Jacobrown v. Garcia

CourtDistrict Court, District of Columbia
DecidedFebruary 22, 2011
DocketCivil Action No. 2009-1420
StatusPublished

This text of Jacobrown v. Garcia (Jacobrown v. Garcia) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jacobrown v. Garcia, (D.D.C. 2011).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

TOBIN DANA JACOBROWN, : : Plaintiff, : Civil Action No.: 09-1420 (RMU) : v. : Re Document No.: 17 : UNITED STATES OF AMERICA et al., : : Defendants. :

MEMORANDUM OPINION

GRANTING THE DEFENDANTS’ MOTION TO DISMISS

I. INTRODUCTION

This matter is before the court on the defendants’ motion to dismiss. The plaintiff alleges

that the defendants have violated the Religious Freedom Restoration Act (“RFRA”), 42 U.S.C.

§§ 2000bb-2000bb-4, by requiring him to register with the Selective Service System (“the

Selective Service”) without providing a mechanism for him to assert that he is a conscientious

objector or maintaining a record of his assertion. The defendants contend that the plaintiff lacks

standing because the Selective Service does, in fact, provide such a mechanism, and because his

refusal to register has not resulted in any concrete injury. In the alternative, the defendants argue

that the complaint fails to state a claim on which relief can be granted because it does not

adequately plead that the Selective Service’s registration procedures place a substantial burden

on the plaintiff’s religious exercise.

As discussed below, the Selective Service already provides the registration and

recordkeeping measures that, according to the complaint, are needed to satisfy the plaintiff’s

religious beliefs. Accordingly, the plaintiff has not adequately pled that he is harmed by the

registration requirement. As a result, the court dismisses the complaint for lack of standing. Because, however, the plaintiff’s failure to adequately plead standing may have resulted from

inadvertent and potentially correctable deficiencies in the drafting of the complaint, the court

dismisses the complaint without prejudice and grants the plaintiff leave to file a new complaint

that remedies those deficiencies.

II. FACTUAL & PROCEDURAL BACKGROUND

A. The Selective Service Registration Requirement

The Military Selective Service Act (“MSSA”) provides that with very few exceptions, all

men between the ages of eighteen and twenty-six must register with the Selective Service in the

manner prescribed by the President of the United States and the regulations of the Selective

Service. 50 U.S.C. App. § 453(a). The registration requirement is designed to create a ready

pool of potential combat troops should Congress be called upon to exercise its power to

conscript. Rostker v. Goldberg, 453 U.S. 57, 75-76 (1981).

The Selective Service regulations provide a number of different avenues for satisfying the

registration requirement. 32 C.F.R. §1615(c). For instance, an individual can register by

completing a Selective Service Registration Card, registering online at the Selective Service

website or returning the Selective Service reminder mailback card. Id. Whatever the method,

the registrant is required to provide his name, date of birth, sex, Social Security Number, current

mailing address, permanent residence, telephone number and signature. Id. § 1615.4(a).

Although the MSSA does not exempt conscientious objectors from the registration

requirement, it does provide that conscientious objectors whose opposition to participation in

war is founded on their religious beliefs are not subject to training and service in the armed

forces. See 50 U.S.C. App. § 456(j) (“Nothing contained in this title . . . shall be construed to

2 require any person to be subject to combatant training and service in the armed forces of the

United States who, by reason of religious training and belief, is conscientiously opposed to

participation in war in any form.”). If such an individual is called on to report for induction, he

may submit to his local draft board a claim for reclassification as a conscientious objector. 32

C.F.R. § 1633.2(a); see also id. §§ 1630.11, 1630.16. The local board may then determine that

the individual is a conscientious objector opposed to all service, id. § 1630.11, or a conscientious

objector opposed to combat training and service, id. § 1630.16. If the local board does not

classify the individual as a conscientious objector, the individual may appeal that determination

to the district appeal board. Id. § 1651.1(b). If the registrant is classified as a conscientious

objector, he shall either be inducted and assigned to noncombatant service, or, if he is found to

be conscientiously opposed to participation in such noncombatant service, be ordered to perform

“such civilian work contributing to the maintenance of the national health, safety, or interest as

the Director [of the Selective Service] may deem appropriate.” 50 U.S.C. App. § 456(j).

Selective Service regulations prohibit an individual from seeking classification as a

conscientious objector until the time he is ordered to report for induction. 32 C.F.R. § 1633.3.

This policy recognizes that classification claims and determinations must be based on the

registrant’s status at the time he is ordered to report for induction. See United States v.

Schmucker, 815 F.2d 413, 418 (6th Cir. 1986) (“[T]he filing of a claim . . . in advance of

induction, would only serve to encumber the [Selective Service] with the responsibility for

processing claims which may not even prove pertinent to the registrant’s requested classification

at the time of induction.” (quoting 46 Fed. Reg. 56,434, 56,436)).

3 B. The Plaintiff’s Claims

The plaintiff is a member of the Religious Society of Friends, more commonly known as

the Quakers. Compl. ¶ 10. Although he has reached his eighteenth birthday, he has not

registered with the Selective Service. Id. ¶ 11. According to the plaintiff, his refusal to register

results from his religious training and beliefs, on the basis of which he conscientiously opposes

participation in war in any form. Id. ¶ 12.

Specifically, the plaintiff alleges that his religious beliefs preclude him from registering

with the Selective Service because the Selective Service “will not allow [him] to register, or

otherwise officially assert, a claim to conscientious objector status in connection with [his]

registration for the draft,” id. ¶ 16, and “will not maintain any record of [his] claim to

conscientious objector status in connection with his registration for the draft,” id. ¶ 19. Thus,

[b]ecause the Selective Service System will not allow plaintiff to register his claim to conscientious objector status in conjunction with his registration for the draft, and will not maintain any record of his claim to conscientious objector status, plaintiff cannot register with the Selective Service System without violating his sincere religious beliefs – both his fundamental religious belief in nonviolence and his fundamental religious belief in non-submission to a system that is unjust.

Id. ¶ 21.

The plaintiff contends that his refusal to register with the Selective Service has exposed

him to criminal and civil penalties. Id. ¶¶ 22-23. In addition, the plaintiff, who is a college

student on leave of absence, alleges that because of his refusal to register, he is barred from

obtaining federal student loans or grants. Id. ¶ 24.

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