2026-02-16T07:59:33-06:00 2025-09-30 994625061 CRI ADVISORS LLC 4004 SUMMIT BLVD NE SUITE 800 ATLANTA GA 30319 990EZ 2024-10-01 581539320 THE UNITED STATES CONSTITUTIONAL RIGHTS LEGAL DEFENSE FUND INC UNIT 7709800921 3360 E TERRELL BRANCH COURT MARIETTA GA 300675164 BAKER A SMITH SECRETARY / TREASURER 7709800921 2026-02-10 1 1 STANLEY M SMITH II P00319916 7703948000 2026-02-10 2024 2025-03-06 01:10:19Z X N/A X X 19000 X 19000 19000 46610 46610 -27610 36298 0 8688 36298 8688 36298 8688 0 0 36298 8688 X TO PROVIDE CERTAIN LEGAL ASSISTANCE ON VARIOUS CONSTITUTIONAL RIGHTS ISSUES. LITIGATION ACTIVITIES 0 40577 LEGAL DEFENSE INFORMATION SERVICES AND REPORTS, RESOURCE DEVELOPMENT 0 1813 42390 GREG MOURAD CHAIRMAN/PRESIDENT/DIRECTOR 1.00 0 0 0 MICHAEL ROTHFELD VICE-CHAIRMAN/DIRECTOR 1.00 0 0 0 BAKER A SMITH SECRETARY/TREASURER/DIRECTOR 1.00 0 0 0 X 0 0 0 0 0 0 0 0 0 0 0 0 0 0 GA BAKER A SMITH 3360 E TERRELL BRANCH COURT MARIETTA GA 300675164 7709800921 0 0 0 0 0 0 0 0 0 0 NONE NONE 1 X 13500 13500 13500 13500 19000 73000 13500 13500 13500 13500 19000 73000 25540 47460 73000 0.65010 0.68670 X RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED FORM 990-EZ, PART I, LINE 16 - OTHER EXPENSES DESCRIPTION: LITIGATION ACTIVITIES. AMOUNT: 40,577. DESCRIPTION: LEGAL DEFENSE INFORMATION SERVICES AND REPORTS. AMOUNT: 125. DESCRIPTION: MANAGEMENT AND GENERAL OPERATING EXPENSES. AMOUNT: 2,408. DESCRIPTION: RESOURCE DEVELOPMENT. AMOUNT: 3,500. TOTAL TO FORM 990-EZ, LINE 16: 46,610. FORM 990-EZ, PART III, LINE 28: DUNCAN V. BONTA, CASE NO. 25-198. PETITION FOR A WRIT OF CERTIORARI FILED AUGUST 15, 2025. AMICUS CURIAE BRIEF IN SUPPORT OF PETITIONERS FILED SEPTEMBER 18, 2025. OUR BRIEF ENCOURAGES THE COURT TO GRANT THE PETITION TO ENSURE THAT THE LOWER COURTS ARE FOLLOWING THE BRUEN FRAMEWORK, RATHER THAN ARBITRARILY NARROWING THE DEFINITION OF "ARMS" TO PERMIT A BAN ON ANY CLASS OF WEAPON THAT OFFENDS THE SENSIBILITIES OF FEDERAL JUDGES. SEE NINTH CIRCUIT DISCUSSION OF THIS CASE, BELOW, FOR MORE INFORMATION. FORM 990-EZ, PART III, LINE 28: LITTLE V. HECOX/WV V. B.P. J., CASE NOS. 24-38 & 24-43. PETITION FOR A WRIT OF CERTIORARI GRANTED ON JULY 3, 2025. MERITS AMICUS CURIAE BRIEF IN SUPPORT OF PETITIONERS FILED SEPTEMBER 19, 2025. ORAL ARGUMENT HELD ON JANUARY 13, 2026. LITTLE V. HECOX INVOLVES IDAHO'S FAIRNESS IN WOMEN'S SPORTS ACT, IDAHO CODE SECTION 33-6201-06 (2020), WHICH MANDATES THAT ONLY BIOLOGICAL FEMALES MAY COMPETE ON INTERSCHOLASTIC WOMEN'S AND GIRLS' TEAMS IN IDAHO STATE SCHOOLS, RESTRICTING BIOLOGICAL MALES TO MEN'S AND BOYS' TEAMS AND TEAMS IN DESIGNATED MIXED SPORTS, THUS PROTECTING GIRLS' SPORTS FROM BIOLOGICAL MALES WHO CLAIM TO IDENTIFY AS FEMALE. THE LAW WAS CHALLENGED BY A BIOLOGICAL MALE WISHING TO TRY OUT FOR THE WOMEN'S CROSS COUNTRY AND TRACK TEAMS AT BOISE STATE UNIVERSITY. THE U.S. DISTRICT COURT FOR THE DISTRICT OF IDAHO ENJOINED THE ACT, DECLARING IT VIOLATED THE FOURTEENTH AMENDMENT'S EQUAL PROTECTION GUARANTEE. HECOX V. LITTLE, 479 F. SUPP. 3D 930, 988-89 (D. ID. 2020) ("HECOX I"). THE NINTH CIRCUIT AFFIRMED, HECOX V. LITTLE, 79 F.4TH 1009 (9TH CIR. 2023). HOWEVER, AFTER THE SUPREME COURT'S RULING IN LABRADOR V. POE, 144 S. CT. 921 (2024), THE NINTH CIRCUIT ISSUED AN AMENDED OPINION REMANDING THE CASE AND STATING THAT "THE SCOPE OF THE INJUNCTION IS NOT CLEAR. . . .[T]HE COURT'S ORDER DOES NOT SPECIFY WHETHER ENFORCEMENT OF THE ACT IS ENJOINED IN WHOLE OR IN PART. . . . ON REMAND, THE DISTRICT COURT SHOULD TAILOR THE INJUNCTION TO PROVIDE. . . .SPECIFICITY." HECOX V. LITTLE, 2024 U.S. APP. LEXIS 13929, *60-61 ("HECOX II"). THE NINTH CIRCUIT THEN DENIED PETITIONS FOR REHEARING EN BANC AS MOOT. HECOX V. LITTLE, 2024 U.S. APP. LEXIS 14077 (9TH CIR. 2024). IN WV V. B.P.J., WEST VIRGINIA ASKS THE SUPREME COURT TO DECIDE TWO ISSUES: (1) "WHETHER TITLE IX PREVENTS A STATE FROM CONSISTENTLY DESIGNATING GIRLS AND BOYS' SPORTS TEAMS BASED ON BIOLOGICAL SEX DETERMINED AT BIRTH; AND (2) "WHETHER THE EQUAL PROTECTION CLAUSE PREVENTS A STATE FROM OFFERING SEPARATE BOYS AND GIRLS' SPORTS TEAMS BASED ON BIOLOGICAL SEX DETERMINED AT BIRTH." THE FOURTH CIRCUIT HAD REVERSED A DISTRICT COURT DECISION IN WEST VIRGINIA'S FAVOR AND REMANDED THE CASE WITH INSTRUCTIONS TO ENTER SUMMARY JUDGMENT FOR B.P.J. ON THE TITLE IX CLAIMS AND FOR FURTHER PROCEEDINGS, INCLUDING REMEDIAL PROCEEDINGS, CONSISTENT WITH THE FOURTH CIRCUIT OPINION. OUR BRIEF POINTS OUT, "ACTUALLY, SEX IS DETERMINED BEFORE BIRTH-AT CONCEPTION. . . . IT CAN BE ESTABLISHED GENETICALLY. IT IS IMMUTABLE." BR. AT 7, N.3. RECENT LEGAL DEVELOPMENTS ARE BASED ON THE STANDARDS OF CARE PUBLISHED BY THE WORLD PROFESSIONAL ASSOCIATION FOR TRANSGENDER HEALTH ("WPATH"), A HIGHLY POLITICIZED ORGANIZATION HEAVILY FUNDED BY PERSONS PUSHING TRANSGENDERISM RATHER THAN AN OBJECTIVE MEDICAL STANDARDS ORGANIZATION. BR. AT 12-18. IT REMOVED MINIMUM AGE LIMITS FOR TRANSGENDER SURGERY AT THE BEHEST OF THE BIDEN ADMINISTRATION. BR. AT 19-20. NOT A SINGLE DRAFTING COMMITTEE MEMBER WANTED TO REMOVE THE MINIMUM AGE LIMITS. BR. AT 20. WE ALSO SHOW THAT TRANSGENDERISM HAS ANCIENT SPIRITUAL ROOTS AND TYPICALLY MANIFESTS ITSELF IN LATE PHASES OF CULTURE, AS RELIGIOUS, POLITICAL, AND FAMILY TRADITIONS WEAKEN AND CIVILIZATIONS BEGIN TO DECLINE. BR. AT 23-24. FORM 990-EZ, PART III, LINE 28: ROBINSON V. UNITED STATES, NO. 25-5150. PETITION FOR A WRIT OF CERTIORARI FILED JULY 16, 2025. AMICUS CURIAE BRIEF IN SUPPORT OF PETITION FILED SEPTEMBER 19, 2025. DAVID ROBINSON JR. WAS CONVICTED UNDER 26 U.S.C. SECTIONS 5861(D), 5871, AND 5841--SECTIONS OF THE NATIONAL FIREARMS ACT (NFA) THAT IMPOSE CRIMINAL PENALTIES OF UP TO 10 YEARS' IMPRISONMENT FOR POSSESSING A SHORT-BARRELED RIFLE (SBR) NOT REGISTERED BY THE TRANSFEROR OF THE RIFLE. AS THE TRANSFEREE, ROBINSON WAS NOT RESPONSIBLE FOR PAYING THE $200 FEE REQUIRED TO REGISTER THE RIFLE. THE CONSTITUTIONAL FOUNDATION JUSTIFYING THE FEDERAL CRIMINALIZATION OF HIS CONDUCT IS CONGRESS'S POWER TO TAX UNDER ARTICLE I, SECTION 8, CLAUSE 1 OF THE CONSTITUTION. HE RAISED TWO QUESTIONS: (1) WHETHER FEDERAL CRIMINAL PUNISHMENT OF THE POSSESSION OF AN UNREGISTERED SHORT-BARRELED RIFLE VIOLATES THE SECOND AMENDMENT; AND (2) WHETHER FEDERAL CRIMINAL PUNISHMENT OF THE POSSESSION OF AN UNREGISTERED SHORT-BARRELED RIFLE EXCEEDS CONGRESS'S POWER TO TAX UNDER ARTICLE I, SECTION 8, CLAUSE 1 OF THE CONSTITUTION. OUR BRIEF ARGUED THAT SBRS, AT THE FOUNDING AND CURRENTLY, ARE COMMON MILITARY WEAPONS, I.E., "ARMS," THAT THE PEOPLE ARE CONSTITUTIONALLY PROTECTED IN POSSESSING AND BEARING UNDER THE SECOND AMENDMENT. "CONTRARY TO THE NFA'S MODERN RESTRICTIONS, THE UNIMPEDED, WIDESPREAD CITIZEN OWNERSHIP OF SBRS 'IS CONSISTENT WITH THE PRINCIPLES THAT UNDERPIN OUR REGULATORY TRADITION.' UNITED STATES V. RAHIMI, 602 U.S. 680, 692 (2024). . . . INDEED, ALONG WITH THEIR WIDESPREAD CIVILIAN USE, SUB-16-INCH-BARRELED RIFLES ARE THE MOST COMMON RIFLES IN THE AMERICAN MILITARY TODAY." BR. AT 22. THE COURT DENIED THE PETITION ON DECEMBER 15, 2025, ENDING THE CASE. FORM 990-EZ, PART III, LINE 28: FIRST CHOICE WOMEN'S RESOURCE CENTERS, INC. V. PLATKIN, NO. 24-781. PETITION FOR A WRIT OF CERTIORARI GRANTED ON JUNE 16, 2025. AMICUS CURIAE MERITS BRIEF IN SUPPORT OF PETITIONERS FILED AUGUST 28, 2025. ORAL ARGUMENT HELD ON DECEMBER 2, 2025. ISSUE: WHERE THE SUBJECT OF A STATE INVESTIGATORY DEMAND HAS ESTABLISHED A REASONABLY OBJECTIVE CHILL OF ITS FIRST AMENDMENT RIGHTS, IS A FEDERAL COURT IN A FIRST-FILED ACTION DEPRIVED OF JURISDICTION BECAUSE THOSE RIGHTS MUST BE ADJUDICATED IN STATE COURT? NEW JERSEY'S ATTORNEY GENERAL ("AG") SERVED AN INVESTIGATORY SUBPOENA ON FIRST CHOICE WOMEN'S RESOURCE CENTERS, INC., A FAITH-BASED PREGNANCY CENTER, DEMANDING IT TURN OVER MOST OF ITS DONORS' NAMES. FIRST CHOICE CHALLENGED THE SUBPOENA UNDER 42 U.S.C. 1983 IN FEDERAL COURT, AND THE AG FILED A SUBSEQUENT SUIT TO ENFORCE IT IN STATE COURT. THE STATE COURT GRANTED THE AG'S MOTION TO ENFORCE THE SUBPOENA BUT EXPRESSLY DID NOT DECIDE FIRST CHOICE'S FEDERAL CONSTITUTIONAL CHALLENGES. THE AG THEN MOVED IN STATE COURT TO SANCTION FIRST CHOICE. MEANWHILE, THE DISTRICT COURT HELD THAT FIRST CHOICE'S CONSTITUTIONAL CLAIMS WERE NOT RIPE IN FEDERAL COURT. THE THIRD CIRCUIT AFFIRMED IN A DIVIDED PER CURIAM DECISION. JUDGE BIBAS WOULD HAVE HELD THE ACTION RIPE AS INDISTINGUISHABLE FROM AMERICANS FOR PROSPERITY FOUNDATION V. BONTA, 594 U.S. 595, 618-19 (2021). BUT THE MAJORITY CONCLUDED FIRST CHOICE'S CLAIMS WERE NOT YET RIPE BECAUSE FIRST CHOICE COULD LITIGATE ITS CONSTITUTIONAL CLAIMS IN STATE COURT. IN DOING SO, THE MAJORITY FOLLOWED THE RULE OF THE FIFTH CIRCUIT AND SPLIT FROM THE NINTH CIRCUIT. IT DID NOT ADDRESS THE LIKELY LOSS OF A FEDERAL FORUM ONCE THE STATE COURT RULES ON THE FEDERAL CONSTITUTIONAL ISSUES. FORM 990-EZ, PART III, LINE 28: TRUMP V. AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES, NO. 24A1174. AMICUS CURIAE BRIEF IN SUPPORT OF APPLICANT FILED JUNE 9, 2025. FEDERAL EMPLOYEE UNIONS AND OTHER PLAINTIFFS CHALLENGED PRESIDENT TRUMP'S EXECUTIVE ORDER 14210, "IMPLEMENTING THE PRESIDENT'S 'DEPARTMENT OF GOVERNMENT EFFICIENCY' WORKFORCE OPTIMIZATION INITIATIVE," 90 FED. REG. 9,669 (WORKFORCE EO). THE WORKFORCE EO DIRECTED AGENCY HEADS TO "UNDERTAKE PREPARATIONS TO INITIATE LARGE-SCALE REDUCTIONS IN FORCE (RIFS), CONSISTENT WITH APPLICABLE LAW." THE DIRECTORS OF THE OFFICE OF MANAGEMENT AND BUDGET ("OMB") AND THE OFFICE OF PERSONNEL MANAGEMENT ("OPM") TOOK STEPS TO IMPLEMENT THE EXECUTIVE ORDER, INSTRUCTING AGENCY HEADS TO SUBMIT AGENCY RIF AND REORGANIZATION PLANS ("ARRPS") TO OMB AND OPM FOR REVIEW AND APPROVAL. THE DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA GRANTED A TEMPORARY RESTRAINING ORDER ("TRO") ON MAY 9, 2025. SEE AFGE V. TRUMP, 2025 U.S. DIST. LEXIS 89344 (N.D. CAL. 2025) ("AFGE I"). THE DISTRICT COURT FOLLOWED WITH A PRELIMINARY INJUNCTION ON MAY 22, 2025. SEE AFGE V. TRUMP, 2025 U.S. DIST. LEXIS 98195 (N.D. CAL. 2025) ("AFGE II"). A DIVIDED MOTIONS PANEL OF THE NINTH CIRCUIT DENIED THE GOVERNMENT'S EMERGENCY MOTION FOR A STAY OF THE PRELIMINARY INJUNCTION. AFGE V. TRUMP, 2025 U.S. APP. LEXIS 13315 (MAY 30, 2025) ("AFGE III"). THE GOVERNMENT THEN APPLIED FOR AN IMMEDIATE ADMINISTRATIVE STAY FROM THE SUPREME COURT. OUR BRIEF ARGUES THAT RIF'S HAVE ALWAYS BEEN PART OF THE PRESIDENT'S EXECUTIVE POWERS TO DETERMINE THE SIZE AND SHAPE OF THE FEDERAL WORKFORCE AND THAT DISTRICT COURTS HAVE NO JURISDICTION TO INTERFERE WITH THE PRESIDENT'S DETERMINATIONS. ALSO, THAT ANY DISPUTES ABOUT PERSONNEL ACTIONS MUST BE LODGED WITH AND DETERMINED IN THE FIRST INSTANCE BY THE FEDERAL LABOR RELATIONS AUTHORITY AND THE MERIT SYSTEMS PROTECTION BOARD. THUS THE DISTRICT COURT'S INTERFERENCE WITH THE WORKFORCE EO IS ULTRA VIRES. THE COURT GRANTED THE STAY ON JULY 8, 2025, "PENDING THE DISPOSITION OF THE APPEAL IN THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT AND DISPOSITION OF A PETITION FOR A WRIT OF CERTIORARI, IF SUCH A WRIT IS TIMELY SOUGHT." FORM 990-EZ, PART III, LINE 28: UNITED STATES OF AMERICA V. SHILLING, NO. 24A1030. APPLICATION FOR STAY OF INJUNCTION ISSUED BY U.S. DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON FILED APRIL 24, 2025. AMICUS CURIAE BRIEF IN SUPPORT OF APPLICANT FILED MAY 1, 2025. THIS CASE CHALLENGES PRESIDENT TRUMP'S EXECUTIVE ORDER 14183, ISSUED ON JANUARY 28, 2025, WHICH STATED, "[I]T IS THE POLICY OF THE UNITED STATES GOVERNMENT TO ESTABLISH HIGH STANDARDS FOR TROOP READINESS, LETHALITY, COHESION, AND "UNIFORMITY," AMONG OTHER FACTORS, AND THAT THIS "POLICY IS INCONSISTENT WITH THE MEDICAL, SURGICAL, AND MENTAL HEALTH CONSTRAINTS ON INDIVIDUALS WITH GENDER DYSPHORIA." 90 FED. REG. 8757 (FEB. 3, 2025). PURSUANT TO EO 14183, DEFENSE SECRETARY PETE HEGSETH PROMULGATED A POLICY THAT "DISQUALIFIES INDIVIDUALS WITH A HISTORY OF GENDER DYSPHORIA FROM MILITARY SERVICE, UNLESS THEY OBTAIN WAIVERS." HEGSETH'S POLICY, LIKE THE 2018 POLICY UNDER FORMER DEFENSE SECRETARY JAMES MATTIS, "EXCLUDES INDIVIDUALS BASED ON A MEDICAL CONDITION (GENDER DYSPHORIA) OR RELATED MEDICAL INTERVENTIONS, AND REQUIRES INDIVIDUALS TO SERVE IN THEIR [BIOLOGICAL] SEX." RESPONDENTS ARE SEVEN TRANS-IDENTIFYING INDIVIDUALS WHO ARE CURRENTLY SERVING IN THE MILITARY, ONE TRANS-IDENTIFYING INDIVIDUAL WHO WISHES TO JOIN THE MILITARY, AND AN ADVOCACY ORGANIZATION WHOSE MEMBERS INCLUDE THREE OF THE INDIVIDUAL RESPONDENTS. THEY CLAIM A VIOLATION OF EQUAL PROTECTION, THE FIRST AMENDMENT, PROCEDURAL DUE PROCESS, AND THE DOCTRINE OF EQUITABLE ESTOPPEL. GOVT'S BR. AT 12-13. OUR BRIEF ARGUES THAT THE COURT VIOLATED THE SEPARATION OF POWERS-IGNORING THE PRESIDENT IS COMMANDER IN CHIEF OF THE MILITARY-AND THAT IT HAD NO JURISDICTION TO INTERFERE WITH MATTERS OF MILITARY DISCIPLINE, READINESS, AND NATIONAL SECURITY. ALSO, CONGRESS HAS BROADLY DELEGATED ITS CONSTITUTIONAL AUTHORITY "[T]O MAKE RULES FOR THE GOVERNMENT AND REGULATION OF THE LAND AND NAVAL FORCES" (ARTICLE I, SEC. 8, CL. 14) TO SECRETARY HEGSETH: "THE SECRETARY IS THE PRINCIPAL ASSISTANT TO THE PRESIDENT IN ALL MATTERS RELATING TO THE DEPARTMENT OF DEFENSE. SUBJECT TO THE DIRECTION OF THE PRESIDENT AND TO THIS TITLE AND SECTION 2 OF THE NATIONAL SECURITY ACT OF 1947 (50 U.S.C. 3002) HE HAS AUTHORITY, DIRECTION, AND CONTROL OVER THE DEPARTMENT OF DEFENSE." 10 U.S.C. SECTION 113(B). WE URGE THE COURT TO GRANT THE APPLICATION FOR STAY. THE APPLICATION FOR STAY WAS GRANTED MAY 6, 2025, "PENDING THE DISPOSITION OF THE APPEAL IN THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT AND DISPOSITION OF A PETITION FOR A WRIT OF CERTIORARI, IF SUCH A WRIT IS TIMELY SOUGHT." FORM 990-EZ, PART III, LINE 28: TRUMP V. CASA, INC., TRUMP V. WASHINGTON, & TRUMP V. NEW JERSEY, NOS. 24A884, 24A885, & 24A886. APPLICATIONS FOR STAYS OF LOWER COURT ORDERS FILED ON MARCH 13, 2025. AMICUS CURIAE BRIEF IN SUPPORT OF APPLICANTS FILED MARCH 28, 2025. ORAL ARGUMENT HELD MAY 15, 2025. THESE CASES CHALLENGED PRESIDENT TRUMP'S EXECUTIVE ORDER 14160 (EO) CONCERNING "BIRTHRIGHT" CITIZENSHIP. LOWER COURTS ISSUED UNIVERSAL INJUNCTIONS AGAINST THE EO. THE GOVERNMENT ASKED THE COURT TO STAY ENFORCEMENT OF THE INJUNCTIONS PENDING FURTHER DISPOSITION AND, SPECIFICALLY, TO LIMIT THE SCOPE OF THE INJUNCTIONS TO THE PLAINTIFFS WITH STANDING. THE COURT ISSUED ITS 6-3 DECISION ON JUNE 27, 2025, GRANTING THE STAYS "TO THE EXTENT THAT THE INJUNCTIONS ARE BROADER THAN NECESSARY TO PROVIDE COMPLETE RELIEF TO EACH PLAINTIFF WITH STANDING TO SUE." SLIP OP. AT 26. THE CASES CONTINUE IN THE COURTS BELOW. FORM 990-EZ, PART III, LINE 28: MISSOURI V. UNITED STATES, CASE NO. 24-796. PETITION FOR A WRIT OF CERTIORARI FILED JANUARY 23, 2025. AMICUS CURIAE BRIEF IN SUPPORT OF PETITIONER FILED FEBRUARY 26, 2025. IN JUNE 2021, MISSOURI ENACTED THE "SECOND AMENDMENT PRESERVATION ACT" ("SAPA"), MO. REV. STAT. 1.410-1.485, WHICH DECLARED CERTAIN FEDERAL RESTRICTIONS ON FIREARMS TO BE "INFRINGEMENTS" OF MISSOURIANS' RIGHTS PROTECTED BY THE SECOND AMENDMENT TO THE UNITED STATES CONSTITUTION. SAPA ORDERS THAT "[A]LL FEDERAL ACTS, LAWS, EXECUTIVE ORDERS, ADMINISTRATIVE ORDERS, RULES, AND REGULATIONS [WHICH] INFRINGE ON THE PEOPLE'S RIGHT TO KEEP AND BEAR ARMS AS GUARANTEED BY THE SECOND AMENDMENT . . . SHALL NOT BE ENFORCED BY THIS STATE." ID. AT 1.430. ADDITIONALLY, SAPA PROVIDES THAT: "NO ENTITY OR PERSON, INCLUDING ANY PUBLIC OFFICER OR EMPLOYEE OF THIS STATE OR ANY POLITICAL SUBDIVISION OF THIS STATE, SHALL HAVE THE AUTHORITY TO ENFORCE OR ATTEMPT TO ENFORCE ANY FEDERAL ACTS, LAWS, EXECUTIVE ORDERS, ADMINISTRATIVE ORDERS, RULES, REGULATIONS, STATUTES, OR ORDINANCES INFRINGING ON THE RIGHT TO KEEP AND BEAR ARMS." ID. AT 1.450. FINALLY, SAPA IMPOSES A $50,000 CIVIL FINE ON ANY "POLITICAL SUBDIVISION OR LAW ENFORCEMENT AGENCY" THAT AFTERWARD HIRES ANY FEDERAL EMPLOYEE WHO ATTEMPTS TO ENFORCE AN "INFRINGEMENT." ID. AT 1.470. IN FEBRUARY 2022, THE UNITED STATES SUED THE STATE OF MISSOURI IN THE U.S. DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI FOR VIOLATION OF THE CONSTITUTION'S SUPREMACY CLAUSE AND ON OTHER GROUNDS. THE DISTRICT COURT DECLARED SAPA "INVALID, NULL, VOID, AND OF NO EFFECT" FOR HAVING EXCEEDED THE STATE'S AUTHORITY UNDER THE SUPREMACY CLAUSE. UNITED STATES V. STATE OF MISSOURI, ET AL., 2:22-CV-04022-BCW (W.D. MO. MAR. 7, 2023), AFF'D 114 F.4TH 980 (8TH CIR. 2024). OUR BRIEF ARGUED THAT MISSOURI'S STATUTE COMPLEMENTS--RATHER THAN UNDERMINES--FEDERAL LAW AND IS THEREFORE LAWFUL UNDER THE SUPREMACY CLAUSE. THE SUPREME COURT DENIED THE PETITION ON OCTOBER 6, 2025 ENDING THE CASE. FORM 990-EZ, PART III, LINE 28: CASE V. MONTANA, CASE NO. 24-624. PETITION FOR A WRIT OF CERTIORARI FILED DECEMBER 4, 2024. AMICUS CURIAE BRIEF IN SUPPORT OF PETITIONER FILED AUGUST 6, 2025. ORAL ARGUMENT HELD ON OCTOBER 15, 2025. ISSUE: WHETHER, UNDER THE FOURTH AMENDMENT, POLICE MAY ENTER A HOME TO CONDUCT A WELLNESS CHECK ON A REPORTEDLY SUICIDAL INDIVIDUAL WITHOUT A WARRANT ISSUED UPON PROBABLE CAUSE THAT A CRIME IS ABOUT TO BE OR HAS BEEN COMMITTED. THE MONTANA SUPREME COURT DECIDED THAT NEITHER A WARRANT NOR PROBABLE CAUSE IS NEEDED. OUR BRIEF ARGUES THAT MONTANA'S "CARETAKER EXCEPTION" RULE VIOLATES THE FOURTH AMENDMENT'S PROHIBITION OF SEARCHES OF HOMES CONDUCTED WITHOUT A WARRANT ISSUED UPON PROBABLE CAUSE THAT A CRIME HAS BEEN COMMITTED. WE URGE THE COURT TO REJECT MONTANA'S REASONABLENESS TEST FOR ENTRY. FORM 990-EZ, PART III, LINE 28: CHILES V. SALAZAR, CASE NO. 24-539. PETITION FOR A WRIT OF CERTIORARI FILED NOVEMBER 3, 2024. PETITION GRANTED MARCH 10, 2025. MERITS AMICUS CURIAE BRIEF IN SUPPORT OF PETITIONER FILED JUNE 13, 2025. ORAL ARGUMENT HELD OCTOBER 7, 2025. COLORADO LAW BARS LICENSED COUNSELORS FROM USING "[C]ONVERSION THERAPY WITH A CLIENT WHO IS UNDER EIGHTEEN YEARS OF AGE." C.R.S. SECTION 12-245-224(1)(T)(V). "'CONVERSION THERAPY' MEANS ANY PRACTICE OR TREATMENT BY A LICENSEE, REGISTRANT, OR CERTIFICATE HOLDER THAT ATTEMPTS OR PURPORTS TO CHANGE AN INDIVIDUAL'S SEXUAL ORIENTATION OR GENDER IDENTITY, INCLUDING EFFORTS TO CHANGE BEHAVIORS OR GENDER EXPRESSIONS OR TO ELIMINATE OR REDUCE SEXUAL OR ROMANTIC ATTRACTION OR FEELINGS TOWARD INDIVIDUALS OF THE SAME SEX." C.R.S. SECTION 12-245-202(3.5)(A). PETITIONER KAYLEY CHILES ALLEGES THAT COLORADO'S RESTRICTIONS ON HER SPEECH BAN HER ABILITY TO COUNSEL HER CLIENTS TOWARD TRADITIONAL BIBLICAL MORALITY, PERMITTING ONLY COUNSELING AGAINST SUCH BIBLICAL MORALITY, WHICH CONSTITUTES BOTH CONTENT AND VIEWPOINT DISCRIMINATION IN VIOLATION OF THE FIRST AMENDMENT SPEECH AND FREE EXERCISE OF RELIGION PROTECTIONS. NEVERTHELESS, THE DISTRICT COURT RULED THAT "[T]HE MINOR THERAPY CONVERSION LAW IS VIEWPOINT NEUTRAL AND DOES NOT IMPOSE CONTENT-BASED SPEECH RESTRICTIONS." CHILES V. SALAZAR, 2022 U.S. DIST. LEXIS 227887, *25 (D. COLO. 2022) ("CHILES I"). THE TENTH CIRCUIT AFFIRMED "IN FULL." CHILES V. SALAZAR, 116 F.4TH 1178, 1191 (10TH CIR. 2024) ("CHILES II"). OUR BRIEF ARGUES THAT COLORADO'S LAW IS A CONTENT-BASED FIRST AMENDMENT VIOLATION, CENSORING CHRISTIAN PROFESSIONALS' BIBLICAL PERSPECTIVE AND DRIVING THEM OUT OF THE PROFESSION. FORM 990-EZ, PART III, LINE 28: NATIONAL RIFLE ASSOCIATION V. GLASS, CASE NO. 24-1185. PETITION FOR A WRIT OF CERTIORARI FILED MAY 16, 2025. AMICUS CURIAE BRIEF IN SUPPORT OF PETITIONERS FILED JUNE 20, 2025. THIS CASE CHALLENGES A FLORIDA LAW THAT PROHIBITS (A) PERSONS UNDER AGE 21 FROM PURCHASING A FIREARM AND (B) LICENSED IMPORTERS, LICENSED MANUFACTURERS, AND LICENSED DEALERS FROM SELLING OR TRANSFERRING A FIREARM TO PERSONS UNDER AGE 21. THE LAW VIOLATES THE SECOND AMENDMENT RIGHTS OF ALL 18 TO 20 YEAR OLD ADULTS IN FLORIDA. THE ELEVENTH CIRCUIT UPHELD THE LAW. THE CASE WAS DISTRIBUTED FOR CONFERENCE OF NOVEMBER 14, 2025. FORM 990-EZ, PART III, LINE 28: FEDERAL COMMUNICATIONS COMMISSION V. CONSUMERS' RESEARCH, & SCHOOLS, HEALTH, & LIBRARIES BROADBAND COALITION V. CONSUMER'S RESEARCH, CONSOLIDATED CASE NOS. 24-354 & 24-422. PETITION FOR A WRIT OF CERTIORARI FILED SEPTEMBER 30, 2024. AMICUS CURIAE BRIEF IN SUPPORT OF RESPONDENTS FILED FEBRUARY 18, 2025. ORAL ARGUMENT HELD MARCH 6, 2025. IN 47 U.S.C. 254, CONGRESS REQUIRED THE FEDERAL COMMUNICATIONS COMMISSION (FCC) TO OPERATE UNIVERSAL SERVICE SUBSIDY PROGRAMS USING MANDATORY CONTRIBUTIONS FROM TELECOMMUNICATIONS CARRIERS. THE FCC APPOINTED A PRIVATE COMPANY AS THE PROGRAM ADMINISTRATOR, AUTHORIZING THAT COMPANY TO PERFORM ADMINISTRATIVE TASKS SUCH AS SENDING OUT BILLS, COLLECTING CONTRIBUTIONS, AND DISBURSING FUNDS TO BENEFICIARIES. THE QUESTIONS PRESENTED WERE: (1) WHETHER CONGRESS VIOLATED THE NONDELEGATION DOCTRINE BY AUTHORIZING THE FCC TO DETERMINE, WITHIN THE LIMITS SET FORTH IN SECTION 254, THE AMOUNT THAT PROVIDERS MUST CONTRIBUTE TO THE FUND; (2) WHETHER THE FCC VIOLATED THE NONDELEGATION DOCTRINE BY USING THE ADMINISTRATOR'S FINANCIAL PROJECTIONS IN COMPUTING UNIVERSAL SERVICE CONTRIBUTION RATES; AND (3) WHETHER THE COMBINATION OF CONGRESS'S CONFERRAL OF AUTHORITY ON THE FCC AND THE FCC'S DELEGATION OF ADMINISTRATIVE RESPONSIBILITIES TO THE ADMINISTRATOR VIOLATES THE NONDELEGATION DOCTRINE. OUR AMICUS BRIEF ARGUED THAT CONGRESS HAD UNCONSTITUTIONALLY DELEGATED ITS TAXING POWER TO THE FCC IN VIOLATION OF ARTICLE I, SECTION 1, OF THE U.S. CONSTITUTION, AND THE FCC HAD FURTHER UNCONSTITUTIONALLY DELEGATED THAT POWER TO THE ADMINISTRATOR, A PRIVATE ENTITY. ON JUNE 27, 2025, IN A 6-3 DECISION, THE SUPREME COURT UPHELD THE DELEGATION TO THE FCC AS ADEQUATELY "TETHERED TO LEGISLATIVE JUDGMENTS ABOUT THE SCOPE AND CONTENT OF THE UNIVERSAL-SERVICE PROGRAM." SLIP OP. AT 30. IT UPHELD THE ADMINISTRATOR'S ROLE AS MERELY "AN ADVISORY ROLE, THE COMMISSION ALONE HAS DECISION-MAKING AUTHORITY." ID. AT 32. THE DECISION EFFECTIVELY ENDED THE CASE. FORM 990-EZ, PART III, LINE 28: TRUMP V. WILCOX & BESSENT V. HARRIS, CONSOLIDATED CASE NO. 24A966. ON APRIL 9, 2025, THE TRUMP ADMINISTRATION ASKED THE SUPREME COURT TO STAY JUDGMENTS OF THE U.S. DISTRICT COURT FOR THE DISTRICT OF COLUMBIA. AMICUS CURIAE BRIEF IN SUPPORT OF APPLICANTS FILED APRIL 15, 2025. THESE CASES CHALLENGE THE AUTHORITY OF THE PRESIDENT TO REMOVE A MEMBER OF THE NATIONAL LABOR RELATIONS BOARD (NLRB) AND A MEMBER OF THE MERIT SYSTEMS PROTECTION BOARD (MSPB) WITHOUT CAUSE. WILCOX AND HARRIS RELY ON HUMPHREY'S EXECUTOR V. UNITED STATES, 295 U.S. 602 (1935), A CASE WHICH HAS BEEN LIMITED SEVERELY, ARGUABLY DOES NOT EVEN APPLY, AND APPEARS LIKELY TO BE OVERRULED. OUR AMICUS BRIEF ADDRESSED ONLY THE WILCOX/NLRB CASE, BUT THE ISSUES ARE VERY SIMILAR. THE DISTRICT COURT ORDERED REINSTATEMENT OF WILCOX AND HARRIS PENDING DISPOSITION OF THEIR CASES. ON MAY 22, 2025, THE SUPREME COURT STAYED THOSE ORDERS "PENDING THE DISPOSITION OF THE APPEAL IN THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT AND DISPOSITION OF A PETITION FOR A WRIT OF CERTIORARI, IF SUCH A WRIT IS TIMELY SOUGHT." THE COURT ACTED "TO AVOID THE DISRUPTIVE EFFECT OF THE REPEATED REMOVAL AND REINSTATEMENT OF OFFICERS DURING THE PENDENCY OF THIS LITIGATION." THE CASES CONTINUE IN THE COURTS BELOW. FORM 990-EZ, PART III, LINE 28: TRUMP V. SLAUGHTER, CASE NO. 25A264. ON SEPTEMBER 4, 2025, THE TRUMP ADMINISTRATION ASKED THE SUPREME COURT TO STAY THE JUDGMENT OF THE U.S. DISTRICT COURT FOR THE DISTRICT OF COLUMBIA. AMICUS CURIAE BRIEF IN SUPPORT OF APPLICANTS FILED SEPTEMBER 15, 2025. ON SEPTEMBER 22, 2025, THE COURT TREATED THE APPLICATION AS A PETITION FOR A WRIT OF CERTIORARI BEFORE JUDGMENT, GRANTED IT, AND ASSIGNED NEW CASE NO. 25-332. THIS CASE CHALLENGES THE AUTHORITY OF THE PRESIDENT TO REMOVE A MEMBER OF THE FEDERAL TRADE COMMISSION WITHOUT CAUSE. SLAUGHTER RELIES ON HUMPHREY'S EXECUTOR V. UNITED STATES, 295 U.S. 602 (1935), A CASE WHICH HAS BEEN LIMITED SEVERELY, ARGUABLY DOES NOT EVEN APPLY BECAUSE THE FTC NOW EXERCISES EXECUTIVE POWERS THAT IT DID NOT EXERCISE 90 YEARS AGO, AND APPEARS LIKELY TO BE OVERRULED. FORM 990-EZ, PART III, LINE 28: JOSHUA WADE V. UNIVERSITY OF MICHIGAN, CASE NO. 24-773. PETITION FOR A WRIT OF CERTIORARI FILED JANUARY 16, 2025. AMICUS CURIAE BRIEF IN SUPPORT OF PETITIONER FILED MARCH 10, 2025. PETITION DENIED APRIL 21, 2025. ISSUE: WHETHER THE SECOND AND FOURTEENTH AMENDMENTS ALLOW A CRIMINAL ORDINANCE THAT PROHIBITS MERE POSSESSION OF FIREARMS ON AN ENTIRE POORLY-DELINEATED UNIVERSITY CAMPUS, EXCEPT BY PERMISSION OF A SINGLE GOVERNMENT OFFICIAL WITH UNFETTERED DISCRETION, WHICH IS GRANTED ONLY FOR "EXTRAORDINARY CIRCUMSTANCES." OUR BRIEF ARGUES THAT "THE UNIVERSITY OF MICHIGAN IS, AS A MATTER OF LAW, A 'POLITICAL SUBDIVISION' OF THE STATE. THE UNIVERSITY IS FIRST AND FOREMOST A GOVERNMENTAL ENTITY WITH SPECIFIC BOUNDARIES LIKE THAT OF A MUNICIPALITY. . . . AS SUCH, THERE IS NO HISTORICAL BASIS FOR THE UNIVERSITY OF MICHIGAN TO EFFECTIVELY DECLARE THE GEOGRAPHICAL OUTER BOUNDARIES OF ALL UNIVERSITY-OWNED PROPERTY . . . A 'SENSITIVE PLACE.'" AMICUS BR. AT 24. FORM 990-EZ, PART III, LINE 28: MERRICK GARLAND, ATTORNEY GENERAL, ET AL., V. TEXAS TOP COP SHOP, INC., CASE NO. 24A653. ON DECEMBER 31, 2024, THE BIDEN ADMINISTRATION APPLIED FOR A STAY OF AN INJUNCTION ISSUED BY THE U.S. DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS. AMICUS CURIAE BRIEF IN SUPPORT OF RESPONDENTS FILED JANUARY 10, 2025. THIS CASE IS SIMILAR TO STEVEN F. HOTZE, M.D. V. U.S. DEPARTMENT OF THE TREASURY, PENDING IN THE U.S. DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS. SEE REPORT BELOW. IT CHALLENGES THE CORPORATE TRANSPARENCY ACT ("CTA"), 31 U.S.C. 5336, AND IMPLEMENTING REGULATIONS ISSUED BY THE TREASURY DEPARTMENT'S FINANCIAL CRIMES ENFORCEMENT NETWORK ("FINCEN"). 31 C.F.R. 1010.380. RESPONDENTS SOUGHT INJUNCTIVE RELIEF BASED ON A VARIETY OF THEORIES BUT THE DISTRICT COURT FOCUSED ON THE CLAIM THAT CONGRESS LACKED AUTHORITY TO ENACT THE CTA. SEE APPENDIX TO THE APPLICATION FOR STAY ("APPENDIX") AT 13A. ON DECEMBER 3, 2024, THE DISTRICT COURT GRANTED THE RESPONDENTS' MOTION FOR A PRELIMINARY INJUNCTION. SEE APPENDIX AT 19A. A FIFTH CIRCUIT MOTIONS PANEL STAYED THE INJUNCTION (APPENDIX AT 3A), BUT THAT STAY WAS VACATED BY THE MERITS PANEL (APPENDIX AT 1A). OUR AMICUS BRIEF URGES THE SUPREME COURT TO DENY THE GOVERNMENT'S APPLICATION, FILED IN THE WANING DAYS OF THE BIDEN ADMINISTRATION. WE PROVIDE THE COURT WITH ADDITIONAL INFORMATION ABOUT THE CURIOUS HISTORY OF THE CTA'S ENACTMENT, ITS UNCONSTITUTIONALITY UNDER DIFFERENT VIEWS OF THE COMMERCE CLAUSE AND THE NECESSARY AND PROPER CLAUSE, EXPLAINING THE RISK THAT THE CTA PRESENTS AS A TRAP FOR AMERICANS TO HAVE THEIR SECOND AMENDMENT RIGHTS STOLEN, AS WELL AS THE RISK TO AMERICANS POSED BY CTA INFORMATION BEING IN THE HANDS OF AN INCREASINGLY WEAPONIZED GOVERNMENT. ON JANUARY 23, 2025, THE SUPREME COURT GRANTED THE GOVERNMENT'S APPLICATION FOR A STAY "PENDING THE DISPOSITION OF THE APPEAL IN THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT AND DISPOSITION OF A PETITION FOR A WRIT OF CERTIORARI, IF SUCH A WRIT IS TIMELY SOUGHT."* OUR AMICUS BRIEF IN THE FIFTH CIRCUIT, NOW NAMED TEXAS TOP COP SHOP, INC. V. PAMELA BONDI, CASE NO. 24-40792, FILED ON MARCH 4, 2025, REPEATS AND EXPOUNDS UPON THE ARGUMENTS MADE IN OUR SUPREME COURT BRIEF. THE TRUMP ADMINISTRATION PROPOSED REVISIONS TO THE FINAL RULE TO "EXEMPT DOMESTIC REPORTING COMPANIES AND THEIR BENEFICIAL OWNERS FROM THE REPORTING REQUIREMENTS," 90 FED. REG. 13688, 13691, WHICH MAY MOOT THE CASE. BEING APPRISED OF THIS, ON AUGUST 5, 2025, THE FIFTH CIRCUIT ORDERED THE APPEAL HELD IN ABEYANCE PENDING ISSUANCE OF A FINAL RULE. * A PRELIMINARY INJUNCTION/STAY OF ENFORCEMENT WAS ENTERED IN A SEPARATE CASE, SMITH V. DEPARTMENT OF TREASURY, U.S.D.C., D.TEX., 6:24-CV-336-JDK, ON JANUARY 7, 2025, PROMPTING FINCEN TO ANNOUNCE THAT IT WILL NOT NOW BE ENFORCING THE CTA REPORTING REQUIREMENT. "REPORTING COMPANIES ALSO ARE NOT SUBJECT TO LIABILITY IF THEY FAIL TO FILE THIS INFORMATION WHILE THE SMITH ORDER REMAINS IN FORCE." BENEFICIAL OWNERSHIP INFO'N, HTTPS://WWW.FINCEN.GOV/BOI. FORM 990-EZ, PART III, LINE 28: BOST ET AL. V. ILLINOIS STATE BOARD OF ELECTIONS, CASE NO. 24-568. PETITION FOR A WRIT OF CERTIORARI FILED NOVEMBER 19, 2024. AMICUS CURIAE BRIEF IN SUPPORT OF PETITIONERS FILED DECEMBER 23, 2024. PETITION GRANTED JUNE 2, 2025. MERITS AMICUS CURIAE BRIEF FILED JULY 29, 2025. ORAL ARGUMENT HELD OCTOBER 8, 2025. THREE FORMER AND PROSPECTIVE CANDIDATES FOR FEDERAL OFFICE CHALLENGED ILLINOIS' "BALLOT RECEIPT DEADLINE STATUTE," WHICH PERMITS MAIL-IN BALLOTS TO BE "RECEIVED AND COUNTED FOR UP TO 14 DAYS AFTER ELECTION DAY, SO LONG AS THE BALLOT WAS POSTMARKED OR CERTIFIED ON OR BEFORE ELECTION DAY." BOST V. ILL. STATE BD. OF ELECTIONS, 684 F. SUPP. 3D 720, 725-26 (N.D. ILL. 2023) ("BOST I"). PLAINTIFFS ALLEGED THAT ILLINOIS' LAW VIOLATES FEDERAL LAW, INCLUDING, INTER ALIA, 2 U.S.C. SECTION 7, WHICH STATES: "[T]HE TUESDAY NEXT AFTER THE 1ST MONDAY IN NOVEMBER, IN EVERY EVEN NUMBERED YEAR, IS ESTABLISHED AS THE DAY FOR THE ELECTION, IN EACH OF THE STATES AND TERRITORIES OF THE UNITED STATES, OF REPRESENTATIVES . . . [TO] CONGRESS." PLAINTIFFS ALSO RAISED CONSTITUTIONAL CLAIMS THAT THE STATUTE "DEPRIVES THEM OF THEIR RIGHTS AS CANDIDATES UNDER THE FIRST AND FOURTEENTH AMENDMENTS BY FORCING THEM TO SPEND TIME AND MONEY TO ORGANIZE, FUND, AND RUN THEIR CAMPAIGN AFTER ELECTION DAY." BOST I AT 726. DEFENDANT ILLINOIS BOARD OF ELECTIONS MOVED TO DISMISS, ARGUING THAT THE PLAINTIFFS LACKED STANDING, AND THAT STATE SOVEREIGN IMMUNITY UNDER THE ELEVENTH AMENDMENT BARRED THE CLAIM. ID. AT 725. THE DISTRICT COURT DISMISSED THE CASE ON STANDING GROUNDS. ID. AT 730, 732. ON APPEAL, THE SEVENTH CIRCUIT AFFIRMED ON THE SAME STANDING GROUNDS, WITHOUT REACHING THE ELEVENTH AMENDMENT ISSUE. BOST V. ILL. STATE BD. OF ELECTIONS, 114 F.4TH 634, 644 (7TH CIR. 2024) ("BOST II"). FORM 990-EZ, PART III, LINE 28: L.M. V. TOWN OF MIDDLEBOROUGH, MASSACHUSETTS, CASE NO. 24-410. PETITION FOR A WRIT OF CERTIORARI FILED OCTOBER 9, 2024. AMICUS CURIAE BRIEF IN SUPPORT OF PETITIONER FILED DECEMBER 20, 2024. PETITION DENIED MAY 27, 2025, ENDING THE CASE. IN MARCH 2023, 12-YEAR-OLD L.M. WORE A SHIRT TO SCHOOL THAT READ, "THERE ARE ONLY TWO GENDERS." L.M. V. TOWN OF MIDDLEBOROUGH, 677 F. SUPP. 3D 29, 33 (DIST. MASS. 2023) ("LM I"). L.M. WAS RESPONDING TO THE SCHOOL'S FLOOD OF MESSAGES TO STUDENTS THAT "SEX AND GENDER ARE SELF-DEFINED, LIMITLESS, AND UNMOORED FROM BIOLOGY." THE SCHOOL REQUIRED HIM TO REMOVE THE SHIRT. SCHOOL OFFICIALS TOLD L.M.'S FATHER THAT L.M.'S SHIRT IS LIKELY TO BE CONSIDERED DISCRIMINATORY, HARASSING AND/OR BULLYING TO OTHERS INCLUDING THOSE WHO ARE GENDER NONCONFORMING BY SUGGESTING THAT THEIR SEXUAL ORIENTATION, GENDER IDENTITY OR EXPRESSION DOES NOT EXIST OR IS INVALID." LM I AT 35. ON MAY 5, 2023, L.M. WORE THE SHIRT TO SCHOOL AGAIN, "BUT WITH THE PHRASE 'ONLY TWO' COVERED BY A PIECE OF TAPE WITH THE WORD 'CENSORED.'" ID. AT 35. AGAIN, THE SCHOOL REQUIRED HIM TO REMOVE THE SHIRT. ID. THE DISTRICT COURT RULED THAT L.M. HAD NOT SHOWN THAT THE SCHOOL HAD VIOLATED HIS CONSTITUTIONAL RIGHTS. ID. AT 38. THE COURT RULED THAT THE SCHOOL'S ACTION "FALLS WITHIN THE 'INVASION OF THE RIGHTS OF OTHERS' FRAMEWORK OF TINKER" V. DES MOINES INDEPENDENT COMMUNITY SCHOOL DISTRICT, 393 U.S. 508 (1969). ON APPEAL, THE FIRST CIRCUIT UPHELD THE DISTRICT COURT BUT ON DIFFERENT GROUNDS, I.E., THAT THE SHIRT COULD PRODUCE A DISRUPTION OF THE EDUCATIONAL ENVIRONMENT AT THE SCHOOL AND THAT THAT TINKER'S "MATERIAL-DISRUPTION LIMITATION" APPLIED. L.M. V. TOWN OF MIDDLEBOROUGH, 103 F.4TH 854, 866 (1ST CIR. 2024) ("LM II"). OUR BRIEF ARGUED THAT THE FIRST CIRCUIT DECISION ACTUALLY CIRCUMVENTS TINKER, AUTHORIZING SCHOOL CENSORSHIP IN THE ABSENCE OF ANY REAL THREAT OF SUBSTANTIAL DISRUPTION. IN ADDITION, THE TRANSGENDER DEBATE, AT ITS CORE, IS A RELIGIOUS ONE, AND BY CHOOSING WINNERS OR LOSERS IN THAT DEBATE, THE GOVERNMENT IS IMPOSING RELIGION, FAR MORE THAN THE PUBLIC SCHOOL SOUGHT TO DO IN W. VA. STATE BD. OF EDUC. V. BARNETTE, 319 U.S. 624 (1943). A TRANSGENDER MESSAGE REJECTS A CHRISTIAN'S MOST INTIMATE BELIEFS REGARDING "ONE'S OWN CONCEPT OF EXISTENCE, OF MEANING, OF THE UNIVERSE, AND OF THE MYSTERY OF HUMAN LIFE" BUT IS PERMITTED AND PROTECTED IN MASSACHUSETTS SCHOOLS TO THE EXCLUSION OF CHRISTIAN BELIEFS. FORM 990-EZ, PART III, LINE 28: SMITH & WESSON BRANDS, INC. V. ESTADOS UNIDOS MEXICANOS, CASE NO. 23-1141. PETITION FOR A WRIT OF CERTIORARI FILED APRIL 18, 2024. PETITION GRANTED OCTOBER 4, 2024. MERITS AMICUS CURIAE BRIEF IN SUPPORT OF PETITIONERS FILED DECEMBER 3, 2024. MEXICO SUED SEVEN MANUFACTURERS OF FIREARMS AND ONE COMPANY THAT DISTRIBUTES FIREARMS FROM MANUFACTURERS TO RETAIL FEDERAL FIREARMS LICENSEES ("FFLS") THAT IN TURN SELL FIREARMS TO CONSUMERS ACROSS THE U.S. THE DEFENDANTS RAISED SEVERAL DEFENSES, INCLUDING THE PROTECTION OF LAWFUL COMMERCE IN ARMS ACT ("PLCAA"), WHICH THE DISTRICT COURT RULED "UNEQUIVOCALLY BARS LAWSUITS SEEKING TO HOLD GUN MANUFACTURERS RESPONSIBLE FOR THE ACTS OF INDIVIDUALS USING GUNS FOR THEIR INTENDED PURPOSE. AND WHILE THE STATUTE CONTAINS SEVERAL NARROW EXCEPTIONS, NONE ARE APPLICABLE HERE." ESTADOS UNIDOS MEXICANOS V. SMITH & WESSON BRANDS, INC., 633 F. SUPP. 3D 425, 432 (D. MASS. 2022) ("EUM I"). THE DISTRICT COURT DISMISSED THE LAWSUIT. MEXICO APPEALED. ON APPEAL, MEXICO ARGUED THAT THE FIREARMS MANUFACTURERS HAD "AIDED AND ABETTED" CRIMES PERPETRATED BY MEXICAN DRUG CARTELS, BY AIDING AND ABETTING THE TRAFFICKING OF FIREARMS TO THE CARTELS BY FFLS. ESTADOS UNIDOS MEXICANOS V. SMITH AND WESSON BRANDS, INC., 91 F.4TH 511, 529 (1ST CIR. 2024) ("EUM II"). THE FIRST CIRCUIT AGREED AND SENT THE CASE BACK TO THE DISTRICT COURT FOR FURTHER PROCEEDINGS. ID. OUR BRIEF ARGUED THAT THE FIRST CIRCUIT'S DECISION NEGATED THE VERY PROTECTIONS THE PLCAA WAS ENACTED TO PROVIDE. LEFT UNCORRECTED, THIS DECISION COULD LEAD TO THE BANKRUPTCY OF THE MOST IMPORTANT FIREARMS MANUFACTURERS AND THE CLOSURE OF REMAINING MANUFACTURERS NOT NAMED AS DEFENDANTS. IF ALLOWED TO ELIMINATE NEW SOURCES OF FIREARMS, THIS SUIT WOULD DANGEROUSLY INFRINGE THE EXERCISE OF THE SECOND AMENDMENT-RECOGNIZED RIGHT OF ALL AMERICANS TO KEEP AND BEAR ARMS. "CLEARLY, THE PLCAA CLOSED THE COURTHOUSE DOORS TO 'THE FEDERAL GOVERNMENT, STATES, MUNICIPALITIES, PRIVATE INTEREST GROUPS, AND OTHERS' (INCLUDING MEXICO) WHICH WOULD SEEK TO IMPOSE LIABILITY ON LAWFUL COMMERCE FOR THE REMOTE ILLEGAL ACTS OF THIRD PARTIES. 15 U.S.C. SECTION 7901(A)(7) (EMPHASIS ADDED)." BR. AT 32. WE ASKED THE SUPREME COURT TO FOLLOW THE PLCAA'S MANDATE AND DISMISS THIS CASE TO PROTECT AMERICANS' SECOND AMENDMENT RIGHTS. ON JUNE 5, 2025, THE SUPREME COURT UNANIMOUSLY RULED IN FAVOR OF SMITH & WESSON AND SEVERAL OTHER FIREARMS MANUFACTURERS IN AN OPINION WRITTEN BY JUSTICE KAGAN. ALL OF THE JUSTICES AGREED THAT THE PLCAA PROHIBITS MEXICO'S LAWSUIT, REJECTING MEXICO'S AIDING-AND-ABETTING THEORY OF LIABILITY. THIS EFFECTIVELY ENDED THE CASE. FORM 990-EZ, PART III, LINE 28: PETERSEN V. DOE, CASE NO. 24-449. PETITION FOR A WRIT OF CERTIORARI FILED OCTOBER 17, 2024. AMICUS CURIAE BRIEF IN SUPPORT OF PETITIONERS FILED NOVEMBER 21, 2024. IN 2022, ARIZONA ENACTED THE "SAVE WOMEN'S SPORTS ACT" ("ACT"). SEE ARIZ. REV. STAT. SECTION 15.120.02. THE LAW PROHIBITS BIOLOGICAL MALES FROM COMPETING ON INTERSCHOLASTIC WOMEN'S AND GIRLS' TEAMS IN ARIZONA SCHOOLS, RESTRICTING BIOLOGICAL MALES TO MEN'S AND BOYS' TEAMS AND TEAMS IN DESIGNATED MIXED SPORTS. DOE V. HORNE, 2024 U.S. APP. LEXIS 22847, *16-17 (9TH CIR. 2024) ("DOE"). THE LAW WAS CHALLENGED BY BIOLOGICAL MALES WISHING TO PARTICIPATE IN GIRLS' SPORTS IN ARIZONA SCHOOLS. ID. AT *22. THE DISTRICT COURT ISSUED A PRELIMINARY INJUNCTION AGAINST ENFORCEMENT OF THE ACT. ID. AT *25-26. THE NINTH CIRCUIT AFFIRMED THE PRELIMINARY INJUNCTION ON EQUAL PROTECTION GROUNDS, DETERMINING IT WAS NOT NECESSARY TO REACH THE TITLE IX CLAIMS. THE NINTH CIRCUIT REJECTED ANY ARGUMENT THAT THE ACT WAS REASONABLE AND WELL MOTIVATED, PREFERRING TO DEEM IT AN ACT OF INVIDIOUS DISCRIMINATION BORN OF ANIMUS. THE NINTH CIRCUIT GROUNDED ITS OPINION ON THE NOTION THAT THE NEW CONCEPT OF TRANSGENDERISM MUST COMPLETELY DISPLACE THE CONCEPT OF BIOLOGICAL SEX. IT VIEWS ALL DISTINCTIONS IN LAW BETWEEN MALES AND FEMALES AS INHERENTLY SUSPECT IF THEY ARE NOT SUBORDINATED TO TRANSGENDER IDENTITY. OUR BRIEF ARGUES, INTER ALIA: (1) THAT THE ACT WAS ENACTED TO PROTECT WOMEN'S SPORTS AS A LOGICAL CONSEQUENCE OF THE REASONABLE FACTUAL FINDINGS OF THE LEGISLATURE; AND (2) THAT THE EQUAL PROTECTION CLAUSE OF THE FOURTEENTH AMENDMENT WAS WRITTEN INTO THE CONSTITUTION TO ENSURE THAT AFRICAN AMERICANS WOULD HAVE THE SAME RIGHTS AS WHITE PERSONS--NOT TO OVERTURN AGE-OLD DISTINCTIONS IN LAW BASED ON THE MOST ETERNAL AND ENDURING ASPECT OF HUMANS--BIOLOGICAL SEX. THE CASE WAS DISTRIBUTED FOR CONFERENCE OF JUNE 26, 2025. FORM 990-EZ, PART III, LINE 28: MAHMOUD ET AL. V. TAYLOR, CASE NO. 24-297. PETITION FOR A WRIT OF CERTIORARI FILED SEPTEMBER 12, 2024. AMICUS CURIAE BRIEF IN SUPPORT OF PETITIONERS FILED OCTOBER 16, 2024. PETITION GRANTED JANUARY 17, 2025. AMICUS CURIAE MERITS BRIEF FILED MARCH 10, 2025. IN OCTOBER 2022, MONTGOMERY COUNTY, MARYLAND, PUBLIC SCHOOLS ("MCPS") ANNOUNCED A NEW LINE OF "OVER 22 LGBTQ+-INCLUSIVE TEXTS." MAHMOUD V. MCKNIGHT, 688 F. SUPP. 3D 265, 272 (D. MD. 2023) ("MAHMOUD I"). THESE INCLUDED BOOKS CELEBRATING SAME-SEX MARRIAGE AND CHANGING "GENDER IDENTITY, AND WERE FOR USE IN CLASSES FROM PRE-K THROUGH FIFTH GRADE. ID. AT 273. IN MARCH 2023, MCPS ANNOUNCED THAT IT WOULD NO LONGER ADVISE PARENTS WHEN TEACHING SUCH CONTROVERSIAL SEXUAL MATERIAL AND WOULD NOT ALLOW PARENTS AND STUDENTS TO OPT OUT AS HAD BEEN PREVIOUSLY PERMITTED. ID. AT 271, 273-74. THREE SETS OF PARENTS CHALLENGED THE POLICY: TAMER MAHMOUD AND ENAS BARAKAT, A MUSLIM COUPLE; JEFF AND SVITLANA ROMAN, MEMBERS OF THE ROMAN CATHOLIC AND UKRAINIAN ORTHODOX FAITHS, RESPECTIVELY; AND CATHOLIC PARENTS CHRIS AND MELISSA PERSAK. ID. AT 274. THE PARENTS ARGUED THAT UNDER WISCONSIN V. YODER, 406 U.S. 205 (1972), STRICT SCRUTINY SHOULD APPLY TO THE MCPS DECISION TO ELIMINATE THE OPT-OUT PROVISION. MAHMOUD I AT 288. THE DISTRICT COURT DENIED THE PARENTS' REQUEST FOR INJUNCTIVE RELIEF. ID. AT 307. THE U.S. COURT OF APPEALS FOR THE FOURTH CIRCUIT AFFIRMED. MAHMOUD V. MCKNIGHT, 102 F.4TH 191 (4TH CIR. 2024) ("MAHMOUD II"). OUR AMICUS BRIEFS ARGUED THAT MCPS IS ACTING IN A TRULY COERCIVE AND ABUSIVE MANNER TO INDOCTRINATE STUDENTS WITH ITS SECULAR HUMANIST, RELIGIOUS AGENDA. BUT UNDER A LONG AND UNBROKEN LINE OF SUPREME COURT ESTABLISHMENT CLAUSE DECISIONS, GOVERNMENT SCHOOLS MAY NOT TEACH THE BIBLE, OR HAVE ORGANIZED PRAYER, OR EVEN POST THE TEN COMMANDMENTS. IF PUBLIC SCHOOLS MAY NOT TEACH TRADITIONAL MORALITY, SURELY THE MCPS CANNOT TEACH A PAGAN MORALITY--ESPECIALLY WHEN MCPS RULES PREVENT PARENTS AND STUDENTS FROM OPTING OUT TO AVOID BEING SUBJECTED TO AN LGBTQ+ CATECHISM. ON JUNE 27, 2025, THE SUPREME COURT HELD 6-3 THAT THE PARENTS WERE ENTITLED TO A PRELIMINARY INJUNCTION, THAT "THE PARENTS ARE LIKELY TO SUCCEED ON THEIR CLAIM THAT THE BOARD'S POLICIES UNCONSTITUTIONALLY BURDEN THEIR RELIGIOUS EXERCISE. '[W]E HAVE LONG RECOGNIZED THE RIGHTS OF PARENTS TO DIRECT "THE RELIGIOUS UPBRINGING" OF THEIR CHILDREN[, AND] THOSE RIGHTS ARE VIOLATED BY GOVERNMENT POLICIES THAT 'SUBSTANTIALLY INTERFER[E] WITH THE RELIGIOUS DEVELOPMENT' OF CHILDREN." SLIP OP. AT 17. THE COURT REVERSED THE 4TH CIRCUIT AND REMANDED THE CASE FOR FURTHER PROCEEDINGS CONSISTENT WITH THE COURT'S DECISION. FORM 990-EZ, PART III, LINE 28: UNITED STATES V. SKRMETTI, NO. 23-477. PETITION FOR A WRIT OF CERTIORARI FILED NOVEMBER 6, 2023. PETITION GRANTED JUNE 24, 2024. MERITS AMICUS CURIAE BRIEF IN SUPPORT OF RESPONDENTS FILED OCTOBER 15, 2024. THIS CASE CHALLENGED A 2023 TENNESSEE LAW BANNING THREE TYPES OF "TREATMENTS" FOR MINORS EXPERIENCING GENDER DYSPHORIA--A CONDITION IN WHICH AN INDIVIDUAL IDENTIFIES AS BEING SOMETHING OTHER THAN HIS OR HER ACTUAL BIOLOGICAL SEX. SPECIFICALLY, THE LAW BANS CROSS-SEX HORMONE TREATMENTS, PUBERTY-BLOCKER DRUG REGIMENS, AND SURGICAL REMOVAL OR MODIFICATION OF BREASTS OR GENITALS. THREE MINORS WHO IDENTIFIED AS "TRANSGENDER AND ASSERTED THEIR DESIRE TO RECEIVE SUCH PROCEDURES AS WELL AS A PHYSICIAN WHO WISHED TO PERFORM SUCH PROCEDURES FOR PROFIT BROUGHT THE CASE. THE UNITED STATES INTERVENED ON BEHALF OF THE PLAINTIFFS. THE U.S. DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE RULED FOR THE PLAINTIFFS AND ENJOINED THE LAW. L.W. V. SKRMETTI, 679 F. SUPP. 3D 668, 684-85 (M.D. TENN. 2023) ("SKRMETTI I"). THE COURT RULED THAT THE LAW VIOLATED THE EQUAL PROTECTION CLAUSE OF THE FOURTEENTH AMENDMENT, BECAUSE THE LAW DISCRIMINATES ON THE BASIS OF "TRANSGENDER STATUS," WHICH THE COURT DEEMED A "QUASI-SUSPECT CLASS." ID. AT 687-90. ON APPEAL, THE U.S. COURT OF APPEALS FOR THE SIXTH CIRCUIT REVERSED THE DISTRICT COURT. L.W. V. SKRMETTI, 83 F.4TH 460 (6TH CIR. 2023) ("SKRMETTI II"). THE COURT OF APPEALS HELD "STATE AND FEDERAL GOVERNMENTS HAVE LONG PLAYED A CRITICAL ROLE IN REGULATING HEALTH AND WELFARE, WHICH EXPLAINS WHY THEIR EFFORTS RECEIVE 'A STRONG PRESUMPTION OF VALIDITY,'" ID. AT 473 (CLEANED UP), AND "THE GOVERNMENT HAS THE POWER TO REASONABLY LIMIT THE USE OF DRUGS, [NOT ONLY] FOR ADULTS, [BUT ALSO] FOR THEIR CHILDREN . . . . THIS COUNTRY DOES NOT HAVE A CUSTOM OF PERMITTING PARENTS TO OBTAIN BANNED MEDICAL TREATMENTS FOR THEIR CHILDREN AND TO OVERRIDE CONTRARY LEGISLATIVE POLICY JUDGMENTS IN THE PROCESS," ID. AT 475. OUR AMICUS BRIEF URGED THE SUPREME COURT TO AFFIRM THE SIXTH CIRCUIT AND PROTECT MINORS, IN PARTICULAR, FROM BEING IRREVERSIBLY SCARRED FROM THE PROHIBITED TREATMENTS. EIGHTY-SEVEN AMICUS BRIEFS WERE FILED, PERHAPS A RECORD! ON JUNE 18, 2025, IN A 6-3 DECISION, THE SUPREME COURT UPHELD TENNESSEE'S LAW AND AFFIRMED THE SIXTH CIRCUIT'S DECISION. FORM 990-EZ, PART III, LINE 28: COOPER V. UNITED STATES, NO. 24-5381. PETITION FOR A WRIT OF CERTIORARI FILED AUGUST 21, 2024. AMICUS CURIAE BRIEF IN SUPPORT OF PETITION FILED OCTOBER 15, 2024. AFTER BEING SUBJECTED TO A STOP-AND-FRISK AT HIS PLACE OF EMPLOYMENT BASED ON ONLY "REASONABLE SUSPICION," PETITIONER NATHAN COOPER WAS ARRESTED FOR BEING A FELON-IN-POSSESSION OF A FIREARM AND AMMUNITION. HIS MOTION TO SUPPRESS EVIDENCE OBTAINED FROM THE SEARCH WAS DENIED, AND HE WAS CONVICTED IN THE U.S. DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA IN AN UNREPORTED 2023 CASE. THE ELEVENTH CIRCUIT AFFIRMED. UNITED STATES V. COOPER, 2024 U.S. APP. LEXIS 9940 AT *1 (11TH CIR. 2024). THE COURT FOUND THAT THE DISTRICT COURT DID NOT ERR IN FINDING THAT THE OFFICER HAD "REASONABLE SUSPICION" TO STOP AND FRISK PETITIONER BECAUSE THE OFFICER REASONABLY BELIEVED CRIMINAL ACTIVITY WAS ABOUT TO OCCUR. ID. AT *4. THE COURT ALSO AFFIRMED THE DISTRICT COURT'S FINDING THAT THE OFFICER HAD REASONABLE GROUNDS TO BELIEVE PETITIONER WAS ARMED AND DANGEROUS. ID. AT *5. LASTLY, THE COURT REJECTED COOPER'S CHALLENGE TO THE CONSTITUTIONALITY OF THE RULE OF TERRY V. OHIO, 392 U.S. 1 (1968), THAT "REASONABLE SUSPICION" IS SUFFICIENT GROUNDS FOR A LAW ENFORCEMENT OFFICER TO CONDUCT A SEARCH FOR WEAPONS WHEN AN INDIVIDUAL IS LAWFULLY DETAINED. PETITIONER ASKED THE COURT TO GRANT CERTIORARI TO "OVERRULE THE FRISK HOLDING OF TERRY . . . WHICH ALLOWS POLICE OFFICERS TO SEARCH PEOPLE ABSENT PROBABLE CAUSE TO ARREST" AS REQUIRED BY THE TEXT OF THE FOURTH AMENDMENT AND THIS COURT'S JURISPRUDENCE PRIOR TO 1968 WHEN TERRY WAS DECIDED. OUR BRIEF SUPPORTED HIS PETITION. THE PETITION WAS DENIED ON JANUARY 13, 2025, ENDING THE CASE. FORM 990-EZ, PART III, LINE 28: MARYLAND SHALL ISSUE, INC. V. MOORE, CASE NO. 24-373. PETITION FOR A WRIT OF CERTIORARI FILED SEPTEMBER 27, 2024. AMICUS CURIAE BRIEF IN SUPPORT OF PETITION FILED NOVEMBER 1, 2024. PETITIONERS CHALLENGED A 2013 MARYLAND HANDGUN LICENSE LAW REQUIRING THAT, IN ORDER TO ACQUIRE A HANDGUN, A MARYLAND CITIZEN MUST FIRST PROVIDE FINGERPRINTS TO THE STATE, PASS A BACKGROUND CHECK, COMPLETE A FOUR-HOUR FIREARM SAFETY TRAINING COURSE INCLUDING FIRING AT LEAST ONE LIVE ROUND, AND WAIT 30 DAYS FOR APPROVAL. FAILURE TO COMPLETE ALL THESE STEPS DISQUALIFIES A CITIZEN FROM POSSESSING A HANDGUN. ON NOVEMBER 21, 2023, A FOURTH CIRCUIT PANEL STRUCK THE LAW DOWN, RULING THAT THE REQUIREMENT TO "QUALIFY" FOR A LICENSE TO EXERCISE THE SECOND AMENDMENT RIGHT DID IN FACT BURDEN THAT RIGHT. MARYLAND SHALL ISSUE, INC. V. MOORE, 86 F.4TH 1038, 1045 (4TH CIR. 2023) (VACATED BY REH'G EN BANC). THE PANEL FURTHER FOUND THAT MARYLAND'S PROPOSED HISTORICAL ANALOGUES OF "DANGEROUSNESS" STATUTES WERE NOT RELEVANTLY SIMILAR, AS SUCH LAWS PERMITTED SEIZURE OF WEAPONS FROM PERSONS ADJUDICATED AS DANGEROUS, WHILE MARYLAND'S LAW REQUIRED ALL CITIZENS TO FIRST PROVE THEY ARE NOT "DANGEROUS" AS A PRECONDITION TO A LICENSE TO OWN A FIREARM AT ALL. ID. AT 1047. MARYLAND THEN SOUGHT AND WAS GRANTED REHEARING EN BANC, WHICH VACATED THE PANEL OPINION. MARYLAND SHALL ISSUE, INC. V. MOORE, 2024 U.S. APP. LEXIS 766 (4TH CIR. 2024). IN ITS EN BANC DECISION, 2024 U.S. APP. LEXIS 21378, THE FOURTH CIRCUIT USED WHAT IT CALLED "SUBSTANTIVE DICTUM" FROM FOOTNOTE NINE IN NEW YORK STATE RIFLE & PISTOL ASS'N, INC. V. BRUEN, 597 U.S. 1 (2022), TO EVISCERATE THE SUPREME COURT'S REQUIREMENT THAT REGULATION OF SECOND AMENDMENT RIGHTS BE GROUNDED IN HISTORICAL PRECEDENT. ID. *4. THE DISSENT ARGUED THAT THIS ALLOWED THE COURT TO "ESTABLISH A CARVEOUT FROM SUPREME COURT DOCTRINE AND THAT "MARYLAND HAS IDENTIFIED NO HISTORICAL BASIS FOR ITS LAW." ID. *53-56. THE SUPREME COURT DENIED THE PETITION ON JANUARY 13, 2025, ENDING THE CASE. FORM 990-EZ, PART III, LINE 28: SNOPE V. BROWN (FORMERLY BIANCHI V. BROWN), CASE NO. 24-203. PETITION FOR A WRIT OF CERTIORARI FILED AUGUST 21, 2024. AMICUS CURIAE BRIEF IN SUPPORT OF PETITION FILED SEPTEMBER 23, 2024. (DAVID SNOPE BECAME THE LEAD PETITIONER BECAUSE DOMINIC BIANCHI NO LONGER LIVED IN MARYLAND.) THIS WAS A CHALLENGE TO THE MARYLAND "FIREARMS SAFETY ACT OF 2013" ("THE ACT"), WHICH EFFECTIVELY BANNED PRIVATE POSSESSION OF MANY SEMIAUTOMATIC WEAPONS IN THE STATE. PLAINTIFFS PREVIOUSLY FILED A PETITION FOR WRIT OF CERTIORARI WITH THE SUPREME COURT, BUT THE CASE WAS VACATED AND REMANDED TO THE U.S. COURT OF APPEALS FOR THE FOURTH CIRCUIT FOR FURTHER CONSIDERATION UNDER THE RECENTLY DECIDED N.Y. STATE RIFLE & PISTOL ASS'N V. BRUEN, 597 U.S. 1 (2022). UPON REHEARING EN BANC, A FOURTH CIRCUIT MAJORITY UPHELD THE ACT, CONCLUDING THAT BRUEN DID NOT FORECLOSE LEGISLATIVE DETERMINATIONS THAT "ASSAULT WEAPONS" ARE NOT PROTECTED ARMS. SEE BIANCHI V. BROWN, 2024 U.S. APP. LEXIS 19624, *4-5 (4TH CIR. 2024). INSTEAD OF APPLYING THE PLAIN TEXT OF THE SECOND AMENDMENT, THE FOURTH CIRCUIT INTERPRETED THE SECOND AMENDMENT AGAINST ITS "HISTORICAL AND LEGAL BACKDROP," A PHRASE THAT DOES NOT APPEAR IN BRUEN, TO UPHOLD MARYLAND'S SUPPOSED RIGHT TO CRIMINALIZES POSSESSION OF SEMIAUTOMATIC RIFLES, HANDGUNS, AND SHOTGUNS ARTIFICIALLY CHARACTERIZED AS "ASSAULT WEAPONS"--WHICH ARE AT CORE ORDINARY SEMIAUTOMATIC WEAPONS AND ARE "COMMONLY USED," IF NOT UBIQUITOUS AMONG THE GUN OWNING PUBLIC, EXCEPT WHERE BANNED BY A FEW STATES. THIS APPROACH ALLOWED MARYLAND TO PREVAIL WITHOUT PROVING THE EXISTENCE OF ANY RELEVANT HISTORICAL ANALOGUES THAT SUPPORT ITS LAW. OUR BRIEF ARGUED, INTER ALIA, THAT MILITARY TYPE "ARMS" ARE PROTECTED BECAUSE THE FRAMERS WANTED TO PROTECT THE SORT OF WEAPONS WHICH THEY HAD JUST USED TO WIN A WAR AGAINST THE BRITISH. INDEED, IT WAS THOSE ARMS WHICH THE FRAMERS OF THE SECOND AMENDMENT BELIEVED WERE "NECESSARY TO THE SECURITY OF A FREE STATE" SHOULD THE PEOPLE EVER NEED TO RESIST TYRANNY AND RECONSTITUTE THEIR GOVERNMENT. WE GAVE EXAMPLES OF FREED BLACK AMERICANS AND KOREAN AMERICANS DEFENDING THEIR COMMUNITIES WHEN LAW ENFORCEMENT FAILED TO DO SO. THE SUPREME COURT DENIED THE PETITION ON JUNE 2, 2025, ENDING THE CASE. FORM 990-EZ, PART III, LINE 28: CROUCH V. ANDERSON, CASE NO. 24-90. PETITION FOR A WRIT OF CERTIORARI FILED JULY 25, 2024. AMICUS CURIAE BRIEF IN SUPPORT OF PETITION FILED AUGUST 28, 2024. WEST VIRGINIA PROHIBITED ITS STATE MEDICAID PROGRAM FROM PROVIDING COVERAGE FOR CERTAIN SEX CHANGE SURGERIES. THE FOURTH CIRCUIT EN BANC DECIDED THIS CASE IN THE SAME OPINION AS FOLWELL V. KADELL, HOLDING THAT WEST VIRGINIA'S LAW VIOLATES THE EQUAL PROTECTION CLAUSE, AS WELL AS THE MEDICAID ACT AND THE AFFORDABLE CARE ACT. SEE KADEL V. FOLWELL, 100 F.4TH 122 (4TH CIR. 2024). OUR AMICUS BRIEF URGED THE SUPREME COURT TO REVIEW THE FOURTH CIRCUIT DECISION ORDERING WEST VIRGINIA MEDICAID TO PAY FOR GENDER TRANSITION PROCEDURES, ARGUING THAT THE OPINION WAS BASED ON MODERN TRANSGENDER IDEOLOGY, FINDING NO DIFFERENCE BETWEEN REMOVAL OF CANCEROUS TISSUE AND REMOVING HEALTHY BODY PARTS. THE FOURTH CIRCUIT BASED ITS DECISION ON ITS GRIMM V. GLOUCESTER CO. SCHOOL BOARD CASE, WHICH HELD THAT A GIRL SUFFERING FROM "GENDER DYSPHORIA" WAS ENTITLED TO USE THE BOYS' RESTROOM. NOW THAT SEEMINGLY INNOCUOUS (AND ERRONEOUS) PRECEDENT IS BEING BADLY MISUSED. THE CIRCUIT COURT RELIED ON STANDARDS OF CARE OF THE WORLD PROFESSIONAL ASSOCIATION FOR TRANSGENDER HEALTH ("WPATH"), BUT RECENTLY AN ABUNDANCE OF EVIDENCE HAS SURFACED THAT WPATH IS AN ADVOCACY GROUP, NOT AN INDEPENDENT MEDICAL ORGANIZATION. EVEN THE AMERICAN SOCIETY OF PLASTIC SURGEONS RESCINDED ITS SUPPORT FOR AND IS REASSESSING ITS POSITION ON TRANSGENDER SURGERY. THERE WAS NO JUSTIFICATION TO EXPAND THE EQUAL PROTECTION CLAUSE TO REQUIRE DANGEROUS AND IRREVERSIBLE PROCEDURES TO MAKE PERSONS SUFFERING A TYPE OF MENTAL DISORDER FEEL BETTER ABOUT THEMSELVES. ON JUNE 30, 2025, THE SUPREME COURT GRANTED THE PETITION, REVERSED THE 4TH CIRCUIT, AND REMANDED THE CASE FOR FURTHER CONSIDERATION IN LIGHT OF ITS DECISION IN UNITED STATES V. SKRMETTI. FORM 990-EZ, PART III, LINE 28: FOLWELL V. KADELL, CASE NO. 24-99. PETITION FOR A WRIT OF CERTIORARI FILED JULY 26, 2024. WE DID NOT FILE AN AMICUS CURIAE BRIEF IN THIS CASE, BELIEVING THAT OUR BRIEF IN CROUCH WAS SUFFICIENT. NORTH CAROLINA'S HEALTH PLAN FOR STATE EMPLOYEES AND TEACHERS DOES NOT PROVIDE COVERAGE FOR SEX CHANGE SURGERIES. THIS CASE WAS DECIDED WITH CROUCH V. ANDERSON, BY THE FOURTH CIRCUIT IN ONE OPINION. KADEL V. FOLWELL, 100 F.4TH 122 (4TH CIR. 2024). THE COURT HELD THAT THE NORTH CAROLINA HEALTH PLAN VIOLATES THE EQUAL PROTECTION CLAUSE. ON JUNE 30, 2025, THE SUPREME COURT GRANTED THE PETITION, REVERSED THE 4TH CIRCUIT, AND REMANDED THE CASE FOR FURTHER CONSIDERATION IN LIGHT OF ITS DECISION IN UNITED STATES V. SKRMETTI. FORM 990-EZ, PART III, LINE 28: FREE SPEECH COALITION, INC. V. PAXTON, CASE NO. 23-1122, FORMERLY FREE SPEECH COALITION, INC. V. COLMENERO, FIFTH CIRCUIT NO. 23-50627. PETITION FOR A WRIT OF CERTIORARI FILED APRIL 12, 2024. PETITION GRANTED JULY 2, 2024. MERITS AMICUS CURIAE BRIEF IN SUPPORT OF RESPONDENTS FILED NOVEMBER 22, 2024. ORAL ARGUMENT HELD JANUARY 15, 2025. WE ORIGINALLY FILED AN AMICUS CURIAE BRIEF IN THE U.S. COURT OF APPEALS FOR THE FIFTH CIRCUIT ON SEPTEMBER 25, 2023, SUPPORTING THE VALIDITY OF TEXAS' LAW REQUIRING PROTECTIONS TO KEEP MINORS FROM ACCESSING ONLINE PORN. THE U.S. DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS, AUSTIN DIVISION, HAD HELD THE STATUTE UNCONSTITUTIONAL UNDER THE FIRST AMENDMENT TO THE U.S. CONSTITUTION, CONCLUDING THAT PROTECTING MINORS FROM PORNOGRAPHY "IS NOT ENOUGH FOR A LAW TO SURVIVE STRICT SCRUTINY," A JUDICIALLY CREATED BALANCING TEST THAT OFTEN LEADS JUDGES TO DECLARE LAWS UNCONSTITUTIONAL. THE FIFTH CIRCUIT ISSUED A DECISION ON MARCH 7, 2024, UPHOLDING THE AGE VERIFICATION REQUIREMENT AND DISSOLVING THE INJUNCTION AS TO THAT. OUR MERITS AMICUS BRIEF IN THE SUPREME COURT MADE SUBSTANTIALLY THE SAME ARGUMENTS WE MADE AT THE FIFTH CIRCUIT. ON JUNE 27, 2025, THE COURT, IN A 6-3 OPINION, AFFIRMED THE FIFTH CIRCUIT, HOLDING THAT STRICT SCRUTINY DID NOT APPLY AND THAT ADULTS HAVE NO FIRST AMENDMENT RIGHT TO AVOID AGE VERIFICATION DESIGNED TO KEEP MINORS FROM BEING EXPOSED TO ONLINE PORN. FORM 990-EZ, PART III, LINE 28: TALBOT V. UNITED STATES, D.C. CIRCUIT NO. 25-5087. AMICUS CURIAE BRIEF IN SUPPORT OF DEFENDANTS-APPELLANTS FILED SEPTEMBER 30, 2025. THIS CASE IS SIMILAR TO UNITED STATES OF AMERICA V. SHILLING, IN THE U.S. SUPREME COURT, AND THE BRIEFING IS SIMILAR. PLAINTIFFS ARE "TRANS-IDENTIFYING CURRENT AND ASPIRING SERVICEMEMBERS" WHO ALLEGE THAT EXECUTIVE ORDER 14183 AND SECRETARY HEGSETH'S POLICY VIOLATE THEIR EQUAL PROTECTION RIGHTS. THE DISTRICT COURT ISSUED A PRELIMINARY INJUNCTION AGAINST THE TRUMP/HEGSETH POLICY, APPLYING IT NATIONWIDE IN FAVOR OF THE PLAINTIFFS AND ANY OTHER CURRENT OR ASPIRING SERVICE-MEMBER SIMILARLY SITUATED. WE URGE THE COURT OF APPEALS TO REVERSE THE DECISION OF THE DISTRICT COURT. FORM 990-EZ, PART III, LINE 28: UNITED STATES V. JUSTIN BRYCE BROWN, FIFTH CIRCUIT NO. 25-60102. AMICUS CURIAE BRIEF IN SUPPORT OF DEFENDANT-APPELLEE FILED JUNE 3, 2025. IN 2022, LAW ENFORCEMENT RAIDED THE HOME OF JUSTIN BRYCE BROWN, INVESTIGATING HIS ALLEGED RECEIPT OF INTERNATIONAL SHIPMENTS OF SO-CALLED "MACHINEGUN CONVERSION DEVICES." ROA.61-62. DURING THE RAID, AUTHORITIES SEIZED AN AR-15-STYLE RIFLE EQUIPPED WITH A THREE-POSITION SAFETY SELECTOR SWITCH. ROA.63. DURING A LATER EXAMINATION, THE BUREAU OF ALCOHOL, TOBACCO, FIREARMS, AND EXPLOSIVES ("ATF") CLAIMED THAT THE THIRD SELECTOR POSITION ALLOWED THE FIREARM TO FIRE FULLY AUTOMATICALLY. ROA.63. ACCORDINGLY, ATF CLASSIFIED THE FIREARM AS A "MACHINEGUN" UNDER FEDERAL LAW. SEE 26 U.S.C. SECTION 5845(B). BROWN WAS CHARGED WITH POSSESSION OF AN UNREGISTERED MACHINEGUN, 18 U.S.C. SECTIONS 924(A)(2) & 922(O)(1). BROWN MOVED TO DISMISS, ARGUING THAT THE STATUTE'S CRIMINALIZATION OF HIS PEACEFUL POSSESSION OF A FIREARM WITHIN HIS HOME VIOLATES THE SECOND AMENDMENT, AS APPLIED. UNITED STATES V. BROWN, 2025 U.S. DIST. LEXIS 23823, *1-2 (S.D. MISS. JAN. 29, 2025). THE DISTRICT COURT GRANTED BROWN'S MOTION, CONCLUDING THAT THE UNITED STATES HAD FAILED TO BEAR ITS BURDEN TO SHOW RELEVANT HISTORICAL ANALOGUES UNDER N.Y. STATE RIFLE & PISTOL ASS'N V. BRUEN, 597 U.S. 1 (2022). THE UNITED STATES TIMELY APPEALED. OUR BRIEF ARGUES THAT THE DISTRICT COURT APPLIED BRUEN FAITHFULLY AND THAT THE GOVERNMENT HAS NOT SHOWN ANY FOUNDING-ERA HISTORICAL TRADITION OF SIMILAR REGULATION. WITHOUT SUCH AN EXAMPLE, THE GOVERNMENT CANNOT ONSTITUTIONALLY CRIMINALIZE BROWN'S SIMPLE POSSESSION OF A FIREARM WITHIN HIS OWN HOME. FORM 990-EZ, PART III, LINE 28: SANCHEZ V. BONTA, NINTH CIRCUIT NO. 24-5566. AMICUS CURIAE BRIEF FILED APRIL 4, 2025. IN APRIL 2024, GARY SANCHEZ APPLIED FOR FEDERAL AUTHORIZATION TO LEGALLY FABRICATE AND REGISTER A FIREARM SUPPRESSOR. DESPITE SANCHEZ MEETING ALL THE REQUIREMENTS UNDER FEDERAL LAW, THE BUREAU OF ALCOHOL, TOBACCO, FIREARMS, AND EXPLOSIVES ("ATF") DENIED HIS APPLICATION, CITING CALIFORNIA'S CRIMINAL BAN ON SUPPRESSORS. CALIFORNIA PENAL CODE SECTION 33410. CALIFORNIA BANS AND CRIMINALIZES THE POSSESSION OF ALL SUPPRESSORS, WHICH ARE LEGAL TO POSSESS UNDER FEDERAL LAW AND IN THE VAST MAJORITY OF STATES. AFTER SANCHEZ'S APPLICATION WAS DENIED, HE SUED CALIFORNIA ALLEGING THAT ITS SUPPRESSOR BAN VIOLATES THE SECOND AND FOURTEENTH AMENDMENTS OF THE UNITED STATES CONSTITUTION. THE DISTRICT COURT DISMISSED HIS PRO SE COMPLAINT, RULING THAT SUPPRESSORS DO NOT QUALIFY AS "ARMS" ENTITLED TO ANY SECOND AMENDMENT PROTECTION. OUR BRIEF ARGUES THAT SUPPRESSORS, JUST LIKE ANY OTHER ACCESSORY THAT MAKES A FIREARM MORE USABLE OR ACCURATE, IS COVERED BY THE TERM "ARMS" AS THE FOUNDERS UNDERSTOOD THE TERM. FORM 990-EZ, PART III, LINE 28: NATIONAL INSTITUTE OF FAMILY AND LIFE ADVOCATES (NIFLA) V. LETITIA JAMES, SECOND CIRCUIT NO. 24-2481. AMICUS CURIAE BRIEF IN SUPPORT OF PLAINTIFFS-APPELLEES FILED MARCH 24, 2025. NEW YORK ATTORNEY GENERAL (AG) LETITIA JAMES WAS TRYING TO USE COMMERCIAL FRAUD LAWS TO SILENCE PRO-LIFE GROUPS LIKE NIFLA FROM DISSEMINATING INFORMATION THAT EVEN IF A PREGNANT WOMAN TAKES MIFEPRISTONE TO CAUSE AN ABORTION, HER PREGNANCY CAN BE SAVED BY PROGESTERONE THERAPY, KNOWN AS ABORTION PILL REVERSAL (APR). NIFLA SUED JAMES TO ENJOIN HER USE OF THAT LAW AGAINST THEM. PLAINTIFFS ALLEGE THAT THE ATTORNEY GENERAL "HAS TARGETED PRO-LIFE CENTERS FOR DISFAVORED TREATMENT BECAUSE OF THEIR PRO-LIFE AND RELIGIOUS VIEWPOINTS." SPECIFICALLY, SHE "INSTITUTE[ED] A CIVIL ENFORCEMENT ACTION" AGAINST "ELEVEN FAITH-BASED, PRO-LIFE PREGNANCY CENTERS," AS WELL AS A "NETWORK OF AFFILIATED CENTERS" BASED ON THEIR SPEECH ABOUT APR. ACCORDING TO PLAINTIFFS, THE ATTORNEY GENERAL HAS "CONCOCTED AN UNCONSTITUTIONAL AND EXPANSIVE INTERPRETATION OF [NEW YORK LAW] TO INSTITUTE AGGRESSIVE PROCEEDINGS AGAINST PRO-LIFE PREGNANCY CENTERS FOR THEIR TRUTHFUL STATEMENTS ABOUT PROGESTERONE TREATMENT." AS A RESULT OF THE ATTORNEY GENERAL'S ENFORCEMENT ACTION, PLAINTIFFS "HAVE CENSORED THEIR CONSTITUTIONALLY PROTECTED SPEECH IN ORDER TO AVOID PROSECUTION BY THE ATTORNEY GENERAL." NAT'L INST. FOR FAM. & LIFE ADVOCATES (NIFLA) V. JAMES, 746 F. SUPP. 3D 100, 109-110 (W.D. NY 2024) (CLEANED UP). JUDGE SINATRA IN THE WD OF NY ENJOINED JAMES IN A VERY CRISP OPINION. ID. AG JAMES APPEALED. OUR AMICUS BRIEF ARGUES THAT NEW YORK'S COMMERCIAL FRAUD STATUTES DO NOT COVER DIFFERENCES OF OPINION; THAT THE FIRST AMENDMENT PROTECTS A MARKETPLACE OF IDEAS, ESPECIALLY THOSE RELATED TO RELIGIOUS OR POLITICAL ADVOCACY; AND THAT AG JAMES IS TWISTING THE COMMERCIAL FRAUD STATUTES TO PURSUE A POLITICAL AGENDA FOR ABORTION. FORM 990-EZ, PART III, LINE 28: WASHINGTON V. TRUMP, NINTH CIRCUIT NO. 25-807. AMICUS CURIAE LETTER BRIEF IN SUPPORT OF THE TRUMP ADMINISTRATION FILED APRIL 4, 2025. ON JANUARY 21, 2025, THE STATE OF WASHINGTON SUED TO OVERTURN PRESIDENT TRUMP'S JANUARY 20 EXECUTIVE ORDER (EO) 14160 DIRECTING FEDERAL AGENCIES NOT TO CONSIDER A PERSON BORN ON U.S. SOIL TO BE A CITIZEN OF THE UNITED STATES WHEN, 'AT THE TIME OF SAID PERSON'S BIRTH,' THE FATHER 'WAS NOT A UNITED STATES CITIZEN OR LAWFUL PERMANENT RESIDENT . . . AND 'WHEN THAT PERSON'S MOTHER' WAS: (1) 'UNLAWFULLY PRESENT IN THE UNITED STATES' . . . OR (2) . . . WHEN [THE MOTHER'S PRESENCE] . . . WAS LAWFUL BUT TEMPORARY (SUCH AS, BUT NOT LIMITED TO, VISITING THE UNITED STATES UNDER THE AUSPICES OF THE VISA WAIVER PROGRAM OR VISITING ON A STUDENT, WORK, OR TOURIST VISA). . . ." NO. 25-CV-127 (W.D. WASHINGTON). THE TRUMP ADMINISTRATION FILED ITS OPPOSITION TO PLAINTIFF'S MOTION FOR PRELIMINARY INJUNCTION (PI) ON JANUARY 31, 2025. THE SAME DAY WE FILED AN AMICUS CURIAE BRIEF IN SUPPORT OF THE EO. ON FEBRUARY 6, 2025, THE DISTRICT COURT GRANTED A PI ENJOINING IMPLEMENTATION OR ENFORCEMENT OF THE EO NATIONWIDE. THE GOVERNMENT FILED AN EMERGENCY MOTION FOR STAY PENDING APPEAL IN THE U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT, AND ON FEBRUARY 17, 2025, WE FILED AN AMICUS CURIAE BRIEF IN SUPPORT THEREOF. THE NINTH CIRCUIT AFFIRMED THE DISTRICT COURT'S DECISION ON JULY 23, 2025. THE TRUMP ADMINISTRATION SOUGHT AND OBTAINED PARTIAL RELIEF IN THE U.S. SUPREME COURT. SEE THE REPORT ON TRUMP V. CASA, INC., TRUMP V. WASHINGTON, & TRUMP V. NEW JERSEY, IN THE U.S. SUPREME COURT SECTION, ABOVE. FORM 990-EZ, PART III, LINE 28: NEW HAMPSHIRE INDONESIAN COMMUNITY SUPPORT V. TRUMP, FIRST CIRCUIT NO. 25-1348. AMICUS CURIAE BRIEF FILED JUNE 3, 2025. THIS CASE IS SIMILAR TO WASHINGTON V. TRUMP, FILED TO OVERTURN PRESIDENT TRUMP'S EXECUTIVE ORDER (EO) 14160 CONCERNING SO-CALLED BIRTHRIGHT CITIZENSHIP. WE FILED AN AMICUS CURIAE BRIEF IN THE DISTRICT COURT ON JANUARY 31, 2025. NO. 25-CV-38 (D. N.H.) THE AMICUS BRIEFS WE FILED IN THIS CASE ARE SIMILAR TO THE ONES WE FILED IN WASHINGTON V. TRUMP. FORM 990-EZ, PART III, LINE 28: DOE V. TRUMP & NEW JERSEY V. TRUMP, FIRST CIRCUIT NOS. 25-1169 & 25-1170. AMICUS CURIAE BRIEF FILED APRIL 28, 2025. THIS CASE IS SIMILAR TO WASHINGTON V. TRUMP, FILED TO OVERTURN PRESIDENT TRUMP'S EXECUTIVE ORDER (EO) 14160 CONCERNING SO-CALLED BIRTHRIGHT CITIZENSHIP. THE AMICUS BRIEF WE FILED IN THIS CASE IS SIMILAR TO THE ONES WE FILED IN WASHINGTON V. TRUMP. FORM 990-EZ, PART III, LINE 28: KANSAS V. U.S. DEPARTMENT OF EDUCATION, TENTH CIRCUIT NO. 24-3097. AMICUS CURIAE BRIEF IN SUPPORT OF KANSAS FILED OCTOBER 16, 2024. OUR AMICUS BRIEF IS SIMILAR TO THOSE FILED IN TENNESSEE V. CARDONA, NO. 24-5588, SIXTH CIR., BRIEF AMICUS CURIAE OF AMERICA'S FUTURE, ET AL. (SEPT. 3, 2024); AND LOUISIANA V. DEPT. OF EDUCATION, NO. 24-30399, FIFTH CIR., BRIEF AMICUS CURIAE OF AMERICA'S FUTURE, ET AL. (SEPT. 26, 2024) INVOLVING CHALLENGES TO THE SAME TITLE IX RULE AT ISSUE IN THIS APPEAL. THE RULE, INTER ALIA, REQUIRES STUDENTS ACCESS TO BATHROOMS AND LOCKER ROOMS BASED ON THEIR GENDER IDENTITY AND REQUIRES SCHOOLS TO USE WHATEVER PRONOUNS THE STUDENT CHOOSES. THE DISTRICT COURT AGREED WITH PLAINTIFFS AND ENTERED AN INJUNCTION AGAINST THE RULE BEING ENFORCED IN THE PLAINTIFF STATES, THE INDIVIDUAL PLAINTIFF'S SCHOOL, AND SCHOOLS ATTENDED BY MEMBERS OF THE ORGANIZATIONAL PLAINTIFFS. 2024 U.S. DIST. LEXIS 116479, *73-74 (D. KAN. 2024). WE ASKED THAT THE APPELLATE COURT AFFIRM THE DISTRICT COURT'S DECISION. THE TRUMP EDUCATION DEPARTMENT HAS SWITCHED SIDES AND IS NO LONGER DEFENDING THE BIDEN ADMINISTRATION RULE, THUS ENDING THIS AND SIMILAR CASES. SEE TENNESSEE V. CARDONA DISCUSSION, BELOW. FORM 990-EZ, PART III, LINE 28: DEFENDING EDUCATION, F/K/A PARENTS DEFENDING EDUCATION V. OLENTANGY LOCAL SCHOOL DISTRICT BOARD OF EDUCATION, SIXTH CIRCUIT NO. 23-3630. AMICUS CURIAE BRIEF FILED DECEMBER 18, 2024. THE OLENTANGY SCHOOL DISTRICT, THE FOURTH-LARGEST SCHOOL DISTRICT IN OHIO, ADOPTED POLICIES FORBIDDING WHAT IT TERMED "'DISCRIMINATORY LANGUAGE,' INCLUDING . . . FAILING TO ADDRESS A STUDENT BY THEIR PREFERRED PRONOUNS" RATHER THAN PRONOUNS REFLECTING THEIR BIOLOGICAL SEX. PARENTS DEFENDING EDUC. V. OLENTANGY LOC. SCH. DIST. BD. OF EDUC., 684 F. SUPP. 3D 684, 689-90, 692 (S.D. OH. 2023) ("PARENTS DEFENDING I"). A GROUP OF ANONYMOUS STUDENTS AND THEIR PARENTS SOUGHT A PRELIMINARY INJUNCTION AGAINST THESE POLICIES BECAUSE SUCH RULES "UNCONSTITUTIONALLY COMPEL SPEECH, ARE IMPERMISSIBLE VIEWPOINT-AND-CONTENT-BASED RESTRICTIONS ON SPEECH, AND ARE OVERBROAD." ID. AT 694. THE DISTRICT COURT DENIED THE REQUESTED PRELIMINARY INJUNCTION AS IT BELIEVED THAT "A HOSTILE ENVIRONMENT CREATED BY DISCRIMINATORY SPEECH [E.G., USE OF BIOLOGICALLY CORRECT PRONOUNS] IS ENOUGH TO CAUSE A SUBSTANTIAL DISRUPTION ON ITS OWN." ID. AT 701. "IDENTITY-BASED COMMENTS CUT TO THE CORE OF WHO WE ARE AS INDIVIDUALS AND BELITTLE OUR SENSE OF PLACE IN SOCIETY--ESPECIALLY, THOUGH NOT EXCLUSIVELY, FOR INDIVIDUALS WHO ARE MEMBERS OF MINORITY GROUPS THAT HAVE BEEN HISTORICALLY OPPRESSED," THE DISTRICT JUDGE WROTE. ID. THE COURT RULED THAT THE PLAINTIFFS "HAVE NOT SHOWN THAT THE POLICIES FAIL TO SATISFY RATIONAL-BASIS REVIEW, AND DENIED A PRELIMINARY INJUNCTION. ID. AT 711. A DIVIDED PANEL OF THE COURT OF APPEALS UPHELD THE DISTRICT COURT RULING. PARENTS DEFENDING EDUC. V. OLENTANGY LOC. SCH. DIST. BD. OF EDUC., 109 F.4TH 453 (6TH CIR. 2024) ("PARENTS DEFENDING II"). JUDGE BATCHELDER DISSENTED, ASSERTING THAT THE SCHOOL DISTRICT HAD NOT MADE THE REQUIRED SHOWING THAT THE SPEECH "'WOULD MATERIALLY AND SUBSTANTIALLY INTERFERE WITH THE REQUIREMENTS OF APPROPRIATE DISCIPLINE IN THE OPERATION OF THE SCHOOL.'" ID. AT 476 (BATCHELDER, J., DISSENTING) (CITING TINKER V. DES MOINES INDEPENDENT COMMUNITY SCHOOL DISTRICT, 393 U.S. 503, 508-09 (1969)). ON NOVEMBER 1, 2024, THE COURT OF APPEALS VACATED THE PANEL OPINION, GRANTED REHEARING EN BANC, AND STAYED THE MANDATE. PARENTS DEFENDING EDUC. V. OLENTANGY LOC. SCH. DIST. BD. OF EDUC., 2024 U.S. APP. LEXIS 27759 (6TH CIR. NOV. 1, 2024). FORM 990-EZ, PART III, LINE 28: UNITED STATES V. TRUMP, ELEVENTH CIRCUIT NO. 24-12311. AMICUS CURIAE BRIEF IN SUPPORT OF DEFENDANTS-APPELLEES AND FOR AFFIRMANCE FILED NOVEMBER 1, 2024. THIS CASE ARISES OUT OF ATTORNEY GENERAL MERRICK GARLAND'S APPOINTMENT OF ATTORNEY JOHN SMITH AS SPECIAL COUNSEL TO CONDUCT THE ONGOING INVESTIGATION INTO WHETHER ANY PERSON OR ENTITY VIOLATED THE LAW IN CONNECTION WITH EFFORTS TO INTERFERE WITH THE LAWFUL TRANSFER OF POWER FOLLOWING THE 2020 PRESIDENTIAL ELECTION OR THE CERTIFICATION OF THE ELECTORAL COLLEGE VOTE HELD ON OR ABOUT JANUARY 6, 2021." OFFICE OF THE ATTORNEY GENERAL, ORDER NO.5559-2022, APPOINTMENT OF JOHN L. SMITH AS SPECIAL COUNSEL, PARAGRAPH (B) (NOV.18, 2022). ON FEBRUARY 22, 2024, FORMER PRESIDENT TRUMP MOVED TO DISMISS THE SUPERSEDING INDICTMENT ALLEGING THAT HE HAD MISHANDLED CLASSIFIED DOCUMENTS ON THE GROUNDS THAT THE APPOINTMENT OF THE SPECIAL COUNSEL VIOLATED THE APPOINTMENTS CLAUSE OF THE CONSTITUTION (ART. II, SECTION 2, CL. 2) AND THAT THE FUNDING FOR THE SPECIAL COUNSEL FROM THE PERMANENT INDEFINITE APPROPRIATION FOR THE DEPARTMENT OF JUSTICE VIOLATED THE APPROPRIATIONS CLAUSE (ART. I, SECTION 9, CL. 7). UNITED STATES V. TRUMP, NO. 9:23-CR-80101-AMC, DOC. NO. 326. ON JULY 15, 2024, THE DISTRICT COURT GRANTED TRUMP'S MOTION TO DISMISS. ID., DOC. NO. 672. SPECIAL COUNSEL SMITH APPEALED THE DISTRICT COURT'S DISMISSAL ORDER. OUR AMICUS BRIEF ARGUED THAT THE DISTRICT COURT'S JULY 15, 2024 ORDER GRANTING MOTION TO DISMISS SUPERSEDING INDICTMENT BASED ON INVALIDITY OF THE APPOINTMENT OF JACK SMITH AS SPECIAL COUNSEL SHOULD BE AFFIRMED. ON NOVEMBER 25, 2024, FOLLOWING DONALD TRUMP'S REELECTION AS PRESIDENT, JACK SMITH FILED A MOTION TO DISMISS THE APPEAL AS TO DONALD TRUMP. SMITH'S MOTION WAS GRANTED ON NOVEMBER 26, 2024. THE APPEAL IS STILL PENDING AS TO THE REMAINING DEFENDANTS/APPELLEES, BUT OUR INVOLVEMENT IS OVER. FORM 990-EZ, PART III, LINE 28: UNITED STATES V. DANIELS, FIFTH CIRCUIT NO. 22-60596. LETTER AMICUS CURIAE BRIEF FILED IN SUPPORT OF DEFENDANT-APPELLANT JULY 24, 2024. APPELLANT DANIELS WAS CHARGED WITH "KNOWINGLY POSSESSING A FIREARM WHILE AN UNLAWFUL USER OF A CONTROLLED SUBSTANCE," IN VIOLATION OF 18 U.S.C. SECTION 922(G)(3). UNITED STATES V. DANIELS, 610 F. SUPP. 3D 892 (S.D. MISS. 2022) ("DANIELS I"). THE DISTRICT COURT DENIED DANIELS' MOTION TO DISMISS, ASSERTING "CONGRESS ENACTED THE EXCLUSIONS IN SECTION 922(G)" TO CATEGORICALLY "KEEP GUNS OUT OF THE HANDS OF PRESUMPTIVELY RISKY PEOPLE." ID. AT 897. THE FIFTH CIRCUIT REVERSED, FINDING THAT, IN APPLYING N.Y. STATE RIFLE & PISTOL ASS'N V. BRUEN, 597 U.S. 1 (2022), "[J]UST AS THERE WAS NO HISTORICAL JUSTIFICATION FOR DISARMING A CITIZEN OF SOUND MIND, THERE IS NO TRADITION THAT SUPPORTS DISARMING A SOBER CITIZEN WHO IS NOT CURRENTLY UNDER AN IMPAIRING INFLUENCE." UNITED STATES V. DANIELS, 77 F.4TH 337, 340 (5TH CIR. 2023) ("DANIELS II"). THE GOVERNMENT PETITIONED FOR CERTIORARI, AFTER WHICH THE SUPREME COURT DECIDED UNITED STATES V. RAHIMI, 219 L. ED. 2D 351 (2024). THEN, THE SUPREME COURT GRANTED CERTIORARI IN DANIELS, VACATED THIS COURT'S JUDGMENT, AND REMANDED THE CASE FOR RECONSIDERATION IN LIGHT OF RAHIMI. IN RAHIMI, THE SUPREME COURT MERELY APPLIED THE METHODOLOGY IT ENUNCIATED IN BRUEN. THE BURDEN WAS PLACED ON THE GOVERNMENT TO DEMONSTRATE A FOUNDING-ERA HISTORICAL ANALOGUE THAT WAS "'RELEVANTLY SIMILAR' TO LAWS THAT OUR TRADITION IS UNDERSTOOD TO PERMIT, 'APPLY[ING] FAITHFULLY THE BALANCE STRUCK BY THE FOUNDING GENERATION TO MODERN CIRCUMSTANCES.'" RAHIMI AT 363. OUR AMICUS BRIEF ARGUES THAT THE FIFTH CIRCUIT'S DECISION IN DANIELS II FAITHFULLY FOLLOWED BRUEN AND IS ENTIRELY CONSISTENT WITH RAHIMI. IN THIS CASE, THE GOVERNMENT OFFERED THREE GROUPS OF COLONIAL-ERA LAWS AS POSSIBLE HISTORICAL ANALOGUES. DANIELS II AT 345-46 & 350-51. AFTER REVIEWING THEM, THIS COURT CONCLUDED THAT, WHILE "HISTORY AND TRADITION MAY SUPPORT SOME LIMITS ON AN INTOXICATED PERSON'S RIGHT TO CARRY A WEAPON . . . IT DOES NOT JUSTIFY DISARMING A SOBER CITIZEN BASED EXCLUSIVELY ON HIS PAST DRUG USAGE." ID. AT 340. RAHIMI DEALT WITH A VERY NARROW SITUATION GOVERNED BY 18 U.S.C. SECTION 922(G)(8)(C)(I), WHICH INVOLVES A COURT ORDER ISSUED AFTER ACTUAL NOTICE AND A HEARING AT WHICH THE TARGETED PERSON HAD AN OPPORTUNITY TO PARTICIPATE THAT RESTRAINS THE PERSON FROM HARASSING, STALKING, OR THREATENING AN INTIMATE PARTNER, ETC., AND WHICH INCLUDES A FINDING THAT SUCH PERSON REPRESENTS A CREDIBLE THREAT TO THE PHYSICAL SAFETY OF SUCH INTIMATE PARTNER, ETC. THE COURT EMPHASIZED: "[O]UR ANALYSIS STARTS AND STOPS WITH SECTION 922(G)(8)(C)(I) BECAUSE THE GOVERNMENT OFFERS AMPLE EVIDENCE THAT THE SECOND AMENDMENT PERMITS THE DISARMAMENT OF INDIVIDUALS WHO POSE A CREDIBLE THREAT TO THE PHYSICAL SAFETY OF OTHERS." RAHIMI AT 364. WE ARGUE THAT THE BAN CHALLENGED HERE INVOLVES NONE OF THOSE ELEMENTS. THUS, RAHIMI DOES NOT ALTER THIS COURT'S EVALUATION OF THE CONSTITUTIONALITY OF SECTION 922(G)(3). SUBSECTION 3 IS CATEGORICAL AND NOT INDIVIDUALIZED. IT NEITHER REQUIRES NOR EVEN PERMITS ANY JUDICIAL DETERMINATION OF DANGEROUSNESS, BUT SIMPLY PREEMPTIVELY LABELS AN ENTIRE CATEGORY OF CITIZENS AS TOO DANGEROUS TO POSSESS WEAPONS, NO MATTER THEIR PRESENT SOBRIETY. ON JANUARY 6, 2025, THE FIFTH CIRCUIT AGAIN REVERSED DANIELS' CONVICTION AND REMANDED THE CASE TO THE DISTRICT COURT BECAUSE THE JURY DID NOT NECESSARILY FIND THAT DANIELS WAS PRESENTLY OR EVEN RECENTLY ENGAGED IN UNLAWFUL DRUG USE AT THE TIME OF HIS ARREST. T HE GOVERNMENT AGAIN, ON JUNE 5, 2025, PETITIONED THE U.S. SUPREME COURT FOR A WRIT OF CERTIORARI. CASE NO. 24-1248. WE HAVE NOT FILED AN AMICUS BRIEF IN THAT PROCEEDING. THE CASE WAS DISTRIBUTED FOR CONFERENCE OF OCTOBER 17, 2025. FORM 990-EZ, PART III, LINE 28: KENNEDY V. BIDEN, FIFTH CIRCUIT NO. 24-30252. AMICUS CURIAE BRIEF FILED SEPTEMBER 25, 2024. AMICUS CURIAE BRIEF ON REHEARING EN BANC FILED NOVEMBER 25, 2024. OUR FIRST BRIEF SUPPORTED ROBERT F. KENNEDY, JR. AND CHILDREN'S HEALTH DEFENSE ("CHD") IN THEIR FIGHT AGAINST THE GOVERNMENT'S CENSORSHIP ENTERPRISE. THE GOVERNMENT INTERPRETS THE SUPREME COURT'S RECENT MURTHY V. MISSOURI DECISION TO MAKE IT IMPOSSIBLE FOR AMERICANS WHOSE VOICES HAVE BEEN SECRETLY THROTTLED OR EVEN EXTINGUISHED BY THE GOVERNMENT TO GET THEIR DAY IN COURT. WE EXPLAINED WHY THE KENNEDY PLAINTIFFS HAD STANDING UNDER MURTHY. GOVERNMENT PROMISES TO BEHAVE CANNOT BE TRUSTED. FUTURE OFFENSES CAN BE EXPECTED THAT SHOULD BE ENJOINED, AS THE SAME FBI WHICH CENSORED STORIES ABOUT THE HUNTER BIDEN LAPTOP TO ELECT BIDEN-HARRIS CAN BE EXPECTED TO DO SO AGAIN TO TRY TO AFFECT FUTURE ELECTIONS. WE CALLED OUT THE GOVERNMENT'S ONGOING CENSORSHIP OF SOCIAL MEDIA PLATFORMS, BACKED BY THREATS, WHICH THEY EUPHEMISTICALLY DESCRIBE AS "CONTENT MODERATION." OUR SECOND BRIEF EMPHASIZED WHITE HOUSE EFFORTS TO DEPLATFORM KENNEDY AND CHD, SHORTLY AFTER WHICH FACEBOOK REPORTED TO SURGEON GENERAL MURTHY THAT IT HAD CENSORED EVERY MEMBER OF THE "DISINFORMATION DOZEN," INCLUDING KENNEDY AND CHD. THIS ESTABLISHED A SYMBIOTIC RELATIONSHIP BETWEEN FACEBOOK AND THE WHITE HOUSE SUFFICIENT TO ESTABLISH JOINT ACTION. THUS, THE GOVERNMENT AND BIG TECH WERE PARTNERING TO SUPPRESS DISSENTING SPEECH, A FIRST AMENDMENT VIOLATION, WHICH ESTABLISHED STANDING TO LITIGATE THE CASE. ON JANUARY 30, 2025, WITH THE CHANGE IN ADMINISTRATIONS AND PRESIDENT TRUMP'S JANUARY 20, 2025, EXECUTIVE ORDER TITLED "RESTORING FREEDOM OF SPEECH AND ENDING FEDERAL CENSORSHIP," THE FIFTH CIRCUIT VACATED ITS PRIOR OPINION AND REMANDED FOR THE DISTRICT COURT TO CONSIDER MOOTNESS, WHICH IS A JURISDICTIONAL MATTER. DOCUMENT: 166-1 FILED 1/30/2025. THE CASE IS STILL PENDING AT THE DISTRICT COURT. FORM 990-EZ, PART III, LINE 28: UNITED STATES V. IDAHO & MOYLE V. UNITED STATES, NINTH CIRCUIT NOS. 23-35440 & 23-35450. AMICUS CURIAE BRIEF FILED SEPTEMBER 19, 2024 IN SUPPORT OF IDAHO AND MOYLE. ON JULY 8, 2022, PRESIDENT BIDEN SIGNED EXECUTIVE ORDER ("EO") 14076, INSTRUCTING ALL FEDERAL AGENCIES TO DO EVERYTHING THEY COULD TO "PROTECT . . . AND PROMOTE ACCESS TO . . . ABORTION," DECLARING IT "THE POLICY OF [HIS] ADMINISTRATION TO SUPPORT WOMEN'S RIGHT TO CHOOSE AND TO PROTECT AND DEFEND REPRODUCTIVE RIGHTS"EUPHEMISTIC LANGUAGE MEANING "ABORTION ON DEMAND." ON AUGUST 3, 2022, BIDEN SIGNED EO 14079, DIRECTING THE DEPARTMENT OF HEALTH AND HUMAN SERVICES ("HHS") TO ENSURE THAT HHS FORCE "HEALTHCARE PROVIDERS THAT RECEIVE FEDERAL FINANCIAL ASSISTANCE" TO COMPLY WITH EO 14076. IN AUGUST 2022, THE BIDEN JUSTICE DEPARTMENT SUED IDAHO CLAIMING THAT ITS DEFENSE OF LIFE ACT, PASSED IN 2020, VIOLATED A POST-DOBBS V. JACKSON WOMEN'S HEALTH ORG., 597 U.S. 215 (2022), INTERPRETATION THE SECRETARY OF THE DEPARTMENT OF HEALTH AND HUMAN SERVICES ("HHS") HAS GIVEN TO THE "EMERGENCY MEDICAL TREATMENT AND ACTIVE LABOR ACT OF 1986" ("EMTALA"), 42 U.S.C. SECTION 1395DD.2, TO FORCE HOSPITAL EMERGENCY ROOMS AND PHYSICIANS, WHICH RECEIVE FEDERAL FUNDS, TO PROVIDE ABORTIONS IF THAT IS DEEMED TO BE THE "STABILIZING TREATMENT" A "PREGNANT PATIENT" NEEDS, OR TRANSFER THE "PREGNANT PATIENT" TO A FACILITY THAT WILL PROVIDE SUCH "TREATMENT" IRRESPECTIVE OF STATE LAWS TO THE CONTRARY. HHS WAS IMPLEMENTING PRESIDENT BIDEN'S DIRECTIVE THAT HHS "TAKE STEPS TO ENSURE THAT . . . POLITICIANS CANNOT INTERFERE IN THE DECISIONS THAT SHOULD BE MADE BETWEEN A WOMAN AND HER DOCTOR." THE WHITE HOUSE, "REMARKS BY PRESIDENT BIDEN ON THE SUPREME COURT DECISION TO OVERTURN ROE V. WADE" (JUNE 24, 2022). OUR AMICUS BRIEF ARGUED THAT THE SECRETARY'S INTERPRETATION EXCEEDED HIS AUTHORIZATION UNDER THE STATUTE, IS CONTRARY TO THE STATUTE, AND REPRESENTS AN ATTEMPT TO TAKE OVER THE GENERAL POLICE POWER RESERVED TO THE STATES BY THE TENTH AMENDMENT. WE POINTED OUT THAT FEDERAL LAW IS MORE PRO-LIFE THAN THE BIDEN ADMINISTRATION ACKNOWLEDGED, SUCH AS TITLE XXI OF THE SOCIAL SECURITY ACT, ENACTED IN 1997, WHICH AUTHORIZES FEDERAL GRANTS TO STATES FOR THE PROVISION OF CHILD HEALTH ASSISTANCE TO UNINSURED, LOW-INCOME CHILDREN, KNOWN AS THE CHIP PROGRAM. FOR PURPOSES OF THAT PROGRAM, 42 C.F.R. SECTION 457.10 DEFINES "CHILD" AS "AN INDIVIDUAL UNDER THE AGE OF 19 INCLUDING THE PERIOD FROM CONCEPTION TO BIRTH." IN ADDITION, EMTALA ITSELF REQUIRES MEDICAL STAFF TO TREAT AN "UNBORN CHILD" AS A PATIENT WHEN MAKING A DETERMINATION ABOUT WHETHER AN EMERGENCY MEDICAL CONDITION EXISTS AND, IF SO, WHAT TREATMENT MAY BE REQUIRED. WE URGED THE NINTH CIRCUIT TO REJECT HHS'S ATTEMPT TO USURP IDAHO'S POLICE POWERS AND ARROGATE ALL POLICE POWERS OVER ABORTION REGULATION TO THE FEDERAL GOVERNMENT IN DEFIANCE OF THE DOBBS DECISION RETURNING ABORTION REGULATION TO THE STATES. AFTER TAKING OFFICE ON JANUARY 24, 2025, PRESIDENT TRUMP SIGNED EO 14182, REVOKING BIDEN'S EOS 14076 AND 14079, AND REESTABLISHING "THE POLICY OF THE UNITED STATES, CONSISTENT WITH THE HYDE AMENDMENT, TO END THE FORCED USE OF FEDERAL TAXPAYER DOLLARS TO FUND OR PROMOTE ELECTIVE ABORTION." FOLLOWING THIS DEVELOPMENT, THE FEDERAL GOVERNMENT DROPPED ITS CASE AGAINST IDAHO AND THE NINTH CIRCUIT APPEAL WAS DISMISSED ON MARCH 5, 2025, ENDING THE CASE. FORM 990-EZ, PART III, LINE 28: LOUISIANA V. U.S. DEPARTMENT OF EDUCATION, FIFTH CIRCUIT NO. 24-30399. AMICUS CURIAE BRIEF IN SUPPORT OF PLAINTIFFS-APPELLEES FILED SEPTEMBER 26, 2024. THIS SUIT CHALLENGES A FINAL U.S. DEPARTMENT OF EDUCATION (DOE) REGULATION ISSUED ON APRIL 29, 2024, TO IMPLEMENT AN EXECUTIVE ORDER PRESIDENT BIDEN SIGNED ON HIS FIRST DAY IN OFFICE, JANUARY 20, 2021, ORDERING EACH FEDERAL AGENCY TO CHANGE THE DEFINITION OF "SEX DISCRIMINATION" TO INCLUDE "SEXUAL ORIENTATION AND "GENDER IDENTITY." THE FINAL RULE DECLARES THAT "'[D]ISCRIMINATION ON THE BASIS OF SEX INCLUDES DISCRIMINATION ON THE BASIS OF SEX STEREOTYPES, SEX CHARACTERISTICS, PREGNANCY OR RELATED CONDITIONS, SEXUAL ORIENTATION OR GENDER IDENTITY.'" LOUISIANA V. UNITED STATES DEP'T OF EDUC., 2024 U.S. DIST. LEXIS 105645, *5 (W.D. LA. 2024) ("LOUISIANA"). THE RULE, INTER ALIA, "REQUIRES STUDENTS TO BE ALLOWED TO ACCESS BATHROOMS AND LOCKER ROOMS BASED ON THEIR GENDER IDENTITY [AND] . . . REQUIRES SCHOOLS TO USE WHATEVER PRONOUNS THE STUDENT REQUIRES. . . ." ID. AT *4. LOUISIANA, MISSISSIPPI, MONTANA, AND IDAHO AS WELL AS A GROUP OF LOUISIANA PARISH SCHOOL BOARDS SUED DOE ALLEGING THAT TITLE IX, WHICH BANS DISCRIMINATION ON THE BASIS OF SEX IN FEDERAL EDUCATION FUNDING, WAS INTENDED TO REMEDY DISCRIMINATION AGAINST BIOLOGICAL WOMEN, AND THAT DOE'S FINAL RULE CONSTITUTED A LEGISLATIVE DETERMINATION THE DOE HAD NO AUTHORITY TO MAKE. ID. AT *25. THEY ALSO ALLEGED THAT REQUIRING TEACHERS AND STATE EDUCATION OFFICIALS TO USE THE PREFERRED PRONOUNS OF STUDENTS VIOLATED THE FIRST AMENDMENT'S PROHIBITION ON COMPELLED SPEECH. ID. AT *32. THE U.S. DISTRICT COURT FOR THE WESTERN DISTRICT OF LOUISIANA AGREED AND ISSUED AN INJUNCTION AGAINST ENFORCING THE RULE IN THE PLAINTIFF STATES. BOTH THE COURT OF APPEALS AND THE U.S. SUPREME COURT DECLINED TO ISSUE A STAY OF THE DISTRICT COURT'S INJUNCTION. SEE AUGUST 16, 2024, PER CURIAM OPINION IN SUPREME COURT CASE NO. 24A-78, DEP'T OF EDUC. V. LOUISIANA. OUR BRIEF ARGUED THAT THE RULE HAS NO STATUTORY BASIS AND, IN FACT, UNDERMINES THE PROTECTIONS FOR ACTUAL WOMEN AND GIRLS THAT TITLE IX WAS INTENDED TO PROTECT. IT IMPOSES AND INSTITUTIONALIZES DISCRIMINATION AGAINST BIOLOGICAL FEMALES AND DESTROYS THE PERSONAL PRIVACY AFFORDED WOMEN AND GIRLS BY USE OF THEIR OWN BATHROOMS AND LOCKER ROOMS, AS WELL AS THREATENING THEIR SAFETY. WE ALSO ARGUED THAT THE RULE REQUIRES BOTH TEACHERS AND STUDENTS TO SAY WHAT ALL KNOW IS FALSE, IN SERVICE TO THE COLLECTIVE, IN VIOLATION OF FIRST AMENDMENT FREE SPEECH RIGHTS. OUR BRIEF ARGUED THAT THE RULE IS ENTITLED TO NO DEFERENCE AND SHOULD BE REJECTED UNDER THE RECENTLY DECIDED U.S. SUPREME COURT CASE LOPER BRIGHT ENTERPRISES V. RAIMONDO, 144 S. CT. 2244 (2024). THE TRUMP ADMINISTRATION, REVERSING COURSE, TOOK A COMPLETELY DIFFERENT VIEW OF TITLE IX AND WITHDREW THE BIDEN ADMINISTRATION'S DOE RULE. THEN, THE TRUMP ADMINISTRATION FILED A JOINT MOTION TO DISMISS THE APPEAL, WHICH THE FIFTH CIRCUIT GRANTED "WITH PREJUDICE" ON MARCH 14, 2025, ENDING THE CASE. FORM 990-EZ, PART III, LINE 28: JANE DOE V. SURGEON GENERAL, STATE OF FLORIDA, ELEVENTH CIRCUIT NO. 24-11996. AMICUS CURIAE BRIEF IN SUPPORT OF FLORIDA FILED SEPTEMBER 4, 2024. ORAL ARGUMENT HELD ON JANUARY 15, 2025. ISSUE: WHETHER FLORIDA'S BAN ON PUBERTY BLOCKERS AND CROSS-SEX HORMONES FOR MINORS VIOLATES THE EQUAL PROTECTION CLAUSE OF THE FOURTEENTH AMENDMENT. THE DISTRICT COURT DECLARED BOTH THE STATUTE AND IMPLEMENTING RULES UNCONSTITUTIONAL AND ENJOINED ENFORCEMENT OF THE LAW. DOE V. LADAPO, 2024 U.S. DIST. LEXIS 105334, *108-109 (N.D. FL. 2024) ("DOE"). THE COURT BELIEVED THAT THE FLORIDA LEGISLATURE WAS MOTIVATED BY "ANIMUS" AGAINST INDIVIDUALS IDENTIFYING AS "TRANSGENDER," EQUATING TRANSGENDERISM TO RACISM. ID. AT *46-51, 56. ON AUGUST 26, 2024, THE COURT OF APPEALS STAYED THE INJUNCTION PENDING APPEAL, FINDING THE DEFENDANTS LIKELY TO SUCCEED ON THE MERITS. DOE V. SURGEON GEN., 2024 U.S. APP. LEXIS 21601 (11TH CIR. 2024). THE COURT NOTED THAT THE DISTRICT COURT CONCEDED "THAT THERE WAS 'EVIDENCE ON EACH SIDE' [ON THE QUESTION OF ANIMUS], AND EVEN THAT 'ONCE THE ISSUE CAME UP, A SIGNIFICANT NUMBER OF LEGISLATORSMORE LIKELY THAN NOT A MAJORITY--WERE ALSO MOTIVATED BY THEIR DESIRE TO ENSURE THAT PATIENTS RECEIVE ONLY PROPER MEDICAL CARE.' THAT SHOULD HAVE BEEN THE END OF IT." ID. AT *10. OUR BRIEF ARGUES THE FLORIDA LEGISLATORS ARE SIMPLY TRYING TO PROTECT MINORS FROM TREATMENTS THAT MAY BE DAMAGING AND IRREVERSIBLE FOR A DEVELOPMENTAL STAGE ANY NUMBER OF MINORS GO THROUGH WHILE MATURING AND THAT THEY TYPICALLY OUTGROW. WE ALSO ARGUE THAT TRANSGENDER STATUS IS A CHOICE WHEREAS RACE IS AN IMMUTABLE CHARACTERISTIC, AND THAT EQUAL PROTECTION ARGUMENTS HAVE NO PLACE IN THIS CASE. FORM 990-EZ, PART III, LINE 28: TENNESSEE, ET AL. V. CARDONA, SIXTH CIRCUIT NO. 24-5588. AMICUS CURIAE BRIEF FILED SEPTEMBER 3, 2024. SIX STATES CHALLENGED THE DEPARTMENT OF EDUCATION'S ("DOE") FINAL RULE, 89 FED. REG. 33474 (APR. 29, 2024), CHANGING THE DEFINITION OF "SEX" IN TITLE IX OF THE CIVIL RIGHTS ACT (RELATING TO EDUCATION) TO INCLUDE "DISCRIMINATION ON THE BASIS OF SEX STEREOTYPES, SEX CHARACTERISTICS, PREGNANCY OR RELATED CONDITIONS, SEXUAL ORIENTATION, AND GENDER IDENTITY." NEW 34 C.F.R. SECTION 106.10, ID. AT 33886. THE DISTRICT COURT PRELIMINARILY ENJOINED ENFORCEMENT OF THE RULE IN THE SIX STATES CHALLENGING THE RULE. TENNESSEE V. CARDONA, 2024 U.S. DIST. LEXIS 106559 AT *131 (E.D. KY. 2024) ("CARDONA I"). THE SIXTH CIRCUIT DECLINED TO STAY THE PRELIMINARY INJUNCTION, BUT EXPEDITED THE APPEAL. TENNESSEE V. CARDONA, 2024 U.S. APP. LEXIS 17600 (6TH CIR. 2024) ("CARDONA II"). THE SUPREME COURT LIKEWISE DECLINED TO STAY THE PRELIMINARY INJUNCTION. SEE DEP'T OF EDUC. V. LOUISIANA, 2024 U.S. LEXIS 2983 (AUG. 16, 2024). OUR BRIEF ARGUES THAT DOE'S DEFINITION IS INCONSISTENT WITH TITLE IX'S TEXT, CONTEXT, AND PURPOSE AND THUS ULTRA VIRES, AND THAT IT UNDERMINES THE PROTECTIONS FOR ACTUAL WOMEN AND GIRLS THAT TITLE IX WAS INTENDED TO PROTECT--THEIR PERSONAL PRIVACY AND SAFETY AND THEIR ABILITY TO PARTICIPATE SAFELY AND FAIRLY IN SPORTS. WE ARGUE THAT THE RULE IS ENTITLED TO NO DEFERENCE UNDER THE SUPREME COURT'S RECENT DECISION IN LOPER BRIGHT ENTER'S. V. RAIMONDO, 603 U.S. 369 (2024). WE URGE THE SIXTH CIRCUIT TO AFFIRM THE DISTRICT COURT. THE DISTRICT COURT RULED AGAINST THE DEPARTMENT OF EDUCATION ON THE MERITS ON JANUARY 9, 2025, VACATING THE FINAL RULE ON GROUNDS, INTER ALIA, THAT THE RULE AND ITS CORRESPONDING REGULATIONS EXCEED THE DEPARTMENT'S AUTHORITY UNDER TITLE IX, VIOLATE THE FIRST AMENDMENT, AND ARE THE RESULT OF ARBITRARY AND CAPRICIOUS AGENCY ACTION. CORRESPONDINGLY THE COURT GRANTED THE STATES' MOTION FOR SUMMARY JUDGMENT AND DENIED THE DEPARTMENT'S MOTION FOR SUMMARY JUDGMENT. THE COURT EXPRESSLY STATED THAT IT WAS EXERCISING "ITS INDEPENDENT JUDGMENT IN INTERPRETING TITLE IX AND DETERMINING WHETHER THE DEPARTMENT ACTED WITHIN ITS STATUTORY AUTHORITY," CITING LOPER BRIGHT AT 412-13. THE DEPARTMENT OF EDUCATION'S WEBSITE NOW STATES, "ON JANUARY 9, 2025, A FEDERAL DISTRICT COURT ISSUED A DECISION VACATING THE 2024 FINAL RULE. CONSISTENT WITH THE COURT'S ORDER, THE 2024 TITLE IX REGULATIONS AND THESE RESOURCES ARE NOT EFFECTIVE IN ANY JURISDICTION." HTTPS://WWW.ED.GOV/LAWS-AND-POLICY/CIVIL-RIGHTS-LAWS/TITLE-IX-AND-SEX-DI SCRIMINATION/SEX-DISCRIMINATION-OVERVIEW-OF-LAW. THIS CASE IS ESSENTIALLY OVER AND A VICTORY FOR US. FORM 990-EZ, PART III, LINE 28: RHODE V. BONTA, NINTH CIRCUIT NO. 24-542. AMICUS CURIAE BRIEF IN SUPPORT OF PLAINTIFFS-APPELLEES FILED JULY 31, 2024. CALIFORNIA LAW REQUIRES A BACKGROUND CHECK EVERY TIME SOMEONE SEEKS TO BUY AMMUNITION. RHODE V. BONTA, 2024 U.S. DIST. LEXIS 17052, *2-3 (S.D. CAL. 2024) ("RHODE III"). THE LAW RESULTED IN "GUN OWNERS IN CALIFORNIA UNDERGO[ING] BACKGROUND CHECKS MORE THAN ONE MILLION TIMES EACH YEAR SIMPLY TO BUY AMMUNITION." ID. AT *4. THE LAW ALSO PROHIBITED CALIFORNIANS FROM PURCHASING AMMUNITION OUT OF STATE FOR POSSESSION IN THE STATE. ID. THE LAW WAS CHALLENGED BY SEVEN INDIVIDUAL CALIFORNIA GUN OWNERS, THREE FIREARMS DEALERS, AND THE CALIFORNIA RIFLE & PISTOL ASSOCIATION, INC. IN 2020, THE DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA GRANTED PLAINTIFFS' MOTION FOR A PRELIMINARY INJUNCTION, FINDING THAT THE LAW OFFENDED THE SECOND AMENDMENT AS WELL AS THE FEDERAL DORMANT COMMERCE CLAUSE DUE TO ITS IMPORTATION RESTRICTIONS. RHODE V. BECERRA, 445 F. SUPP. 3D 902, 910-911 (S.D. CAL. 2020) ("RHODE I"). AFTER THE SUPREME COURT'S DECISION IN N.Y. STATE RIFLE & PISTOL ASS'N V. BRUEN, 597 U.S. 1 (2022), THE NINTH CIRCUIT VACATED AND REMANDED THE RULING FOR FURTHER CONSIDERATION. SEE RHODE V. BONTA, 2022 U.S. APP. LEXIS 32554 (9TH CIR. 2022) ("RHODE II"). ON REMAND, THE DISTRICT COURT FOUND THAT UNDER BRUEN "[T]HE AMMUNITION BACKGROUND CHECKS LAWS HAVE NO HISTORICAL PEDIGREE AND OPERATE IN SUCH A WAY THAT THEY VIOLATE THE SECOND AMENDMENT RIGHT OF CITIZENS TO KEEP AND BEAR ARMS [AND T]HE ANTI-IMPORTATION COMPONENTS VIOLATE THE DORMANT COMMERCE CLAUSE." RHODE III AT *43. THE COURT FURTHER FOUND THAT THE STATUTE IS PREEMPTED BY 18 U.S.C. SECTION 926A, WHICH PROVIDES, "[N]OTWITHSTANDING ANY OTHER PROVISION OF ANY LAW . . . OF A STATE . . . ANY PERSON WHO IS NOT OTHERWISE PROHIBITED BY THIS CHAPTER FROM TRANSPORTING, SHIPPING, OR RECEIVING A FIREARM SHALL BE ENTITLED TO TRANSPORT A FIREARM FOR ANY LAWFUL PURPOSE FROM ANY PLACE WHERE HE MAY LAWFULLY POSSESS AND CARRY SUCH FIREARM TO ANY OTHER PLACE WHERE HE MAY LAWFULLY POSSESS AND CARRY SUCH FIREARM." ID. AT *39-40. OUR BRIEF SUMMARIZES THE LONG HISTORY OF CALIFORNIA, FROM 1923 TO THE PRESENT, TO RESTRICT AND BURDEN THE EXERCISE OF SECOND AMENDMENT RIGHTS. ON JUNE 8, 2023, GOVERNOR NEWSOM WENT SO FAR AS TO PROPOSE A CONVENTION OF STATES TO PASS A NEW CONSTITUTIONAL AMENDMENT TO OVERTURN THE SECOND AMENDMENT. (PRESS RELEASE, "GOVERNOR NEWSOM PROPOSES HISTORIC 28TH AMENDMENT TO THE UNITED STATES CONSTITUTION TO END AMERICA'S GUN VIOLENCE CRISIS" (JUNE 8, 2023).) CALIFORNIA IS THE ONLY STATE CALLING FOR REPEAL OF THE SECOND AMENDMENT. WE ARGUE THAT THE DISTRICT COURT DECISIONS WERE CORRECT AND SHOULD BE AFFIRMED UNDER BRUEN AND THE RECENT UNITED STATES V. RAHIMI, 144 S.CT. 1889, DECIDED ON JUNE 21, 2024. THE DISTRICT COURT EXPLAINED: THE STATE'S AMMUNITION BACKGROUND CHECK REGIME . . . TREATS ALL CITIZENS AS IF THEY DO NOT ENJOY A RIGHT TO BUY AMMUNITION. IT FORCES AMERICANS TO ENTREAT AND SUPPLICATE THE STATE FOR PERMISSION. ONLY WHEN THE STATE IS SATISFIED THAT A CITIZEN HAS PROVEN THAT THEY MEET THE QUALIFICATIONS--ONLY THEN--DOES THE STATE ISSUE ITS STAMP OF AUTHORIZATION. [RHODE III AT 34-35.] RAHIMI DOES NOTHING TO WEAKEN THE BRUEN CALCULUS FOR ANALYZING AMMUNITION BACKGROUND CHECKS. INDEED, IT UPHOLDS BRUEN'S CONSTITUTIONAL PRESUMPTION IN FAVOR OF THE EXERCISE OF THE RIGHT TO KEEP AND BEAR ARMS--AND THE AMMUNITION THEY REQUIRE TO FUNCTION. IN JULY 2025, A NINTH CIRCUIT PANEL AFFIRMED THE DISTRICT COURT, BUT ON DECEMBER 1, 2025, THE NINTH CIRCUIT GRANTED REHEARING EN BANC, VACATING THE PANEL DECISION AND REVIVING THE CALIFORNIA LAW. WE AWAIT A DECISION BY THE EN BANC COURT. FORM 990-EZ, PART III, LINE 28: BAIRD V. BONTA, NINTH CIRCUIT NO. 24-565. AMICUS CURIAE BRIEF IN SUPPORT OF MARK BAIRD CHALLENGING CALIFORNIA'S PRACTICAL BAN ON OPEN CARRY OF FIREARMS IN VIOLATION OF THE 2ND AMENDMENT FILED APRIL 25, 2024. ONE OF OUR ARGUMENTS IS THAT BY CRIMINALIZING VIRTUALLY ALL LOADED OPEN CARRY, PARTICULARLY OF LONG GUNS, CALIFORNIA PREVENTS THE PEOPLE FROM ORGANIZING THEMSELVES INTO A WELL REGULATED MILITIA, AND TRAINING IN THE USE OF ARMS, A RIGHT PROTECTED AGAINST INFRINGEMENT BY THE SECOND AMENDMENT. WE ADDED, "[A]LTHOUGH THE CONSTITUTIONAL NOTION OF AN ARMED POPULACE AND PEOPLE'S 'MILITIA' SEEMS TO HAVE BECOME ANATHEMA TO MANY MODERN JURISTS, THE SECOND AMENDMENT'S PROTECTIONS DO NOT DEPEND ON THE PREFERENCES OF MODERN JUDGES." AMICUS BR. AT 10-11. CALIFORNIA FILED ITS ANSWERING BRIEF ON JUNE 17, 2024. IN FOOTNOTE 8 ON PAGE 24, CALIFORNIA ASKED THE NINTH CIRCUIT TO DISREGARD OUR MILITIA ARGUMENT BECAUSE IT WAS RAISED BY US AMICI INSTEAD OF MARK BAIRD. THAT CALIFORNIA THOUGHT IT IMPORTANT TO SAY SOMETHING ABOUT OUR ARGUMENT IS A TESTAMENT TO ITS FORCE. FORM 990-EZ, PART III, LINE 28: FOUTS V. BONTA, NINTH CIRCUIT NO. 24-1039. AMICUS CURIAE BRIEF IN SUPPORT OF PLAINTIFFS-APPELLEES FILED JUNE 14, 2024. THIS CASE PRESENTS A SECOND AMENDMENT CHALLENGE TO CALIFORNIA'S BAN ON "BILLY" CLUBS, I.E., "ANY LEADED CANE, OR ANY INSTRUMENT OR WEAPON OF THE KIND COMMONLY KNOWN AS A BILLY, BLACKJACK, SANDBAG, SANDCLUB, SAP, OR SLUNGSHOT." CALIFORNIA PENAL CODE SECTION 22210. UNDER THE SECOND AMENDMENT, THE PEOPLE HAVE THE RIGHT "TO KEEP AND BEAR ARMS." AFTER THE U.S. SUPREME COURT'S DECISION IN N.Y. STATE RIFLE & PISTOL ASS'N V. BRUEN, 597 U.S. 1 (2022), THE DISTRICT COURT FOUND THAT A BILLY IS AN "ARM AND THEREFORE COVERED BY THE SECOND AMENDMENT'S PLAIN TEXT. FOUTS V. BONTA, 718 F. SUPP. 3D 1276 (S.D. CAL. 2024). CALIFORNIA IS ASKING THE NINTH CIRCUIT TO OVERTURN THAT DECISION, ARGUING THAT BILLIES ARE NOT "ARMS" BECAUSE THEY "ARE NOT COMMONLY USED FOR SELF-DEFENSE." OUR BRIEF SHOWS THAT BILLYS ARE ARMS COMMONLY USED FOR SELF-DEFENSE AND HAVE BEEN SINCE THE FOUNDING OF THE COUNTRY AND EONS BEFORE THAT, REFERENCING I CHRONICLES 11:23 (NASB). (BENAIAH, A COMMANDER OF THE JEWISH KING DAVID'S ARMY, WHO CONFRONTED AN INVADING EGYPTIAN, "WENT DOWN TO HIM WITH A CLUB AND SNATCHED THE SPEAR FROM THE EGYPTIAN'S HAND AND KILLED HIM WITH HIS OWN SPEAR.") WE AWAIT THE NINTH CIRCUIT'S DECISION. FORM 990-EZ, PART III, LINE 28: UNITED STATES V. TEXAS AND LAS AMERICAS IMMIGRANT ADVOCACY CENTER V. MCCRAW, FIFTH CIRCUIT NO. 24-50149. AMICUS CURIAE BRIEF FILED MARCH 13, 2024. THE DISTRICT COURT PRELIMINARILY ENJOINED ENFORCEMENT OF NEW TEXAS LAW S.B. 4, WHICH MAKES ILLEGAL ENTRY ACROSS THE TEXAS BORDER A CRIMINAL MISDEMEANOR OFFENSE. THE COURT OF APPEALS ISSUED A TEMPORARY ADMINISTRATIVE STAY OF THE DISTRICT COURT'S INJUNCTION TO ALLOW THE PARTIES TO BRIEF THE CASE AND THE COURT TO HEAR AND DECIDE THE CASE. THE UNITED STATES ASKED THE U.S. SUPREME COURT TO INTERVENE AND STAY THE COURT OF APPEAL'S ADMINISTRATIVE STAY, WHICH WOULD HAVE REINVIGORATED THE DISTRICT COURT'S INJUNCTION. ON MARCH 19, 2024, THE SUPREME COURT DENIED THE UNITED STATES' APPLICATION TO VACATE THE COURT OF APPEAL'S ADMINISTRATIVE STAY, LEAVING S.B. 4 ENFORCEABLE WHILE THE COURT OF APPEALS PROCESSES THE APPEAL. A 5TH CIRCUIT PANEL THEN HELD AN EMERGENCY HEARING AND LIFTED THE ADMINISTRATIVE STAY, THEREBY REINSTITUTING THE DISTRICT COURT'S PRELIMINARY INJUNCTION. OUR AMICUS BRIEF SUPPORTS TEXAS'S SOVEREIGN POWERS TO CONTROL ITS BORDERS AND TO PROTECT ITS PEOPLE FROM INVASION. U.S. CONST., ART. I, SEC. 10, CL. 3 ("NO STATE SHALL, WITHOUT THE CONSENT OF CONGRESS, . . . ENGAGE IN WAR, UNLESS ACTUALLY INVADED, OR IN SUCH IMMINENT DANGER AS WILL NOT ADMIT OF DELAY."). THE UNITED STATES VOLUNTARILY DISMISSED ITS CASE ON MARCH 18, 2025, AFTER DONALD TRUMP BECAME PRESIDENT AND THE UNITED STATES STARTED WORKING WITH TEXAS TO ENFORCE IMMIGRATION LAWS INSTEAD OF AGAINST TEXAS, AS THE BIDEN ADMINISTRATION HAD DONE. ON JULY 3, 2025, THE FIFTH CIRCUIT HELD THAT THE REMAINING PLAINTIFFS HAD STANDING TO SUE, RULED AGAINST TEXAS, UPHELD THE PRELIMINARY INJUNCTION ENTERED BY THE DISTRICT COURT, AND REMANDED THE CASE TO THE DISTRICT COURT FOR FURTHER PROCEEDINGS. BUT ON AUGUST 29, 2025, THE COURT ORDERED REHEARING EN BANC. WE AWAIT THE EN BANC COURT'S DECISION. FORM 990-EZ, PART III, LINE 28: BRANDT V. GRIFFIN, EIGHTH CIRCUIT NO. 23-2681. AMICUS CURIAE BRIEF FILED NOVEMBER 14, 2023, DEFENDING ARKANSAS' LAW BANNING RADICAL TRANSGENDER TREATMENTS FOR MINORS. ON APRIL 6, 2021, THE ARKANSAS LEGISLATURE PASSED THE "ARKANSAS SAVE ADOLESCENTS FROM EXPERIMENTATION (SAFE) ACT." THE ACT "PROHIBITS A PHYSICIAN OR OTHER HEALTHCARE PROFESSIONAL FROM PROVIDING 'GENDER TRANSITION PROCEDURES' TO ANY INDIVIDUAL UNDER EIGHTEEN YEARS OF AGE AND FROM REFERRING ANY INDIVIDUAL UNDER EIGHTEEN YEARS OF AGE TO ANY HEALTHCARE PROFESSIONAL FOR 'GENDER TRANSITION PROCEDURES.'" BRANDT V. RUTLEDGE, 2023 U.S. DIST. LEXIS 106517, AT *5-6 (E.D. ARK. 2023) ("BRANDT"). THE ACT PROHIBITS, INTER ALIA, DISFIGURING SURGERIES TO ARTIFICIALLY ADD OR REMOVE BODY PARTS IN PURSUIT OF "GENDER TRANSITION AND PUBERTY-BLOCKING HORMONES. ID. AT *6. THE ACT CREATES A PRIVATE RIGHT OF ACTION AGAINST ANY PHYSICIAN PERFORMING SUCH PROCEDURES. ID. AT *7. THE ACT WAS CHALLENGED BY A COALITION OF PLAINTIFFS, INCLUDING PHYSICIANS WISHING TO PERFORM "GENDER TRANSITION PROCEDURES FOR PROFIT, AND MINOR PLAINTIFFS BELIEVING THEMSELVES TO BE "TRANSGENDER," WHOSE PARENTS SUED ON THEIR BEHALF AS "FIRST FRIENDS." ID. AT *1. THE DISTRICT COURT RULED THAT THE ACT VIOLATED THE EQUAL PROTECTION CLAUSE FOR DISCRIMINATING ON THE BASIS OF SEX AND DISCRIMINATING AGAINST TRANSGENDER PEOPLE. BRANDT, AT *92-107. THE COURT ALSO RULED THAT THE ACT VIOLATED DUE PROCESS OF LAW FOR INFRINGING ON THE "FUNDAMENTAL LIBERTY INTEREST" OF THE MINOR PLAINTIFFS' PARENTS IN DIRECTING THE MEDICAL TREATMENT OF THEIR CHILDREN. ID. AT *107-110. FINALLY, THE COURT RULED THAT THE ACT VIOLATES THE FIRST AMENDMENT FOR REGULATING SPEECH BY PREVENTING DOCTORS FROM REFERRING FOR GENDER TRANSITION TREATMENT. ID. AT *110-113. OUR BRIEF ARGUED, INTER ALIA, THAT THE DISTRICT COURT'S FINDINGS OF FACT ASSUME MODERN "GENDER IDENTITY" THEORY'S LEGITIMACY, WHICH REJECTS THE UNIVERSALLY RECOGNIZED MEDICAL FACT THAT EVERY PERSON IS EITHER A MAN OR A WOMAN AND THAT NO ONE CAN SHIFT BETWEEN THE SEXES. WE CRITICIZED THE DISTRICT COURT'S RELIANCE ON THE WORLD PROFESSIONAL ASSOCIATION FOR TRANSGENDER HEALTH ("WPATH") AND THE ENDOCRINE SOCIETY ("ES"), DEMONSTRATING THAT THEY ARE CONFLICTED BELLIGERENTS IN THE CULTURE WAR, NOT NEUTRAL UMPIRES. WPATH AND ES RECEIVE FUNDING FROM THE PHARMACEUTICAL INDUSTRY AND OTHERS WHO STAND TO PROFIT FROM TRANSGENDER TREATMENTS, WHICH IS A MULTIBILLION DOLLAR INDUSTRY. THOSE WHO COMMENCE TREATMENTS END UP IN EXPENSIVE, LIFELONG RELATIONSHIPS WITH THE MEDICAL INDUSTRIAL COMPLEX. FINALLY, WE ARGUED THAT CHARACTERIZING TREATMENTS AS "GENDER REASSIGNMENT" DOES NOT ALTER THE FACT THAT STERILIZATION IS THE END RESULT, AND ARKANSAS MUST HAVE THE AUTHORITY TO PREVENT THE STERILIZATION OF CHILDREN ON THE SAY-SO OF A PARENT OR GUARDIAN. WE URGED THE COURT OF APPEALS TO REVERSE THE DISTRICT AND UPHOLD ARKANSAS'S LAW. ON AUGUST 12, 2025, THE EIGHTH CIRCUIT ISSUED AN 8-2 EN BANC OPINION UPHOLDING ARKANSAS'S LAW. BRANDT V. GRIFFIN, 147 F.4TH 867 (CA8 2025). FORM 990-EZ, PART III, LINE 28: BOLAND V. BONTA, NINTH CIRCUIT NO. 23-55276. AMICUS CURIAE BRIEF FILED JUNE 2, 2023, CHALLENGES CALIFORNIA'S APPROVED HANDGUN LIST UNDER THE SECOND AMENDMENT. THE LIST RESULTS FROM CALIFORNIA'S UNSAFE HANDGUN ACT, A "CONSUMER PROTECTION" LAW OSTENSIBLY ENACTED TO PROTECT THE PUBLIC FROM "UNSAFE" GUNS. UNDER THAT LAW, CALIFORNIA DETERMINES WHAT HANDGUNS CITIZENS MAY BUY AND WHAT HANDGUNS THEY MAY NOT BUY. WE SAY IN RESPONSE: CALIFORNIA[] TREATS HANDGUNS AS IF THEY WERE JUST ANY CONSUMER PRODUCT, WHERE THE RIGHT TO PURCHASE AND OWN IS A MATTER OF LEGISLATIVE GRACE AND WHERE THE GOVERNMENT HAS BROAD POLICE POWER TO PROTECT THE CONSUMER. THIS APPROACH DELIBERATELY IGNORES THE RICH HISTORY OF AND PURPOSE OF GUN RIGHTS--A RIGHT THAT WAS NOT CONFERRED BY GOVERNMENT, AND THUS WHICH MAY NOT BE TAKEN AWAY BY GOVERNMENT. AMICUS BRIEF AT 23. THE NINTH CIRCUIT HEARD ORAL ARGUMENT ON AUGUST 23, 2023. ON MARCH 25, 2024, THE PANEL DECIDED TO PAUSE THE CASE ("SUBMISSION OF THIS CASE IS VACATED") PENDING THE EN BANC DECISION IN DUNCAN V. BONTA, AND IT HAS NOW ORDERED BRIEFING BY THE PARTIES ON HOW THE MARCH 20, 2025 NINTH CIRCUIT DECISION IN THAT CASE AFFECTS THIS CASE. FORM 990-EZ, PART III, LINE 28: DUNCAN V. BONTA, NINTH CIRCUIT NO. 23-55805. AMICUS CURIAE BRIEF IN SUPPORT OF PLAINTIFFS-APPELLEES FILED DECEMBER 28, 2023. THIS CASE CHALLENGES CALIFORNIA'S YEAR 2000 LAW PROHIBITING THE MANUFACTURE, IMPORTATION, SALE, AND TRANSFER OF SO-CALLED LARGE-CAPACITY MAGAZINES, WHICH IT DEFINES AS "ANY AMMUNITION FEEDING DEVICE WITH THE CAPACITY TO ACCEPT MORE THAN 10 ROUNDS," CALIFORNIA PENAL CODE SECTION 16740; CALIFORNIA'S 2016 LAW BANNING THE POSSESSION OF LARGE-CAPACITY MAGAZINES; AND THE NOVEMBER 2016 PROPOSITION 63, WHICH CALIFORNIA VOTERS APPROVED TO THE SAME EFFECT, AS SECOND AMENDMENT VIOLATIONS. THIS CASE HAS HAD A LONG HISTORY AND EVENTUALLY MADE IT TO THE U.S. SUPREME COURT AFTER AN EN BANC NINTH CIRCUIT DECISION REVERSED THE DISTRICT COURT AND UPHELD THE BAN. FOLLOWING ITS DECISION IN N.Y. STATE RIFLE & PISTOL ASS'N V. BRUEN, 142 S. CT. 2111 (2022), THE SUPREME COURT GRANTED THE PETITION FOR A WRIT OF CERTIORARI, VACATED THE NINTH CIRCUIT DECISION, AND REMANDED THE CASE TO THE NINTH CIRCUIT, DUNCAN V. BONTA, 142 S. CT. 2895 (2022), WHICH REMANDED THE CASE TO THE DISTRICT COURT FOR FURTHER PROCEEDINGS, SEE DUNCAN V. BONTA, 49 F.4TH 1228 (9TH CIR. 2022). THE DISTRICT AGAIN HELD THE LAW UNCONSTITUTIONAL, 2023 U.S. DIST. LEXIS 169577 (S.D. CAL. 2023), AND CALIFORNIA APPEALED AGAIN. OUR BRIEF URGES THE NINTH CIRCUIT TO CEASE ITS LONG-STANDING HOSTILITY TO SECOND AMENDMENT RIGHTS AND THE U.S. SUPREME COURT'S SECOND AMENDMENT JURISPRUDENCE AND AFFIRM THE DISTRICT COURT'S POST-REMAND DECISION, ARGUING THAT IT IS FULLY CONSISTENT WITH BRUEN. ON MARCH 20, 2025, THE NINTH CIRCUIT, IN A 7-4 EN BANC DECISION, REVERSED THE DISTRICT COURT'S PROPER APPLICATION OF BRUEN AND UPHELD CALIFORNIA'S LAW. DUNCAN ET AL. FILED A PETITION FOR A WRIT OF CERTIORARI AT THE U.S. SUPREME COURT ON AUGUST 15, 2025. SEE U.S. SUPREME COURT SECTION, ABOVE, FOR MORE INFORMATION. FORM 990-EZ, PART III, LINE 28: MILLER V. BONTA, NINTH CIRCUIT NO. 23-2979. AMICUS CURIAE BRIEF FILED DECEMBER 29, 2023. THIS CASE CHALLENGES CALIFORNIA'S ASSAULT WEAPONS CONTROL ACT OF 1989 AS AMENDED IN 1999 TO EXPAND ITS LIST OF "ASSAULT WEAPONS" TO INCLUDE SEMIAUTOMATIC FIREARMS WHICH HAD CERTAIN FEATURES: (A) A PISTOL GRIP THAT PROTRUDES CONSPICUOUSLY BENEATH THE ACTION OF THE WEAPON; (B) A THUMBHOLE STOCK; (C) A FOLDING OR TELESCOPING STOCK; (D) A GRENADE LAUNCHER OR FLARE LAUNCHER; (E) A FLASH SUPPRESSOR; OR (F) A FORWARD PISTOL GRIP. [CAL. PENAL CODE SECTION 30515(A)(1) ("AWCA").] FOLLOWING A TRIAL, THE U.S. DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA HELD THAT AWCA AMOUNTED TO A BAN ON THE POSSESSION OF SUCH WEAPONS, AND THAT "[A] LAW THAT IMPOSES SUCH A SEVERE RESTRICTION ON THE FUNDAMENTAL RIGHT OF SELF-DEFENSE OF THE HOME THAT IT AMOUNTS TO A DESTRUCTION OF THE SECOND AMENDMENT RIGHT IS UNCONSTITUTIONAL UNDER ANY LEVEL OF SCRUTINY." THE COURT ENJOINED THE CHALLENGED PROVISIONS. THE NINTH CIRCUIT STAYED THE INJUNCTION PENDING APPEAL. OUR AMICUS BRIEF PROVIDES HISTORICAL PERSPECTIVE TO THE RIGHT TO BEAR ARMS ENSHRINED IN THE SECOND AMENDMENT AND THEN ADDRESSES EACH OF THE PROHIBITED FEATURES IN TURN, SHOWING HOW SOME OF THE FEATURES HAVE NO EFFECT ON THE AMORPHOUS, ASSERTED "DANGEROUSNESS" OF THE WEAPON WHILE OTHERS ARE ERGONOMIC, SAFETY-INCREASING ITEMS THAT REDUCE OR ELIMINATE UNINTENDED HARM, ACTUALLY ENHANCING SAFETY. AMICUS BRIEF AT 13-18 & 24. THE NINTH CIRCUIT HEARD ORAL ARGUMENT ON JANUARY 24, 2024, AFTER WHICH THE PANEL DECIDED TO HOLD THE CASE IN ABEYANCE PENDING THE OUTCOME OF DUNCAN V. BONTA, DISCUSSED ABOVE. FORM 990-EZ, PART III, LINE 28: NGUYEN V. BONTA, NINTH CIRCUIT NO. 24-2036, A CHALLENGE TO CALIFORNIA'S ONE GUN A MONTH LAW. AMICUS CURIAE BRIEF IN SUPPORT OF PLAINTIFFS-APPELLEES FILED JUNE 4, 2024. THE DISTRICT COURT ENJOINED ENFORCEMENT OF THE LAW ON THE GROUNDS THAT THE SECOND AMENDMENT'S PLAIN TEXT PROTECTS THE CONDUCT CRIMINALIZED BY THE CALIFORNIA LAW. THE COURT CONDUCTED HISTORICAL ANALYSIS TO DETERMINE WHETHER THE LAW'S CONDITIONS AND QUALIFICATIONS ON THE COMMERCIAL SALE OF ARMS IS "LONGSTANDING" UNDER NEW YORK STATE RIFLE & PISTOL ASS'N, INC. V. BRUEN, 597 U.S. 1 (2022), AND CONCLUDED THAT THE HISTORICAL LAWS OFFERED BY CALIFORNIA WERE NOT RELEVANTLY SIMILAR. ID. AT 28-29. ON APRIL 24, 2024, A NINTH CIRCUIT MOTIONS PANEL ISSUED A STAY OF THE DISTRICT COURT'S PERMANENT INJUNCTION PENDING APPEAL; HOWEVER, ON AUGUST 15, 2024, IN A PROMISING DEVELOPMENT, THE PANEL HEARING THE CASE REVERSED THE MOTIONS PANEL'S ORDER, ALLOWING THE DISTRICT COURT INJUNCTION TO AGAIN GO INTO EFFECT. OUR BRIEF ARGUES THAT THE RIGHT TO KEEP AND BEAR ARMS INCLUDES THE RIGHT TO ACQUIRE THEM, AND NOT JUST ONE A MONTH, BUT MORE THAN ONE, AS THE SECOND AMENDMENT USES THE PLURAL TERM "ARMS." WE ALSO SHOW THAT CALIFORNIA'S PROFERRED HISTORICAL JUSTIFICATIONS FOR THE LAW DO NOT SATISFY BRUEN. ON JUNE 20, 2025, THE NINTH CIRCUIT AFFIRMED THE DISTRICT COURT DECISION STRIKING DOWN CALIFORNIA'S ONE-GUN-A-MONTH LAW IN A 3-0 OPINION, SAYING "[T]HE SECOND AMENDMENT EXPRESSLY PROTECTS THE RIGHT TO POSSESS MULTIPLE ARMS. IT ALSO PROTECTS AGAINST MEANINGFUL CONSTRAINTS ON THE RIGHT TO ACQUIRE ARMS BECAUSE OTHERWISE THE RIGHT TO 'KEEP AND BEAR' WOULD BE HOLLOW." NGUYEN V. BONTA, 140 F.4TH 1237, 1249 (CA9 2025). THE COURT FOUND NO HISTORICAL PRECEDENT SUPPORTING THIS RESTRICTION ON SECOND AMENDMENT RIGHTS. ID. THIS CASE APPEARS TO BE OVER. FORM 990-EZ, PART III, LINE 28: STATE OF NEW JERSEY V. PAMELA J. BONDI, U.S. DISTRICT COURT FOR THE DISTRICT OF MARYLAND CASE NO. 1:25-CV-01807-PX . AMICUS CURIAE BRIEF FILED JULY 3, 2025. IN THIS CASE, PLAINTIFFS ATTEMPTED TO ENJOIN THE FEDERAL GOVERNMENT'S RETURN OF UNLAWFULLY SEIZED FORCED-RESET TRIGGERS ("FRTS"), INCLUDING TO INDIVIDUALS AND ENTITIES LOCATED IN STATES WHERE SUCH ITEMS MAY BE LAWFULLY POSSESSED UNDER FEDERAL AND STATE LAW. OUR AMICUS BRIEF ARGUES THAT FRTS ARE PROTECTED UNDER THE SECOND AMENDMENT AND ANY PRELIMINARY INJUNCTION AGAINST THE RETURN OF FRTS WOULD BE PRESUMPTIVELY UNCONSTITUTIONAL UNDER THE SUPREME COURT'S SECOND AMENDMENT JURISPRUDENCE. PLAINTIFFS WITHDREW THEIR MOTION FOR A PRELIMINARY INJUNCTION AND ON AUGUST 19, 2025, THE COURT GRANTED A JOINT MOTION TO STAY THE PROCEEDINGS. FORM 990-EZ, PART III, LINE 28: STEVEN F. HOTZE, M.D., ET AL. V. U.S. DEP'T OF THE TREASURY, N.D. TEXAS CASE NO. 2:24-CV-210-Z. AMICUS CURIAE BRIEF IN SUPPORT OF PLAINTIFFS FILED NOVEMBER 19, 2024. THIS CASE CHALLENGES THE CORPORATE TRANSPARENCY ACT ("CTA"), INCLUDED IN THE NATIONAL DEFENSE AUTHORIZATION ACT ("NDAA"), ENACTED BY OVERRIDING THEN PRESIDENT'S VETO BY HOUSE VOTE ON DECEMBER 28, 2020, AND SENATE VOTE ON JANUARY 1, 2021. THE CTA REQUIRES ALL "BENEFICIAL OWNERS" OF BUSINESS ENTITIES WITH LESS THAN 20 EMPLOYEES AND ANNUAL REVENUE OF LESS THAN $5 MILLION TO SUBMIT PERSONAL IDENTIFYING INFORMATION TO THE TREASURY DEPARTMENT'S FINANCIAL CRIMES ENFORCEMENT NETWORK ("FINCEN"). A "BENEFICIAL OWNER" IS DEFINED AS "AN INDIVIDUAL WHO . . . (I) EXERCISES SUBSTANTIAL CONTROL OVER THE ENTITY; OR (II) OWNS OR CONTROLS NOT LESS THAN 25 PERCENT OF THE OWNERSHIP INTERESTS OF THE ENTITY." 31 U.S.C. SECTION 5336(A)(3). THIS NECESSARILY INCLUDES SINGLE-MEMBER LLCS AND PRIVATELY HELD CORPORATIONS. ANY "BENEFICIAL OWNER" WHO WILLFULLY FAILS TO REPORT THE INFORMATION TO FINCEN IS SUBJECT TO A CIVIL PENALTY OF UP TO $500 PER DAY, A SEPARATE FINE UP TO $10,000, AND TWO YEARS' IMPRISONMENT, OR BOTH. 31 U.S.C. SECTIONS5336(H)(1), (3)(A). FINCEN'S FINAL RULE IMPLEMENTING THE CTA TOOK EFFECT ON JANUARY 1, 2024 FOR NEWLY-FORMED ENTITIES AND WAS SET TO TAKE EFFECT FOR EXISTING ENTITIES ON JANUARY 1, 2025. PLAINTIFFS ALLEGE THAT CONGRESS LACKS CONSTITUTIONAL AUTHORITY TO ENACT CTA, RAISE NUMEROUS OTHER CONSTITUTIONAL ISSUES, AND ALLEGE A VIOLATION OF THE ADMINISTRATIVE PROCEDURES ACT ("APA"). OUR AMICUS BRIEF URGES THE COURT TO GRANT PLAINTIFFS' MOTION FOR AN EXPEDITED PRELIMINARY INJUNCTION FOR THE REASONS ADVANCED BY PLAINTIFFS, AS WELL AS THOSE SET OUT IN OUR AMICUS BRIEF, WHICH PROVIDES THE COURT WITH ADDITIONAL INFORMATION ABOUT THE CURIOUS HISTORY OF THE CTA'S ENACTMENT, THE CTA'S UNCONSTITUTIONALITY UNDER DIFFERENT COMMERCE CLAUSE VIEWS, THE RISK THE CTA PRESENTS AS A TRAP FOR AMERICANS TO HAVE THEIR SECOND AMENDMENT RIGHTS STOLEN, AS WELL AS THE RISK TO AMERICANS POSED BY THE CTA IN THE HANDS OF AN INCREASINGLY WEAPONIZED GOVERNMENT. WHILE A DECISION IS PENDING IN THIS COURT, ON DECEMBER 3, 2024, ANOTHER FEDERAL COURT IN A SIMILAR CASE GRANTED A PRELIMINARY INJUNCTION ENJOINING THE CTA AND THE FINCEN RULE NATIONWIDE. SEE N. 1, ABOVE. BOTH CASES MAY ALSO BE IMPACTED BY TEXAS TOP COP SHOP, INC. V. MERRICK GARLAND, ATT'Y GEN'L, ET AL., E.D. TEXAS CASE NO. 4:24-CV-478, WHERE THE U.S. SUPREME COURT GRANTED THE GOVERNMENT'S APPLICATION FOR A STAY "PENDING THE DISPOSITION OF THE APPEAL IN THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT AND DISPOSITION OF A PETITION FOR A WRIT OF CERTIORARI, IF SUCH A WRIT IS TIMELY SOUGHT." FORM 990-EZ, PART III, LINE 28: NEW YORK V. DONALD TRUMP, SUPREME COURT OF NEW YORK, APPELLATE DIVISION, NOS. 2023-04925, 2024-01134, & 2024-01135. AMICUS CURIAE BRIEF FILED AUGUST 2, 2024. THIS CASE DEALS WITH ALLEGEDLY FALSE ENTRIES MADE IN THE ACCOUNTING RECORDS OF TRUMP BUSINESSES, WHICH ALLEGEDLY MISLED LENDERS AND ENABLED DEFENDANTS TO OBTAIN LOANS ON MORE FAVORABLE RATES THAN THEY OTHERWISE WOULD HAVE OBTAINED. THIS IS A NOVEL USE OF THE STATE'S CONSUMER PROTECTION LAWS. OUR BRIEF ARGUES THE $435 MILLION CIVIL PENALTY JUDGMENT ENTERED AGAINST DONALD TRUMP, OTHER FAMILY MEMBERS AND ASSOCIATES, AND BUSINESSES IN WHICH HE HAD A CONTROLLING INTEREST EXCEEDED THE CASE'S STATUTORY BASIS AND VIOLATED THE FIRST, EIGHTH, AND FOURTEENTH AMENDMENTS TO THE U.S. CONSTITUTION. ORAL ARGUMENT WAS HELD ON SEPTEMBER 26, 2024. JUSTICES ASKED NEW YORK'S LAWYERS WHETHER THERE WERE ANY LIMITS TO EXECUTIVE LAW 63(12) AND WHETHER THERE WERE ANY OTHER CASES WHERE THERE WERE NO ACTUAL VICTIMS, JUSTICE DAVID FRIEDMAN COMMENTING THAT HERE NOBODY "LOST ANY MONEY." ON AUGUST 21, 2025, THE APPELLATE DIVISION COURT VACATED THE NEARLY HALF A BILLION DOLLAR FINE IMPOSED BY TRIAL JUDGE ARTHUR ENGORON. THE FIVE APPELLATE JUDGES COULDN'T AGREE ON MUCH, WITH A SPLIT 2-2-1 DECISION, BUT THEY DID VACATE THE PENALTY, DETERMINING IT WAS CONSTITUTIONALLY EXCESSIVE, AS OUR AMICUS BRIEF HAD ARGUED. FORM 990-EZ, PART III, LINE 28: STATE OF WASHINGTON V. GATOR'S CUSTOM GUNS, INC., SUPREME COURT OF THE STATE OF WASHINGTON CASE NO. 102940-3. AMICUS CURIAE BRIEF FILED NOVEMBER 27, 2024. ISSUE: WHETHER WASHINGTON STATE'S SENATE BILL 5078, WHICH MAKES IT ILLEGAL TO SELL OR POSSESS "LARGE CAPACITY MAGAZINES" ("LCMS") WITH A CAPACITY OF MORE THAN 10 ROUNDS, IS CONSTITUTIONAL. THE SUPERIOR COURT JUDGE FOUND THAT LCMS WERE "ARMS" PROTECTED BY WASHINGTON CONSTITUTION ART. 1, SEC. 4, AND THE SECOND AMENDMENT OF THE U.S. CONSTITUTION AND ENJOINED ENFORCEMENT OF S.B. 5078. OUR BRIEF ARGUED THAT THE SUPERIOR COURT'S DECISION SHOULD BE AFFIRMED. ON MAY 8, 2025, IN A 6-1 DECISION, THE STATE OF WASHINGTON'S SUPREME COURT REVERSED, HOLDING, "BECAUSE LCMS ARE NOT 'ARMS' IN THE CONSTITUTIONAL SENSE, AND THE RIGHT TO PURCHASE LCMS IS NOT AMONG THE ANCILLARY RIGHTS PROTECTED BY THE SECOND AMENDMENT, NEITHER ARTICLE I, SECTION 24 NOR THE SECOND AMENDMENT OFFER ANY PROTECTION TO AGAINST ESSB 5078'S RESTRICTION ON LCMS." SLIP OP. AT 16. GATOR'S CUSTOM GUNS FILED A PETITION FOR A WRIT OF CERTIORARI IN THE U.S. SUPREME COURT ON AUGUST 6, 2025, DOCKETED AS NO. 25-153. WE HAVE NOT FILED AN AMICUS BRIEF IN THE U.S. SUPREME COURT AT THIS TIME. THE CASE WAS DISTRIBUTED FOR CONFERENCE OF JANUARY 23, 2026. LOOKING TO THE FUTURE: THE FUND CONTINUES TO MONITOR DEVELOPMENTS IN THE AREAS OF FIRST AMENDMENT, SECOND AMENDMENT, FOURTEENTH AMENDMENT, SEPARATION OF POWERS, CAMPAIGN FINANCE AND REGULATION, AND OTHER CONSTITUTIONAL ISSUES WITH A VIEW TOWARD PARTICIPATING IN OR SUPPORTING ADDITIONAL LITIGATION WHEN THE OPPORTUNITY ARISES. THE ORGANIZATION DID NOT, DURING THE YEAR, RECEIVE ANY FUNDS, DIRECTLY,OR INDIRECTLY, TO PAY PREMIUMS ON A PERSONAL BENEFIT CONTRACT.THE ORGANIZATION, DID NOT, DURING THE YEAR, PAY ANY PREMIUMS, DIRECTLY,OR INDIRECTLY, ON A PERSONAL BENEFIT CONTRACT.