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Judge Joseph M. Cosgrove (Ret) Retired Judge of Commonwealth Court and the Court of Common Pleas of Luzerne County

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Judge Joseph M. Cosgrove (Ret) Retired Judge of Commonwealth Court and the Court of Common Pleas of Luzerne County FREEDOM OF ASSEMBLY CLE – Wilkes Barre Law and Library Association March 4, 2021 A JudGe’s perspective: Judge Joseph M. Cosgrove (ret) Retired judGe of Commonwealth Court and The Court of Common Pleas of Luzerne County This continuing education course is premised on review of the parameters guiding the constitutional concept of freedom of assembly. As with all matters of constitutional civil liberty, the presumed right to assemble will not see any case law evolution unless a question arises as to its legitimacy, i.e., unless someone is arrested and the opportunity for judicial review is present. That, of course, has been a large part of the American experience, from the Boston Massacre through the Civil War draft riots, the Civil Rights movement, the protests against the Vietnam War, up to the insurrection of January 6. How judges approach these matters is of utmost importance to the protection of liberty interests as well as the protection of the public’s safety. This balance may, at times, be difficult to find. Consider three judges who, at least in part (and perhaps, in large part) did not get it “right” when it came to fulfilling their role in the context of trials resulting from organized protest. Do these examples offer us a perspective on a judge’s role in civil rights/civil liberty matters, especially the right to “assemble”? And how is the practitioner to “deal” with the “difficult” judge in this context? 1 Judge Eugene Carter: With the legally ordered segregation of public transportation, a young minister named Martin Luther King was faced with addressing the purposeful “disobedience” of Rosa Parks, an African American who was arrested for refusing to surrender her up-front bus seat to a White passenger. Involving himself directly in the Montgomery Bus Boycott, Dr. King was charged with violating state law. His non-jury trial was before Judge Carter, who was described in a law review article as “an ardent segregationist who once sponsored a resolution at his church barring [African Americans] from the premises unless they were performing janitorial services.” Randall Kennedy, Martin Luther King's Constitution: A Legal History of the Montgomery Bus Boycott, 98 Yale L.J. 999, 1030. Along with possessing such inherent racial bias, Judge Carter was criticized for proceeding as trial judge when he was also “a prime mover in obtaining an indictment from the grand jury,” id. at 1038, having “brought to the attention of the grand jury the question of whether the boycott violated state law.” Id. at 1029-1030. Dr. King was found guilty, “assessed court costs and fined $500.” Id. at 1034. While “[e]ven Judge Carter acknowledged that [Dr.] King had worked hard to prevent violence and ex-pressly refrained from sentencing him to jail for precisely that reason,” id. at 1041, “[w]hen [Dr. King] indicated that he would not pay the fine, Judge Carter sentenced him ‘to hard labor in Montgomery County for 140 days for the fine and 246 additional days for the [court] cost.’ Later, someone paid the fine on King's behalf.” Id. at 1034. (internal citations omitted). Judge Julius Hoffman: The Trial of the Chicago 7 (originally, the “8”) is one of the most remarkable stories emanating from the turbulence of the Vietnam Era and 60’s political upheaval. The story of the trial is currently on display in an Aaron Sorkin film, but for our purposes, consideration of the manner in which Judge Hoffman conducted the trial is worthy of 2 review. Here is an analysis offered in a law review article several decades later, which not only criticizes Judge Hoffman but also suggests that he is not alone in the judicial firmament: Judge Hoffman's conduct was heavily criticized by the Seventh Circuit for numerous deficiencies: (1) failing to conduct a more extensive voir dire into the attitudes of prospective jurors given the extraordinary setting involving nation-wide protests against the Vietnam War, the extensive attention in the media to the youth culture, and the aggressive actions of the Chicago police; (2) communicating privately with jurors during their deliberations without making a record or alerting the defense; (3) preventing the defense from presenting expert witnesses to testify on crowd dynamics and police tactics relating to crowd control; and (4) excluding exculpatory statements by some of the defendants relating to their state of mind while traveling to Chicago. But by far the most enduring image from that trial was Judge Hoffman's antagonistic and abusive conduct toward the defendants, their lawyers, and courtroom spectators. As the Seventh Circuit remarked, "Trial decorum often fell victim to dramatic and emotionally inflammatory episodes." The most inflammatory episode was Judge Hoffman's brutal treatment of defendant Bobby Scale, whose insistence on representing himself incited Judge Hoffman to order him bound and gagged. Stoking fear of a breakdown in the proceedings, Judge Hoffman commanded nineteen marshals to be stationed around the courtroom, which gave the trial an aura of military-like repression. Judge Hoffman displayed throughout the trial an unremitting hostility toward the defendants and their lawyers. Bennett L. Gershman, Judging Judges Fifty Years After – Was Judge Julius Hoffman’s Conduct so Different?, 50 Loy. U. Chi. L.J. 839, 840-841 (2019)(internal citations omitted) Judge Samuel Salus: Closer to home, the conduct of a Pennsylvania judge during the trial of anti-nuclear demonstrators, particularly at sentencing, caused the Superior Court to order a new trial and direct that a new judge preside.1 After the Supreme Court reversed and remanded, the Superior Court affirmed the verdict but ordered a new sentencing, again with a new judge presiding. This decision was left intact by the Supreme Court. Judge Salus’ conduct relative to the original sentencing was outlined in the Superior Court’s subsequent opinion. 1 In the interest of full disclosure, I was a participating counsel during the appellate and resentencing phases of this case. 3 Judge Salus responded to numerous letters sent in support of the defendants, and spoke to the press as well. These responses were problematic, some outlined here: The law has learned from history that you deal in the past, present, and future from equality, not weakness. The hordes of Nazis would not have overrun Europe in World War II if there had been equality in armaments. Would Chamberlain's appeasement have ever stopped Hitler? Lift your head from the sand and see the world as it always is and always was! It is part of [the defendants'] policy and tactics to delude people about their good intentions when their sole purpose is to have no master, no government, and really, no God. Salus: ‘Even their letters of support and advice show signs of vocabulary similarities, the same propaganda, and even some thought control.’ Salus: “The receipt of mail from various states and various sectors of the community at various times points to and gives an uneasy sense of conspiracy and prompting by those herein involved. Such witch hunts and conspiracies have been condemned with respect to any individual in government, the majority, or in this case, any minority view espousing a particular cause.” Com. v. Berrigan, 535 A.2d 91, 104-105 (Pa. Super. 1987) In directing that a new judge preside at resentencing, the Superior Court noted that “[w]hen a judge implies that he is the target of a ‘witch hunt’ secretly organized by a defendant by means of ‘thought control’, we think that there is good reason for that judge to step aside before pronouncing sentence.” Id. at 105. --------- As afternote, consider the difficult job of a judge in maintaining order while at the same time allowing for full advocacy in cases where political issues and tensions are at their hottest. How do these experiences temper our dedication to freedom while also preserving our most cherish institutions? 4 .
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