Partnership for Civil Justice
Information Center

If you have come here in search of the Partnership for Civil Justice's Consumer Resource Center, that web site has been temporarily removed and will return shortly. We apologize for any inconvenience.

This web page has been posted in response to the many requests for information relating to our recent litigation protecting the right to free speech. We anticipate that during the summer, our regular web site will return, updated to enable easy access to the information that has been most requested of us.

Complaint Filed in International Action Center v. United States of America

Complaint -- International Action Center, et al. v. United States of America, et al. 
(Lawsuit filed against the Government and the Presidential Inaugural Committee for violations of protesters' Constitutional rights at the January, 2001 Bush Inauguration)

Amended Complaint Filed in Fifty Years is Enough v. District of Columbia

Amended Complaint -- Fifty Years is Enough, et al. v. District of Columbia, et al. 
(Lawsuit filed against the Government for violations of protesters' Constitutional rights at the April, 2000 meetings of the IMF and World Bank)


Guide to Effective Participation in the 2001 Inauguration (Wordperfect format -- save to disk and open in word processor)

  Supplement to the Guide -- IMPORTANT UPDATES

Exercising Your Rights of Political Protest - A National Lawyers Guild Manual

*** Click here to be taken to the 2001 Inauguration Law Enforcement Misconduct Reporting Site. ***

Law Suit Filed Against Government

Press Release Issued by National Lawyers Guild [PDF]

On January 16, 2001, the Partnership for Civil Justice and the National Lawyers Guild filed a complaint seeking, among other things, an injunction against the federal and D.C. law enforcement agencies. The complaint asserts that the unprecedented system of checkpoints and screens, as proposed, is unconstitutionally vague and impermissible, that it provides law enforcement the unfettered discretion to single out demonstrators and interfere with their access to Pennsylvania Avenue. It also alleges that it is impermissably vague for law enforcement to refuse to disclose in advance what items will be deemed illegal to possess at the Inauguration, including expressive papier mache puppets.

The complaint also alleges that the International Action Center is entitled to full access to their permitted demonstration area at Freedom Plaza, and should not be relegated to a tiny portion of the Plaza that is presently occupied by a large fountain. In addition, certain federal and local regulatory provisions are challenged as unconstitutional.

The relevant documents follow below (note: large PDF documents may take a few minutes to download):






Motion for Preliminary Injunction




Points and Authorities In Support of Motion for Preliminary Injunction





Attachment 1 (1/4/01 ltr to law enforcement requesting details about plans) PDF
Attachment 2 (1/9/01 ltr from National Park Service) PDF
Attachment 3 (1/11/01 ltr to National Park Service) PDF
Attachment 4 (1/12/01 ltr from National Park Service) PDF
Attachment 5 (1/12/01 ltr from Secret Service) PDF
Attachment 6 (1/12/01 ltr from Metropolitan Police Dept.) PDF
Attachment 7 (affidavit of Brian Becker) PDF
Attachment 8 (affidavit of Adam Eidinger) PDF
Attachment 9 (affidavit of Daniel Holstein) PDF
Attachment 10 (affidavit of Elizabeth Butler) PDF
Attachment 11 (affidavit of Lawrence Holmes) PDF
Attachment 12 (application of IAC for Freedom Plaza) PDF
Attachment 13 (application of National Park Service) PDF

Signs and Banners Allowed Along Parade Route

The U.S. Secret Service and the National Park Service have acknowledged that signs and placards may be displayed along the parade route, and have imposed the following restrictions:

Signs and placards (and banners) must be:

  1. made of cardboard, posterboard or cloth
  2. less than 1/4" (one quarter inch) thick
  3. no more than three feet in width and twenty feet in length

Poles supporting signs must be:

  1. made of wood
  2. no more than 3/4" (three quarters of an inch) by 3/4"

The federal authorities have banned, along the parade route, props, including coffins, statues, platforms, among other items.

January 12, 2002 letter from Secret Service

poster announcing signage restrictions -- suitable for posting

Web Site For Reporting Law Enforcement Misconduct

We hope that there is no need for anyone to report misconduct by law enforcement during the presidential Inauguration 2001. However, if prior practice is repeated, there will be violations of the law by law enforcement.

The Partnership for Civil Justice has created what it believes to be the very first Internet based police misconduct reporting system, which can be set up and customized in advance of police actions, such as those related to the 2001 Inauguration. Other public interest organizations interested in using this system for local demonstrations are welcome to contact the Partnership for Civil Justice who will make this model freely available for replication. Click here to be taken to the 2001 Inauguration Law Enforcement Misconduct Reporting Site.

For those persons who have not completed our Internet based misconduct reporting form for misconduct and unconstitutional conduct by law enforcement at the April, 2000 IMF - World Bank Annual Meeting in Washington, D.C., please do so. Click here to be taken to the A16 IMF - World Bank Law Enforcement Misconduct Reporting Site.

Note: it sometimes takes more than one attempt to connect with these sites, due to their high demand and the need to establish a secure connection.

Permits Secured for Demonstrators Within the Free Speech Zone of Pennsylvania Avenue

Individuals and Groups From Across the Country Coming to Washington, D.C. to Demonstrate at the 2001 Inauguration

Public pressure and the threat of legal action have caused the National Park Service to reverse their original position, and to acknowledge the permits of demonstration groups. Our client, the International Action Center has secured a permit at Freedom Plaza, 14th Street and Pennsylvania Avenue, as well as at other locations, and welcomes you to join them at the Plaza.

No permit, however, is required for individuals and groups of up to 25 persons to come to the Inauguration and protest.

You are invited and welcome to stand shoulder to shoulder with thousands of individuals, families and groups that will converge upon the nation's capitol to participate in this important moment in our democratic process.

The Partnership for Civil Justice, along with other civil rights attorneys, stand by to protect the rights of Americans to peaceably assemble along Pennsylvania Avenue, the Avenue of the People.

Police and Secret Service To Use Checkpoints To Restrict Access to Pennsylvania Avenue

Unfettered Discretion of Law Enforcement Threatens Access to Parade Route to Political Dissenters

Law enforcement will be establishing an Exclusion Perimeter that prevents access to the Inaugural Route unless persons pass through only a very few number of possible entry and checkpoints.

According to the MPD, six entry points will be established to the ticketed White House reviewing area (which encompasses only 3 blocks). Every single avenue of access will be open for these favored ticket holders.

For the rest of the public, (which MPD estimates could number in excess of 700,000) including the demonstrators, there will be a total of only ten bottleneck entry points for the entirety of the Parade Route. Streets normally available for access to Pennsylvania Avenue will be closed as part of the Exclusion Perimeter.

The following access points will be closed, for those approaching Pennsylvania Avenue from the North: F Street,12th Street, 10th Street, 9th Street, 6th Street and 4th Street.

The following access points will be closed, for those approaching Pennsylvania Avenue from the South: 14th Street, 10th Street, and 9th Street.

Metro stations at the Smithsonian and the National Archives will be closed.

It remains unanswered:

What prevents unfettered discretion of law enforcement from being exercised to single out persons on the basis of personal appearance or political affiliation?