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 insur- rection 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 “impar- tial” 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 in- surrection 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. 3 “knowingly or willfully advocat[ing], abet[ting], advis- [ing], or teach[ing] the duty, necessity, desirability, or propriety of overthrowing or destroying the govern- ment of the [Kingdom of Camelot] * * * by force or violence,” 18 Cam. Code 2385. For a period, King Arthur’s vision for a peaceful or- der 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 illegit- imate 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 4 Kingdom, see Cam. 2.2, at 64 (“The seven deadly vir- tues”); 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.