In the Supreme Court of the Kingdom of Camelot

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No. [05]24-007 In the Supreme Court of the Kingdom of Camelot

MORDRED, PETITIONER v. KINGDOM OF CAMELOT

ON WRIT OF CERTIORARI TO THE COURT OF APPEALS FOR THE DISTRICT OF CAMELOT CIRCUIT

BRIEF FOR THE KINGDOM OF CAMELOT

NOEL J. FRANCISCO Solicitor General Counsel of Record ERICA L. ROSS Assistant to the Solicitor General MARGARET A. UPSHAW Attorney Department of Justice Washington, D.C. 20530- 0001 (202) 514-2217

QUESTIONS PRESENTED 1. Whether, as applied in this case, 18 Cam. Code 2385 violates petitioner’s First Amendment rights of free speech and association. 2. Whether, viewing all of the evidence in the light most favorable to the Kingdom of Camelot, a reasonable jury could have found that petitioner violated 18 Cam. Code 2383 and 2385.

(I) TABLE OF CONTENTS Page Statement ...... 1 Summary of argument ...... 6 Argument: A. Section 2385 does not violate the Camelotian First Amendment as applied to petitioner ...... 7 B. “The jury decides”: Sufficient evidence supports the guilty verdict ...... 13 Conclusion ...... 16

TABLE OF AUTHORITIES

Cases: Brandenburg v. Ohio, 395 U.S. 444 (1969) ...... 7, 9, 10 Brown v. Entertainment Merchs. Ass’n, 564 U.S. 786 (2011)...... 9 Chaplinsky v. New Hampshire, 315 U.S. 568 (1942) ...... 9 Dennis v. United States, 341 U.S. 494 (1951) ...... 7, 8, 9, 10, 15, 16 Jackson v. Virginia, 443 U.S. 307 (1979) ...... 7, 13 Noto v. United States, 367 U.S. 290 (1961) ...... 9 Parker v. Levy, 417 U.S. 733 (1974) ...... 12 Pinkerton v. United States, 328 U.S. 640 (1946) ...... 11 Scales v. United States, 367 U.S. 203 (1961) ...... 9, 10, 14 United States v. Scheffer, 523 U.S. 303 (1998) ...... 14 United States v. Silverman, 248 F.2d 671 (2d Cir. 1957), cert. denied, 355 U.S. 942 (1958) ...... 8 Yates v. United States, 354 U.S. 298 (1957) ...... 10, 11

Constitution and statutes: Cam. Const. Amend. I ...... 7, 8, 9, 12, 13 Smith Act of 1940, 18 U.S.C. 2385 ...... 9

(III) IV

Statutes—Continued: Page 18 Cam. Code 2383 ...... 1, 2, 6, 8, 13, 14 18 Cam. Code 2385 ...... passim

In the Supreme Court of the Kingdom of Camelot

No. [05]24-007 MORDRED, PETITIONER v. KINGDOM OF CAMELOT

ON WRIT OF CERTIORARI TO THE COURT OF APPEALS FOR THE DISTRICT OF CAMELOT CIRCUIT

BRIEF FOR THE KINGDOM OF CAMELOT

STATEMENT Following a jury trial in the District Court for the District of Camelot, petitioner was convicted on one count of inciting and engaging in a rebellion and insurrection against the authority of the Kingdom of Camelot and its laws, in violation of 18 Cam. Code 2383, and one count of advocating the overthrow by force of Camelot’s government, in violation of 18 Cam. Code 2385. Sce- nario 2. The Court of Appeals for the District of Came- lot Circuit affirmed. Ibid. 1. Recognizing that “[m]ight doesn’t always mean right,” King Arthur set out to establish a “new order of chivalry” in the Kingdom of Camelot. Cam. 1.3, at 17,

(1) 2

19.1 The new order, in which “might is only used for right, to improve instead of destroy,” called for “all the knights, good or bad, to lay down their arms” and “gather at the table” to “talk! Discuss! Make laws! Plan improvements!” Cam. 1.3, at 20. In short, King Arthur sought to fulfill his promise to all Camelotians to “Make Camelot Great Again.” (@RealKingArthur) Among his many efforts to drain the swamp, King Arthur’s reforms ensured that “[d]isputes will be set- tled by law and not by bloodshed.” Cam. 2.2, at 60; see Cam. 2.3, at 67. (“[W]e practice civil law now and we cannot take the law back into our own hands.”). He thus established courts with “prosecutor[s]” and “defender[s]” who would “argue” “[w]ith words,” as well as “impartial” juries to decide cases. Cam. 2.2, at 60-61. These reforms, moreover, would be backed by a robust pardon power that allowed the King to right any wrongs that this new system might inadvertently produce. At the same time, the Camelot Code was enacted to ensure continued peace among the people. In addition to guaranteeing that “the climate must be perfect all the year,” Cam. 1.1, at 11A (capitalization omitted), the Camelot Code protected the people from violence, in- fighting, and attempts at subversion by those embedded within the deep state. As relevant here, Section 2383 of Title 18 of the Camelot Code made it a crime to “incite[], set[] on foot, assist[], or engage[] in any rebellion or insurrection against the authority of the [Kingdom of Cam- elot] or the laws thereof,” 18 Cam. Code 2383, while Sec- tion 2385 of Title 18 of the Camelot Code outlawed

1 References to “Cam. X.Y, at Z” are to Act X, Scene Y, page Z of the March 2, 2018 draft of Camelot by Alan Jay Lerner and Fred- erick Loewe, directed by Alan Paul at the Shakespeare Theatre.

“knowingly or willfully advocat[ing], abet[ting], advis- [ing], or teach[ing] the duty, necessity, desirability, or propriety of overthrowing or destroying the government of the [Kingdom of Camelot] * * * by force or violence,” 18 Cam. Code 2385. For a period, King Arthur’s vision for a peaceful order came to fruition, and it seemed as though “when people hear[d] . . . what ha[d] happened at Camelot . . . they m[ight] lay down their arms” altogether. Cam. 1.8, at 54. Indeed, conditions were so tranquil that nearly everyone agreed “there’s simply not a more congenial spot for happ’ly-ever-aftering than here in Camelot.” Cam. 1.1, at 12 (capitalization omitted). 2. Unfortunately, not everyone shared King Ar- thur’s desire to drain the swamp. Petitioner, the illegitimate son of King Arthur and the Queen of Scotland, see Cam. 2.1, at 57; Cam. 2.2, at 63; Scenario 1, arrived in Camelot with nefarious intentions, seeking to destroy the Round Table and gain control of the White Castle and the entire Kingdom of Camelot. See Cam. 2.1, at 57; Scenario 1. Unlike those who seek to overthrow the government to advance their own political ideology, petitioner’s mo- tives were entirely personal. He harbored a profound bitterness about his status as an illegitimate son, as well as his foreign birth to the Queen of Scotland. By his own account, petitioner’s mother was a selfish and unpleasant person, and his stepfather “despised” him. Cam. 2.2, at 63. In light of this difficult upbringing, petitioner resented that his father abandoned him only to become “the King of all England.” Ibid. Seeking to “destroy” King Arthur and “make his in- heritance come faster,” Scenario 1, and motivated by a deep disdain for the values at the very foundation of the

Kingdom, see Cam. 2.2, at 64 (“The seven deadly virtues”); Cam. 2.4, at 72 (“Fie on Goodness), petitioner set in motion a plan to incite rebellion and overthrow the Arthurian administration. His plan was evident to all. Even before petitioner’s appearance on the (world) stage, Merlyn sought to “warn” King Arthur about him, Cam. 1.2, at 16; and after his arrival, Sir Lancelot ad- vised the King to “[g]et rid of ” petitioner as “quickly” as possible because he was “bent on the destruction of the [Round] Table,” Cam. 2.3, at 66. Indeed, King Ar- thur himself recognized that he had “sired a skunk.” Ibid. Nor was petitioner shy about his intentions: He told all who would listen that “[i]n a little while, I shall be in charge of this castle, and shortly after that . . . this kingdom.” Cam. 2.1, at 57 (emphasis omitted). Petitioner went about his aims through treachery, force, and objectionable songs—all aided and abetted by the fake news peddled by the failing Camelot News Network. Using his newly-appointed post as the Minister of Justice, petitioner “stirr[ed] up the Knights to defy Arthur and to abandon the newly established rule of law.” Scenario 1. He looked on with “amuse- ment” while knights fought with swords, Cam. 2.4, at 72 (emphasis omitted), and he led them in a song about burning towns and killing men, Cam. 2.4, at 73; see Scenario 2. Petitioner observed that Queen Guenevere and Sir Lancelot, King Arthur’s Minister of Defense and head of the knights of the Round Table, were attracted to one another, and he saw in their love an opportunity to destabilize the Kingdom of Camelot. See Scenario 1. Petitioner insinuated at every turn that Sir Lancelot and Queen Guenevere would betray King Arthur. See, e.g., Cam. 2.1, at 57 (“Ah me, the chain of wedlock is so heavy that it takes two to carry it,

5 sometimes three.”); ibid. (“Delicious little rumors are skipping about these days. Such as the round table is not round. It’s a triangle.”); Cam. 2.2, at 63 (“And where the famous Lancelot? Or does he stand in between” the King and Queen?). And he convinced King Arthur to stay away from the castle for a night to test Sir Lancelot’s and Queen Guenevere’s virtue. Cam. 2.5, at 78; see Scenario 1. At the same time, abusing his position as Minister of Justice—and failing to provide King Arthur with the “honest loyalty” he had promised—petitioner sought and obtained a warrant from the Camelot Special Intelligence Court (CSIC) to surveil Sir Lancelot. Scenario 1; see Cam. 2.2, at 64 (Petitioner promised to “try” to “earn the right to knighthood by virtue and proper deeds.”). The ill- gotten warrant allowed petitioner and his agents to be present outside the Queen’s bedchamber when, with King Arthur away, Sir Lancelot and Queen Guenevere ultimately embraced there. Scenario 1; see Cam. 2.6, at 80-81. Petitioner then seized the Queen by force and arrested her for treason. Scenario 2; Cam. 2.6, at 81. The Queen was convicted by a jury and “sentenced to the flame.” Cam. 2.7, at 82 (capitalization omitted). The failing Camelot News Network covered the story obsessively, distorting many facts along the way. And just as petitioner had hoped, these events put King Arthur in a “magnificent dilemma.” Cam. 2.7, at 83. Pe- titioner rejoiced as the King was forced to choose between “[k]ill[ing] the Queen or kill[ing] the law.” Ibid. As petitioner had planned, Queen Guenevere’s arrest and conviction led to a violent confrontation: Sir Lance- lot, who escaped arrest and fled to France, returned to rescue the Queen, killing many knights in the process. Scenario 2; see Cam. 2.7, at 85 (“Can you see your

6 goodly Lancelot murdering your goodly knights?”); Cam. 2.8, at 88 (“Over half the knights were killed in the yard.”). Other knights joined in the carnage, burning Camelot’s towns and killing its citizens. Scenario 2; see Cam. 2.8, at 88. All the while, petitioner gloated and admitted that his own “ruthless[ness]” had put these events in motion. Cam. 2.7, at 85. As petitioner fled to Scotland with some of the remaining knights, Scenario 2, King Arthur astutely inferred that petitioner had mo- bilized the deep state to “organize an army against [him],” Cam. 2.8, at 88. 3. Even as petitioner called for the Kingdom’s destruction, King Arthur stayed true to the Camelotian adage that when a citizen “violates the law, the law shall deal with him.” Cam. 2.3, at 67. And so it has. Peti- tioner was arrested and indicted on one count of inciting and engaging in a rebellion and insurrection against the authority of the Kingdom of Camelot and its laws, in violation of 18 Cam. Code 2383, and one count of advocating the overthrow by force of Camelot’s government, in violation of 18 Cam. Code 2385. Scenario 2. Petitioner’s case was tried to a jury so “impartial” they cared not “a fig” who won. Cam 2.2, at 61. The jury returned a verdict of guilty on both counts. The Court of Appeals for the District of Camelot Circuit affirmed. Scenario 2. Justice was done. SUMMARY OF ARGUMENT In striving to settle disputes “by law and not by bloodshed,” Cam. 2.2, at 60, the Kingdom of Camelot has followed the sterling example of the United States. The constitutional and statutory provisions involved in this case thus mirror those of the United States, and the courts of the Kingdom of Camelot interpret them by

7 reference to the case law of the United States Supreme Court and the federal courts of appeals. A. Petitioner argues (Scenario 2) that Section 2385 of Title 18 of the Camelot Code, as applied to his case, violates his rights to speech and association under the Camelotian First Amendment. But the Camelotian Constitution is not a suicide pact. Although Camelot recognizes the value of free speech, the “ultimate value of any society” is the preservation of “its very structure,” which protects all other values. Dennis v. United States, 341 U.S. 494, 509 (1951) (plurality opinion). Ap- plying that principle, Camelotian courts have held that a conviction for advocating the violent overthrow of the government does not offend the First Amendment if such advocacy is directed to inciting imminent lawless action and is likely to produce such action. Ibid.; see Brandenburg v. Ohio, 395 U.S. 444, 447 (1969) (per curiam). Because petitioner’s cowardly conduct satisfies that standard, application of Section 2385 to him does not violate his First Amendment rights. B. Petitioner further contends (Scenario 2) that in- sufficient evidence supports the jury’s verdict of conviction. But substantial deference is due to the verdict of the “impartial” jury. Cam. 2.2, at 61; see Jackson v. Vir- ginia, 443 U.S. 307, 319 (1979) (“[T]he relevant question is whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.”). Here, testimony and evidence at trial amply established that petitioner incited and engaged in a rebellion against the Kingdom of Cam- elot and willfully advocated the overthrow of the King- dom’s government by force, with the intent that such a violent overthrow occur.

The decision of the court of appeals should be affirmed. ARGUMENT

A. Section 2385 Does Not Violate The Camelotian First Amendment As Applied To Petitioner Petitioner was convicted of advocating the overthrow of the Camelotian government by force, in violation of 18 Cam. Code 2385. Scenario 2. Petitioner contends that, as applied to his case, Section 2385 violates the Camelotian First Amendment, which (like its American progenitor) provides that the Camelotian “Congress shall make no law * * * abridging the freedom of speech * * * or the right of the people peaceably to assemble.” Cam. Const. Amend. I.2 Petitioner’s argument is totally false. “That it is within the power of the Congress to protect the Govern- ment of [Camelot] from armed rebellion is a proposition which requires little discussion.” Dennis v. United States, 341 U.S. 494, 501 (1951) (plurality opinion) (emphasis omitted). Such protection from “violence, revolution and terrorism,” ibid., is “the ultimate value of any society, for if a society cannot protect its very structure from armed internal attack, it must follow that no sub- ordinate value can be protected,” id. at 509.

2 Petitioner also was convicted of inciting and engaging in a rebellion and insurrection against the authority of the Kingdom of Cam- elot and its laws, in violation of 18 Cam. Code 2383. Scenario 2. Pe- titioner does not challenge that conviction on First Amendment grounds, see ibid., and for good reason: petitioner’s conviction under Section 2383 punishes his conduct, not his speech. Cf. United States v. Silverman, 248 F.2d 671, 676 (2d Cir. 1957) (noting that the “speech element” of Section 2385’s advocacy provision distinguishes it from the offense in Section 2383), cert. denied, 355 U.S. 942 (1958).

1. To balance the government’s substantial interest in preventing violent revolution with the First Amend- ment’s protection of the right to free speech and association, Camelotian courts have followed the American “principle that the constitutional guarantees of free speech and free press do not permit [the government] to forbid or proscribe advocacy of the use of force or of law violation except where such advocacy is directed to inciting or producing imminent lawless action and is likely to incite or produce such action.” Brandenburg v. Ohio, 395 U.S. 444, 447 (1969) (per curiam); see Dennis, 341 U.S. at 508 (plurality opinion) (similar). Such advocacy to imminent, lawless action “is not constitutionally protected speech” and “a combination to promote such advocacy * * * is not such association as is protected by the First Amendment.” Scales v. United States, 367 U.S. 203, 228-229 (1961); see Brown v. Entertain- ment Merchs. Ass’n, 564 U.S. 786, 791 (2011) (recognizing “incitement” under Brandenburg as one of the few, “well-defined and narrowly limited classes of speech, the prevention and punishment of which have never been thought to raise any Constitutional problem”) (quoting Chaplinsky v. New Hampshire, 315 U.S. 568, 571-572 (1942)). The key distinction is between “the mere abstract teaching . . . of the moral propriety or even moral necessity for a resort to force and violence,” which is protected by the First Amendment, and “preparing a group for violent action and steeling it to such action,” which is not. Brandenburg, 395 U.S. at 448 (quoting Noto v. United States, 367 U.S. 290, 297-298 (1961)). In Dennis, supra, the Court upheld convictions under the Smith Act of 1940, 18 U.S.C. 2385—which is materially similar to the Camelotian provision at issue here—where the jury

10 instructions provided that the statute prohibits only “the teaching and advocacy of action” to overthrow or destroy the government by unlawful means “by lan- guage reasonably and ordinarily calculated to incite persons to such action.” 341 U.S. at 511 (plurality opinion). By contrast, in Yates v. United States, 354 U.S. 298 (1957), the Court held that convictions under the Smith Act of 1940 could not stand where the jury instructions failed to make “[t]he essential distinction” that “those to whom the advocacy is addressed must be urged to do something, now or in the future, rather than merely to believe in something.” Id. at 324-325; see also Scales, 367 U.S. at 232, 234 (“Yates makes clear” that evidence regarding the “teaching of Marxism-Leninism,” “dissemination of the [Communist] Party’s general lit- erature,” and “statements by officials evidencing sym- pathy for and alliance with the [U.S.S.R.]” are “not * * * sufficient to show illegal advocacy,” while evidence of, for example, “the teaching of forceful overthrow, accompanied by directions as to the type of illegal action which must be taken when the time for the revolution is reached,” would suffice). 2. Here, petitioner engaged in no mere abstract advocacy. Rather, his songs and deeds were “directed to inciting or producing imminent lawless action” to overthrow the government of Camelot by force, and they were “likely to incite or produce such action.” Branden- burg, 395 U.S. at 447. There is no question that petitioner advocated the overthrow of the Arthurian government. He denigrated Camelotian virtues, see Cam. 2.2, at 64-65; Cam. 2.4, at 73-74; “set[] knight against knight,” with the aim of “the destruction of the [Round] Table,” Cam. 2.3, at 66; and freely admitted that he wished to place himself “in

11 charge” of the White Castle and the entire kingdom, Cam. 2.1, at 57. The evidence further shows that petitioner’s advocacy was intended to—and in fact, did—incite imminent, lawless action. Most significantly, petitioner led a group of armed knights in a song that exalted violence, with one of his co-conspirators specifically encouraging the “burn[ing] [of ] a little town” and the “slay[ing] [of ] a dozen men.” Cam. 2.4, at 73 (capitalization omitted); see generally Pinkerton v. United States, 328 U.S. 640, 646- 647 (1946) (holding that a defendant is generally liable for the acts of his co-conspirators in furtherance of the conspiracy). During the song, knights fought with swords, and as the fight “rage[d]” on, petitioner encouraged them to engage in violence, “watching with amuse- ment.” Cam. 2.4, at 72 (emphases omitted). At the same time, petitioner told his followers that the situation “crie[d] out for justice. Our kind of justice”—a far cry from mere “talk[].” Cam. 2.4, at 73; cf. Yates, 354 U.S. at 325 (distinguishing between “advocacy of abstract doctrine” and “advocacy of action”). Petitioner thus sought to exploit the well-recognized impulse “to whack.” Cam. 1.3, at 20; see Cam. 2.8, at 87 (“Barbarism is the natural state of man.”). And he sought to do so immi- nently, forthrightly declaring that he would take charge of the White Castle “[i]n a little while,” and the King- dom of Camelot only “shortly after.” Cam 2.1, at 57. As attested to by Sir Lancelot—a witness “too noble to lie,” Cam 1.4, at 23 (capitalization omitted)—petitioner was likely to be successful in his attempt to “destr[oy] * * * the [Round] Table,” Cam. 2.3, at 66. 3. Section 2385’s prohibition on advocating the “duty, necessity, desirability, or propriety of overthrowing or

12 destroying” the Camelotian government “by force or violence” thus would be constitutional as applied to petitioner even were he a common citizen. 18 Cam. Code 2385. But he was not. Rather, he was a knight of the Round Table and Minister of Justice, see Cam. 2.2, at 64; Scenario 1, sworn to uphold and defend the Came- lotian Constitution. It is thus particularly clear that petitioner’s challenge must fail. For like the American military, the “character of the [knights’] community and of [their] mission * * * may render permissible” re- strictions on speech that “would be constitutionally im- permissible” if applied to civilians. Parker v. Levy, 417 U.S. 733, 758 (1974). Just as it does not violate the First Amendment to the United States Constitution to prohibit a “commissioned officer [from] publicly urging enlisted personnel to refuse to obey orders which might send them into combat,” id. at 761, it does not violate the First Amendment to the Camelotian Constitution to prohibit the Minister of Justice and a knight of the Round Table from advocating the overthrow of the very government he is sworn to protect. At the least, petitioner’s position of public trust made it especially likely that his statements would encourage the knights that he incited to follow his lead and abandon the newly established rule of law in favor of armed rebellion. And in fact, several knights and enlisted men followed petitioner’s call to violence, “burning Camelot’s towns and slaying its citizens,” while others were so swayed by petitioner’s words that they followed him to Scotland. Scenario 2. * * * * * In sum, petitioner, a government official, rejected abstract “talk[]” of revolution, Cam 2.4, at 73, instead advocating the imminent overthrow of the government

13 by force. And petitioner came ever so close to achieving his mission of destroying the Round Table and return- ing the Kingdom to “the old, uncivilized,” and “dreadful days.” Cam. 2.8, at 88. The law properly may punish such scurrilous scoundrels. As applied to petitioner, Section 2385’s prohibition on advocating the overthrow by force of the government does not violate the Came- lotian First Amendment.

B. “The Jury Decides”: Sufficient Evidence Supports The Guilty Verdict Petitioner further contends (Scenario 2) that insuffi- cient evidence supports the jury’s verdict of guilt. In reviewing the sufficiency of the evidence, “the relevant question is whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.” Jackson v. Vir- ginia, 443 U.S. 307, 319 (1979). This standard “gives full play to the responsibility of the trier of fact fairly to resolve conflicts in the testimony, to weigh the evidence, and to draw reasonable inferences from basic facts to ultimate facts,” ibid., and it reflects Camelotian law’s re- spect for the jury, see, e.g., Cam. 2.2, at 61 (“The jury decides”); ibid. (explaining that the use of an impartial jury will prevent bloodshed). The jury’s verdict in this case fully comports with the Camelotian adage that with a “court of law,” “[t]here can be no accusation without evidence.” Cam. 2.1, at 58; see Cam. 2.5, at 78 (“Isn’t your civil law marvelous? No proof ? No crime.”). The prosecution provided over- whelming evidence—and thus a reasonable jury easily could have found beyond a reasonable doubt—that petitioner was guilty of violating Sections 2383 and 2385.

1. To prove a violation of Section 2383, the prosecution had to show that petitioner incited or engaged in a rebellion or insurrection against the authority of the Camelotian government. 18 Cam. Code 2383; see Sce- nario 2. Viewed in the light most favorable to the King- dom of Camelot, the evidence set forth above was more than sufficient for a reasonable jury to conclude that petitioner committed the requisite acts. Testimony and evidence at trial established that petitioner publicly denigrated Arthurian virtues; encouraged sword- fighting, violence, and the burning of villages by the knights; and forcibly arrested the Queen in excess of his authority—all of which led to a bloody rebellion in which he rejoiced. See pp. 3-6, supra. In addition, the jury could rationally find that petitioner made frequent trips to Scotland for the purpose of organizing an army against the Kingdom of Camelot.3 The jury, moreover, was entitled to disbelieve petitioner’s testimony that he traveled to Scotland to inves- tigate attempts to improperly influence Camelotian officials. Scenario 2; see United States v. Scheffer, 523 U.S. 303, 313 (1998) (plurality opinion) (“A funda- mental premise of our criminal trial system is that the jury is the lie detector.”) (citation, emphasis, and internal quotation marks omitted); Scales, 367 U.S. at 254 (similar). Indeed, petitioner lacks all credibility given his own statements decrying honesty as “fatal” and one of

3 Absent an adverse evidentiary ruling, King Arthur would have testified to his belief that petitioner frequently traveled to Scotland to organize an army. See Scenario 2. Because there was sufficient evidence to support the verdict even without that testimony, the Kingdom of Camelot did not cross-appeal the district court’s decision to exclude the evidence.

15 the “seven deadly virtues” not “meant for [him].” Cam. 2.2, at 64-65 (capitalization omitted). 2. The evidence also was sufficient to satisfy Section 2385. To prove a violation of that provision, the prosecution had to show that petitioner willfully advocated the “duty, necessity, desirability, or propriety of overthrowing or destroying the government * * * by force or violence,” 18 Cam. Code 2385, and that he did so with “the intent * * * to overthrow the Government by force and violence,” Dennis, 341 U.S. at 499 (plurality opinion). As discussed above, the evidence demonstrated that petitioner advocated the desirability of overthrowing the Arthurian government when, inter alia, he denigrated Arthurian values, encouraged violence, and stated that he would soon rule the kingdom. See pp. 3-6, supra. Moreover, witnesses confirmed that petitioner’s desire to overthrow the government was well-known. See, e.g., Cam. 2.3, at 66 (Sir Lancelot noted that petitioner was “bent on the destruction of the [Round] Ta- ble.”); Scenario 1 (Pellinore “believe[d] Mordred [wa]s secretly inciting a rebellion and insurrection by stirring up the Knights to defy Arthur and to abandon the newly established rule of law.”). Petitioner also clearly had the intent to overthrow the Arthurian government by force and violence. He was “amuse[d]” by the knights’ sword-fighting, and he participated in a song advocating the burning of a town and the slaying of men. Cam. 2.4, at 72 (emphasis omitted); see Cam. 2.4, at 73. What is more, petitioner himself acknowledged his “ruthless” nature, Cam. 2.7, at 85, and his delight in the murder of King Arthur’s knights confirms that he intended to encourage not peaceful

16 change but “violence, revolution and terrorism,” Den- nis, 341 U.S. at 501 (plurality opinion).4 CONCLUSION “The jury has ruled. Let justice be done.” Cam. 2.7, at 83. Respectfully submitted.

NOEL J. FRANCISCO Solicitor General ERICA L. ROSS Assistant to the Solicitor General MARGARET A. UPSHAW Attorney JUNE 2018

4 Additional evidence likely would have been available against petitioner, but 31,000 of his emails were mysteriously deleted.