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PILF Amicus Brief Nos. 19-251, 19-255 IN THE Supreme Court of the United States AMERICANS FOR PROSPERITY FOUNDATION, Petitioner, v. XAVIER BECERRA, IN HIS OFFICIAL CAPACITY AS THE ATTORNEY GENERAL OF CALIFORNIA, Respondent. THOMAS MORE LAW CENTER, Petitioner, v. XAVIER BECERRA, IN HIS OFFICIAL CAPACITY AS THE ATTORNEY GENERAL OF CALIFORNIA, Respondent. On Writs of Certiorari to the United States Court of Appeals for the Ninth Circuit Brief of the Public Interest Legal Foundation and Foundation for Michigan Freedom as Amici Curiae in Support of Petitioners J. CHRISTIAN ADAMS KAYLAN PHILLIPS Counsel of Record PUBLIC INTEREST LEGAL FOUNDATION 32 E. Washington St., Ste. 1675 Indianapolis, IN 46204 (317) 203-5599 [email protected] (Additional Counsel Inside Cover) ERIC E. DOSTER DOSTER LAW OFFICES, PLLC 2145 Commons Parkway Okemos, MI 48864 (517) 977-0147 [email protected] i Table of Contents Table of Authorities ................................................. ii Interests of Amici Curiae ......................................... 1 Summary of the Argument ...................................... 3 Argument ................................................................. 4 I. Compelled Disclosure Is Antithetical to the Foundational Principles of the United States ................................................. 4 II. The Recent History Demonstrates that Donor Disclosure Is a Tool that Has Been Used to Engage in Personal Attacks ............. 6 A. National Organization for Mar- riage’s Leaked Tax Document ............ 6 B. IRS Targeting Scandal........................ 8 C. Friends of Abe ..................................... 8 D. League of United Latin American Citizens v. Public Interest Legal Foundation .......................................... 9 E. Chick-fil-A ......................................... 11 F. U.S. Virgin Islands Subpoena .......... 11 III. Donor Disclosure Is Also Used to Engage in Personal Attacks in the Election Con- text ............................................................... 12 A. California’s Proposition 8 ................. 12 B. Will & Grace...................................... 14 C. Representative Joaquin Castro ........ 15 D. Michigan Chamber of Commerce ..... 16 E. SoulCycle ........................................... 17 Conclusion .............................................................. 18 ii Table of Authorities Cases Citizens United v. FEC, 558 U.S. 310 (2010) ...................................... 12-14 Doe v. Reed, 561 U.S. 186 (2010) ........................................... 13 League of Latin American Citizens v. Public Interest Legal Foundation, No. 1:18-cv-00423 (E.D. Va. April 12, 2018) ..... 10 McIntyre v. Ohio Elections Comm’n, 514 U.S. 334, 357 (1995) .................................... 5 NAACP v. Ala. ex rel. Patterson, 357 U.S. 449 (1958) .......................................... 4-6 National Org. for Marriage, Inc. v. United States, 24 F. Supp. 3d 518 (E.D. Va. 2014) ..................... 7 True the Vote, Inc. v. IRS, 831 F.3d 551 (D.C. Cir. 2016) ............................. 8 Constitutions and Statutes Cal. Const. Art. I § 7.5 ........................................... 12 Cal. Govt. Code Ann. § 84211(f) ............................. 12 Other Authorities Brief Summary of the Ballot Proposal................... 16 iii Caitlin O’Kane, Debra Messing demands attendee list for Beverly Hills Trump fundraiser, president hits back, CBS News (Sept. 2, 2019) ................. 14-15 CEI, First Amendment Fight: CEI’s Climate Change Subpoena (April 5, 2017) ....................................... 11 Debra Messing (DebraMessing) ............................. 14 Fredreka Schouten, Rep. Joaquin Castro tweets names, employers of Trump donors in San Antonio, CNN (Aug. 7, 2019) ................................................ 15 Kate Taylor, For Chick-fil-A, impact trumps ‘any po- litical or cultural war’ when it comes to controversial donations, Business Insider (May 15, 2019) ......... 11 Kelly Phillips Erb, IRS Targeting Scandal: Citizens United, Lois Lerner And The $20M Tax Saga That Won’t Go Away (June 24, 2016) ............................... 8 Matt Kempner, Chick-fil-A, criticized for its charita- ble giving, narrows donations, The Atlanta Journal- Constitution (Nov. 23, 2019) ................................. 11 Michael Cieply and Nicholas Confessore, Leaning Right in Hollywood, Under a Lens, The New York Times (Jan. 22, 2014) ............................................... 9 Michelle Ye Hee Lee, Trump’s critics are targeting his donors, sparking fears of a backlash against dis- closure, Washington Post (Sept. 10, 2019) ............ 15 iv Nolan Finley, Finley: Left turns to terroristic tactics to silence critics, The Detroit News (July 11, 2018) ........................................................ 16 NOM, National Organization for Marriage Demands a Federal Investigation of the Human Rights Cam- paign and the Internal Revenue Service (April 5, 2012) ...................................................................... 6-7 Pew Research Center, Mobile Fact Sheet (June 12, 2019) ....................................................................... 14 Rani Molla, One Trump fundraiser was all it took to slash SoulCycle’s attendance, Vox (Sept. 5, 2019) ........................................................ 17 Sam Levine and Spenser Mestel, ‘Just like propa- ganda’: the three men enabling Trump’s voter fraud lies, The Guardian (Oct. 26, 2020) ........................... 1 Ted Johnson, Friends of Abe: Hollywood’s Comfort Zone for Industry Conservatives Winds Down, Varie- ty (April 27, 2016) ................................................. 8-9 Testimony of J. Christian Adams, U.S. House Sub- committee on the Constitution, Civil Rights and Civil Liberties (Sept. 10, 2019) ........................... 9-10 The Federalist No. 1 ............................................. 4-5 Thomas M. Messner, The Price of Prop 8, Heritage Foundation Backgrounder, No. 2328 (Oct. 22, 2009) ................................................................. 13 v Thomas Paine, COMMON SENSE, Introduction ......... 5 Transcript of Motion Hearing, League of Latin Amer- ican Citizens v. Public Interest Legal Foundation (May 24, 2019) ........................................................ 10 Trish Loughran, THE REPUBLIC IN PRINT: PRINT CULTURE IN THE AGE OF U.S. NATION BUILDING (2007) ........................................................................ 5 1 INTERESTS OF AMICI CURIAE1 The Public Interest Legal Foundation, Inc., (the “Foundation”) is a nonpartisan, public interest organ- ization incorporated and based in Indianapolis, Indi- ana. The Foundation’s mission is to promote the in- tegrity of elections nationwide through research, edu- cation, remedial programs, and litigation. The Foun- dation also seeks to ensure that voter qualification laws and election administration procedures are fol- lowed. Specifically, the Foundation seeks to ensure that the nation’s voter rolls are accurate and current, working with election administrators nationwide and educating the public about the same. The Foundation and individuals publicly associated with it are often targeted by the media and special interest groups with voracious attacks on their work. See Sam Levine and Spenser Mestel, ‘Just like propaganda’: the three men enabling Trump’s voter fraud lies, The Guardian (Oct. 26, 2020). The Foundation has terminated fund- raising in California due to California’s insistence on forcing the production of unredacted donor infor- mation. The Foundation has serious concerns about how the state will use and safeguard its donors infor- mation from abusive behavior. 1 No counsel for a party authored this brief in whole or in part, nor did any person or entity, other than amici curiae and their counsel, make a monetary contribution intended to fund the preparation or submission of this brief. Petitioners in both 19- 251 and 19-255 issued blanket consents to the filing of amicus curiae briefs. Respondent was notified and consented to the fil- ing of this brief. 2 The Foundation for Michigan Freedom is a non- profit, nonpartisan organization recognized by the In- ternal Revenue Service as tax-exempt pursuant to Section 501(c)(3) of the Internal Revenue Code. A core mission of the Foundation for Michigan Freedom is to undertake legal research projects in the public inter- est and to provide legal support in litigation designed to present positions on behalf of the public at-large on matters of public interest. In particular, the Founda- tion for Michigan Freedom is dedicated to the promo- tion and protection of the democratic process, includ- ing the right of all citizens to participate and enter the marketplace of ideas. As a nonprofit, nonpartisan or- ganization, the Foundation for Michigan Freedom recognizes that the First Amendment protects citi- zens from government interference of our right to pe- tition, criticize, and speak openly and freely on mat- ters of public policy. The ability to do so anonymously and without fear of retribution is a key principle of that right and one that should be protected for all viewpoints, regardless of whether one agrees with the particular speaker. Both amici have a substantial interest in the res- olution of this matter as they are 501(c)(3) charitable organizations reliant on funding from generous do- nors. California’s attempt to coerce the disclosure of charitable donors implicates serious constitutional concerns and chills the speech of amici. 3 SUMMARY OF ARGUMENT
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