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As Promised: YAF Sues Berkeley for Free Speech Violations - Young America's Foundation
Full complaint included here: http://www.yaf.org/wp-content/uploads/2017/04/20170424-YAF-Complaint_condensed1.pdf
"After offering and discussing all of the above potential venues with BCR and YAF, Defendants suddenly announced to BCR, YAF, and BridgeCal the imposition of the newly adopted High-Profile Speaker Policy, unreasonably restricting the time and place at which Ms. Coulter could speak. After initially canceling the event, the University and Defendants offered a purported alternative date – that effectively relegated the event out of existence.
83. Following BCR and YAF’s rejection of the sham alternative date of May 2, the University and Defendants have maliciously and publicly made numerous false statements about the series of events leading up to their unilateral cancellation of the Coulter Event, falsely indicating that the University only learned that Ms. Coulter would be speaking on campus through the press, and that BCR had failed to provide four weeks’ notice that the event would be held on the University campus.
84. These representations are categorically false. As described above, the University and Defendants were provided with ample notice, no less than six weeks prior to the event, and BCR provided the University with confirmed date of April 27, 2017, on March 28, 2017, more than four weeks prior to the event, which is documented by email communications between BridgeCal, BCR, YAF and University officials.
85. The University has attempted to bully BCR and BridgeCal out of holding the Coulter Event at all, by escalating the arbitrary requirements on the event, concealing the High-Profile Speaker Policy until shortly before the University’s cancellation, and concealing their true intentions behind a smokescreen of platitudes and misrepresentations. The High-Profile Speaker Policy, with its infinitely malleable “securable location” parameters, ensures that University officials can pick and choose which speech to permit, and then justify their illegitimate censorship by pointing to their unwritten and unconstitutional policy.
86. In addition to substituting their private speech criteria for the free speech requirements mandated by the Constitution, University officials concede that they allow the tastes and criminal actions of a masked mob to define who they allow to speak at U.C. Berkeley. In a letter dated April 21, 2017 to legal counsel for YAF and BRC, Campus Counsel Christopher M. Patti admitted to Harmeet K. Dhillon that UC Berkeley’s decision to cancel the Coulter Event was triggered by a “security assessment” by the UCPD which revealed “mounting intelligence that some of the same groups that previously engaged in local violent action also intended violence at the Coulter Event.” Mr. Patti appears to be referring to the so-called “antifa” groups from outside the campus indulging in violence at Berkeley to silence conservatives gathering in or around the UC Berkeley campus – who appear to have more power and rights on the campus than students showing their faces, paying tuition, and seeking a balanced educational environment at a publicly-funded institution of higher learning."
And yes, that's less than 20% of the complaint.
Full complaint included here: http://www.yaf.org/wp-content/uploads/2017/04/20170424-YAF-Complaint_condensed1.pdf
"After offering and discussing all of the above potential venues with BCR and YAF, Defendants suddenly announced to BCR, YAF, and BridgeCal the imposition of the newly adopted High-Profile Speaker Policy, unreasonably restricting the time and place at which Ms. Coulter could speak. After initially canceling the event, the University and Defendants offered a purported alternative date – that effectively relegated the event out of existence.
83. Following BCR and YAF’s rejection of the sham alternative date of May 2, the University and Defendants have maliciously and publicly made numerous false statements about the series of events leading up to their unilateral cancellation of the Coulter Event, falsely indicating that the University only learned that Ms. Coulter would be speaking on campus through the press, and that BCR had failed to provide four weeks’ notice that the event would be held on the University campus.
84. These representations are categorically false. As described above, the University and Defendants were provided with ample notice, no less than six weeks prior to the event, and BCR provided the University with confirmed date of April 27, 2017, on March 28, 2017, more than four weeks prior to the event, which is documented by email communications between BridgeCal, BCR, YAF and University officials.
85. The University has attempted to bully BCR and BridgeCal out of holding the Coulter Event at all, by escalating the arbitrary requirements on the event, concealing the High-Profile Speaker Policy until shortly before the University’s cancellation, and concealing their true intentions behind a smokescreen of platitudes and misrepresentations. The High-Profile Speaker Policy, with its infinitely malleable “securable location” parameters, ensures that University officials can pick and choose which speech to permit, and then justify their illegitimate censorship by pointing to their unwritten and unconstitutional policy.
86. In addition to substituting their private speech criteria for the free speech requirements mandated by the Constitution, University officials concede that they allow the tastes and criminal actions of a masked mob to define who they allow to speak at U.C. Berkeley. In a letter dated April 21, 2017 to legal counsel for YAF and BRC, Campus Counsel Christopher M. Patti admitted to Harmeet K. Dhillon that UC Berkeley’s decision to cancel the Coulter Event was triggered by a “security assessment” by the UCPD which revealed “mounting intelligence that some of the same groups that previously engaged in local violent action also intended violence at the Coulter Event.” Mr. Patti appears to be referring to the so-called “antifa” groups from outside the campus indulging in violence at Berkeley to silence conservatives gathering in or around the UC Berkeley campus – who appear to have more power and rights on the campus than students showing their faces, paying tuition, and seeking a balanced educational environment at a publicly-funded institution of higher learning."
And yes, that's less than 20% of the complaint.