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Amicus Brief of Governor No. 20-35630 _____________________________________________________________ _____________________________________________________________ IN THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT ___________________ PEOPLE NOT POLITICIANS OREGON; COMMON CAUSE; LEAGUE OF WOMEN VOTERS OF OREGON; NAACP OF EUGENE/SPRINGFIELD; INDEPENDENT PARTY OF OREGON; C. NORMAL TURRILL, Plaintiffs-Appellees, v. BEVERLY CLARNO, Oregon Secretary of State, Defendant-Appellant. ___________________ AMICUS BRIEF OF OREGON GOVERNOR KATE BROWN IN SUPPORT OF DEFENDANT-APPELLANT ___________________ Appeal from the United States District Court for the District of Oregon ___________________ DUSTIN E. BUEHLER General Counsel Office of the Governor 900 Court St. NE, Suite 254 Salem, Oregon 97301-4047 Telephone: (503) 378-6246 [email protected] Attorney for Amicus Curiae Oregon Governor Kate Brown _______________________________________________________________ _______________________________________________________________ TABLE OF CONTENTS STATEMENT OF INTEREST OF AMICUS CURIAE ....................................... 1 SUMMARY OF ARGUMENT ............................................................................ 2 ARGUMENT ........................................................................................................ 3 A. The district court improperly relied on the effects of the Governor’s executive orders to conclude that a burden exists on plaintiffs’ First Amendment rights. ............................................. 3 1. Plaintiffs do not challenge the Governor’s COVID-19 executive orders, and the effects of those orders do not establish a burden on First Amendment rights in this case. ................................................................................ 3 2. Even if the Governor’s executive orders were relevant to plaintiffs’ claims, the district court erroneously assumed those orders prevented communication with voters. .................................................................................... 7 B. The extraordinary remedy requested and granted in this case interferes with Oregon’s sovereign interests, and provides an independent basis to vacate the preliminary injuction. ..................11 CONCLUSION ...................................................................................................16 TABLE OF AUTHORITIES Cases Calvary Chapel Dayton Valley v. Sisolak, No. 19A1070, 2020 WL 4251360 (U.S. July 24, 2020) ..........................14 Elkhorn Baptist Church v. Brown, 466 P.3d 30 (Or. 2020) .............................................................................13 Garcia v. San Antonio Metropolitan Transit Authority, 469 U.S. 528, 105 S. Ct. 1005, 83 L. Ed. 2d 1016 (1985) .......................14 i Jacobson v. Massachusetts, 197 U.S. 11, 25 S. Ct. 358, 49 L. Ed. 643 (1905) ....................................14 Kadderly v. City of Portland, 74 P. 710 (Or. 1903) ................................................................................... 6 Lemons v. Bradbury, No. CV-07-1782-MO, 2008 WL 336823 (D. Or. Feb. 1, 2008) ................ 4 Little v. Reclaim Idaho, No. 20A18, 2020 WL 4360897 (U.S. July 30, 2020) ..........................6, 12 Marshall v. United States, 414 U.S. 417, 94 S. Ct. 700, 38 L. Ed. 2d 618 (1974) .............................14 Prete v. Bradbury, 438 F.3d 949 (9th Cir. 2006) ...................................................................... 5 South Bay United Pentecostal Church v. Newsom, __ U.S. __, 140 S. Ct. 1613, __ L. Ed. 2d __ (2020) ...............................14 Statutes & Constitutional Provisions U.S. Const., Amend. I ................................................................................. passim Or. Const., Art. IV § 1 .......................................................................................... 6 Or. Const., Art. IV § 1(2)(c) ................................................................................ 3 Or. Const., Art. IV § 1(2)(e) ................................................................................. 3 Or. Const., Art. XVII § 1 ...................................................................................... 1 Other Authorities Or. Exec. Order 20-05 (Mar. 12, 2020) ................................................................ 8 Or. Exec. Order 20-07 (Mar. 17, 2020) ............................................................... 8 Or. Exec. Order 20-12 (Mar. 23, 2020) ................................................................ 9 Or. Exec. Order 20-25 (May 14, 2020) ............................................................... 9 Or. Exec. Order 20-27 (June 5, 2020) ............................................................... 10 Oregon Blue Book: Initiative, Referendum and Recall History (2019–2020) ..... 6 State Initiative and Referendum Manual (Mar. 2020) ....................................... 12 ii Amicus Brief of Oregon Governor Kate Brown in Support of Defendant-Appellant _______________ STATEMENT OF INTEREST OF AMICUS CURIAE Oregon Governor Kate Brown appears as amicus curiae1 because she is deeply involved in the State of Oregon’s emergency response to the COVID-19 pandemic. In particular, she has issued several executive orders and emergency directives that provide factual and legal context for plaintiffs’ claims and the parties’ arguments on appeal. Additionally, as governor of Oregon—and as a former Oregon secretary of state—Governor Brown has an interest in the fair and equitable administration of state election laws, and in Oregon’s sovereign authority to determine the process by which its state constitution is amended. See also Or. Const. art. XVII, § 1 (constitutional amendment adopted by initiative is effective upon a proclamation by the Governor that the measure received a majority of votes). In this amicus brief, Governor Brown seeks to clarify the proper scope and effect of her COVID-19 related executive orders, and to argue that the remedy afforded by the district court in this case is inconsistent with the sovereign prerogatives of the State of Oregon. 1 This brief is filed pursuant to Federal Rule of Appellate Procedure 29(a)(2), as all parties have consented to its filing. Pursuant to the statement required by Federal Rule of Appellate Procedure 29(a)(4)(E), no party’s counsel authored any portion of this brief; and no party, party’s counsel, or other person contributed money intended to fund the preparation or submission of this brief. 2 SUMMARY OF ARGUMENT The district court granted extraordinary and unprecedented relief in this case. After plaintiffs failed to gather sufficient signatures to place Initiative Petition 57 (“IP 57”) on the November 2020 general election ballot, the district court attributed that failure to the Secretary of State’s adherence to well- established signature and deadline requirements for citizen initiatives, enshrined in Oregon’s constitution, and then unilaterally altered those requirements. As part of its analysis on plaintiffs’ First Amendment claims, the district court also conflated the burden imposed by those requirements with burdens purportedly imposed on signature gathering by the COVID-19 pandemic in general, and Governor Brown’s pandemic-related executive orders in particular. The district court abused its discretion by doing so. Plaintiffs do not challenge the Governor’s pandemic-related executive orders and, contrary to the district court’s reasoning, the effects of those orders are not properly part of the analysis regarding plaintiffs’ First Amendment claims. The district court erred by concluding that the Governor’s orders “prevented any one-on-one communication” with voters, and that they “specifically prohibited” the ability of initiative petitioners to connect with voters in person. Lastly, and perhaps most significantly, the district court erred by straying outside its proper judicial 3 role, by unilaterally rewriting state constitutional provisions. For those reasons, this court should vacate the preliminary injunction. ARGUMENT A. The district court improperly relied on the effects of the Governor’s executive orders to conclude that a burden exists on plaintiffs’ First Amendment rights. 1. Plaintiffs do not challenge the Governor’s COVID-19 executive orders, and the effects of those orders do not establish a burden on First Amendment rights in this case. Plaintiffs challenge two provisions that regulate the submission of citizen initiative petitions seeking to amend Oregon’s constitution. (E.R. 32). First, petitioners are required to submit valid signatures “equal to eight percent of the total number of votes cast for all candidates for Governor” at the last regular gubernatorial election. Or. Const. art. IV, § 1(2)(c). Second, petitioners must file those signatures “not less than four months before the election at which the proposed law or amendment to the Constitution is to be voted upon.” Or. Const. art. IV, § 1(2)(e). The district court concluded that those signature and deadline requirements unconstitutionally burdened plaintiffs’ First Amendment right to petition the government, because plaintiffs were not able to meet those requirements in light of the COVID-19 pandemic and Governor Brown’s pandemic-related executive orders. (E.R. 14). The premise underlying that decision is flawed because the purported burden on plaintiffs’ First Amendment rights does not arise from the specific 4 regulations they challenge in this case. As the Secretary’s brief explains, the signature and deadline requirements provide
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