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Page 1 of 32 in the UNITED STATES DISTRICT IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF MISSISSIPPI Northern Division JASON ALAN GRIGGS, DERENDA HANCOCK, L. KIM GIBSON, MISSISSIPPI HUMANIST ASSOCIATION, and AMERICAN ATHEISTS, INC., Case No._________________ Plaintiffs, JURY TRIAL REQUESTED v. CHRIS GRAHAM, COMMISSIONER OF REVENUE, in his official capacity, Defendant. COMPLAINT INTRODUCTION 1. No state may force a person to be a mouthpiece for the government’s preferred message. This freedom from compelled speech is a foundational tenet of American society. Yet the State of Mississippi demands exactly that from every single car owner1 in the state. In so doing, the state is violating of nearly a century of settled First Amendment law. 1 For the sake of brevity, Plaintiffs will generally refer to owners of motor vehicles and trailers, as those terms are defined in Miss. Code Ann. § 27-19-3(a) (2021), as “car owners.” Page 1 of 32 2. Mississippi law requires most car owners to choose between displaying the state’s standard license tag (“Standard Tag”) on their vehicles or instead pay an additional fee to display a special tag of their choice (“Paid Specialty Tag”). Since 2019, the Standard Tag has contained an ideological, religious message, “IN GOD WE TRUST,” and the vast majority of Mississippi’s car owners have faced a choice: turn their personal vehicles into billboards for the state’s message or pay an additional fee for a Paid Specialty Tag. 3. Other Mississippi car owners are not even afforded a choice. Mississippi residents who operate RVs, motorcycles, or trailers must display a license tag derived from the current Standard Tag design, with the state’s accompanying message. 4. Perversely, any Mississippi car owner who wishes to use her vehicle to convey her own custom message by obtaining a personalized license tag (“Personalized Tag”) with alphanumeric combinations of her own choosing is forced to also send the state’s message because only the current Standard Tag design, rather than the designs of Paid Specialty Tags, can be personalized. 5. This statutory and regulatory regime violates numerous Mississippi car owners’ right to be free from compelled speech. To remedy this violation, Mississippi must offer car owners an alternative to the Standard Tag. 6. This is not an action challenging the national motto. Nor is this an action challenging the Seal of the State of Mississippi. This is an action challenging the statutes, rules, policies, practices, and customs enforced by Defendant Chris Graham, as the Commissioner of Revenue, that together require Mississippi’s nonreligious Page 2 of 32 drivers to display the government’s preferred ideological, religious message on their vehicles or, if they refuse to do so, pay higher fees to legally drive their vehicles. 7. These statutes, rules, policies, practices, and customs operate to impose on the Plaintiffs language with a long and substantial history of hostility toward atheists and other non-Christians. PARTIES 8. Plaintiff Jason Alan Griggs (“Jason”) is a resident of Brandon, Mississippi. 9. Plaintiff Derenda Hancock (“Derenda”) is a resident of Brandon, Mississippi. 10. Plaintiff L. Kim Gibson (“Kim”) is a resident of Jackson, Mississippi. 11. The Mississippi Humanist Association (“MHA”) is a 501(c)(3) nonprofit corporation based in Jackson, Mississippi. The MHA works toward providing opportunities for secular humanists to come together for social events and to volunteer and fundraise for charitable causes, as well as to inform and educate their fellow Mississippians about Humanism. The MHA has dozens of members across Mississippi. 12. American Atheists, Inc. (“American Atheists”), is a 501(c)(3) nonprofit corporation based in Cranford, New Jersey. American Atheists is dedicated to the separation of religion and government and elevating atheists and atheism in our nation’s public and political discourse. American Atheists has more than 350,000 members and supporters across the country, including in the State of Mississippi. 13. Defendant Chris Graham is the Commissioner of Revenue of the Department of Revenue (“Commissioner”). By statute, the Commissioner, as head of Page 3 of 32 the Mississippi Department of Revenue, is responsible for administering and enforcing Title 27 of the Mississippi Code, including the state’s Motor Vehicle Privilege Taxes. Miss. Code Ann. §§ 27-3-3, 27-19-1 (2021). JURISDICTION AND VENUE 14. This is an action arising under 42 U.S.C. §§ 1983 and 1988 to redress the deprivation, under color of state law, of rights secured by the First and Fourteenth Amendments to the United States Constitution. 15. Declaratory relief is authorized by Rule 57 of the Federal Rules of Civil Procedure and 28 U.S.C. §§ 2201 and 2202. 16. This Court has jurisdiction over this action pursuant to 28 U.S.C. §§ 1331 (federal question jurisdiction) and 1343 (civil rights jurisdiction). 17. Venue is proper in this Court under 28 U.S.C. § 1391(b)(1) and (b)(2). The Defendant is located within the District and a substantial part of the events giving rise to this claim occurred in this District. 18. The Eleventh Amendment of the U.S. Constitution does not preclude this Court’s jurisdiction because the defendant, a state employee responsible for enforcement of section 27-19-31 of the Mississippi Code, is sued here in his official capacity for declaratory and injunctive relief prohibiting the future unconstitutional enforcement of section 27-19-31(1) against the Plaintiffs. Ex parte Young, 209 U.S. 123, 154-56 (1908); Verizon Md. Inc. v. PSC, 535 U.S. 635, 645 (2002). Page 4 of 32 FACTUAL ALLEGATIONS Mississippi License Tags 19. Mississippi car owners must display one valid license tag and decal on their vehicles and trailers at all times. A car owner who fails to do so is guilty of a misdemeanor and faces a fine of up to $25.00. Miss. Code Ann. § 27-19-31(2) (2021). 20. The Defendant, as the Commissioner of the Mississippi Department of Revenue, is responsible for issuing license tags to Mississippi car owners and collecting the associated fees and taxes. § 27-19-31(1). 21. The Defendant, in the course of enforcing section 27-19-31, has established regulations, policies, practices, and customs governing the operation of the Department of Revenue. 22. Unless a car owner qualifies for certain narrowly defined categories, see ¶ 31, below, she must choose between a license tag designed by the Mississippi License Tag Commission (“Commission”), available at no added cost, or a Paid Specialty Tag, for which a car owner is required to pay an additional fee. 23. Owners of trailers, RVs, and motorcycles do not have the option to place Paid Specialty Tags on these types of vehicles. These individuals must display “IN GOD WE TRUST” on their vehicles as part of a license tag derived from the current Standard Tag design. 24. By statute, it is a misdemeanor punishable by a fine of up to $25 to deface, cover, or obstruct any portion of a license tag in a manner that obscures any of the characters on the tag. § 27-19-31(2). Page 5 of 32 25. Section 27-19-31(1) directs the Mississippi License Tag Commission to issue a Standard Tag design for a period of 5 years for non-fleet motor vehicles of equal or less than 10,000 pounds gross vehicle weight and for non-fleet trailers. 26. Pursuant to this statute, the Commission was to issue a new Standard Tag in 2017. However, delays in the allocation of funds for a new design resulted in the current Standard Tag being issued in 2019. 27. The Standard Tag currently bears a design announced by then-governor Phil Bryant on Thursday, May 10, 2018. The design contains “MISSISSIPPI” in stylized letters centered at the top of the tag and the county of registration in capital letters centered at the bottom of the tag. Displayed between the name of the state and the name of the county is the registration of the vehicle to which it is affixed. The registration consists of three characters followed by a space followed by four characters. The design also features the state seal off-center over a background described as “bronze,” “gold,” or “dirt-colored.” 28. Mississippi adopted a new design for its state seal in 2014, adding the words “IN GOD WE TRUST” under the eagle depicted in the state’s prior seal. 29. Almost all of the seal, including the entirety of the words “IN GOD WE TRUST,” appears in the space between the first three characters of the registration and the last four characters of the registration. Depending on the third and fourth character of the registration, a portion of the left-most and right-most edges of the seal may be obscured. 30. Pursuant to section 27-19-31(1), the current Standard Tag will remain in Page 6 of 32 use in Mississippi until at least 2024. 31. In addition to the Standard Tag issued by the License Tag Commission, Mississippi law provides special tags at no additional fee to individuals who fall within certain narrowly defined categories (“Alternate Tags”): a. Active duty or retired armed forces: available to active or retired members of the Armed Forces of the United States, including the Army National Guard, Air National Guard, the United States Reserves, and the United States Merchant Marines, or their surviving spouses, upon providing proof of their membership in the form of a certificate signed by the member’s commanding officer on forms prescribed by the Adjutant General of Mississippi; (Miss. Code Ann. § 27-19-51 (2021)) b. Government officials and veterans’ group commanders: available to United States Senators; members of the United States House of Representatives; former United States Congressmen and Senators; State Commanders of the American Legion, Veterans of Foreign Wars, and The Forty and Eight; and enforcement and investigative personnel of the State Tax Commission, Public Service Commission, Mississippi Department of Public Safety, Mississippi Department of Transportation, or Mississippi Bureau of Narcotics, upon providing certification of eligibility; (Miss.
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