Here is the pdf (there’s where we wrote about the lawsuit before. My question : Is Rollins really this stupid or is she merely thumbing her nose at the USDA in pursuit of power. For someone who wants to force her religion on people who work in her departement, she sure does lie a lot.
PLEASE TAKE NOTICE that on August 27, 2026 at 9:30 a.m., or as soon thereafter as the matter
may be heard by the Honorable Laurel Beeler in Courtroom B, 15th Floor, U.S. District Court for the
Northern District of California, San Francisco Courthouse, Plaintiffs, National Federation of Federal
Employees, Lanette Dietrich, Thomas MaGee, Ashley Miller, Anne Poopatanapong, Ethan Roberts,
and Jennifer Wolfe (collectively, “Plaintiffs”), will and hereby do move this Court for a preliminary
injunction, pursuant to Rule 65 of the Federal Rules of Civil Procedure. Plaintiffs seek to have the
Court enjoin Defendants U.S. Department of Agriculture (“USDA”) and Brooke L. Rollins, in her
official capacity as the Secretary of Agriculture, and their officers, agents, attorneys, and any other
persons who are in active concert or participation with them (collectively, “Defendants”) from
sending or otherwise communicating messages that proselytize, promote, or favor any particular
religion during the pendency of this litigation. Plaintiffs also seek a stay under the Administrative
Procedure Act, 5 U.S.C. § 705 to preliminarily set aside Defendants’ policy of issuing messages that
proselytize, promote, or favor any particular religion to USDA employees. This motion is based on
this Notice and Memorandum of Points and Authorities, declarations and exhibits, records on file in
this action, and any other written or oral evidence or argument as may be presented at or before the
time this motion is heard by the Court.
Dated: July 22, 2026
Here’s part of that new PDF- READ THE WHOLE THING
C. The Secretary’s proselytizing messages express a denominational preference.
The denominational favoritism in the Secretary’s proselytizing messages creates another,
independent violation of the Establishment Clause. The Founders “knew . . . that one of the greatest
dangers to the freedom of the individual to worship in his own way lay in the Government’s placing
its official stamp of approval upon one particular kind of prayer or one particular form of religious
services.” Engel, 370 U.S. at 429. In keeping with that history, the Supreme Court has long held that
a guiding principle of the Establishment Clause is neutrality: Government may not express favoritism
for one religion over other religions, or religion over nonreligion. See Epperson v. Arkansas, 393 U.S.
97, 104 (1968). The Court recognized that foundational principle as early as 1872, see id. (“The law
knows no heresy, and is committed to the support of no dogma, the establishment of no sect.’”
(quoting Watson v. Jones, 80 U.S. (13 Wall.) 679, 728 (1872))), and as recently as last year, Cath.
Charities, 605 U.S. at 247 (“The clearest command of the Establishment Clause is that the government
may not officially prefer one religious denomination over another.” (citation modified)). The
government “must be neutral in matters of religious theory, doctrine, and practice[,] . . . and it may
not aid, foster, or promote one religion or religious theory against another or even against the militant
opposite.” Epperson, 393 U.S. at 103–04. “[A]ny state-sponsored denominational preference [is
subject to] strict scrutiny.” Cath. Charities, 605 U.S. at 242.
The Secretary’s explicitly proselytizing messages to 100,000 federal employees are “textbook
denominational discrimination,” Cath. Charities, 605 U.S. at 248, and the government cannot
articulate a compelling government interest to satisfy strict scrutiny. The messages “effect [a]favoritism among sects . . . [and] work deterrence of [other] religious belief[s].” Larson v. Valente,
456 U.S. 228, 246 (1982) (quoting Schempp, 374 U.S. at 305 (Goldberg, J., concurring)). They
amount to a “practice” that “over time is . . . ‘exploited to proselytize” and “advance . . . one . . . faith
or belief.’” Town of Greece, 572 U.S. at 583 (quoting Marsh v. Chambers, 463 U.S. 783, 794–95
(1983)). Since the Secretary took office, the Secretary’s religious messages have escalated in
proselytizing language, particularly on Christian holidays, without any acknowledgment—let alone
celebration—of holidays from other religions. She abuses her authority to email all 100,000 of her
subordinates to proselytize and expressly promote and favor Christianity. Such practices are outside
our nation’s “tradition” and violate the Establishment Clause. Id.
On behalf of USDA, the Secretary has conveyed to Plaintiffs that USDA’s mission has become
a Christian one. By comparing federal employees to “the very first disciples to encounter our risen
Lord in the Upper Room almost two thousand years ago” and calling on those employees to carry out
“the mission each of us has been called for” with “Paschal joy,” the Secretary is portraying the
agency’s work as a mission to serve her particular Christian views. Plaintiffs understand that the
Christian “we” and “us” who are addressed in her sermons are imbuing USDA with a religious—
rather than a secular—mission.37 This “fusion of governmental and religious functions” stemming
from government elevating a particular religion or sect is what the Founders fought to stamp out
through the Establishment Clause. See Schempp, 374 U.S. at 222.
Further, the Secretary’s use of “we,” “us,” and “our,” along with her failure to recognize other
religious holidays or acknowledge that other employees may have different beliefs, expresses to
Plaintiffs that the agency expects that its employees share in the Secretary’s beliefs and that those
who do not hold the same beliefs “are outsiders, not full members of the political community.
