendant in the trial court. Mr. Miscavige has not been served and was not named as a real party in interest in the Petition for Writ of Mandate or in the California Supreme Court. Mr. Miscavige has not appeared in the action.

Petitioners Church of Scientology International, Church of Scientology Celebrity Centre International, and Religious Technology Center are corporations. There are no parent corporations of Church of Scientology International, Church of Scientology Celebrity Centre International, or Religious Technology Center. There are no publicly held companies that own 10% or more of Church of Scientology International, Church of

e Scientology Celebrity Centre International, or Religious Deadlin Technology Center.

iv

RELATED PROCEEDINGS

This case arises from and is related to the following proceedings in the Superior Court of California, County of Los Angeles, the California Court of Appeal, and the California Supreme Court:

Chrissie Carnell Bixler, et al. v. Church of Scientology International, et al., Case No. 19STCV29458 (Cal. Super. Ct. Dec. 30, 2020) (order granting petition to compel arbitration) (App. 41a-63a);

Chrissie Carnell Bixler, et al., Petitioners v. Superior Court for the State of California, County of Los Angeles,

e Respondent; Church of Scientology International, et al.,

Real Parties in Interest, Case No. B310559 (Cal. Ct. App. Mar. 9, 2021) (order summarily denying petition

lin for writ of mandate) (App. 68a-69a); Chrissie Carnell Bixler, et al., Petitioners v. Superior Court for the State of California, County of Los Angeles, Respondent; Church of Scientology International, et

d al., Real Parties in Interest, Case No. S267740 (Cal.

May 26, 2021) (order granting review and directing

a order to show cause to issue) (App. 70a-71a); Chrissie Carnell Bixler, et al., Petitioners v. Superior

e Court for the State of California, County of Los Angeles,

Respondent; Church of Scientology International, et al., Real Parties in Interest, Case No. B310559 (Cal.

D Ct. App. Jun. 4, 2021) (issuing order to show cause)

(App. 72a-73a);

Chrissie Carnell Bixler, et al., Petitioners v. Superior Court for the State of California, County of Los Angeles, Respondent; Church of Scientology International, et al., Real Parties in Interest, Case No. B310559 (Cal. Ct. App. Sept. 22, 2021) (ordering supplemental briefing) (App. 64a-65a);

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