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Michael Quinn Sullivan, Petitioner v. Texas Ethics Commission

Docket 24-803, Supreme Court of the United States (Jan. 28, 2025)
Petitioner Michael Quinn Sullivan
Respondent Texas Ethics Commission
Other Ken Paxton, Attorney General of Texas
...
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Amicus brief of Texas Home School - Main Document

Document Michael Quinn Sullivan, Petitioner v. Texas Ethics Commission, 24-803, Amicus brief of Texas Home School, Main Document (U.S. Feb. 24, 2025)
Chapter 305 of the Texas Government Code, as in- terpreted by the court of appeals, imposes burdensome requirements for broad swaths of people who wish to “communicate directly with a member of the legisla- tive or executive branch to influence legislation or ad- ministrative action.” Tex.
Given the law’s broad reach and the homeschool- ing community’s interest in democratic participation, there’s a significant risk that members of Texas Home School Coalition—or the homeschooling community in general—are forced to satisfy Chapter 305’s strict li- censing requirements before engaging in political speech.
The court of appeals upheld Chapter 305 in large part by relying on a purportedly valid interest in gath- ering “information from those who for hire attempt to influence legislation or who collect or spend funds for that purpose.” Pet. App. 11a–12a (quoting United States v. Harriss, 347 U.S. 612, 625 (1954)).
But now, the Coalition must warn its members and local homeschool group leaders that they might need to register as lobbyists, make the burdensome disclosures, and pay a $150 licensing fee before going on these trips to speak with their elected representatives—or risk civil penalties and criminal prosecution.
Several local group leaders have told the Coalition that their concerns about triggering Chapter 305 are so great that they’ve drafted their bylaws to prohibit taking positions on legislation or engaging in the leg- islative process altogether—not because they don’t have anything to say, but because they fear any foot fault might draw reprisal from the Ethics Commis- sion.
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Amicus brief of Texas Home School - Certificate of Word Count

Document Michael Quinn Sullivan, Petitioner v. Texas Ethics Commission, 24-803, Amicus brief of Texas Home School, Certificate of Word Count (U.S. Feb. 24, 2025)
Supreme Court of the United States
I hereby certify that I am a member in good standing of the bar of this Court and that the Brief of Texas Home School Coalition as Amicus Curiae in Support of Petitioner contains 4,738 words and complies with the word limitation established by Rule 33.1(g)(x) of the Rules of this Court.
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Amicus brief of Texas Home School - Proof of Service

Document Michael Quinn Sullivan, Petitioner v. Texas Ethics Commission, 24-803, Amicus brief of Texas Home School, Proof of Service (U.S. Feb. 24, 2025)
Supreme Court of the United States
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Brief amicus curiae of Manhattan - Proof of Service

Document Michael Quinn Sullivan, Petitioner v. Texas Ethics Commission, 24-803, Brief amicus curiae of Manhattan, Proof of Service (U.S. Feb. 18, 2025)
I, Bryant Lee, being duly sworn according to law and being over the age of 18, upon my oath depose and say that: I am retained by Counsel of Record for Amicus Curiae The Manhattan Institute.
by sending three copies of same, addressed to each individual respectively, through FedEx Overnight Mail.
That on the same date as above, I sent to this Court forty copies of the within Brief of The Manhattan Institute as Amicus Curiae Supporting Petitioner through FedEx Overnight Mail.
I declare under penalty of perjury that the foregoing is true and correct.
Notary Public State of New York No. 01BR6004935 Qualified in Richmond County Commission Expires March 30, 2026 #120293
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Brief amici curiae of Cato Institute et - Certificate of Word Count

Document Michael Quinn Sullivan, Petitioner v. Texas Ethics Commission, 24-803, Brief amici curiae of Cato Institute et, Certificate of Word Count (U.S. Feb. 18, 2025)
No. 24-803 In the Supreme Court of the United States
On Petition for a Writ of Certiorari to the Texas Court of Appeals, Third District
As required by Supreme Court Rule 33.1(h), I certify that Brief of the Cato Institute and Foundation for Individual Rights and Expression as Amici Curiae in Support of Petitioner contains 2,571 words, excluding the parts of the document that are exempted by Supreme Court Rule 33.1(d).
1000 Mass.
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Brief amici curiae of Cato Institute et - Main Document

Document Michael Quinn Sullivan, Petitioner v. Texas Ethics Commission, 24-803, Brief amici curiae of Cato Institute et, Main Document (U.S. Feb. 18, 2025)
The Cato Institute is a nonpartisan public policy research foundation founded in 1977 and dedicated to advancing the principles of individual liberty, free markets, and limited government.
This Court should grant certiorari because a state lobbying registration scheme that functions as a prior restraint on political speech raises significant First Amendment concerns.
The en banc Eighth Circuit held that a similar Mis- souri lobbying law was unconstitutional where an in- dividual had to register as a lobbyist when he “neither spen[t] nor receive[d] money in connection with his ad- vocacy.” Calzone v. Summers, 942 F.3d 415, 424 (8th Cir. 2019).
Because the government “may target only a specific type of corruption— ‘quid pro quo’ corruption, ... or its appearance” and there was no exchange of money related to Sullivan’s discus- sions with representatives, Texas does not have a le- gitimate interest in burdening Sullivan’s speech to this degree.
Alt- hough speaking to legislative and executive officials on behalf of an organization is clearly protected speech under the First Amendment, Texas may impose hefty fines and jail time for the failure to register as a lobby- ist under Chapter 305.
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Brief amicus curiae of Manhattan - Certificate of Word Count

Document Michael Quinn Sullivan, Petitioner v. Texas Ethics Commission, 24-803, Brief amicus curiae of Manhattan, Certificate of Word Count (U.S. Feb. 18, 2025)
No. 24-803 In the Supreme Court of the United States
On Petition for Writ of Certiorari to the Supreme Court of the United States
As required by Supreme Court Rule 33.1(h), the undersigned certifies that the Brief of the Manhattan Institute as Amicus Curiae Supporting Petitioners contains 2,207 words, excluding the parts of the brief that are exempted by Supreme Court Rule 33.1(d).
I declare under penalty of perjury that the foregoing is true and correct.
Executed on February 18, 2025.
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