Thomas v US, CA 87-1820

Section 4


Defendants argue that the complaint portrays plaintiffs as a group sharing a particular political perspective rather than a racial or ethnic trait such as typically identifies a "class" for the purpose of § 1985(3). Times' Motion to Dismiss at 17. Defendants maintain, further, that the complaint characterizes their actions as arising out of political differences with plaintiffs rather than as being motivated by invidious, class-based animus. Section 1985(3) does not reach conspiracies motivated by economic or commercial animus. Nor has it been extended to reach conspiracies motivated by political animus. United

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Brotherhood of Carpenters and Joiners of America, Local 610 v. Scott, 463 U,S. 825, 836-39 (1983), Defendants contend that plaintiffs have failed to bring their § 1985(3) conspiracy claim within that statutes limited scope. Plaintiffs urge, in opposition, that although much of the complaint charges defendants with "animus to squelch [plaintiffs'] free expression," Plaintiffs' Opposition at 10, it also contains "ample" allegations that "at least some defendants have also been motivated by religious animus." Id. Plaintiffs invoke Ward v. Connox, 657 F.2d 45, 47-48 (4th Cir. 1981), cert. denied sub nom, Mandelkorn v, Ward, 455 U.S. 907 (1982), in which injured members of the Unification Church were permitted to sue under the civil rights conspiracy provision because "religious discriminatfon, being akin to invidious racial bias, falls within the ambit of § 1985(c) [sic]." Id. at 48; see also Hobson v. Wilson, 737 F.2d at 21 (citing cases in other circuits that extend § 1985(3) to protect political and religious classes). Plaintiffs, as a group, thus appear to rely most heavily on a characterization of themselves as a religious rather than a political "class" -- and, accordingly, on a characterization of the alleged torts against them as being rmotivated by religious rather than political animus -- for the purpose of their § 1985(3) claims.

The question of whetber plaintiffs constitute a

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religious class remains undecided in this Circuit. Indeed, in dismissing five criminal informations, several of which involved individual plaintfffs in the present action and arose out of the same expressive activities at issue here, the district court assumed that appellees' anti-nuclear vigil in Lafayette Park was the product of sincerely held religious beliefs. United States v. Galindez, Cr. No. 87-60, slip op. (D.D.C, Apr. 23, 1987), rev'd bnd remanded on other arounds, Nos. 87-0060, 87-0061, 87-0062, 87-0063, & 87-0064 (D.C. Cir. Sept. 22, 1987).

Nonetheless, even assuming that plaintiffs have successfully identified themselves as a religiaus group, it does not follow that the complaint alleges, with sufficient specificity, that any of the defendants have be~n motivated by "invidiously discriminatory animus" against plaintiffs based an that reliqious identification. Hobson v. Wilson has established that,

in cases involving a claim that defendants acted with an unconstitutional motive, we will require that nonconclusory allegations of evidence of such intent must be present in a complaint

Hobson v. Wilson, 737 F,2d at 29. Plaintiffs' failure to satisfy this criterion extends as well to their claim that the Times conspired with members of the YAF to plan and execute a "raid" on plaintiffs in Lafayette Park with the intent violently to interfere with plaintiffs' exerrcise of their First Amendment rights, The camplaint does not allege,

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with sufficient specificfty, that the Times defendants acted in concert with the YAF out of racial or religious bias or out of any invidious, class-based animus recognized under § 1985(3).

A review of thase paragraphs of the complaint relied an by plaintiffs to support their allegation that defendants acted with actionable animus, see Plaintiffs' Opposition at 10, reveals that the complaint fails to satisfy the Hobson specificity criteria with respect to that element of a § 1985(3) conspiracy claim.

Paragraph 21, for instance, states that plaintiffs perceive the purportedly "false and defamatory misrepresentations" of defendants as a menace to "their freedoms of belief and expression." Complaint at ¶ 21, Yet, although they imply that their religious beliefs would suffer the threatened injury, plaintiffs describe defendants' alleged defamation as befng "invidiously animated by religious and/or political bias." (emphasis supplied). Similarly, ¶ 29 asserts that defendants "conspired to place administrative policy above the law" that, "in theory," prohibits the use of "police power . . . to stifle religious exercise or mute political dissent." Id. at para. 29 (emphasis supplied). Paragraph 78, in turn, identifies an injury to plaintiffs' "religious practice" but fails even to mention any possible religious anirmus in defendants that might have motivated or contributed to the Injury alleged, Id, at ¶ 78.

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Again, in paragraph 79, plaintiffs claim injury to their "religious practice" but imply that one defendant's motivation may be inferred irom his "supervisory respons ability for a smear campaign against those opposed to Reverend Moon's suicidal economic interests." Id. at ¶ 79 (emphasis supplied). Paragraph 89 does expressly allege that defendants were motivated by religious animus; however, that same paragraph charges also that they were motivated by "personal prejudice ... or cultural animus." Plaintiffs fail to specify any evidence that would support any of these allegations. Id. at ¶ 89. Paragraph 90 alleges only that "[d]efendants opposed plaintiffs' message in their official (political) capacities, and/or in their personal (religious, social) capacities." Id. at ¶ 90, Paragraph 91 makes no mention of defendants' motivation at all. It alleges merely that they disagree with plaintiffs on religious issues. Id. at ¶ 91. Finally, paragraph 93, while alleging that defendants acted "with willful, malicious, and reckless disregard to disrupt the practice of plaintiffs' chosen profesion and religion," does not allege that any such action was motivated by invidious animus based on plaintiffs' membership in a particular religious class, at ¶ 93; see Martin v. Malhoyt, 830 F.2d at 258. Even if the complaint were construed to allege conspfracy motivated by invidious, class-based animus, the claims under §§ 1983 and 1985(3) could not withstand the

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Times defendants' motion to dismiss. It is well established that a plaintiff suing under these statutes must allege and prove four basic elements: 1) a conspiracy; 2) for the purpase of depriving, either directly or indirectly, any person or class of persons of the equal protection of the laws; and 3) an act in furtherance of the conspiracy; 4) whereby a person is either injured in his or her person or property or deprived of any right or privilege of a United States citiien. Martin v. Malhoyt, 830 F.2d at t58, quoting Hobson v. Wilson, 737 F.2d at 14.

Plaintiffs contend that the complaint alleges, with sufficient specificity, each element of a § 1985(3) conspiracy claim. See Plaintiff's Opposition at 8-10, To satisfy the "purpose" prong of the conspiracy test, plaintiffs rely on paragraph 20 of the complaint, which alleges that the "intention of the conspiracy" was to utilize, inter alia, the various Lafayette Park regulations, "disinformation," and "public defamation of character" to encourage public support for the regulations that purportedly infringed plaintiffs' First Amendment rights, as vell as to "aggrandize [defendants'] political opposition" to plaintiffs' twenty-four hour vigil, Id. at 9. Plaintiffs cite Exhibits 12 and 13 , appended to the complaint, of containing "references to specific material facts" supporting an inference of an intent among defendants

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to conspire against plaintiffs. Id. [5] Both exhibits are copies of editorials critical of plaintiffs that were published by The Washinston Times and discussed extensively above, Plaintiffs infer from the editorials that "for years these defendants have been opposed to plaintiffs' high- profile, 24-hour, year-around, anti-nuclear vigil[.]" Id. Yet, while plaintiffs, by means of these exhibits, describe a specific attitude that defendants may have held towards plaintiffs' expressive activity, plaintiffs fail to allege sufficiently particular facts that would support an inference that such an attitude ever ripened into an intent to conspire


[5 It is noteworthy that plaintiffs do not elaborate or support their passing allegation that the Times' purported role in the "raid" evidences the newspaper' s intent with respect to the alleged conspiracy with the federal defendants. 6ee Complaint at ¶¶ 58-61. Plaintiffs suggest that a reasonable jury cauld infer that defendant Masty and a photographer "were on the scene by concerted pre-arrangement as journalistic tools of a propagandistic conspiracy intended to alienate plaintiffs and their ideas from the public, as well as to deprive them of constitutionally protected rights under color of regulation Plaintiffs' Opposition at 2. Yet the complaint itself asserts that the Times participated in the raid "for the agreed upon purpose of striking fear into the hearts: of plaintiffs so that plaintiffs might abandon their expressly-permitted and lawfully-conducted activity in Lafayette Park." Complaint at ¶ 58. Horeover, the complaint claims that the Times engineered the raid "in pursuit of said 'good' copy for its 'patriotic' 4th of July editions [sic]," and that the newspaper then published an account that "defamatorily portrayed [plaintiffs] as 'weirdos' and 'screwballs.'" Complaint at ¶ 61. The complaint, therefore, links the Times' alleged participation in the raid to plaintiffs' defamation and assault claims, but omits any specific, factually supported allegation that the newspaper participated in the raid with the intent to deprive plaintiffs of their First Amendment rights through the alleged conspiracy with the federal defendants.]

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with federal officials illegally to infringe plaintiffs' constitutional rights in violation of federal civil rights laws.


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