The Volokh Conspiracy

Mostly law professors | Sometimes contrarian | Often libertarian | Always independent | Est. 2002

The Volokh Conspiracy

Free Speech

Organization Serving Disabled People Claims Newspaper Discriminatorily Targeted It for Criticism

A N.J. judge has thrown out the lawsuit, on the narrow grounds that, even if the newspaper deliberately discouraged people from attending the group's charity gala, the N.J. Law Against Discrimination doesn't apply to charity galas.

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In Arc Mercer, Inc. v. MediaNews Group, decided Wednesday by N.J. trial court judge Brian McLaughlin, Arc Mercer—"a non-profit organization serving the needs of the persons with developmental and intellectual disabilities"—sued the newspaper The Trentonian and one of its journalists under the N.J. Law Against Discrimination. To quote the court, the journalist, "alerted to the planned attendance of several prominent elected officials at a charity event held at a venue co-owned by an allegedly controversial figure, wrote a series of opinion articles critical of said elected officials" and likewise criticizing "Arc Mercer for hosting the gala at the venue."

Arc Mercer argued that this violated the LAD, because "Defendants unlawfully discriminated against Plaintiff by targeting Plaintiff on the basis of the disabilities of its consumers in order to incite others, and attempt to incite others, to refuse to do business with Plaintiff":

In 2022, Plaintiff, like multiple other businesses and politicians, chose to host its annual fundraising gala at [the restaurant and catering venue] the Stone Terrace…. [T]he Arc [believes it] is the only organization that has held an event at the Stone Terrace since June 2020 that had a client base of persons with developmental and intellectual disabilities….

On June 11, 2020, Joseph Russo, the head chef and partial owner of the Stone Terrace at the time, published statements on social media that were racially offensive. These statements included slurs towards Black Lives Matter, as well as calling George Floyd protesters "evil."

The Stone Terrace experienced a considerable backlash from the local community including protests and boycotting of the venue. John Henry and Catherine Henry, owners of the Stone Terrace, released a statement referring to Russo as their "former executive chef" and apologized for the offensive statements by Russo, and confirming that Russo's views did not reflect the Stone Terrace's views or policies, and that the Stone Terrace supports the Black Lives Matter Movement.

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Copyright

Cardi B's "Wet Ass Pussy" Doesn't Infringe Plaintiff's Song

"The concept of using 'p**** so wet' as a rhetorical device in a song is neither original nor unique to Plaintiff, and, in any event, '[c]opyright does not protect ideas or themes.'"

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The key passage, from Judge Andrew Carter's opinion Tuesday in Jones v. Atlantic Records (S.D.N.Y.) (all expurgation in original):

The Court finds that the short phrases over which Plaintiff seeks copyright protection are not protectable as a matter of law…. "Because songwriters must be free to borrow sayings and expressions from popular culture, the Second Circuit and courts in this district have found that short and commonplace phrases are not protectable, even when used as the title or repeated lyrics of a song…."

The lyrics over which Plaintiff asserts copyright protection are no more than common phrases, employed frequently in popular culture and other Hip-Hop songs. The concept of using "p**** so wet" as a rhetorical device in a song is neither original nor unique to Plaintiff, and, in any event, "[c]opyright does not protect ideas or themes." Indeed, Defendants have cited at least three examples of works pre-dating GEBTP which use similar lyrics.

Likewise, Defendants have provided examples of at least three songs pre-dating GEBTP which use some variation of the phrase "n****s wild'n". Where the only similarity between two works is not original to the author, a plaintiff's work is not protected by copyright, and thus is subject to dismissal….

Another passage, which is less central but struck me as amusing:

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Politics

Short Circuit: A Roundup of Recent Federal Court Decisions

Detroit's forfeiture machine, major nuclear questions, and copyrightable materials.

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Please enjoy the latest edition of Short Circuit, a weekly feature written by a bunch of people at the Institute for Justice.

You want to hear something neat? Next month, IJ is going to argue before the Michigan Supreme Court—but not at the Michigan Supreme Court. Instead, oral argument will be held at a high school in Flint because sometimes—in cases of deep importance and keen public interest—the Michigan supremes take their show on the road. And indeed the question of whether officials who repeatedly flew a drone over private property in search of code violations should have first obtained a warrant is of great moment. Click here to learn more.

And speaking of neat, Georgia Public Radio has a story about IJ's latest eminent domain case, one which asks the question: is a taking by a private railroad, primarily to benefit a different private company, a public use?

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Free Speech

Court Strikes Down W. Va. Law Restricting Property Owners from Asking Visitors About Whether They Have Guns in Their Parked Cars

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From yesterday's decision by Judge John T. Copenhaver, Jr. (S.D. W. Va.) in W. Va. Coalition Against Domestic Violence, Inc. v. Morrisey (some formatting changed); note that the court upheld some other provisions of the law, which I discuss in a separate post:

In March 2018, the West Virginia Legislature enacted House Bill 4817 [the Parking Lot Amendments], which amended the BLPA to prohibit property owners from banning firearms in the parking lot areas of their properties ….

The Parking Lot Amendments also prohibit owners, lessees, or persons "charged with the care, custody, and control" over parking lots from "violat[ing] the privacy rights of a customer, employee, or invitee … [b]y verbal or written inquiry, regarding the presence or absence of a firearm locked inside or locked to a motor vehicle in a parking lot[.]" The court will refer to this section as the "Inquiry Provision." …

Subsection 61-7-14(d)(2)(C) prohibits the same individuals from taking "any action against a customer, employee, or invitee based upon verbal or written statements of any party concerning possession of a firearm stored inside a motor vehicle in a parking lot for lawful purposes, except upon statements made pertaining to unlawful purposes or threats of unlawful actions involving a firearm made in violation of § 61-6-24 [pertaining to threats of terrorist acts] of this code." The court will refer to this subsection as the "Take-No-Action Provision."

The court held that the Inquiry Provision violated the First Amendment, and that the Take-No-Action provision was unconstitutionally vague in part because of the possibility that it would be read as restricting speech as a form of action. The opinion is very long, so I thought I'd excerpt just portions of the free speech discussion (which I think is generally correct):

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Guns

Court Upholds W. Va. Law Requiring Property Owners to Allow Guns Locked in Customer or Employee Cars in Parking Lot

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From yesterday's decision by Judge John T. Copenhaver, Jr. (S.D. W. Va.) in W. Va. Coalition Against Domestic Violence, Inc. v. Morrisey; note that the court struck down two other provisions of the law, which I discuss in a separate post:

Previously, the BLPA [West Virginia's Business Liability Protection Act] allowed property owners to prohibit the open or concealed carry of a firearm anywhere on their properties …[:] "[A]ny owner, lessee or other person charged with the care, custody and control of real property may prohibit the carrying openly or concealing of any firearm or deadly weapon on property under his or her domain." …

In March 2018, the West Virginia Legislature enacted House Bill 4817 [the Parking Lot Amendments], which amended the BLPA to prohibit property owners from banning firearms in the parking lot areas of their properties …:

No owner, lessee, or other person charged with the care, custody, and control of real property may prohibit any customer, employee, or invitee from possessing any legally owned firearm, when the firearm is

  1. Lawfully possessed;
  2. Out of view;
  3. Locked inside or locked to a motor vehicle in a parking lot; and
  4. When the customer, employee, or invitee is lawfully allowed to be present in that area….

No owner, lessee, or other person charged with the care, custody, and control of real property may prohibit or attempt to prevent any customer, employee, or invitee from entering the parking lot of the person's place of business because the customer's, employee's, or invitee's motor vehicle contains a legal firearm being carried for lawful purposes that is out of view within the customer's, employee's, or invitee's motor vehicle….

The court will refer to [those provisions] collectively as the "No-Prohibition Provisions."

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Civil Asset Forfeiture

Sixth Circuit Rules Owners of Cars Taken by Asset Forfeiture Have Constitutional Right to a Hearing Within Two Weeks of Seizure

The decision provides important protection for property rights, and features a powerful concurring opinion by prominent conservative Judge Amal Thapar.

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Reason

In many states, asset forfeiture laws allow law enforcement agencies to seize valuable property based on mere suspicion that it was used in a crime, and then keep it even if the owner was never convicted of any crime. On top of that, some force owners to wait many months before they even have a chance to challenge the forfeiture in a hearing. Yesterday, in Ingram v. Wayne County, the US Court of Appeals for the Sixth Circuit issued a decision holding that the Due Process Clause of the Fourteenth Amendment requires the government to give owners a hearing within two weeks, in at least some cases where their cars seized through asset forfeiture.

The ruling also features a compelling concurring opinion by Judge Amul Thapar, a prominent conservative jurist often considered a potential future Supreme Court nominee. Here's the majority's summary of their ruling (authored by Judge John K. Bush):

Plaintiffs allege the government of Wayne County, Michigan has a policy or practice of seizing and holding vehicles while taking months to decide whether to initiate forfeiture proceedings. Plaintiffs claim they were not provided an opportunity to be heard about the detention of their vehicles and that this failure violates the Due Process Clause of the Fourteenth Amendment. The district court held that plaintiffs are entitled to the requested hearing. We agree and hold that Wayne County violated that Constitution when it seized plaintiffs' personal vehicles—which were vital to their transportation and livelihoods— with no timely process to contest the seizure. We further hold that Wayne County was required to provide an interim hearing within two weeks to test the probable validity of the deprivation.

Following the lead of several other circuit courts, Judge Bush concluded that the court should apply the three-part balancing test outlined in the Supreme Court's 1976 ruling in Mathews v. Eldredge (originally developed in a context far removed from asset forfeiture): "(1) 'the degree of potential deprivation that may be created by a particular decision,' (2) the 'fairness and reliability of the existing pretermination procedures, and the probable value, if any, of additional procedural safeguards,' and (3) the public interest." In this case, the Sixth Circuit concluded all three factors support the property owners, and thus the latter had a right to a hearing within two weeks of seizure. But it is not entirely clear what might happen in other cases involving the seizure of cars, much less forfeitures of other kinds of property.

In his concurring opinion, Judge Thapar argues for a bright-line rule instead of a balancing test, and suggests a 48-hour standard is preferable to a two-week one:

The Constitution requires the government to provide prompt process before depriving someone of life, liberty, or property. Normally, that means a hearing. But Wayne County, Michigan hasn't followed that simple requirement. The County has been seizing cars, holding them for months, and denying hearings to anyone bold enough to ask for them. There's only one surefire way to get your car back: pay up. How much? $900 if it's the first time the County seized your car. $1,800 if it's the second time. Or $2,700 if it's the third. Even worse, if you challenge the seizure too early or too late, the County can just keep your car.

Wayne County's scheme violates the Constitution's due-process requirement. Constitutional text, history, and precedent show why. History links protections for liberty and for property. And when the government arrests someone, depriving them of liberty, Supreme Court precedent requires a preliminary hearing within 48 hours. I would apply the same rule to Wayne County's seizure of the plaintiffs' property.

Judge Thapar's opinion is real tour de force. It effectively explains the relevant history and constitutional text, and why property rights, especially when it comes to important property like a car, are entitled to strong procedural protection, similar - in many cases - to those provided for liberty. He also provides a strong argument for why a bright-line rule is preferable to using the Mathews balancing test:

First, Mathews suffers from problems common to many balancing tests. It requires us to compare values that aren't comparable: (1) the individual's interest in more process, (2) the government's interest in providing the same or less process, and (3) the risk of error in current procedures and the probable value of additional protections. Mathews, 424 U.S. at 335. This test puts judges in an impossible position. "It is more like judging whether a particular line is longer than a particular rock is heavy." Bendix Autolite Corp. v. Midwesco Enters., 486 U.S. 888, 897 (1988) (Scalia, J., concurring).

Also like other balancing tests, Mathews leads to unpredictable results. With three
subjective factors at play, will two judges ever balance them in the same way? I'm skeptical. And unpredictability hurts everyone. It's a problem for government officials who don't know what they're required to do. But Mathews also harms ordinary people. It prevents them from helping themselves. They can't call out government officials for violating their rights because Mathews doesn't say what those rights are. Instead, it says that sometime later a judge will let them know. A potential court victory years in the future is little solace for the Melisa Ingrams and Stephanie Wilsons of the world who need their cars now for work and school.

Apart from these problems, which are common to all balancing tests, Mathews also
suffers from unique shortcomings. For one, Mathews doesn't account for all the important interests at stake. "Nowhere does the test allow the Court to weigh the plain old value of process itself, i.e., of simply knowing why the government has decided to take action against you." Hicks v. Colvin, 214 F. Supp. 3d 627, 641 n.7 (E.D. Ky. 2016). For another, under Mathews, everything is negotiable. "[A]ll process is, potentially, up for sale." Id. at 643 n.8. But that's not what the Constitution says. It says you're entitled to process when the government deprives you of "life, liberty, or property." U.S. Const. amend. XIV, § 1. That should be where we start and end.

The awful facts in these cases highlight the wrongs of the current asset forfeiture regime in Michigan and other similar jurisdictions. Here's Judge Thapar again:

Wayne County claims that it seizes cars to fight crime (and holds onto them for months
for the same reason). But the County is happy to return those very cars as soon as it gets paid. That practice proves the County's scheme is simply a money-making venture—one most often used to extort money from those who can least afford it.

Consider the plaintiffs' experiences. Melisa Ingram works full time and goes to school at night. When her boyfriend asked to borrow her car to find a job, she loaned it to him. Rather than using it to find a job, he used the car to pick up a prostitute. The police pulled him over and seized the car. When Ingram tried to get it back, Wayne County officials told her she'd have to wait four months for a hearing. So rather than spend the long Michigan winter without a car, she paid the ransom Wayne County demanded: $1,355 (the $900 "redemption fee" plus towing and storage).

Several months later, Ingram loaned her car to her boyfriend again. This time, for him to attend a barbecue. Police pulled him over again and took the car, claiming the house he went to was linked to prostitution or drugs. Just like the last time, Ingram demanded her car back from the County. Yet again, County officials told her the best way to get her car back was to pay the redemption fee—increased this time to $1,800. But the first redemption fee had bankrupted her; she couldn't afford to pay another one. Ingram never got her car back.

Stephanie Wilson is a single mom, pursuing her nursing degree at a community college. Her daughter's father is a homeless drug addict. Out of pity, Wilson twice agreed to give him a ride, and twice that cost her a car. Both times, the police took her car only moments after she picked up her daughter's father. After the first seizure, Wilson went to the County office building to get her car back. She was told to come back later. When she did, she was told it was too late—she lost the car forever. Then, she bought a second car from a tow yard using her tax refund. The County took that one too. She insisted on a hearing, but the County delayed and pressured her to pay the $1,800 redemption fee instead. Eventually, a state judge forced the County to return Wilson's car.

Robert Reeves, a construction worker and father of five, had his car taken by the County after leaving a job site. And it wasn't even for anything he'd done or for anything connected to his car. His coworker had allegedly stolen a piece of equipment from Home Depot. Robert didn't know anything about the theft and had seen rental paperwork for the equipment, but the police arrested him and seized his car anyway. The County held onto his car for more than six months even though they let him out of jail after just a few hours.

Does this sound like a legitimate way of cleaning up Wayne County? Or does it sound
like a money-making scheme that preys on those least able to fight it? To ask the question is to answer it.

The Supreme Court has not yet ruled on the extent of procedural due process protections required in asset forfeiture cases. When and if they do, I hope they follow Judge Thapar's approach.

NOTE: The property owners in this case represented by the Institute for Justice, a prominent public interest law firm, with which I have longstanding connections, and for which I have done pro bono work on other property rights cases. I did not, however, have any involvement in this case.

Free Speech

How Can the State Prevent Viewpoint Foreclosure?

By guaranteeing five basic internet rights.

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(This is the final post in a five-part series on regulating online content moderation.)

In Part III, I showed how it is possible for private actors to remove an unpopular viewpoint from the internet by preventing websites that express that viewpoint from operating, a phenomenon I call "viewpoint foreclosure." In Part IV, I explained why every lawful website should have the right to exist—that is, to stay online. In Part II, I argued that regulating core intermediaries—the entities that administer the internet's core resources and, thus, the entities capable of effecting viewpoint foreclosure—would not run afoul of any First Amendment right to editorial discretion.

In this Part, I explain how the state can prevent viewpoint foreclosure by guaranteeing certain basic internet rights. To identify these rights—the bare minimum case for the state to intervene in private content moderation—we simply need to determine what a person requires of others to stand up a public website.

Connectivity. In the first place, for a person to operate a public website, she needs to connect to the internet. For residential subscribers—those who use their internet connection merely to consume websites and other applications—a standard internet access service will suffice. But for those who wish to host their own websites, a residential subscription will not do. They require commercial internet service with the requisite stability and bandwidth to make a self-hosted website available to the world. Although it might seem that net neutrality rules guarantee a right of connectivity, that is not so. The FCC's 2015 Open Internet Order (before it was repealed) pertained only to mass market broadband internet access, not to the kinds of commercial internet service public websites need to stay online. Moreover, the Open Internet Rules were concerned with website blocking when a subscriber is already able to enjoy internet access but his ISP prevents him from accessing certain websites or services that compete with the ISP. They did not concern themselves with ISPs who might refuse internet access altogether. To ensure enjoyment of that resource, we need a right of connectivity.

Addressability. Internet access is important, certainly, but unless you have use of a static IP address, your website will not be long for this world. IP addresses uniquely identify resources, including websites, on the public internet. Without a static IP address, any site reachable today may not be reachable tomorrow.

Just five regional internet registries (RIRs)—each a private organization—administer the IP address space, and each RIR can revoke any in-use block of addresses if the holder violates its terms. Thus far, RIRs have largely steered clear of the culture wars that rage within the application layer of the internet. But the decision by LACNIC, one of those RIRs, to revoke IP addresses that Parler relied on to escape deep deplatforming is concerning. LACNIC claimed to be enforcing a neutral (non-content-based) policy that Parler's new hosting provider had allegedly violated. But as I explain in my article, The Five Internet Rights, there are reasons to question whether LACNIC was enforcing its policies equally (or accurately). That fact, coupled with the broader ideological drive to deplatform Parler, raises the possibility that we may have seen the first instance of IP-based deplatforming.

Even if that suspicion is misplaced, it doesn't change the fact that five entities alone control the world's IP addresses, each of which is as free under current law to revoke IP addresses under its policies as Facebook is free to delete user posts that violate its standards. Given the centrality of IP addresses to online speech, a complete view of expressive access to the internet must include a right to maintain one or more static IP addresses for public websites. It must include a right of addressability.

Nameability. Nameability refers to the right of a website operator to maintain a domain name and, when users query that domain name, to have those queries answered (resolved) by returning the IP address at which the website is hosted.

As with the IP address system, the domain name system (DNS) has historically operated in a content-neutral manner. But that neutrality is waning. Domain registrars have increasingly waded into the content moderation game by inserting "morality clauses" into their registration agreements. For example, various registrars have prohibited registrants from associating domain names with websites that host "profane," "vulgar[]," "embarrass[ing], "derogatory, "racist, "homophobic," "blasphemous," or other "morally objectionable" content.  Thus, dailystormer.com, gab.com, ar15.com, and other websites have seen their domain names suspended because their registrars disliked their viewpoints. Guaranteeing expressive access to the internet should therefore include a right of nameability that prevents DNS intermediaries from taking adverse action against domain names associated with lawful websites merely because they disagree with the viewpoints expressed on those websites.

Routability. Routability refers to the right of a website operator to have traffic to and from her website faithfully routed between intervening networks.

The term internet—short for "inter-network"—concisely captures the fact that the internet operates as a network of networks (in technical parlance, "autonomous systems"). Internet communication, therefore, is fundamentally a matter of "hopping" across networks, where each intervening network represents an additional hop between source and destination. Each network learns where to route internet traffic by receiving information from border routers in neighboring networks that "announce" which IP addresses they own and which other networks they can reach.

This ability to dynamically route traffic via different combinations of independently operated networks was one of the great innovations of the internet. But it also provides opportunities for viewpoint foreclosure. Network operators or others can attempt to take down unpopular websites by falsely announcing their IP addresses, a technique known as "BGP hijacking." Or, less dramatically, network operators could simply refuse to route traffic to or from an unpopular website by declining to announce the website's addresses or network number to neighboring networks. For example, after Cloud Innovation, an English colo provider, made itself a pariah in the African community by suing AfriNIC, certain African ISPs publicly discussed ceasing to route packets to IP addresses belonging to the company as a form of ideological retribution. Any regulatory scheme premised on preventing viewpoint foreclosure should therefore take account of a right to routability.

Accessibility. Finally, accessibility refers to the right of a website operator not to have users blocked from accessing her website.

Some ISPs already block access to illegal or infringing websites. Although the federal Stop Online Piracy Act (SOPA) and PROTECT IP Act (PIPA) bills, which would have required ISPs to block certain infringing sites, met an ignominious end after a well-publicized online revolt, copyright holders are nonetheless securing similar injunctions from courts.

But ISPs have just as much power to block lawful websites as they do unlawful websites. Such actions would no doubt violate net neutrality rules were they still in effect. Each of the FCC's three attempts at net neutrality included some form of a no-blocking rule that prevented ISPs from blocking subscribers' access to lawful applications and websites. And California's Internet Consumer Protection and Net Neutrality Act, which the state enacted in 2018 after the demise of federal net neutrality rules, currently prohibits such behavior. But net neutrality has historically targeted economic discrimination, not moral or ideological discrimination. It aimed to prevent ISPs from leveraging their power over their own networks to block subscribers from accessing websites either because the ISP offered a competing product or because the ISP wished to extract a toll from website operators to reach its subscribers.

Of course, taken literally, net neutrality rules would prevent ISPs from blocking any lawful website, regardless of the reason (economic or moral). But it remains to be seen whether net neutrality advocates, who tend to populate the political left, will continue to support such broad rules if those on the political right begin attempting to use them to protect far-right websites from left-led deplatforming campaigns.

[* * *]

In sum, if it is indeed possible to boot unpopular users, groups, or viewpoints from the internet altogether; if lawful (even offensive) websites should have a basic right to stay online; and if the First Amendment permits the state to intervene in attempts at "content moderation" by the entities that administer the internet's core resources—all of which I believe to be the case—then, fortunately, there is a workable solution. The architecture of the internet reveals five distinct choke points that could be used by private parties to excise disfavored speech from the internet. The state could protect lawful speech from that excision by enshrining five basic internet rights—the rights of connectivity, addressability, nameability, routability, and accessibility—a non-discrimination regime that would be clear and administrable. It could also be bipartisan, as it marries the economic discrimination concerns of the left that animate net neutrality with the ideological discrimination concerns of the right that animate social media non-discrimination laws like those in Texas and Florida. And because it focuses only on the core infrastructure of the internet—and the core issue of whether users should enjoy a basic right to speak on their own websites—its modesty is perhaps its most attractive feature.

Does that mean the state should never intervene in content moderation in higher layers of the internet stack, such as cloud computing or social media? I don't know. I remain unconvinced that either side of that debate has a slam dunk take on the issue. But if we start with the simple premise that all users should be able to speak not on individual websites but on the internet, then I think that that premise of basic viewpoint access could provide a platform from which to tackle those and many other thorny questions of content moderation.

War on Drugs

Republicans' Dangerous Plans to Turn the War on Drugs into a Real War by Attacking Mexico

This awful idea is increasingly popular on the right, and has been embraced by several GOP presidential candidates.

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Over the last few months, leading Republicans - including most of the party's presidential candidates - have converged on the idea that we should turn the War on Drugs into a real war by attacking Mexico. Donald Trump and others have long said the US should wage war against drug cartels in much the same way as we have against the ISIS terrorist group - a campaign that included large-scale use of both air strikes and ground forces. And similar ideas were reiterated by several participants in the recent GOP presidential debate.

The rise of this idea is one of the most dangerous trends in recent GOP/right-wing politics. It would make the already horrific War on Drugs still worse, and also threatens armed conflict with Mexico - destroying our relationship with a crucial neighbor and our largest trading partner. It is simultaneously cruel, unjust, and stupid.

If, like most libertarians, you oppose the War on Drugs as a whole, you obviously have reason to oppose this massive potential escalation. But even if you take a more favorable view of drug prohibition, you would do well to draw the line at turning the metaphorical war into a real one.

The present decades-long War on Drugs is already a horrific disaster. It kills and imprisons large numbers of people in both the US and abroad, while stimulating organized crime, and doing little to curb harmful addiction.  It's a massive infringement on liberty and bodily autonomy. The "war" has also severely undermined both individual constitutional rights and structural constitutional limits on federal power. The current fentanyl crisis - used as a justification for attacking Mexico and other drastic measures - is itself largely a result of the War on Drugs, a predictable consequence of the "Iron Law" of  prohibition, under which banning markets incentivizes dealers and users to turn to harder, more potent drugs.

It's unlikely that attacking Mexico will do much to curb drug addiction in the US. Most fentanyl smuggling is conducted by US citizens crossing legal ports of entry, not undocumented immigrants or Mexican cartel operatives. If military intervention succeeds in killing or disrupting some Mexican suppliers, others (including others from other countries) are likely to take their place, so long as there is still a demand for the product. That has been the result of past attempts to interdict drug supplies from Colombia, Afghanistan, and elsewhere. At most, we might get a modest temporary reduction in drug use.

While the benefits of attacking Mexico are likely to be minimal, doing so could easily have huge costs. Obviously, it is almost unavoidable that innocent civilians will be killed or injured in the fighting, especially since drug traffickers are hard to distinguish from the rest of the population. There are likely to be casualties among US troops, as well.

The 1.6 million Americans living in Mexico could potentially become targets for terrorism or retaliation by drug cartels. Here in the US, we could see racist and vigilante violence against Mexican-Americans. At the very least, a conflict with Mexico would predictably inflame racial and ethnic tensions.

Mexico recently became America's largest trading partner. A military intervention would likely disrupt that relationship, seriously damaging both nations' economies.

Attacking Mexico would also destroy America's moral authority in the world. We cannot credibly condemn Russia's invasion of Ukraine or a potential Chinese invasion of Taiwan if we are simultaneously invading our own neighbor merely to reduce drug smuggling. Such an action would predictably alienate many of our liberal-democratic allies in Europe and Asia, to say nothing of Latin America.

Perhaps worst of all, an invasion of Mexico would permanently damage our relationship with one of our two most important neighbors (along with Canada). Over the last century, the US has greatly benefited from having generally friendly and cooperative relations with the two nations with which we have long borders. Undermining that is sure to cause all sorts of problems and seriously weaken the overall US position in the world. Among other things, we are likely to have far more cross-border violence. And the Mexican government will have incentives to ally with China and other US adversaries.

Turning Mexico and its people into our enemies won't "make American great again." It would predictably weaken us and strengthen our adversaries elsewhere.

In fairness, Republicans are far from the only ones who deserve blame for the evils of the War on Drugs. That ill-advised conflict has a long bipartisan history, one to which President Biden, among other Democrats, has made plenty of contributions. But attacking Mexico would go well beyond even the worst previous drug war policies.

The best that can be said for Republican enthusiasm for attacking Mexico is that some of the GOP politicians who promote it may be just posturing or would content themselves with a symbolic show of force. Alternatively, they might limit themselves to only the kind of small-scale operations that may be approved by the Mexican government.

But I would not put too many eggs in that basket. If the symbolic show of force or small-scale operation fails (as it likely would), there would be pressure to go further. If invading Mexico becomes a major priority of the Republican base, a GOP president might find it hard to resist that pressure.

At the very least, the increasing acceptance of this idea in GOP circles has moved the Overton Window in the wrong direction. A terrible, previously fringe policy has become the mainstream position of one of our two major political parties. That greatly increases the likelihood it will actually be attempted should that party retake control of the White House in the near future.

Donald Trump

Why Efforts to Invoke Section 3 of the 14th Amendment to Keep Donald Trump Off the Ballot May Fail

Election law expert Derek Muller reminds us that we have seen these sorts of claims before.

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Claims that Donald Trump is ineligible to run again for President under Section 3 of the Fourteenth Amendment have prompted extensive discussion. (See, e.g., these posts by Steve Calabresi and Josh Blackman, Judge Michael Luttig's Twitter account, and this paper by Will Baude and Michael Paulsen.)

Over at the Election Law Blog, Professor Derek Muller explains why these claims face serious challenges and are not likely to keep Trump off the ballot. He writes:

Challenges to presidential candidates' eligibility are not new. There were extensive challenges to Barack Obama and Ted Cruz (among others) in administrative tribunals and courts. Most of these challenges never reached the merits stage of whether the candidate was a "natural born citizen" because they failed to clear some other hurdle.

The bulk of challenges right now are doing exactly the same thing and making the same mistakes, or are on pace to do the same.

As Muller notes, there is no clear, established mechanism for keeping candidates off of the ballot. Such questions are generally controlled by state law and administered by state officials. As he notes,

If challenges are not using this specific, pre-existing mechanisms to address presidential qualifications challenges, which are contoured to each state's specific law, the challenges are likely doomed to fail.

Election officials hold no unilateral power to exclude candidates from the ballot–and, frankly, we are fresh off a cycle where election officials purporting to take unilateral action without a statutory authorization to do so have been routinely losing challenges in mandamus.

Some have hypothesized that other candidates -- Chris Christie? Asa Hutchinson? -- could try and sue to keep Trump of the ballot, but there are serious obstacles here as well including (again) that much ballot access is a matter of state law, which could cause federal courts to abstain from reaching the issue.

The bottom line is that a silver bullet to prevent the re-election of Donald Trump remains hard to find. Those who oppose his re-election may have to do things the old fashioned way: Ensure their candidates get more votes.

Free Speech

Court Also Strikes Down "Public Health Warning" for Porn Sites

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From today's long decision in Free Speech Coalition, Inc. v. Colmenero, by Judge David Alan Ezra (W.D. Tex.) (see here for excerpts from the part of the decision that strikes down the separate age-verification requirement):

In addition to the age verification, H.B. 1181 requires adult content sites to post a "public health warning" about the psychological dangers of pornography. In 14-point font or larger, sites must post:

TEXAS HEALTH AND HUMAN SERVICES WARNING:

Pornography is potentially biologically addictive, is proven to harm human brain development, desensitizes brain reward circuits, increases conditioned responses, and weakens brain function.

TEXAS HEALTH AND HUMAN SERVICES WARNING:

Exposure to this content is associated with low self-esteem and body image, eating disorders, impaired brain development, and other emotional and mental illnesses.

TEXAS HEALTH AND HUMAN SERVICES WARNING:

Pornography increases the demand for prostitution, child exploitation, and child pornography.

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Free Speech

Texas Law Mandating Age Verification for Sexually Themed Sites Violates First Amendment,

a federal judge held today.

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Some excerpts from today's long decision in Free Speech Coalition, Inc. v. Colmenero by Judge David Alan Ezra (W.D. Tex.):

This case concerns a law passed by the State of Texas that restricts access to pornographic websites by requiring digital age verification methods … about the alleged harms caused by pornography….

H.B. 1181 is set to take effect on September 1, 2023. H.B. 1181 contains two requirements, both of which are challenged in this litigation. First, the law requires websites to use "reasonable age verification methods … to verify that an individual attempting to access the material is 18 years of age or older." Second, the law requires adult content websites to post a warning about the purported harmful effects of pornography and a national helpline for people with mental health disorders.

The law defines "sexual material harmful to minors" as including any material that "(A) the average person applying contemporary community standards would find, taking the material as a whole is and designed to appeal or pander to the prurient interest" to minors, (B) is patently offensive to minors, and (C) "taken as a whole, lacks serious literary, artistic, political, or scientific value for minors."

The law regulates a "commercial entity that knowingly and intentionally publishes or distributes material on an Internet website, including a social media platform, more than one-third of which is sexual material harmful to minors." H.B. 1181 requires these companies to "comply with a commercial age verification system that verifies age using: (A) government-issued identification; or (B) a commercially reasonable method that relies on public or private transactional data to verify the age of an individual." "Transactional data" refers to a "sequence of information that documents an exchange … used for the purpose of satisfying a request or event. The term includes records from mortgage, education, and employment entities." H.B. 1181 does not allow the companies or third-party verifiers to "retain any identifying information of the individual."

The court concluded that the age verification requirement was unconstitutional for various reasons, including that Ashcroft v. ACLU (II) (2004) and follow-on circuit court decisions struck down a similar federal law (COPA, the Child Online Protection Act). An excerpt that I thought was particularly closely connected to those precedents (though the court also made other arguments as well):

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"Strangers on the Internet" Podcast Ep. 41: Aliza Shatzman on the Joshua Wright Allegations and Law School Culture

The founder of the Legal Accountability Project explores how we got here and how we get out

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The 41st episode (Apple Podcasts link here and Spotify link here) of "Strangers on the Internet" features attorney and activist Aliza Shatzman.

In the third part of my coverage of the sexual misconduct allegations against ex-George Mason University law professor and former FTC Commissioner Joshua Wright (part 1 with Prof. Christa Laser is here and part 2 with Prof. Brandy Wagstaff is here), I speak with a victim of judicial harassment and retaliation who founded the Legal Accountability Project.

After graduating from the Washington University School of Law in 2019, Aliza began clerking for a judge in the Superior Court of the District of Columbia. After subjecting her to harassment and sex discrimination, the judge fired her and then went on to derail her legal career by providing false statements during her final reference check for a prestigious position as a federal prosecutor in such a manner that she lost the position.

Aliza and I discuss how little has changed in the twenty years between when I started law school--a time of shady "open secrets" at my own alma mater and in the judiciary--and today. We talk about the roots of the culture of silence and its reinforcement via tools such as defamation lawsuits, like potentially the one currently faced by two of Josh Wright's alleged victims, and what true change and principled allyship look like.

Note: According to a statement printed in the media by Lindsay McKasson, counsel to Joshua Wright at Binall Law Group "all allegations of sexual misconduct are false," "These false allegations are being made public after unsuccessfully demanding millions of dollars behind closed doors," and "We look forward to total vindication in court." According to a tweet by Prof. Christa Laser, "I don't appreciate that his attorney falsely suggests we are all lying (1/2 was in writing!) & want $ (this is a lie–I only want him gone)."

Aliza Shatzman

Free Speech

Should a Website Have the Right to Exist?

Even outcasts should be able to subsist on their own land.

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(This post is part of a five-part series on regulating online content moderation.)

In Part III, I showed how it is technically possible to boot an unpopular speaker or her viewpoints from the internet. Such viewpoint foreclosure, as I call it, can be accomplished when the private entities that administer the internet's core resources—domain names, IP addresses, networks—deny those resources to websites that host offensive, albeit lawful, user content.

In Part II, I explained that even if the Supreme Court finds that social media platforms and other websites have a First Amendment right to moderate user content however they like, the entities that administer the internet's core resources probably do not. As such, if the state wanted to prevent core intermediaries from discriminating against lawful user speech, it probably could.

But should it? Or, left to itself, would the online marketplace of ideas do a better job of finding the right balance between free expression and cleaning up the internet? Another way of framing this issue is to ask whether a lawful website should have the right to exist. In this post, I argue that it should. I offer four reasons.

Reason #1: The Internet Is Different

Here's a common objection I've received when presenting my paper (on which this series is based): "Why should anyone have a right to speak on the internet? No one has the right to have his op-ed published in a newspaper, his voice broadcast over the radio, or his likeness displayed on TV. If newspapers, radio stations, and cable companies have the freedom to refuse to host your speech, why shouldn't every private intermediary on the internet, including core intermediaries, have the same freedom?

My response to this objection is that the internet is different from these other kinds of media. It's different in two important ways.

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Free Speech

Firing Based on Employee's Pre-Employment Social Media Posts Leads to Discrimination Lawsuit;

federal court allows the case to go forward.

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From Watson v. Philadelphia Parking Auth., decided Monday by Judge Cynthia Rufe (E.D. Pa.):

Plaintiff describes himself as an African-American, homosexual male. He began working at the PPA on February 24, 2020, as a "Data Officer." On his first day of employment, Plaintiff was given a copy of the PPA's social media policy and the employee handbook. Before and during his employment with the PPA, Plaintiff maintained various social media accounts. During Plaintiff's first week of employment, Defendant received an anonymous complaint regarding Plaintiff's social media use. The anonymous complaint referenced posts written before his employment and one post written on February 26, 2020, after Plaintiff started at the PPA, stating "this guy has the prettiest ass…I hope his girlfriend knows how lucky she is!" The post did not include a photograph or identify the individual.

Plaintiff testified in his deposition that during a meeting about the post, his direct supervisor, Deputy Executive Director Clarena Tolson, told him that "heterosexual men, employees, wouldn't want to work with [Plaintiff] without—without fearing for their safety and that people could consider [Plaintiff] a sexual predator because of it." Plaintiff further testified that Richard Dickson, the First Deputy Executive Director, then told him, "I'm sorry, I don't know how it feels to be a Black, gay man, but [ ] gay men are under so much scrutiny here," and that because Plaintiff was "coming from multiple identity groups" he "would face even higher scrutiny." Tolson and Dickson determined that Plaintiff did not create this post during work time, it did not refer to a PPA employee, and it did not violate the company's social media policy. Scott Petri, the Executive Director of the PPA, was not in this meeting and Plaintiff asserts that Petri refused to meet with him.

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