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Brief amici curiae of Ryan T Anderson

Document Masterpiece Cakeshop, Ltd., et al., Petitioners v. Colorado Civil Rights Commission, et al., 16-111, Brief amici curiae of Ryan T Anderson (U.S. Sep. 6, 2017)
Discrimination was so pervasive that the risks of lost economic oppor- tunities or sullied reputation were nonexistent to those who engaged in it.
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Reply of petitioners Gregory Luce et al - Main Document

Document Gregory Luce, et al., Petitioners v. Town of Campbell, Wisconsin, 17-1186, Reply of petitioners Gregory Luce et al, Main Document (U.S. Apr. 6, 2018)
Indeed, by eliminating the need for empirical evidence, the Seventh Circuit panel ruled that any speech visible from the roadway can be banned simply by a municipality invoking a traffic or public safety justification, however unfounded.
As this Court has clarified, “[o]n summary judgment the inferences to be drawn from the underlying facts ... must be viewed in the light most favorable to the party opposing the motion.” Matsushita Elec.
The town asserts that a factual dispute exists because the discredited Chief of Police, Tim Kelemen, was not the only officer to witness potential traffic safety issues.
Respondent claims, “The Town presented evidence of traffic safety problems caused by the protests, such as cars illegally parked on the side of the Interstate with the occupants taking photographs of the overpass protests.” (Resp. 1).
The record includes the opinion of a traffic safety engineer stating that “viewing activity on the overpass does not require a driver diverting attention to a point where vital roadway information would be compromised.” (App. 87) (emphasis added).
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Application of Donald J Trump President

Document Donald J. Trump, President of the United States, et al., Petitioners v. International Refugee Assistance Project, et al., 16-1436, Application of Donald J Trump President (U.S. Jul. 26, 2017)
In No. 16-1436, the Fourth Circuit upheld a global injunction barring enforcement of Section 2(c) of the Order, which temporarily suspends entry of nationals of six countries, on the basis that it likely violates the Establishment Clause.
In addition to those questions, the Court directed the parties to address “[w]hether the challenges to [Section] 2(c) became moot on June 14, 2017.” IRAP, slip op.
There is considerable overlap in the issues presented in these cases, which both concern legal challenges to the same Executive Order.
In light of the five questions presented, as well as because each case presents different facts and the lower courts adopted different rationales, the government further respectfully submits that a single opening brief of 15,000 words and a single reply brief of 6,000 words would be inadequate to provide a thorough airing of the issues.
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Mersino Management Company et al v. Sebelius et al

Docket 2:13-cv-11296, Michigan Eastern District Court (Mar. 22, 2013)
District Judge Paul D. Borman, presiding, Magistrate Judge R. Steven Whalen
Civil Rights - Other
03/22/2013
... Genesee - County Where Action Arose: Genesee - County of 1st Defendant: USA. [Previously dismissed case: No] [Possible companion case(s): None] (Attachments: # 1 Index of Exhibits Index of E...
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Eden Foods, Inc. et al v. Sebelius et al

Docket 2:13-cv-11229, Michigan Eastern District Court (Mar. 20, 2013)
District Judge Denise Page Hood, presiding, Magistrate Judge Mark A. Randon
Civil Rights - Other
03/20/2013
... - County Where Action Arose: Lenawee - County of 1st Defendant: USA. [Previously dismissed case: No] [Possible companion case(s): None] (Mersino, Erin) (Entered: 03/20/2013)
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Petition for a writ of certiorari filed - Proof of Service

Document Gregory Luce, et al., Petitioners v. Town of Campbell, Wisconsin, 17-1186, Petition for a writ of certiorari filed, Proof of Service (U.S. Feb. 20, 2018)
. BECKER GALLAGHER Briefs and Records DONNAl-WOLF.J.D. JULIEA.KER5HNER,J.D. CERTIFICATE OF SERVICE I, Julie A. Kershner, hereby certify that 1 unbound and 40 copies of the foregoing Petition for Writ of Certiorari in Gregory Luce and Nicholas Newman 0.
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No. 219 ORDER granting in part and denying in part 203 Motion for Attorney Fees, Costs, Expenses and ...

Document Luce, Gregory et al v. Town of Campbell, Wisconsin et al, 3:14-cv-00046, No. 219 (W.D.Wis Jan. 9, 2020)
Motion for Attorney FeesPartial
Plaintiffs Gregory Luce and Nicholas Newman brought this suit under 42 U.S.C. § 1983 against defendant the Town of Campbell, challenging the constitutionality of an ordinance prohibiting signs, banners, flags and other similar items on or within 100 feet of a pedestrian bridge or overpass.
This court granted summary judgment in favor of defendants, holding that the ordinance was a reasonable time, place and manner restriction on plaintiffs’ First Amendment rights.
However, the court is not relying on plaintiffs’ request of $1 in nominal damages -- addressed below -- but instead on the court’s entry of a permanent injunction (albeit limited in scope) to find that plaintiffs are entitled to an award under § 1988.
The court agrees with defendant that a substantial discount is warranted here given: (1) the very limited scope of relief achieved in this lawsuit; (2) plaintiffs’ focus on enjoining the Ordinance with respect to the overpass itself, rather than simply the buffer zone; and (3) the loss of plaintiffs’ related First Amendment retaliation claim.
For the reasons explained above, the amended judgment materially alters the parties’ legal relationship by permanently enjoining “the Town from enforcing Ordinance 912.2(2)” as far as barring signs within the 100-foot buffer zone.
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Domino's Farms Corporation et al v. Sebelius et al

Docket 2:12-cv-15488, Michigan Eastern District Court (Dec. 14, 2012)
District Judge Lawrence P. Zatkoff, presiding, Magistrate Judge Michael J. Hluchaniuk
Civil Rights - Other
12/14/2012
... Where Action Arose: Washtenaw County, Michigan - County of 1st Defendant: District of Columbia. [Previously dismissed case: No] [Possible companion case(s): None] (Mersino, Erin) Modified on 12/17/2012 (DTyl). [CO...
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Brief amici curiae of School

Document Gloucester County School Board, Petitioner v. G. G., By His Next Friend and Mother, Deirdre Grimm, 16-273, Brief amici curiae of School (U.S. Mar. 2, 2017)
However, in amici’s professional experience, none of those fears and concerns has materialized in the form of actual problems in their schools.
And I’m pleased to say that none of our fears has materialized.
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Brief amici curiae of Apple et al filed

Document Gloucester County School Board, Petitioner v. G. G., By His Next Friend and Mother, Deirdre Grimm, 16-273, Brief amici curiae of Apple et al filed (U.S. Mar. 1, 2017)
None of these policies has resulted in an increase in sexual assaults or incidents of the kind invoked by the Board and supporters of the Policy.
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Brief amici curiae of Reagan Greenberg

Document Gloucester County School Board, Petitioner v. G. G., By His Next Friend and Mother, Deirdre Grimm, 16-273, Brief amici curiae of Reagan Greenberg (U.S. Mar. 1, 2017)
Amici, due to their race, income level, or current stage in life, have not been afforded the privilege of having their voices heard in front of the Court, yet are likely to be the most dramatically impacted by society’s approach to transgender issues.
In order to escape scrutiny, a man or woman bears the burden of matching very specific, subjective ideas of what it means to be “male” or “female,” and those whose appearance even slightly deviates from that description will 20 Mercedes Allen, Trans History 101: Transgender Expression in Ancient Times, LGBTQ Nation (Feb. 24, 2016), http://www.lgbtqnation.com/2016/02/trans-history-101- transgender-expression-in-ancient-times/3/.
Court in Brown v. Board of Education,48 which represented “nothing short of a reconsecration of American ideals,”49 but also explicitly codified in Title IV of the Civil Rights Act of 1964,50 which prohibited discrimination in public schools on the basis of race, color, or national origin.
The debilitating fear of in-class participation is replaced by a proud answer when a professor refers to me as “Mx.” with the same facility that she calls other students “Mr.” or “Ms.” I start to believe that I could work a full day without apprehension when an employer shows an openness to using my pronouns.
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No. 335-1 Response in Opposition to Motion, filed by Dolores Park, re 313 MOTION to Exclude (Plaintiffs' ...

Document Cervini et al v. Cisneros et al, 1:21-cv-00565, No. 335-1 (W.D.Tex. Feb. 12, 2024)
The Handbook clearly defines aggressive driving as “driving in a combative, forceful or competitive manner.” Ms. Park exhibited none of these aggressive driving behaviors.
Ms. Park exhibited none of the signs of an aggressive driver identified by the Handbook. 11.
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Brief amici curiae of National

Document Gloucester County School Board, Petitioner v. G. G., By His Next Friend and Mother, Deirdre Grimm, 16-273, Brief amici curiae of National (U.S. Jan. 10, 2017)
Because of its advocacy and public education activities surrounding gender-identity issues, NOM has been the recipient of scientific reports on sexuality and gen- der, as well as scores of anecdotal examples of threats to privacy and safety that have occurred in the wake of the adoption of policies that eliminate gender-spe- cific access to intimate facilities such as restrooms, showers, and locker rooms.
In other words, this funda- mental shift in policy and rejection of “common sense [and] decency,” Sepulveda v. Ramirez, 967 F.2d 1413, 1416 (9th Cir. 1992), directly contrary to a statutory exemption and express language in the statute’s im- plementing regulation, was manufactured out of whole cloth by a single, relatively low-level, unelected, and unconfirmed bureaucrat at the Department of Ed- ucation’s Office of Civil Rights.3
C. Mitchell Shaw, Rape Victim: Transgender Agenda Creates “Rape Culture,” The New American (July 1, 2016);6 see also, e.g., Warner T. Huston, Top Twenty- Five Stories Proving Target’s Pro-Transgender Bath- room Policy is Dangerous to Women and Children, Breitbart News Networks (Apr. 23, 20116)7 (illustrat- ing a multitude of instances confirming the privacy and safety concerns of many individuals are valid).
Peter Baklinski, Sexual Predator Jailed After Claim- ing to be ‘Transgender’ to Assault Women in Shelter, Life Site (Mar. 4, 2014).8 As noted above, members of Congress, as the di- rectly-elected representatives of the people, are un- doubtedly much more sensitive to these privacy and safety concerns than was Mr. Ferg-Cadima and his colleagues in the unelected office of civil rights.
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Petition for a writ of certiorari filed

Document Kenosha Unified School District No. 1 Board of Education, et al., Petitioners v. Ashton Whitaker, By His Mother and Next Friend, Melissa Whitaker, 17-301, Petition for a writ of certiorari filed (U.S.
This distinction exists because a “fair reading of the [Title IX] Regulation is that any ‘sex’ discrimination otherwise made unlawful by Title IX, including as to transgender status or gender identity . . . is nonetheless not unlawful if it is limited ...
Nonetheless, the school’s security guards were instructed to monitor’s Ash’s restroom use to ensure that he used the proper facilities.
Nonetheless, the Supreme Court recognized a narrow path for its use in Clinton v. Jones, 520 U.S. 681, 707 n.41, 117 S.Ct.
Nonetheless, neither party has offered any evidence or even alleged that the School District has received any 35a complaints from other students.
... those two to which it referred -- “used qualifiers such as reference to the ‘sum of’ various factors, or ‘typical dichotomous occurrence,’ and ‘typically manifested as maleness and femaleness.’” When the G.G. court concluded that none ...
None of these definitions assist in figuring out whether or not the word “sex” -- how to interpret the word “sex” if there’s an individual who shows some of the characteristics that we associate with biological sex and some of the ...
Nonetheless, Ash was unable to comply with those instructions, out of fear of using the restrooms at school.
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Letter of respondents International

Document Donald J. Trump, President of the United States, et al., Petitioners v. International Refugee Assistance Project, et al., 16-1436, Letter of respondents International (U.S. Jun. 24, 2017)
June 24, 2017 Honorable Scott S. Harris Clerk Supreme Court of the United States Washington, D.C. 20543
Re: Donald J. Trump, et al. v. International Refugee Assistance Project, et al., Nos. 16-1436 & 16A1190 The respondents respectfully submit this letter to inform the Court that on or about June 22, 2017, plaintiff John Doe #1’s wife was granted an immigrant visa.
As the plaintiffs have made clear, even if John Doe #1’s wife is able to enter the United States, he would still be injured by a ban that particularly targets him and condemns his religion.
Here, by preventing the Order that condemns John Doe #1’s religion from going into effect, the injunction below will continue to redress his Establishment Clause injury.
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