Complaint filed by NOM in Rhode Island

8/8/2019 Complaint filed by NOM in Rhode Island

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In the United Sta tes Dist rict Courtfor the District of Rhode Island

National Organization for Marriage, Inc.,Plaintiff

v.

John Daluz, I I I his official capacity aschairman of the Rhode Island Board ofElections; Frank Rego, in his official capacityas vice chairman of the Rhode Island Board ofElections; and Richard Dubois, FlorenceGormley, Martin Joyce, Jr ., Richard Pierce,and William West, in their official capacitiesas members of the Rhode Island Board ofElections,

Defendants

Civil Action No.

CA 10- 392fvtL

Verified Complaint

1NOM COMPLAINT

Case 1:10-cv-00392-ML -DLM Document 1 Filed 09/21/10 Page 1 of 32


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Table of ContentsTable of Contents

............................................................. 2

I. Background ............................................................. 5A. Plaintiff ............................................................. 5

1. NOM 52. NOM's Speech 53. What NOM Does and Does Not Do 6

B.C.

DefendantsRhode Island Law

............................................................. 7

. 81. Regulation ofNOM as a Political Action Committee 92. Expenditure Ban 123. Expenditure Definition and Disclosure Requirements 13

D. Future Speech . 14II. Discussion ........................................................... 15

A. Justiciability ........................................................... 151. Standing ........................................................... 15

a. Constitutional Standing 15b. Prudential Standing 16

2. Ripeness ........................................................... 16B.C.

Irreparable HarmFirst Principles

........................................................... 16

........................................................... 17

1. The Limited Power ofGovernment 172. The First and Fourteenth Amendments as a

Restriction on th e Already Limited Power ofGovernment 17a.b.

VaguenessOverbreadth

2

........................................................... 18

. 18

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3. Determining th e Meaning of Political Speech andwhether Government may Regulate it 19

D. Vagueness ........................................................... 201. Rhode Island Law is Vague, and therefore Overbroad 202. Why Rhode Island Law isVague, and therefore Overbroad 20

E. Overbreadth: In General ........................................................... 21F. Overbreadth: The Political Action Committee Definition 21

1. Strict Scrutiny 212. Applying Strict Scrutiny 23

G. Overbreadth: Expenditure Bans 241. Strict Scrutiny 242. Applying Strict Scrutiny 24

H. Overbreadth: Expenditure Definition andDisclosure Requirements 251. Exacting Scrutiny 252. Spending for Political Speech 253. Government's Interest in Disclosure 264. Applying Exacting Scrutiny 26

I. Facially Unconstitutional 27J. Narrowing Glosses, Certification, and Severability 28

III. Prayers for ReliefVerification

NOM COMPLAINT3

........................................................... 29

........................................................... 32



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1. Plaintiff National Organization for Marriage, Inc. ("NOM"), files thisverified complaint.

2. This action begins with the principle of freedom of speech.Government may limit or otherwise regulate speech only when it has theenumerated power to do so and only when the exercise of that power isconstitutional.

3. This Court has jurisdiction, because this action arises under the Firstand Fourteenth Amendments to t he Unit ed S tat es Constitution. See 28 U.S.C. 1331 (1980).

4. This Court also has jurisdiction, because this act ion arIses underSect ion 1 of the Civil Rights Act of 1871, 42 U.S.C. 1983 (1996). See 28 U.S.C. 1343.a (1979).

5. This Court also has jurisdiction under the Declaratory Judgment Act.See id. 2201 (1993), 2202 (1948).

6. Venue is proper in this Court, because Defendants reside in theDistrict of Rhode Island, and "a substantial part of the events or omissions givingrise to the claim[s]" occurs in th e District of Rhode Island. See id. 1391.b.I-2(1992).

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I. BackgroundA. Plaintiff

1. NOM7. Plaintiff NOM, a non-profit corporation exempt from federal income

taxation under LR.C. 501.cA (2006), is a non-sectarian and non-partisanorganization. I t is not connected with any political candidate or political party. Noris it connected with any political committee other than it s own. Cf 2 U.S.C. 431.7(2002) (defining "connected organization" under federal law).

2. NOM's Speech8. Consistent with it s mission,l NOM seeks in September and Octobner

2010 to engage in multiple forms of speech in Rhode Island, including radio ads,2television ads,3 direct mail,4 and publicly accessible Internet postings of it s radioads, television ads, and direct mail. NOM will run the radio and television ads onstations reaching, and send the direct mail to, persons in Rhode Island. The direct-mail exhibit refers to "Legislator Y." This refers to multiple members of the RhodeIsland general assembly. When NOM sends the direct-mail piece, it will substitute

1 VERIFIED COMPL. (''VC'') Exh. 1, available athttp://www.nationformarriage.org/site/c.omL2KeNOLzHIb.3479573/k.E2DO/About_NOM.htm (all Internet sites visited Sept. 13, 2010).2VC Exhs. 2-3.3 VC Exhs. 4-5.4VC Exh. 6.

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general assembly members' names for "Legislator Y." NOM does no t wish to revealthe members' names in this complaint, because it does no t wish to divulge it sstrategy at this early date.

9. None of this speech has express advocacy as defined in Buckley v.Valeo, 424 U.S. 1, 44 & n.52, 80 (1976), vis-it-vis state or local office in RhodeIsland.5

10. Nevertheless, the speech has characteristics that are significant underconstitutional and Rhode Island law.

11. The speech will have clearly identified candidates for state or localoffice in Rhode Island.

12. The speech will be targeted to the relevant electorate in t ha t it can bereceived in areas where individuals can vote for th e clearly identified candidates.

13. The speech will run in the 30 days before a primary or 60 days before ageneral election ("30-60 Day Windows").

14. Some of the speech will be a broadcast, cable, or satell ite ("Broadcast")communication, and some will not.

3. What NOM Does and Does Not Do15. NOM receives no donations that anyone specifies "be used for" NOM's

speech in Rhode Island. Ct. R. 1. GEN. LAws 17-25-3.10 (2006) (political-action-committee definition).

5 Although it i s not mater ia l, none of this speech has express advocacy as defined inBuckley vis-it-vis any office.6

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16. NOM does not coordinate any of it s speech with any candidate for stateor local office in Rhode Island, the candidate's agents, or the candidate's committee,cf. Buckley, 424 U.S. at 78, quoted in FEC v. Survival Educ. Fund, Inc., 65 F.3d 285,294 (2d Cir. 1995), or a state or local political party in Rhode Island. Cf. McConnellv. FEC, 540 U.S. 93, 219-23 (2003), overruled on other grounds, Citizens United v.FEC, 558 U.S._ , _ , 130 S.Ct. 876, 896-914 (2010).6

17. Nor is there at issue here a contribution NOM receives that (1) isearmarked for a Rhode Island political committee, i.e., an indirect contribution to aRhode Island political committee, ct. Buckley, 424 U.S. at 24 n.23, 78, or (2) "will beconverted to an expenditure[,]" Survival Edu c. Fun d, 65 F.3d at 295, i.e., will beearmarked for express advocacy as defined in Buckley, 424 U.S. at 44 n.52, 80, vis-a-vis state or local office in Rhode Island.7

B. Defendants18. Defendants John Daluz and Frank Rego are the chairman and vice

chairman, respectively, of the Rhode Island Board of Elect ions ("Board").Defendants Richard Dubois, Florence Gormley, Martin Joyce, Jr., Richard Pierce,

6 Although it is not material, NOM does not make direct contributions to anycandidate committee or coordinate it s speech with any candidate, the candidate'sagents, or the candidate's committee, or with any political party.7 Although it is not material, there is not at issue here a contribution NOM receivesthat (1) is earmarked for any political committee, i.e., an indirect contribution toany political committee or (2) "will be conver ted to an expenditure[,]" i.e., wil l beearmarked for express advocacy as defined in Buckley, vis-a-vis any office.

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and William West are Board members.8 Rhode Island law vests Defendants, all o fwhom are sued i n the ir official capacities, with authority vis-a-vis the law at issuein this action. They act under color of law. See, e.g., R. I. GEN. LAws 17-25-5(2007), 17-25-13 (2001), 17-25-16 (1992), 17-25-28 (2001).

c. Rhode Island Law19. NOM reasonably believes that if it does not follow Rhode Island law,

Defendants will subject NOM to enforcement and prosecution leading to civilliabilities and criminal penalties. See id. Even if there were no civil liabilities orcriminal penalties, being cleared provides little comfort to those whom governmenthas wrung through a process that becomes th e punishment. See, e.g., FEC v.Wisconsin Right to Life, Inc., 551 U.S. 449, 468 n.5 (2007) ("WRTL I!'). "The rightof free speech can be trampled or chilled even if convictions are never obtained" andcivil liabilities are never imposed. FEC v. Hall-Tyner Election Campaign Comm.,678 F.2d 416, 422 n.15 (2d Cir. 1982), cert. denied, 459 U.S. 1145 (1983).

20. In two instances,9 Rhode Island law chills10 Plaintiff from proceedingwith it s speech. NOM will do it s speech only if the Court grants the requestedrelief.

8 Commissioners, available at http://www.elections.state.ri.us/.9 Infra Parts I.C.l, 2.10 The term "pre-enforcement" applies before civil enforcement or criminalprosecution. The term "chill" is a proper subse t of "pre-enforcement" and applies inthe First Amendment context when speakers, fearing civil enforcement or criminalprosecution, will not engage in their speech. See, e.g., New Hampshire Right to Life

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21. In one ins tance, ll there is no chil l i f the Court holds for Plaintiff onpolitical-committee status12 and the expenditure ban: 13 NOM wil l do it s speech andcomply with the law while asking the Court to declare the law unconstitutional andenjoin it s enforcement so compliance is no longer necessary.

1. Regulation of NOM as a Poli t ica l Action Committee22. First, under Rhode Island law a political-action committee ("PAC") is

"any group of two (2) or more persons that accepts any contributions to be used foradvocating the election or defeat of any candidate or candidates." R. I. GEN. LAws 17-25-3.10.

23. Plaintiff NOM seeks a declaratory judgment that it is not a political-action committee under R. I. GEN. LAws 17-25-3.10. NOM further asks that theCourt preliminarily and then later permanently enjoin it s enforcement.

24. This will allow NOM to do it s speech, and materially similar speech inthe future, without fear of becoming a PAC, and without fear of enforcement orprosecution.

25. In th e alternative, NOM challenges Rhode Island's PAC definition.

PAC v. Gardner, 99 F.3d 8, 13-14 (1st Cir. 1996) ("NHRL"). Thus, "preenforcement" applies to all of Plaintiffs speech, and "chill" applies to some of it sspeech.II Infra Part I.C.3.12 Infra Part I.C.1.13 Infra Part I.C.2.

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26. NOM is not under the control of a candidate or candidates for state orlocal office in Rhode Island.l4 In addition, NOM's organizational documents - i.e.,it s art ic les of incorporation15 and by-Iawsl6 - and public statements17 do notindicate it has the major purpose of nominating or electing a cand idate orcandidates for state or local office in Rhode Island, and NOM does not spend themajority of it s money on contr ibutions to, or independent expendi tures for, acandidate or candidates for state or local office in Rhode Island.l8 "Independentexpenditure" means express advocacy as defined in Buckley and not coordinatedwith a candidate, a candidate's committee, a candidate's agent, or a party, which isthe standard under the Constitution. 424 U.S. at 39-51; McConnell, 540 U.S. at219-23; cf 2 U.S.C. 431.17 (2002) (following Buckley by limiting t he s ta tu toryindependent-expenditure definition to express advocacy).l9

14 Although it i s not mate rial, NOM is not under the control of any candidate orcandidates.15 VC Exh. 7.16 VC Exh. 8.17 E.g., VC Exh. 1.18 See VC Exh. 9 (IRS Form 990).19 Although it is not material, nothing in NOM's organizational documents or in it spublic statements indicates that NOM has the major purpose o f nominati ng orelecting any candidate or candidates, and NOM does not spend the majority of it smoney on contr ibut ions to, or independent expenditures for, any candidate orcandidates.

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27. Nevertheless, NOM reasonably fears it is a PAC under Rhode Islandlaw. Then NOM will have to comply with a panoply of burdens that Rhode Islandvia it s PAC definition imposes on organizations such as NOM, including:

Registration (including treasurer-designation) requirements. R. 1.GEN. LAws 17-25-7.a (1992), 17-25-8.1 (2006), 17-25-1O.a.3 (2006),17-25-15 (2006).

Recordkeeping requirements. Id. 17-25-7.a, 17-25-11.1 (2001). Extensive reporting requirements. Id. 17-25-7.a, 17-25-11 (2007). Limits on contributions received. Id. 17-25-10.1.a.1, and Contr ibut ion-source bans. Id. 17-25.10.1.h.l; 2 U.S.C. 441h.a,441b.b.2 (2002) (national banks and national corporations), 441e (2002)(foreign nationals).

28. The weight of these burdens is such that the speech would simply no tbe worth it for NOM. I t does not want to bear the burdens of being a polit icalcommittee.

29. Therefore, Plaintiff NOM seeks a declaratory judgment that thepol itical-action commit tee definition, R. 1. GEN. LAws 17-25-3.10, ISunconstitutional as applied to NOM's speech and facially. NOM fur ther asks thatthe Court preliminarily and then later permanently enjoin it s enforcement.

30. This will allow NOM to do its speech, and materially similar speech inthe future, without fear of becoming a PAC, and without fear of enforcement orprosecution.

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2. Expenditure Bans31. Second, an expenditure includes any "thing of value" exceeding $100

"to or by any candidate, committee of a political party , or political action committeeor ballot question advocate." Id. 17-25-3.3, 7 (1992). Rhode Island banscorporations and other business entities from making expenditures "to or for anycandidate, political action committee, or political party committee[.]"20 Id. 17-25-1O.1.h.l (2006). Rhode Island law then says only individuals, PACs, partycommittees, and authorized candidate committees may make expenditures. Id. 17-25-10.1.j; see Rhode Island Affiliate ACLU v. Begin, 431 F. Supp.2d 227, 240(D.R.L 2006) (noting that given Section 10.1.j, th e Section 10.1.h ban is"redundant"). Moreover, a person - including NOM, see R. I. GEN. LAws 17-25-3.9(defining "person" to include corporations) - "not acting in concert with any otherperson or group" may not spend it s own money to "support or defeat" a candidatewhen no one will reimburse the person. Id. 17-25-10.b.

32. NOM reasonably fears it s radio ads, television ads, direct mail, andInternet postings are expenditures that Rhode Island bans , because NOM (1) is acorporation, (2) is neither an individual, a PAC, a party committee, nor anauthorized candidate committee, and (3) will do it s speech by itself withoutreimbursement.

20 See also VC Exh. 10 at 3 (Advisory Op. of Richard Thorton, Director of CampaignFinance, Rhode Island Board of Elections (May 5, 2010.

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33. Therefore, Plaintiff NOM seeks a declaratory judgment that th ecorporate expenditure ban, R. 1. GEN. LAws 17-25-10.1.h.l, the ban onexpenditures by persons other than individuals, PACs, party committees, orauthorized candidate committees, R. 1. GEN. LAws 17-25-10.1.j, and the ban onexpenditures by persons "not act ing in concert with any other person or group"when no one will repay th e money, R. 1. GEN. LAws 17-25-10.b, areunconstitutional as applied to NOM's speech and facially. NOM fur ther asks thatth e Court preliminarily and then later permanently enjoin their enforcement.

34. This will allow NOM to do it s speech, and materially similar speech inthe future, without violating the bans, and without fear of enforcement orprosecution.

3. Expenditure Definition and Reporting Requirements35. Third , even i f NOM may do expenditures as Rhode Island defines

them, NOM must still report them, because NOM's total expenditures will exceed$100 in a calendar year. Id. 17-25-10.b. Further, NOM mus t send reports notonly to th e Board but also to th e campaign treasurers or deputy campaigntreasurers of the candidates or parties "on whose behalf' NOM made theexpenditures. Id. And NOM must report even th e smallest expenditures as RhodeIsland defines them. In this sense, there is no reporting threshold. See id.

36. Even i f NOM's speech did not sweep it into political-committee status,NOM reasonably fears that if it does its speech, it must comply with theserequirements.

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37. Therefore, Plaintiff NOM seeks a declaratory judgment that th eexpenditure definition, R. 1. GEN. LAws 17-25-3.3, and the expenditure-reportingrequirements, R. 1. GEN. LAws 17-25-1O.b, are unconstitutional as applied toNOM's speech and facially. NOM fur ther asks that th e Court preliminarily andthen later permanently enjoin their enforcement.

38. This will allow NOM to do it s speech, and materially similar speech inthe future, without having to comply with these expenditure-reportingrequirements, and without fear of enforcement or prosecution.

D. Future Speech39. In materially similar situations in th e future, NOM intends to do

speech materially similar to al l of it s planned speech such that Rhode Island lawwill apply to NOM as it does now.

40. Plaintiff will plan i ts future speech as the need arises, keeping in mindthat it often cannot know well in advance of when it wants to speak, see WRTL II,551 U.S. at 462-63, and that "timing is of th e essence in politics. I t is almostimpossible to predict th e political future; and when an event occurs, it is oftennecessary to have one's voice heard promptly, i f it is to be considered at all."Shuttlesworth v. City of Birmingham, 394 U.S. 147, 163 (1969) (Harlan, J.,concurring).

41. Despite Citizens United, Plaintiff finds itself in the position of havingto consult campaign-finance lawyers or seek declaratory rulings "before discussingthe most salient political issues of our day." 130 S.Ct. at 889.

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II . Discussion42. Counts 2 to 421 assert various provisions of Rhode Island law fail the

appropriate level of scru tiny. Counts 122 and 523 assert law challenged in Counts 2to 4 is unconstitutionally vague, and therefore overbroad, both as applied to speechand facially. Count 5 then asserts the law challenged in Counts 2 to 4 is faciallyunconstitutional.

A. Justiciability1. Standing

a. Constitutional Standing43. First, part of NOM's injury is the chill to speech caused by Defendants'

prospective enforcement of Rhode Island law or prosecution of NOM. The relief itseeks will redress this chill, thereby allowing NOM to do it s speech without fear ofenforcement or prosecution. Therefore, NOM has standing to seek re lief from thechill. See New Hampshire Right to Life PAC v. Gardner, 99 F.3d 8, 13-15 (1st Cir.1996) ("NHRL").

44. Second, NOM has standing in part because it will do it s speech andcomply with some of the law it challenges - as opposed to being chilled andtherefore not doing it s speech - while asking the Court to declare the law

21 Infra Parts ILE-H.22 Infra Part II.D.23 Infra Part ILL

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unconstitutional and enjoin it s enforcement so compliance is no longer necessary.See Davis v. FEC, 554 U.S. __,__, 128 S.Ct. 2759, 2769 (2008).

b. Prudential Standing45. Plaintiff has prudential standing, because it s injuries are in the "zone

of interests" the challenged law regulates. FEC v. Akins, 524 U.S. 11, 20 (1998)("protected or regulated" (quoting National Credit Union Admin. v. First Nat. Bank& Trust Co., 522 U.S. 479, 488 (1998))).

2. Ripeness46. Pre-enforcement challenges are ripe when:

They address laws chilling political speech, see Mangual v. Rotger-Sabat, 317 F.3d 45, 60 (1st Cir. 2003), or A speaker is already doing or will do it s speech, and is alreadycomplying or will comply with the challenged law but asks a court todeclare the law unconstitutional and enjoin it s enforcement socompliance is no longer necessary. See Peachlum v. City of York, Pa.,333 F.3d 429, 435 (3d Cir. 2003) (citing Presbytery of N.J. of OrthodoxPresbyterian Church v. Florio, 40 F.3d 1454, 1467 (3d Cir. 1994)).47. Therefore, Plaintiffs claims are ripe.B. I r reparable Harm48. The "loss of First Amendment freedoms, for even minimal periods of

time, unquestionably constitutes irreparable injury." Elrod v. Burns, 427 U.S. 347,373 (1976). So unless Pla inti ff receives the relief it requests, it will sufferirreparable harm. There is no adequate remedy at law. See id.

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C. First Principles1. The Limited Power ofGovernment

49. Freedom of speech is th e norm, not the exception. See, e.g., CitizensUnited v. FEC, 558 U.S. __, __, 130 S.Ct. 876, 911 (2010) ("more speech, no tless, is the governing rule"); Buckley v. Valeo, 424 U.S. 1, 14-15 (1976).

50. The framers established government with the consent of the governed,see, e.g., U.S. CONST. preamble (1787) ("We the people of the Uni ted States"); R. 1.CaNST. preamble ("We, the people of the State of Rhode Is land and ProvidencePlantations, grateful to Almighty God for the civil and religious l iberty which Hehath so long permitted us to enjoy, and looking to Him for a blessing upon ourendeavors to secure and to transmit the same"), and government has only thosepowers that the governed surrendered to it in th e first place.

2. The First and Fourteenth Amendments as Restr ict ions onthe Already Limited Power o fGovernment

51. This power - including the "constitutional power of Congress toregulate federal elections[,]" Buckley, 424 U.S. at 13 & n.16, and each s ta te 'sparallel power over its own, though not othe r states', elections, see, e.g., NorthCarolina Right to Life, Inc. v. Leake, 525 F.3d 274,281 (4th Cir. 2008) ("NCRL III')(citing Buckley, 424 U.S. at 13); R. 1. CaNST. art. IV - is further constrained by otherlaw, including the Fir st and FourteenthAmendments.

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a. Vagueness52. Under the Fourteenth Amendment, U.S. CONST. amend. XIV (1868),

state law regulating political speech must no t be vague . See Citizens United, 130S.Ct. at 889 (quoting Connally v. General Constr. Co., 269 U. S. 385, 391 (1926.

53. To avoid the problems vagueness causes, law regulating politicalspeech must also be simple and concise. See id.

b. Overbreadth54. The absence of vagueness, however, does no t make law regulating

political speech constitutional. See WRTL II, 551 U.S. at 479 (quoting FEC v.Massachusetts Citizens for Life, Inc., 479 U.S. 238, 263 (1986) ("MCFL".

55. Even non-vague law regulating political speech must comply with theFirst Amendment, which provides that

Congress shall make no law respecting an establishment of religion, orprohibiting the free exercise thereof; or abridging the freedom ofspeech, or ofthe press; or the right of the people peaceably to assemble,and to petition the Government for a redress of grievances.

U.S. CONST. amend. I (1791). The First Amendment guards against overbreadth,Buckley, 424 U.S. at 80 ("impermissibly broad"),24 and applies to the states throughthe Fourteenth Amendment, regardless of whether it is through the Due ProcessClause, Gitlow v. New York, 268 U.S. 652, 666 (1925) (freedom of speech andfreedom of the press), or th e Privileges and Immunities Clause. Cf. McDonald v.

24 One should no t confuse this overbreadth with the substantial overbreadth courtsaddress in assessing facial unconstitutionality. Infra Part ILL

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City of Chicago, 561 U.S._ , _ , 130 S.Ct. 3020, 3059, 3062-63 (2010) (Thomas,J., concurring in part and concurring in the judgment).

56. The government's power to regulate elections is an exception to thenorm of freedom of speech. See Citizens Against Rent Control u. City of Berkeley,454 U.S. 290, 296-97 (1981). The power to regulate elections is also self-limiting. Toensure law is not "impermissibly broad," Buckley establishes that government may,subject to further inquiry,25 have the power to regulate donations received andspending for political speech only when they are "unambiguously related to thecampaign of a particular .. . candidate" in the jurisdiction in quest ion, 424 U.S. at80, or "unambiguously campaign related" for short. Id. at 81. This principle helpsensure government regulates only speech that government has the "power toregulate," NCRL III, 525 F.3d at 282, i.e., speech that government has aconstitutional interest in regulating. See id. at 281 (citing Buckley, 424 U.S. at 80).This principle is part of the larger principle that law regulating political speechmust not be overbroad, see Buckley, 424 U.S. at 80 ("impermissibly broad"), andthus overlaps with constitutional scrutiny.

3. Determining the Meaning of Politica l Speech andwhether Government may Regulate it

57. WRTL II also reaffirms that in determining the meaning of politicalspeech and whether government may regulate it, one looks to the substance of thespeech itself. 551 U.S. at 469 (citing Buckley, 424 U.S. at 43-44). WRTL II al l but

25 E.g., infra Parts ILF, G.19

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forecloses considering context to determine the meanmg of political speech andwhether government may regulate it. See id. at 467-73.

Count 1: VaguenessD. Vagueness

1. Rhode Island Law is Vague, and therefore Overbroad58. Rhode Island's vague law does not "provide t he k ind of notice that will

enable ordinary people to understand what conduct it" regulates; furthermore, "i tmay authorize and even encourage arbitrary and discriminatory enforcement." Cityof Chicago v. Morales, 527 U.S. 41, 56 (1999) (citing Kolender v. Lawson, 461 U.S.352, 357 (1983.

2. Why Rhode Island Law is Vague, and thereforeOverbroad

59. Rhode Island uses the phra se "advocating the election or defeat of'candidates in its PAC definition. I t also uses th e phrases "support or defeat" and"on whose behalf ' in an expenditure ban and an expenditure-reporting requirement,respectively.26

60. This language is unconstitut ionally vague, and therefore overbroad,and is unconstitutional as applied to NOM's speech and facially.27

26 VC ~ 22, 31,35.27 Part 11.1 addresses facial unconstitutionality, including vagueness.

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E. Overbreadth: In General61. In addition, Rhode Island law is unconstitutional as applied to NOM's

speech facially. 2862. Rhode Island law fails the appropriate level of scrutiny.

Count 2: The Political Action Committee DefinitionF. Overbreadth: The PoliticalAction Committee Definition63. Plaintiff re-alleges the preceding paragraphs.64. I f the Court does not enter declaratory judgment that Rhode Island's

PAC definition does not apply to NOM, then NOM challenges the definition.291. Strict Scrutiny

65. Plaintiff re-alleges th e preceding paragraphs.66. Strict scrutiny applies to government regulation of organizations as

political committees. See Austin v. Michigan Chamber of Commerce, 494 U.S. 652,658 (1990) (holding that a state requirement that an organization form a segregatedfund "must be justified by a compelling state interest"), overruled on other grounds,Citizens United v. FEC, 558 U.S. __ ,__ , 130 S.Ct. 876, 896-914 (2010); ColoradoRight to Life Comm., Inc. v. Coffman, 498 F.3d 1137, 1146 (10th Cir. 2007) ("CRLC')(applying strict scrutiny to a state requirement that organizations themselves bepolitical committees); North Carolina Right to Life, Inc. v. Leake, 525 F.3d 274, 290

28 Parts II.E-H address as-applied challenges, and Part ILl addresses facialunconstitutionality, including overbreadth.29 VC ~ 22-25.

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(4th Cir. 2008) ("NCRL III') (addressing "narrower means" than a staterequirement that organizations themselves be polit ical committees); cf. CitizensUnited, 130 S.Ct. at 897-98 (holding that strict scrutiny applies to a ban on speechand noting the burdens of forming a pol it ical committee to do the same speech);FEC v. Massachusetts Citizens for Life, Inc., 479 U.S. 238, 252 (1986) ("MCFL")(considering whether a ban on independent expenditures "is justified by acompelling state interest" and noting the burdens of forming a separate segregatedfund to do the same speech).

67. Buckley v. Valeo establishes that government may regulate anorganization as a political committee only i f (1) it is "under the control of acandidate" or candidates or (2) "the major purpose" of the organization is "thenomination or election of a candidate" or candidates in the jurisdiction. See 424U.S. 1, 79 (1976).

68. These two tests address whether a definition through whichgovernment imposes political-committee burdens is constitutionaL Unity08 v. FEC,596 F.3d 861, 867 (D.C. Cir. 2010) (quoting FEC v. Machinists Non-PartisanPolitical League, 655 F.2d 380, 392, 395-96 (D.C. Cir.), cert. denied, 454 U.S. 897(1981; NCRL III, 525 F.3d at 288-89; CRLC, 498 F.3d at 1139, 1154-55;Brownsburg Area Patrons Affecting Change v. Baldwin, 137 F.3d 503, 505 n.5 (7thCir. 1998).

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69. Determining whether an organization is "under the control of acandidate" or candidates for state or local office in Rhode Island is straightforward,and NOM is under no such contro1.30

70. Determining whether an organization passes the major-purpose test isalso straightforward.

71. NOM does not have the major purpose of nominating or electing acandidate or candidates for state or local office in Rhode Island: (1) I t has notindicated this in its organizational documents or in its public statements, and (2) itdoes not spend the majority of it s money on contributions to, or independentexpenditures for, such candidates.31

2. Applying Strict Scrutiny72. Rhode Island lacks a compelling interest in regulating organizations

such as NOM as political committees, because they are neither under the control of,nor do they have the major purpose of nominat ing or electing, candidates for stateor local office in Rhode Island. In th e alternative, Rhode Island's PAC definition isnot narrowly tailored, because it lets Rhode Island regulate organizations such asNOM as political committees when they are nei ther under the control of, nor have

30 Although it is not material, NOM is not under the control of any candidate orcandidates.31 Although it is not material, NOM does not have the major purpose of nominatingor electing any cand ida te o r candidates. I t has no t indicated this in it sorganizational documents or in it s public statements. Nor does it spend themajority of it s money on contributions to, or independent expenditures for, anycandidate or candidates.

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the major purpose of nominat ing or electing, candidates for state or local office inRhode Island. See NCRL III, 525 F.3d at 290 (calling a pol iti ca l-commit teedefinition "vague" and addressing "narrower means" when the definition regulatedas political committees organizations that passed neither th e "under the control of acandidate" test nor th e major-purpose test); CRLC, 498 F.3d at 1146 (holding thatstrict scrutiny applies and then addressing th e tests).

73. Therefore, Rhode Island's PAC definition32 IS unconstitutional asapplied to NOM's speech.

74. I f Rhode Island wanted to regulate, for example, spending for politicalspeech by persons it may not regulate as political committees under Buckley, 424U.S. at 74-79, then it could use less-restrictive means.

Count 3: Expenditure BansG. Expenditure Bans

1. Strict Scrutiny75. Plaintiff re-alleges the preceding paragraphs.76. Strict scrutiny applies to bans on independent spending for political

speech. See Citizens United, 130 S.Ct. at 898 (quoting WRTL, 551 U.S. at 464).2. Applying Strict Scrutiny

77. Rhode Island's expenditure bans33 are unconstitutional as applied toNOM's speech. See id. at 896-914.

32 Supra Part I.C.I.24

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Count 4: Expenditure Definition and Report ing RequirementsH. Overbreadth: Expenditure Definition and

Reporting Requirements1. Exacting Scrutiny

78. Plaintiff re-alleges the preceding paragraphs.79. Exact ing scru tiny applies to disclosure requ irements, both for

organizations government may regulate as political committees under Buckley, 424u.s. at 74-79, see Davis v. FEC, 554 U.S. __, _ , 128 S.Ct. 2759, 2775 (2008)(quoting Buckley, 424 U.S. at 64), and for those it may not. See Citizens United, 130S.Ct. at 914 (quoting Buckley, 424 U.S. at 64, 66).

80. Full -f ledged pol iti cal -commit tee disclosure requirements apply only i fthe jurisdiction's regulation of organizations as political committees - i.e., only i f thedefinition through which the jurisdiction imposes political-committee burdens34 - isconstitutional in the fIrst place. So when the defInition is unconstitutional - asRhode Island's is35 - the requirements are unnecessary to consider.

2. Spending for Political Speech81. When it comes to persons Rhode Island may not regulate as political

committees under Buckley, 424 U.S. at 74-79, the only spending for political speech

33 Supra Part 1.C.2.34 VC ,-r 27.35 Supra Part ILF.

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that Supreme Court precedent has established Rhode Island has a sufficientlyimportant interest in regulating is:

Express advocacy, id. at 39-51, 74-81, as defined in Buckley, id. at 44 &n.52, 80, vis-a-vis state or local office in Rhode Island, and Regulable speech "about a candidate shortly before an election."Citizens United, 130 S.Ct. at 915: Electioneering communications asdefined in the Federal Election Campaign Act, 2 U.S.C. 431 et seq.("FECA") , Citizens United, 130 S.Ct. at 914-16, having a clearly

identified candidate for state or local office in Rhode Island.See, e.g., NCRL 111,525 F.3d at 281-82.

3. Government's Interest in Disclosure82. The "constitutional power of Congress to regulate federal elections[,]"

Buckley, 424 U.S. at 13 & n.16, and each state's parallel power over it s own, thoughno t other states', elections, see, e.g., NCRL III, 525 F.3d at 281, cannot includepower to gather "information" or "data" for information's or data's sake.

4. Applying Exacting Scrutiny83. Rhode Island's expenditure definition and expenditure-reporting

requirements36 reach beyond spending for pol it ical speech that courts allowgovernment to regulate. That is, Rhode Island reaches beyond what it has asufficiently important interest in regulating.

84. Rhode Island law reaches beyond spending-for-political-speechboundaries. That is, it reaches beyond express advocacy as defined in Buckley, 424U.S. at 44 n.52, 80, and beyond what the Supreme Court has held may be regulable36 Supra Part LC.3.

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speech "about a candidate shortly before an election." Citizens United, 130 S.Ct. at915. This occurs through the expenditure definition and th e expenditure-reportingrequirements.

85. Because Rhode Island reaches beyond what it has a sufficient lyimportant interest in regulating, it s law fails exacting scrutiny and isunconstitutional as applied to NOM's non-Broadcast speech, and - as to this speech- it is unnecessary to consider whether any factors such as those Citizens Unitedmentions, 130 S.Ct. at 915-16, mean there is no "substantial relation" between thedisclosure requirements and a "'sufficiently important' governmentD interest." Id.at 914 (quoting Buckley, 424 U.S. at 64, 66).

86. For these reasons, th e expenditure definition and the expenditure-reporting requirements are unconstitutional as applied to NOM's speech.

87. Rhode Island law is unconstitutional as applied to NOM's Broadcastand non-Broadcast speech for additional reasons. See Citizens for Responsible Gov'tState PAC v. Davidson, 236 F.3d 1174, 1198 (10th Cir. 2000) (striking down arequirement to provide copies to candidates); Canyon Ferry Road Baptist Church ofEast Helena, Inc. v. Unsworth, 556 F.3d 1021, 1033 (9th Cir. 2009) (referring pre-Citizens United to tailoring); id. at 1036 (Noonan, J. , concurring).

Count 5: Vagueness and Overbreadth:Facial Unconstitutionality

I. Facially Unconstitutional88. Plaintiff re-alleges the preceding paragraphs.

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89. A state law is facially unconstitutional under the First Amendment,Washington State Grange v. Washington State Republican Party, 552 U.S. 442, 449n.6 (2008) (citing New York v. Ferber, 458 U.S. 747, 769-71 (1982, and a state lawburdening free speech is facially unconstitutional for vagueness under theFourteenth Amendment, see United States v. Salerno, 481 U.S. 739, 745 (1987)(citing Schall v. Martin, 467 U.S. 253, 269 n.18 (1984); Kolender v. Lawson, 461U.S. 352, 358 & n.8 (1983, followed in City of Chicago v. Morales, 527 U.S. 41, 60(1999), when it reaches "a substantial amount of protected speech .. . not only in anabsolute sense, but also relative to the [law's] plainly legitimate sweep." UnitedStates v. Williams, 553 U.S. 285, 292-93 (2008) (citing Board of Trs. of State Univ. ofN. Y. v. Fox, 492 U.S. 469, 485 (1989); Broadrick v. Oklahoma, 413 U.S. 601, 615(1973.

I90. Whether the challenge is based on the F ir st Amendment, FourteenthAmendment, or both, all of the law that is unconstitutional as applied to Plaintiffsspeech is also facially unconstitutional.

J. Narrowing Glosses, Certification, and Severability91. Unlike in Buckley v. Valeo, 424 U.S. 1, 44 & n.52, 80 (1976), no

narrowing gloss saves the unconstitutional law in this action. Nor is certifying aquestion appropriate where, as here, the state law is not fairly susceptible.Furthermore, severing the unconstitutional language from the remaining language- which is a question of state law - is not an option in this action.

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III. Prayers for Relief92. Plaintiff NOM seeks a declaratory judgment that it is not a political

action committee under R. 1. GEN. LAws 17-25-3.10. NOM fur ther asks that theCourt preliminarily and then later permanently enjoin it s enforcement. 37

93. In th e alternative to the previous paragraph, Plaintiff NOM seeks adeclaratory judgment that th e political-action committee definition, R. 1. GEN. LAws 17-25-3.10, is unconstitutional as applied to NOM's speech and facially. NOMfurther asks that the Court preliminarily and then later permanently enjoin it senforcement. 38

94. Plaintiff NOM seeks a declaratory judgment that the corporateexpenditure ban, R. 1. GEN. LAws 17-25-10.1.h.1, the ban on expenditures bypersons other than individuals, PACs, party committees, or authorized candidatecommittees, R. 1. GEN. LAws 17-25-10.1.j, and the ban on expenditures by persons"not acting in concert with any other person or group" when no one will repay themoney, R. 1. GEN. LAws 17-25-10.b, are unconstitutional as applied to NOM'sspeech and facial ly. NOM further asks that th e Court preliminarily and then laterpermanently enjoin their enforcement.39

37 VC 23.38VC 29.39VC 33.

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95. Plaintiff NOM seeks a declaratory judgment that the expendituredefinition, R. 1. GEN. LAWS 17-25-3.3, and the expenditure-reporting requirements,R. 1. GEN. LAws 17-25-1O.b, are unconstitutional as applied to NOM's speech andfacially. NOM further asks that the Court preliminarily and then laterpermanently enjoin their enforcement.4o

96. Any narrowing gloss would be incorrect as a matter of law. I f theCourt nevertheless held that a narrowing gloss were possible, Plaintiff NOM praysfor the following relief:

A declaratory judgment limiting Rhode Island's political-actioncommittee definition, R. 1. GEN. LAws 17-25-3.10, and by extensionthe burdens Rhode Island imposes on PACs, to organizations that areunder the control of, or have the major purpose of nominating orelecting, a candidate or candidates for state or local office in RhodeIsland,41 and

40VC 37.41 In the alternative, Plaintiff NOM prays that the Cour t l imit the definition andburdens to organizations that are under the control of, or have the major purpose ofnominating or electing, any candidate or candidates.Plaintiff NOM submits this alternative would also be incorrect, because, forexample, it would allow Rhode Island to regulate as Rhode Island politicalcommittees those organizations that are under the control of, or have the majorpurpose of nominating or electing, candidates for federal office or candidates forstate or local office in another state. This can easily turn against Rhode Island andallow these non-Rhode Island jurisdictions to regulate organizations that really dopass the "under the control of a candidate" or major-purpose t es t in Rhode Island.Moreover, under this approach, a jurisdiction could impose political-committeeburdens on organizations whose activity is minimal - or even zero - in thejurisdiction.

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A declaratory judgment limiting Rhode Island's expendituredefinition, R. 1. GEN. LAws 17-25-3.3, and expenditure-reportingrequirements, R. 1. GEN. LAws 17-25-1O.b, to (a) express advocacy asdefined in Buckley vis-a-vis state or local office in Rhode Island or (b)electioneering communications as defined in FECA having a clearlyidentified candidate for state or local office in Rhode Island.4297. Plaintiff further seeks costs and attorneys' fees under 42 U.S.C. 1988

(2000) and any other applicable statute or authority, and fur ther seeks other reliefthis Court in its discretion deems just and appropriate.

Respectfully submitted,

Stephen A. IzziRhode Island No.2MOSES & AFONSO, L160 Westminster Street, Suite 400Providence, R. 1. 02903Telephone (401) 453-3600Facsimile (401) [email protected] Counsel for Plaintiff

September 14, 2010

James Bopp, Jr., Ind. No. 2838-84Randy Elf, New York No. 2863553Jeffrey Gallant, Va. No. 46876JAMES MADISON CENTER FOR FREE SPEECH1 South Sixth StreetTerre Haute, Ind. 47807Telephone (812) 232-2434Facsimile (812) [email protected] Counsel for Plaintiff

42 In th e alternative, Plaintiff NOM prays that t he Court l imit the definition andcorresponding requirements to (a) express advocacy as defined in Buckley vis-a-visany office or (b) electioneering communications as defined in FECA having anyclearly identified candidate.

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o a UZ, go,DEFENDANTSr-lorence Gormley, Martin J r .

Richard Pierce , William Westin t he ir o f fi ci al capaci t ie

Attorneys (I fKnown)

COWlty of Residence of First Listed Defendant-=-=-=-::-:-::-:-::- _(INU.S. PLAINTIFF CASES ONLY)

NOTE: IN LAND CONDEMNAnON CASES, USE THE LOCAnON OF THELAND INVOLVED.

CIVIL COVER S I r n U J 1 ~

.. .. Pr ince William Co.County of Residence ofFn'St Listed Plamllff ==--:--::-::-::-:----;=,..,-,,==,.(EXCEPT IN U.S. PLAINTIFF CASES) (Virginia)(c) Attorney's (Firnl Name, Address, and Telephone Number)

Bopp, Coleson & Bostrom1 South Six th StTerre Haute, IN 47807(812) 232 2434

(b)

JS-44 (Rev. 3/08 Rl)I. (a) PLAINTIFFS Na ti on a l O r ga n iz at io n

For Marriage , Inc .

11. BASIS OF JURISDICTION (Place an "X" inOne Box Only)01 U,S, Government

Plaintiff113 Federal Question

(U.S. Government Not a Party)

III. CITIZENSHIPOF PRINCIPAL PARTIES (Place an "X" in One Box for Plain(For Diversity Cases Only) and One Box for Defendant)

PTF DEF PTF DEFCitizen of This State 0 I Do Incorporated or Principal Place 04 04

of Business In This State02 U.S. Government

Defendant04 Diversity

(Indicate Citizenship of Parties in Item III)Citizen of Another State 0 2 02 IncOlporated alld Principal Place 05

of Business In Another State 05

Citizen or Subject of aForeign Country

Foreign Nation

0470RlCOI RICO

Mass Torts0360 OUler Personal Inju

Products LiabilityU 195 Contract ProductLiability

0245 Tort Product Liabili0315 Airplane Product

Liability0345 Marine ProductLiability0355 Motor VehicleProduct Liability0365 Personallnjnry

;. , Product Liability... 0385 Property Damage:l:s Product Liability-;c Professional Malpractice0'" U362 Personal Injury ...OJ,.. Med, Malpractice'0= Motor Vehicleo! l AccidenWSlip and FallS !d350 Motor Vehicles!-< 0360 Other Personal Injur

Other Torts and PersonalIniurv incl. Asbestos cnseU360 ad,er Personal Injur(Fed, Tort Claims Act0310 Airplane0320 Assault. Libel and

Slander0330 Federal Employers'

Liability0360 OtherPersonal Injur0368 Asbestos Personal

Injury

I Social Securily

Prisoner Petitions

Miscellaneous Civil CasesCoutinued

50 AirlineRegs.690 Other (Forfeiture)90 Other(Health Care)

810 Selective Service0870 Taxes (U.S. Plaintiffor

Defendant)0871 IRS-Third Party (26

U.S.c. 7609)890 OtherStatutory Actions891 Agricultural Acts892 Economic StabilizationAct0894 Energy Allocation Act

0895 Freedom oflnfonnationAct

0900 Appeal of FeeDetenllination underEqual Access to JusticeAct

510Motions to VacateSentence (2254)

0510 Motions to VacateSentence (2255)

0530 Genel1ll (Habeas)8535 Death Penalty540 Mandamus and Other8550 Civil Rights (1983). 555 Prison Conditions(1983)I Real and Persoual PropertyB10 Land Condemnation220 Foreclosure0230 Rent, Lease and

Ejechnent0240 Torts to Land8290 All other Real Property380 Other Persollal PropertyDamage

462 Naturalization Application0463 Habeas Corpus Alien

Detainees0465 Other Inunigration Actions

Labor and OccupationalSafe

660 OccupationalSafety/Health

07 J 0 Fair Labor Standards ActOno Labor/ManagementRelations

0730 Labor/ManagementReporting and DisclosureAct

0740 Railway Labor Act0790 Other LaborLitigation

Immi rat iou

o 150 Recovery ofOverpayment andEnforcement of Judgment(Collections)

0151 Medicare Act0152 Recovery of DefaultedStudent Loans (excluding

Veterans)0153 Recovery of

Overpayment ofVeterans' Benefits0370 Other Fraud0440 OtherCivil Rights

(Immigration/Deportation)[]450 Conunerce0460 Deportation8610 Agriculture620Other Food and Drug0625 Drug related seizure of

property8630 Liquor Laws640 Railroadand Truck

I Miscellaneous Civil Cases

893 EnvirOlIDlental MattersEnvironmental Low

Constitutional Law~ 9 5 0 Constitutionality of

State Statutes0440 Other Civil Rights

(ConstitutionalityofFederal Statutes)

Elections and VotingLJ400 StateReapportionment0441 Voting

! l-=IlOther - Civil Rights

: b!440 Other Civil RightsV 043 Housing/AcconmlOdations8444 Welfare

446 Americans withDisabilities

EmploymentDiscrimination

! l ~ Employment;:;u 445 Americans withc... Disabilities... EmploymentOJ 0440 Other -Civil Rights.,0C.E ERISAW'0 IU 791 Employment Ret.c Inc. Security Acto-OJ Other Employmente;. , Benefits0C. Ci,I90 Other - Contracte 442 OtberW Employment

410 Anti-TnlSt

130 Miller Act190 Other Contracts

Antitrust

Securities Law &Stockholder Suits

Construction Contracts

IV. NATURE OF SUIT (Place au "X" in Oue Box Only)

Consumer Credit[]3 71 Truth in Lending[j480 Consumer Credit

Ballkru )tc

0190 Other Contracts

Admiraltv

'""... 0196 franchise&S 0490 Cable/Satellite TV

160 Stockholders' Suits'E OS50 SecuritieslS Conul1oditieslE ExchangeoV-e t -Oth-e-r-.-B-lI-si-n-essl-C-o-m-m-.-/; t - - - - - - - - - - /

422 Appeal 28 U.S.c. 1580423 Withdrawal 28 USc. 157

340 Marine(lnjury toSeamen)o 120 Marine (Other)

CONTINUED OND17'/J:'DC'r;'


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V. ORIGIN (Place an "X" In One Box Only)

(]I:l 02 03 04 Os 06 07Original Removed from Remanded from Reinstated or Transferred from Multidistrict Appeal to District JudgeProceeding State Court Appellate Court Reopened another district Litigation From Magistrate Judgment(Specify)Cite the U,S, Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):42 u.s.c. Sect ion 1983

VI. CAUSE OF ACTION Briefdescription of cause: l"lrst Amenament cnaLLenge to constlL:UL:1Ona.Llcyof cer ta in RI campaign f inance and e lec t ion~ t - ; : : : ) t - " t - P ~

VII. REQUESTED IN 0 Check if this is a Class Action DEMAND $ N/A JURY DEMAND: o Yes []eNoCOMPLAINT Under F.R.C.P. 23 (Check YES 2.!!b:: if demanded in complaint)

VIII. RELATED CASE(S)IF ANY JUDGE DOCKET NUMBER

Because of the need for accurate and complete mfmmatlOn, you should ensure the accuracy ofthe mformallon provided pnor to slgnmg the fOlm.

.Date8/30/10

INSTRUCTIONS FORCOMPLETINGCIVIL COVER SHEET JS- 4Authority for Civil Cover SheetThe JS-44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleadings or other papers as require

by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Cof COUlt for the purpose of initiating the civil docket sheet. Consequently a civil cover sheet is submitted to the Clerk of COUlt for each civil complaint tiled. Listed beloware tips for completing the civil cover sheet. These tips coincide with the Roman Numerals on the Cover Sheet.


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Complaint filed by NOM in Rhode Island

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