The Constitution guarantees that all citizens may
enjoy the "free exercise" of the religion of their choice.
Am. 1. The Court has recognized that the government
as an employer may impose some limitations on the
First Amendment rights of public employees, see, e.g.,
Garcetti v. Ceballas, 547 U.S. 410 (2006), but the Court
has never recognized a right to deprive an otherwise
qualified individual of the ability to obtain federal employment solely because of the applicant's religious beliefs where the applicant can demonstrate his eligibility
to work and to fulfill his tax-reporting obligations.

The questions presented are:

1. Whether the Sixth Circuit erred in refusing to
consider Petitioner's Religious Freedom Restoration
Act claim on the ground that it was not fully briefed
where the government changed its litigation position
in its Response Brief to state that Title VII does not
displace RFRA to provide the sole remedy for religious
discrimination in employment and Petitioner fully argued the basis for the RFRA claim in his Reply Brief?

2. Whether the government's requirement that
an individual possess a valid Social Security Number
imposes a substantial burden on Petitioner's religious
liberty in violation of the Religious Freedom Restoration Act where it does not uniformly require the number for all employment purposes and Petitioner has
alternative identification that permit wage reporting
and tax filing?

3. Whether the trial court erred in concluding
that Mr. Truskey cannot state a religious discrimination claim under Title VII where Mr. Truskey had a
valid substitute identification in lieu of a Social Security Number that would not cause Appellee to violate
the law by employing him and Mr. Truskey otherwise
stated a prima facie case of religious discrimination.

Whether the government's requirement that an individual possess a valid Social Security Number imposes a substantial burden on Petitioner's religious liberty in violation of the Religious Freedom Restoration Act