[EL] Check out F.D.A. Surveillance of Scientists Spread to Outside Critic...

JBoppjr at aol.com JBoppjr at aol.com
Tue Jul 17 05:37:16 PDT 2012


The point we made is that they discounted the evidence of harassment by  
applying the wrong legal standards.  First, in Doe v Reed by saying that  only 
criminal harassment which the police ignores and by demanding evidence of  
harassment of signers of R-71 that were not public.  Second, in Prop 8 the  
court also used the criminal harassment standard.  We proved over 250  
specific incidents of harassment of pro-marriage supporters and the courts  
errored in disregarding much of it by erroneous and restrictive legal  standards. 
 Jim Bopp
 
 
In a message dated 7/16/2012 12:11:09 P.M. Eastern Daylight Time,  
rhasen at law.uci.edu writes:



I absolutely agree.
But the two cases---Prop. 8 and Doe  v. Reed---provide the strongest cases 
we've seen in recent years of  claims of harassment---and they were tested 
in court with considerable  resources marshaled on each side.
So they are important pieces of  data.
Rick

On 7/16/2012 8:48 AM, Allen Dickerson  wrote:



I  presume most of us have a high opinion of federal judges. But I think 
people  are talking past each other. 
A  judge made particular factual findings in a particular case. Well and 
good.  That doesn’t prove anything universal, or we wouldn’t have a relevance 
 requirement in the Rules of Evidence. 
The  quantum of evidence required to obtain a Socialist-Workers-style  
exception, and the quantum required to make a policy argument, are  different. I 
took Jim’s point to be broadly about the danger of chill  emanating from 
disclosure of particular political activity. The fact this  record didn’t 
convince a judge doesn’t mean that it didn’t, or shouldn’t,  convince 
legislators. Or, for that matter, academics and practitioners.   
I  haven’t examined the record in sufficient detail to know how this comes 
out.  But you can’t foreclose the broader policy discussion based solely on 
this  ruling. 
 
 
From:  _law-election-bounces at department-lists.uci.edu_ 
(mailto:law-election-bounces at department-lists.uci.edu)   
[_mailto:law-election-bounces at department-lists.uci.edu_ (mailto:law-election-bounces at department-lists.uci.edu) ]  
On Behalf Of Rick Hasen
Sent: Monday, July 16, 2012 11:39  AM
To: Joe La Rue
Cc: _JBoppjr at aol.com_ (mailto:JBoppjr at aol.com) ; _law-election at uci.edu_ 
(mailto:law-election at uci.edu) 
Subject:  Re: [EL] Check out F.D.A. Surveillance of Scientists Spread to 
Outside  Critic...

My experience in the trial  courts is that almost all judges do an 
excellent job when it comes to  factfinding.  Is that not your experience?  If you 
disagree with  the judge's factual findings in the case, you can appeal, and 
my sense is  that appellate courts generally do a very good job reviewing 
factual  findings under a substantial evidence rule.

When it comes to the  value judgments Supreme Court Justices make in 
constitutional cases, that is  a different matter---they mask their value 
judgments behind factual  findings.  And I've been just as critical of how liberal 
Justices do it  (_see my criticism_ 
(http://papers.ssrn.com/sol3/papers.cfm?abstract_id=241458)  of Justice Souter's opinion in  Shrink Missouri on the 
quantum of evidence sufficient to support  contribution laws) as conservative 
Justices.

Do you have a particular  complaint about the factual findings of the 
judges in the Prop 8 and Doe v.  Reed cases, other than the typical complaints of 
a lawyer who has lost a  case before a judge?


On 7/16/2012 8:33 AM, Joe La Rue  wrote:

Rick,  you of all people should recognize that just because a court "finds" 
 something, that doesn't make it so. I've read your criticism of various  
statements of, say, CJ Roberts, in which you question both his motives and  
whether he acted in a principled manner. 


 
Joe
___________________
Joseph  E. La Rue
 
cell: 480.272.2715 
email:  _joseph.e.larue at gmail.com_ (mailto:joseph.e.larue at gmail.com) 
 


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On Mon, Jul 16, 2012 at 8:31 AM, Rick Hasen <_rhasen at law.uci.edu_ 
(mailto:rhasen at law.uci.edu) >  wrote: 
 
Enough already of the  unsupported claims of massive harassment.  These 
were tested in  Court.  Here's the relevant portion of the trial court's 
decision  granting summary judgment against Jim's clients on this issue.    I've 
put in bold some of the more relevant findings. 
ProtectMarriage.com v. Bowen
830 F.Supp.2d  914
E.D.Cal.,2011.
November 04, 2011 (Approx. 34  pages)


Moreover, while  Plaintiffs are quite correct that under _Buckley_ 
(http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&rs=WLW12.04&tc=-1&r
p=/find/default.wl&findtype=Y&ordoc=2026501938&serialnum=1976142308&vr=2.0&f
n=_top&sv=Split&tf=-1&pbc=154255A8&utid=1)  evidence of  harassment “from 
either Government officials or private parties” could  suffice to establish 
the requisite proof of reprisals, the facts of  subsequent cases evidence not 
only the existence of some governmental  hostility, but quite pervasive 
governmental hostility at that. _Buckley, 424 U.S. at 74, 96  S.Ct. 612_ 
(http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&db=708&rs=WLW12.0
4&tc=-1&rp=/find/default.wl&findtype=Y&ordoc=2026501938&serialnum=1976142308
&vr=2.0&fn=_top&sv=Split&tf=-1&pbc=154255A8&utid=1)  (emphasis added); see 
also _McArthur, 716 F.Supp. at  594_ 
(http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&db=345&rs=WLW12.04&tc=-1&rp=/find/default.wl&findt
ype=Y&ordoc=2026501938&serialnum=1989115620&vr=2.0&fn=_top&sv=Split&tf=-1&re
ferencepositiontype=S&pbc=154255A8&referenceposition=594&utid=1)  (“
[H]arassment, reprisals or threats from private persons are  sufficient to allow 
[the] court to enforce the plaintiff's first amendment  rights by cloaking the 
contributors and recipients' names in  secrecy.”). 
 
Indeed, the _Brown_ 
(http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&rs=WLW12.04&tc=-1&rp=/find/default.wl&findtype=Y&ordoc=2026501938&
serialnum=1982152768&vr=2.0&fn=_top&sv=Split&tf=-1&pbc=154255A8&utid=1)  
Court was confronted  with countless acts of government harassment and 
retribution against  members of the SWP, which are detailed above. Furthermore, in 
_Hall–Tyner,_ 
(http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&rs=WLW12.04&tc=-1&rp=/find/default.wl&findtype=Y&ordoc=2026501938&serialn
um=1982123204&vr=2.0&fn=_top&sv=Split&tf=-1&pbc=154255A8&utid=1)  the 
Second  Circuit stated, “[t]he evidence relied on by the district judge included  
the extensive body of state and federal legislation subjecting Communist  
Party members to civil disability and criminal liability, reports and  
affidavits documenting the history of governmental surveillance and  harassment of 
Communist Party members, as well as affidavits indicating  the desire of 
contributors to the Committee to remain anonymous.” _678 F.2d at  419_ 
(http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&db=350&rs=WLW12.04
&tc=-1&rp=/find/default.wl&findtype=Y&ordoc=2026501938&serialnum=1982123204&
vr=2.0&fn=_top&sv=Split&tf=-1&referencepositiontype=S&pbc=154255A8&reference
position=419&utid=1) .
 
Plaintiffs do not, indeed cannot, allege that the  movement to recognize 
marriage in California as existing only between a  man and a woman is 
vulnerable to the same threats as were socialist and  communist groups, or, for that 
matter, the NAACP. Proposition 8 supporters  *932 promoted a  concept 
entirely devoid of governmental hostility. Plaintiffs' belief in  the traditional 
concept of marriage, to disagreement, have not  historically invited 
animosity. The Court is at a loss to find any  principled analogy between two such 
greatly diverging sets of  circumstances.
 
Finally, Plaintiffs' exemption argument appears to  be premised, in large 
part, on the concept that individuals should be free  from even legal 
consequences of their speech. That is simply not the  nature of their right.
 
Just as contributors to Proposition 8 are free  to speak in favor of the 
initiative, so are opponents free to express  their disagreement through 
proper legal means.
 
**17 While the Court is cognizant of the deplorable  nature of many of acts 
alleged by Plaintiffs, the Court also must  reiterate that the legality or 
morality of any specific acts is not before  it. Thus, as much as the Court 
strongly condemns the behavior of those who  resort to violence, and/or 
other illegal behavior, the Court need not,  indeed cannot, evaluate the proper 
legal consequences of those actions  today.
 
By the same token, nothing in the Court's decision  immunizes or excuses 
those who have engaged in illegal acts from the  consequences of their 
conduct. Those responsible for threatening the lives  of supporters of Proposition 
8 are subject to criminal liability. See  Troupis Decl., Exh. C (noting that 
the Fresno chief of police stated the  department was “close to making an 
arrest” in the case of the death  threats delivered to the mayor and a local 
pastor.) Those choosing to  vandalize the property of individuals or the 
public are likewise liable.  Those mailing white powder to organizations are 
subject to federal  prosecution. In each case, there are appropriate legal 
channels through  which to rectify and deter the reoccurrence of such 
reprehensible  behavior.
 
As much as those channels are available today, it is  unlikely that groups 
previously successful in seeking exemptions were  privy to the same 
opportunities. Again, Plaintiffs have shown no societal  or governmental hostility 
to their cause. Contrary to groups such as the  SWP, Plaintiffs can seek 
adequate relief from law enforcement and the  legal system. Such was not the 
case for those thought to be supporting  the SWP or communist groups, those 
subject to actual criminal liability  based on their beliefs and their 
associations.

_ProtectMarriage.com, 599  F.Supp.2d at 1217–1218_ 
(http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&db=4637&rs=WLW12.04&tc=-1&rp=/find/
default.wl&findtype=Y&ordoc=2026501938&serialnum=2018198951&vr=2.0&fn=_top&s
v=Split&tf=-1&referencepositiontype=S&pbc=154255A8&referenceposition=1217&ut
id=1) . 
 
Despite Plaintiffs attempt  now to put forth additional evidence of 
threats, harassment and reprisals,  the Court's findings remain the same. More 
specifically, despite the  additional declarations and exhibits that are now 
before the Court,  Plaintiffs still run into problems of proportionality and  
magnitude.
 
First, while  Plaintiffs characterize their evidence as voluminous and 
comprised of  “virtually countless reports of threats, harassment, and reprisals,
”  Plaintiffs' Motion, 4:14–15, they have pointed to relatively few 
incidents  allegedly suffered by persons located across the entire country who had 
 somehow manifested their support for traditional marriage. In  addition, 
while the evidence before this Court indicates that at least 7  million 
voters showed up at the California polls alone to support the  passage of 
Proposition 8, this number, though large, still deceptively  underestimates the 
number of supporters for Plaintiffs' cause. Indeed,  this figure does not 
capture all individuals supporting Proposition 8 on a  national scale, nor does 
it capture those individuals who may have no  connection to California's 
campaign, but *933 have  supported the same cause in other regions. Plaintiffs' 
evidence of  harassment, nonetheless extends much farther than California's 
borders and  includes incidents that arose in other states and that were 
directed at  the much broader social issue of gay marriage in  general.
 
**18 Accordingly, even  assuming Plaintiffs could, under some set of 
circumstances, prove an  entitlement to an exemption, they would need evidence of 
thousands of acts  of reprisals, threats or harassment, spanning much more 
than the short  period of time covering California's ballot-initiative 
process to prove  contributors to such a massive group are entitled to anonymity 
of the type  justified years ago for the individuals in _Brown_ 
(http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&rs=WLW12.04&tc=-1&rp=/fi
nd/default.wl&findtype=Y&ordoc=2026501938&serialnum=1982152768&vr=2.0&fn=_to
p&sv=Split&tf=-1&pbc=154255A8&utid=1)  and _NAACP._ 
(http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&rs=WLW12.04&tc=-1&rp=/find/default
.wl&findtype=Y&ordoc=2026501938&serialnum=1958121466&vr=2.0&fn=_top&sv=Split
&tf=-1&pbc=154255A8&utid=1)  The declarations of  58 individuals signed in 
the months just following the election, along  with Plaintiffs' anecdotal 
evidence from the same time period as  documented in Exhibits 3 and 4, is 
simply insufficient on the facts of  this case to convince this Court an 
ordinary contributor to Proposition 8  would have faced any backlash worthy of 
quashing the names of all  contributors._FN9_ 
(http://web2.westlaw.com/result/documenttext.aspx?ss=CNT&mt=LawSchoolPractitioner&utid=1&n=1&cnt=DOC&rlt=CLID_F
QRLT799262410167&scxt=WL&service=Find&rp=/Find/default.wl&vr=2.0&cxt=DC&rlti
=1&sv=Split&fn=_top&cite=2011+WL+5507204&rs=WLW12.04#B00992026501938)  See, 
 e.g., _Doe v. Reed, 130 S.Ct. at  2829_ 
(http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&db=708&rs=WLW12.04&tc=-1&rp=/find/default.wl&
findtype=Y&ordoc=2026501938&serialnum=2022366335&vr=2.0&fn=_top&sv=Split&tf=
-1&referencepositiontype=S&pbc=154255A8&referenceposition=2829&utid=1)  
(taking the position exemptions may be permitted “in the rare  circumstance in 
which disclosure poses a reasonable probability of serious  and widespread 
harassment”) (Sotomayor, J., concurring-joined by Stevens  and Ginsburg).

_FN9._ 
(http://web2.westlaw.com/result/documenttext.aspx?ss=CNT&mt=LawSchoolPractitioner&utid=1&n=1&cnt=DOC&rlt=CLID_FQRLT799262410167&scxt=WL&service=F
ind&rp=/Find/default.wl&vr=2.0&cxt=DC&rlti=1&sv=Split&fn=_top&cite=2011+WL+5
507204&rs=WLW12.04#F00992026501938)  Plaintiffs even  acknowledge in their 
papers that only a minority of individuals on the  other side of the 
campaign resorted to the complained of tactics that  are cause for concern. 
Plaintiffs' Motion, 1:10–12 (“Some groups and  individuals, certainly a minority, 
have resorted to advancing  their cause, not by debating the merits of the 
issue, but by  discouraging participation in the democratic process through 
acts  calculated to intimidate.”) (emphasis  added).



_[2]_ (http://web2.westlaw.com/result/do
cumenttext.aspx?ss=CNT&mt=LawSchoolPractitioner&utid=1&n=1&cnt=DOC&rlt=CLID_FQRLT799262410167&scxt=WL&service=Fi
nd&rp=/Find/default.wl&vr=2.0&cxt=DC&rlti=1&sv=Split&fn=_top&cite=2011+WL+55
07204&rs=WLW12.04#F22026501938)   
(http://web2.westlaw.com/KCNotes/default.wl?mt=LawSchoolPractitioner&locatestring=HD(002),CL(H,O),DC(A,L,O,D,G),DT(E,D
,C,M)&utid=1&n=1&rlt=CLID_FQRLT799262410167&service=Find&pbc=154255A8&rp=/KC
Notes/default.wl&vr=2.0&rlti=1&sv=Split&fn=_top&serialnum=2026501938&rs=WLW1
2.04) Moreover,  as the Court previously observed, notably absent from the 
record here are  any instances in which Plaintiffs have suffered any sort of 
governmental  backlash. While, based on the language derived from 
_Buckley,_ 
(http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&rs=WLW12.04&tc=-1&rp=/find/default.wl&findtype=Y&ordoc=2026501938&serialnum=197614230
8&vr=2.0&fn=_top&sv=Split&tf=-1&pbc=154255A8&utid=1)  governmental  
harassment is not necessarily a required showing, it is a factor for this  Court to 
consider. Indeed, some governmental animosity has been present in  all 
other cases in which an exemption has been permitted. Perhaps  recognizing this, 
Plaintiffs argue “[t]here can be no question that in  many areas in 
California, and around the country, views against same-sex  marriage ... are 
extremely unpopular” and “[e]ven our courts of law have  characterized those who 
fight against such laws as advocates of hate and  bigotry who act ‘without 
reason.’ ” Plaintiffs' Motion, 12:15–18.  Nonetheless, any attempt by 
Plaintiffs to show governmental animosity here  is half-hearted at best. As 
described above, parties entitled to an  as-applied exemption (namely the NAACP 
and the SWP) in the past had  suffered from systematic governmental 
discrimination, persecution and  abuse. Those plaintiffs were not only directly 
victimized by the  government, they consequently lacked adequate recourse to 
pursue means  short of non-disclosure to protect against private violence. In 
this case,  Plaintiffs cannot assert that there is some sort of governmental 
hostility  to their cause, nor can they in good conscience argue that law 
enforcement  was or would be non-responsive to any illegal acts directed at 
Plaintiffs  contributors._FN10_ 
(http://web2.westlaw.com/result/documenttext.aspx?ss=CNT&mt=LawSchoolPractitioner&utid=1&n=1&cnt=DOC&rlt=CLID_FQRLT7992624101
67&scxt=WL&service=Find&rp=/Find/default.wl&vr=2.0&cxt=DC&rlti=1&sv=Split&fn
=_top&cite=2011+WL+5507204&rs=WLW12.04#B010102026501938) 

_FN10._ 
(http://web2.westlaw.com/result/documenttext.aspx?ss=CNT&mt=LawSchoolPractitioner&utid=1&n=1&cnt=DOC&rlt=CLID_FQRLT799262410167&scxt=WL&service=
Find&rp=/Find/default.wl&vr=2.0&cxt=DC&rlti=1&sv=Split&fn=_top&cite=2011+WL+
5507204&rs=WLW12.04#F010102026501938)  Plaintiffs do  argue that their 
contributors were victimized despite existing laws  criminalizing the underlying 
conduct. Essentially, Plaintiffs argue  those laws did nothing to deter 
criminal behavior. However, Plaintiffs  have not alleged that any law 
enforcement response was insufficient,  that law enforcement has somehow turned a 
blind eye to any criminal  conduct, or that criminal sanctions will not be 
imposed if appropriate.  That is a critical distinction between the instant case 
and past cases  such as _Brown_ 
(http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&rs=WLW12.04&tc=-1&rp=/find/default.wl&findtype=Y&ordoc
=2026501938&serialnum=1982152768&vr=2.0&fn=_top&sv=Split&tf=-1&pbc=154255A8&
utid=1)  and  NAACP.



*934 To the contrary,  Plaintiffs' own evidence indicates law enforcement 
was not only  responsive, but diligent in undertaking investigations into 
some of the  more heinous acts alleged here. This factor is critical in light 
of the  comments made by several concurring Justices in Doe v. Reed,  
indicating the ability of law enforcement to deal with threats, harassment  and 
reprisals would weigh heavily against a need for an exemption. See,  e.g., 
_Doe, 130 S.Ct. at 2829_ 
(http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&db=708&rs=WLW12.04&tc=-1&rp=/find/default.wl&findtype=Y&ordoc=2026
501938&serialnum=2022366335&vr=2.0&fn=_top&sv=Split&tf=-1&referencepositiont
ype=S&pbc=154255A8&referenceposition=2829&utid=1)   (exemption may be 
warranted “in the rare circumstance in which disclosure  poses a reasonable 
probability of serious and widespread harassment that  the State is unwilling or 
unable to control”) (Sotomayor, J., concurring,  joined by Stevens and 
Ginsburg); _id. at 2831_ 
(http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&rs=WLW12.04&tc=-1&rp=/find/default.wl&findtype=Y&ordoc=2026501938&s
erialnum=2022366335&vr=2.0&fn=_top&sv=Split&tf=-1&pbc=154255A8&utid=1)  (“
>From time to  time throughout history, persecuted groups have been able to 
criticize  oppressive practices and laws either anonymously or not at all ... 
In my  view, this is unlikely to occur in cases involving the PRA. Any 
burden on  speech that petitioners posit is speculative as well as indirect. For 
an  as-applied challenge to a law such as the PRA to succeed, there would 
have  to be a significant threat of harassment directed at those who sign the  
petition that cannot be mitigated by law enforcement measures.”) (Stevens  
and Breyer, JJ., concurring); _id. at 2837_ 
(http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&rs=WLW12.04&tc=-1&rp=/find/default.wl&findt
ype=Y&ordoc=2026501938&serialnum=2022366335&vr=2.0&fn=_top&sv=Split&tf=-1&pb
c=154255A8&utid=1)  (“There are  laws against threats and intimidation; and 
harsh criticism, short of  unlawful action, is a price our people have 
traditionally been willing to  pay for self-governance.”) (Scalia, J., 
concurring).
 
**19 In addition, the vast  majority of the incidents cited by Plaintiffs 
are arguably, as  characterized by Defendants, typical of any controversial 
campaign. For  example, picketing, protesting, boycotting, distributing 
flyers,  destroying yard signs and voicing dissent do not necessarily rise to the 
 level of “harassment” or “reprisals,” especially in comparison to acts  
directed at groups in the past. Moreover, a good portion of these actions  
are themselves forms of speech protected by the United States  Constitution. 
Indeed this Court previously held  that:
 
[T]he Court simply cannot ignore the fact that numerous  of the acts about 
which Plaintiffs complain are mechanisms relied upon,  both historically and 
lawfully, to voice dissent. The decision and ability  to patronize a 
particular establishment or business is an inherent right  of the American people, 
and the public has historically remained free to  choose where to, or not 
to, allocate its economic resources. As such,  individuals have repeatedly 
resorted to boycotts as a form of civil  protest intended to convey a powerful 
message without resort to  non-violent means. The Supreme Court has 
acknowledged these rights on many  an occasion:
 
In _Thornhill v. Alabama, 310 U.S.  88, 60 S.Ct. 736, 84 L.Ed. 1093 (1940)_ 
(http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&db=708&rs=
WLW12.04&tc=-1&rp=/find/default.wl&findtype=Y&ordoc=2026501938&serialnum=194
0125855&vr=2.0&fn=_top&sv=Split&tf=-1&pbc=154255A8&utid=1) , the Court held 
that peaceful  picketing was entitled to constitutional protection, even 
though, in that  case, the purpose of the picketing “was concededly to advise 
customers and  prospective customers of the relationship existing between 
the employer  and its employees and thereby to induce such customers not to 
patronize  the employer.” _Id. at 99, 60 S.Ct. 736._ 
(http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&db=708&rs=WLW12.04&tc=-1&rp=/find/de
fault.wl&findtype=Y&ordoc=2026501938&serialnum=1940125855&vr=2.0&fn=_top&sv=
Split&tf=-1&pbc=154255A8&utid=1)   Cf. _Chauffeurs v. Newell, 356 U.S.  
341, 78 S.Ct. 779, 2 L.Ed.2d 809 [ (1958) ]_ 
(http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&db=708&rs=WLW12.04&tc=-1&rp=/find/default.wl&
findtype=Y&ordoc=2026501938&serialnum=1958207756&vr=2.0&fn=_top&sv=Split&tf=
-1&pbc=154255A8&utid=1) . In _Edwards v. South Carolina, 372  U.S. 229, 83 
S.Ct. 680, 9 L.Ed.2d 697 [ (1963) ],_ 
(http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&db=708&rs=WLW12.04&tc=-1&rp=/find/default.wl&find
type=Y&ordoc=2026501938&serialnum=1963101511&vr=2.0&fn=_top&sv=Split&tf=-1&p
bc=154255A8&utid=1)  we held that a  peaceful march and demonstration was 
protected by the rights of free  speech, free assembly, and freedom to 
petition for a redress of  grievances.
 
_NAACP v. Claiborne Hardware  Co., 458 U.S. 886, 909, 102 S.Ct. 3409, 73 
L.Ed.2d 1215 (1982)_ 
(http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&db=708&rs=WLW12.04&tc=-1&rp=/find/default.wl&findtype=Y&ordoc=202650
1938&serialnum=1982130119&vr=2.0&fn=_top&sv=Split&tf=-1&pbc=154255A8&utid=1)
 .  Notably, “[s]peech does not lose its protected character ... simply  
because it may embarrass others or *935 coerce them into action.” _Id. at 910, 
102 S.Ct.  3409._ 
(http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&db=708&rs=WLW12.04&tc=-1&rp=/find/default.wl&findtype=Y&ordoc=202650
1938&serialnum=1982130119&vr=2.0&fn=_top&sv=Split&tf=-1&pbc=154255A8&utid=1)
 

_ProtectMarriage.com, 599  F.Supp.2d at 1218_ 
(http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&db=4637&rs=WLW12.04&tc=-1&rp=/find/defau
lt.wl&findtype=Y&ordoc=2026501938&serialnum=2018198951&vr=2.0&fn=_top&sv=Spl
it&tf=-1&referencepositiontype=S&pbc=154255A8&referenceposition=1218&utid=1)
 . 
 
As to Plaintiffs'  allegations of “economic reprisals” in the form of 
voluntary or forced  resignations, as opposed to cases in which a relatively 
high percentage of  small groups seeking an exemption were actually fired from 
their places of  employment, Plaintiffs here have documented no 
terminations. See,  e.g., SWP. Rather, Plaintiffs point only to instances of several  
individuals who allegedly resigned amidst controversy over their  
contributions to or support of Proposition 8, but even those individuals  had their own 
supporters and nonetheless made the affirmative and  individual decision to 
resign.
 
More troubling  here are the few instances of violence or criminal activity 
that do not  fall within the realm of protected speech. The Court does not 
take lightly  the use of the mail to terrorize people with counterfeit 
biological agents  or to threaten the lives of individuals taking a stand for 
their  particular beliefs, nor does the Court condone the use of force or the  
escalation of peaceful protests to violence to make one's position known.  
_FN11_ 
(http://web2.westlaw.com/result/documenttext.aspx?ss=CNT&mt=LawSchoolPractitioner&utid=1&n=1&cnt=DOC&rlt=CLID_FQRLT799262410167&scxt=WL&service=Fin
d&rp=/Find/default.wl&vr=2.0&cxt=DC&rlti=1&sv=Split&fn=_top&cite=2011+WL+550
7204&rs=WLW12.04#B011112026501938)   However, Plaintiffs have produced 
insufficient evidence that the more  incendiary events on which they rely were 
connected to Proposition 8 or to  gay marriage at all. Rather, a number of 
these incidents were directed  at the Mormon church, which, though a backer of 
California's proposition,  may also have been a target for any of a number 
of other reasons. In  addition, as stated above, law enforcement appears to 
have responded  swiftly and adequately in each of the instances Plaintiffs 
allege,  rendering this case distinguishable from all cases in the past where 
 exemptions have been granted. And, perhaps more importantly, the Supreme  
Court has never indicated that even a few acts of violence, when directed  
at a target as massive as the groups supporting Plaintiffs, would suffice  to 
shield those groups from the scrutinizing light of the political  process.

_FN11._ 
(http://web2.westlaw.com/result/documenttext.aspx?ss=CNT&mt=LawSchoolPractitioner&utid=1&n=1&cnt=DOC&rlt=CLID_FQRLT799262410167&scxt=WL&service=
Find&rp=/Find/default.wl&vr=2.0&cxt=DC&rlti=1&sv=Split&fn=_top&cite=2011+WL+
5507204&rs=WLW12.04#F011112026501938)  To the contrary, those  resorting to 
these sorts of tactics do more to undermine their cause  than to further 
any civilized and productive  discourse.



**20 _[3]_ 
(http://web2.westlaw.com/result/documenttext.aspx?ss=CNT&mt=LawSchoolPractitioner&utid=1&n=1&cnt=DOC&rlt=CLID_FQRLT799262410167&scxt=WL&servi
ce=Find&rp=/Find/default.wl&vr=2.0&cxt=DC&rlti=1&sv=Split&fn=_top&cite=2011+
WL+5507204&rs=WLW12.04#F32026501938)   
(http://web2.westlaw.com/KCNotes/default.wl?mt=LawSchoolPractitioner&locatestring=HD(003),CL(H,O),DC(A,L,O,D,G),D
T(E,D,C,M)&utid=1&n=1&rlt=CLID_FQRLT799262410167&service=Find&pbc=154255A8&r
p=/KCNotes/default.wl&vr=2.0&rlti=1&sv=Split&fn=_top&serialnum=2026501938&rs
=WLW12.04) This Court  also observes that, even assuming there is no “strict
” requirement that  Plaintiffs prove a chilling effect on anticipated 
speech, any such effect  is notably absent here. Plaintiffs appear to have had no 
problem  collecting contributions and those contributions continued to 
increase  even during the most heated portions of the Proposition 8 campaign.  
Cassady Decl., ¶¶ 24–25. A few John Doe declarants mentioned they may be  
wary of donating in the future, but those relatively few individual  statements 
are unpersuasive to the Court given Plaintiffs' enormous  multi-state 
backing. Plaintiffs have therefore simply not shown any real  chill, nor have 
they shown, as feared by _Buckley,_ 
(http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&rs=WLW12.04&tc=-1&rp=/find/default.wl&findtype=Y&ordoc
=2026501938&serialnum=1976142308&vr=2.0&fn=_top&sv=Split&tf=-1&pbc=154255A8&
utid=1)  that Plaintiffs'  movement was at all susceptible to a fall-off in 
contributions or that,  absent an exemption, the movement might not 
survive. _Buckley, 424 U.S. at 71, 96  S.Ct. 612_ 
(http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&db=708&rs=WLW12.04&tc=-1&rp=/find/default.wl
&findtype=Y&ordoc=2026501938&serialnum=1976142308&vr=2.0&fn=_top&sv=Split&tf
=-1&pbc=154255A8&utid=1) .
 
Finally, this case is unique  because Plaintiffs' contributors' names were 
actually disclosed years ago  and yet Plaintiffs have produced almost no 
evidence of any ramifications  suffered in the almost three years 
post-disclosure. While the evidence  contained in Plaintiffs' Exhibits 3 and 4 contain a 
few instances of  vandalism that have occurred more recently than during the 
height of the  Proposition 8 campaign and its aftermath, none of those 
articles draw any  real connection between the incidents alleged and the 
victims' support of  traditional marriage. See, e.g., Plaintiffs' Exhs. 4–89, 4–
90,  4–91, 4–93. Even Plaintiffs'*936 counsel at oral argument in 2011 
admitted he  was only aware of one instance of harassment that had occurred  
post-election. Accordingly, from a practical perspective, it makes no  sense to 
buy in to the argument that disclosure may result in  repercussions when 
there is simply no real evidence in the record that  such repercussions actually 
did occur in the past three years.  Plaintiffs' evidence is, quite simply, 
stale. See _Doe v. Reed, 823 F.Supp.2d  1195, 1205 n. 3, 2011 WL 4943952 at 
*10 n. 3  (W.D.Wash.2011)_ 
(http://web2.westlaw.com/find/default.wl?mt=LawSchoolPractitioner&db=0000999&rs=WLW12.04&tc=-1&rp=/find/default.wl&findtype=Y&
ordoc=2026501938&serialnum=2026358710&vr=2.0&fn=_top&sv=Split&tf=-1&pbc=1542
55A8&utid=1) .
 
Accordingly, while  Plaintiffs can point to a relatively few unsavory acts 
committed by  extremists or criminals, these acts are so small in number, 
and in some  instances their connection to Plaintiffs' supporters so 
attenuated, that  they do not show a reasonable probability Plaintiffs' contributors 
will  suffer the same fate. Given the grand scale of Plaintiffs' campaign 
and  the massive (and national) support they garnered for their cause,  
Plaintiffs' limited evidence is simply insufficient to support a finding  that 
disclosure of contributors' names will lead to threats, harassment or  
reprisals._FN12_ 
(http://web2.westlaw.com/result/documenttext.aspx?ss=CNT&mt=LawSchoolPractitioner&utid=1&n=1&cnt=DOC&rlt=CLID_FQRLT799262410167&scxt=WL&service=
Find&rp=/Find/default.wl&vr=2.0&cxt=DC&rlti=1&sv=Split&fn=_top&cite=2011+WL+
5507204&rs=WLW12.04#B012122026501938)   Plaintiffs' Motion for Summary 
Judgment as to this claim is DENIED and  Defendants' Motion for Summary Judgment 
is GRANTED.

_FN12._ 
(http://web2.westlaw.com/result/documenttext.aspx?ss=CNT&mt=LawSchoolPractitioner&utid=1&n=1&cnt=DOC&rlt=CLID_FQRLT799262410167&scxt=WL&service=
Find&rp=/Find/default.wl&vr=2.0&cxt=DC&rlti=1&sv=Split&fn=_top&cite=2011+WL+
5507204&rs=WLW12.04#F012122026501938)  It bears mention that if  the Court 
were to find an exemption warranted here, it is likely a similar  exemption 
would prove warranted in any election concerning a controversial  ballot 
measure. As a result, those issues in which the public shows the  greatest 
interest would be subject to the least transparency.   
 
 
 
On 7/16/2012 6:34 AM, _JBoppjr at aol.com_ (mailto:JBoppjr at aol.com)  wrote:

 
Of  course not, this involved scientific critics of the FDA.  The  point is 
that government officials will go after critics however they  find out 
about them and using the methods they have  available.
 

 
Regarding campaign  contribution, in Doe v. Reed and the Prop 8 case, we 
document over 250  incidents of harassment of supporters of Prop 8, many of 
which were only  contributors who were map quested on the Internet. A campaign 
of  harassment that occurred against them is unusual.  Public officials  
that retaliate against critics are usually very careful to make sure  that no 
one knows they are doing it.  The FDA did not send out a  press release on 
their actions against their scientific critics  either.  Jim Bopp
 

 
 
In a  message dated 7/15/2012 11:03:48 P.M. Eastern Daylight Time, 
_rhasen at law.uci.edu_ (mailto:rhasen at law.uci.edu)   writes:

I didn't  see any evidence in this article that anyone was being harassed 
for  making campaign contributions, and as we've discussed on this list  ad 
nauseum (and as spelled out in more detail _here_ 
(http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1948313) ), my view of the  evidence from two 
recent cases involving allegations of harassment of  campaign contributors is 
that there is no systemic evidence that  harassment of campaign contributors is 
a problem.  Rare instances  of genuine threats of harassment may be dealt 
with through an "as  applied" exemption to disclosure  laws.



On 7/15/12  8:06 AM, Joe La Rue wrote:

 
It is  interesting that Van Hollen is upset about THIS disclosure. Of  
course, he was number 14 on the list. I guess disclosure is only  good when it's 
somebody else's speech that is being  disclosed.

On Jul 15, 2012, at 6:28 AM, _JBoppjr at aol.com_ (mailto:JBoppjr at aol.com)   
wrote:

 
 
_Click here: F.D.A.  Surveillance of Scientists Spread to Outside Critics - 
 NYTimes.com_ 
(http://www.nytimes.com/2012/07/15/us/fda-surveillance-of-scientists-spread-to-outside-critics.html?_r=2&pagewanted=all)  
 

 
Government going after  critics, exactly the type of activity that can 
chill political  speech and that makes disclosure a burden.  Jim  Bopp



 
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-- 
Rick  Hasen
Chancellor's Professor of Law and Political Science
UC  Irvine School of Law
401 E. Peltason Dr., Suite 1000
Irvine, CA  92697-8000
_949.824.3072_ (tel:949.824.3072)  - office
_949.824.0495_ (tel:949.824.0495)  - fax
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_http://electionlawblog.org_ (http://electionlawblog.org/) 
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-- 
Rick Hasen
Chancellor's Professor of Law and Political Science
UC Irvine School of Law
401 E. Peltason Dr., Suite 1000
Irvine, CA 92697-8000
_949.824.3072_ (tel:949.824.3072)  - office
_949.824.0495_ (tel:949.824.0495)  - fax
_rhasen at law.uci.edu_ (mailto:rhasen at law.uci.edu) 
_http://law.uci.edu/faculty/page1_r_hasen.html_ 
(http://law.uci.edu/faculty/page1_r_hasen.html) 
_http://electionlawblog.org_ (http://electionlawblog.org/) 
Pre-order The Voting Wars: _http://amzn.to/y22ZTv_ (http://amzn.to/y22ZTv) 


_www.thevotingwars.com_ (http://www.thevotingwars.com/) 





-- 
Rick Hasen
Chancellor's Professor of Law and Political Science
UC Irvine School of Law
401 E. Peltason Dr., Suite 1000
Irvine, CA 92697-8000
949.824.3072 - office
949.824.0495 - fax
_rhasen at law.uci.edu_ (mailto:rhasen at law.uci.edu) 
_http://law.uci.edu/faculty/page1_r_hasen.html_ 
(http://law.uci.edu/faculty/page1_r_hasen.html) 
_http://electionlawblog.org_ (http://electionlawblog.org/) 
Pre-order The Voting Wars: _http://amzn.to/y22ZTv_ (http://amzn.to/y22ZTv) 
_www.thevotingwars.com_ (http://www.thevotingwars.com/) 



-- 

Rick Hasen

Chancellor's Professor of Law and Political Science

UC Irvine School of Law

401 E. Peltason Dr., Suite 1000

Irvine, CA 92697-8000

949.824.3072 - office

949.824.0495 - fax

_rhasen at law.uci.edu_ (mailto:rhasen at law.uci.edu) 

_http://law.uci.edu/faculty/page1_r_hasen.html_ 
(http://law.uci.edu/faculty/page1_r_hasen.html) 

_http://electionlawblog.org_ (http://electionlawblog.org/) 

Pre-order The Voting Wars: _http://amzn.to/y22ZTv_ (http://amzn.to/y22ZTv) 

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