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Emmanuel Liberus John v. Board of Commissioners of Lake County, Indiana, et al.

Paid petition · United States Court of Appeals for the Seventh Circuit, No. 25-1452 · judgment November 13, 2025


Certiorari denied · June 29, 2026
Pre-decision estimate: 0% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Questions presented

This case presents the following questions of exceptional national importance:

  1. Whether a county government’s enforcement of non-tax assessments through tax foreclosure procedures against a house of worship used for taxexempt religious activity constitutes unconstitutional government entanglement in religious affairs in violation of the First Amendment?

  2. Whether a religious leader has standing under 42 U.S.C. § 1983 to challenge government action that, under color of state law, deprives him of personal liberty and protected property-related interests secured by the First and Fourteenth Amendments, where the deprivation arises from the seizure and sale of a house of worship used solely for religious ministry?

  3. Whether lower courts err by declining to apply strict scrutiny when government action directly burdens religious exercise through the seizure and sale of a house of worship?

  4. Whether a local government may circumvent constitutionally protected religious tax exemptions by recharacterizing mandatory charges as “fees” and enforcing them through tax foreclosure mechanisms against houses of worship?

Counsel of record

For petitioner
Emmanuel Liberus John

For respondent
James Allen Barta
Office of the Indiana Attorney General

Case

Conference history
Distributed for 1 conference

Proceedings

  1. Jun 29 2026
    Petition DENIED.
  2. Jun 09 2026
    DISTRIBUTED for Conference of 6/25/2026.
  3. Jun 05 2026
    Waiver of right of respondent Board of Commissioners of Lake County to respond filed.
  4. May 26 2026
    Waiver of right of respondent Honorable Magistrate Judge Lisa Berdine to respond filed.
  5. Feb 03 2026
    Petition for a writ of certiorari filed. (Response due June 8, 2026)