What role was George W. Bush performing when he created the White House Office of Faith-Based and Community Initiatives?

A denial of a writ of certiorari:

A. indicates that the Supreme Court agrees with a lower court's opinion. B. means that the decision of the lower court remains the law within that court's jurisdiction. C. occurs when lower courts are unable to send the record of the case in question to the Supreme Court. D. is a decision on the merits of a case. E. is purely based on the discretion of federal appellate courts.

Why has the creative use of complex rules expanded in recent years?

What will be an ideal response?