2596 South Lewis Way | Lakewood, CO 80227 | Tel: 303.292.2021 May 1, 2024 Ms. Ina Bryant Interim Chief Campus Counsel, UCLA Office of the Campus Counsel University of California Los Angeles Box 951405 Los Angeles, CA 90095-1405 ibryant@conet.ucla.edu Re:
Notice of Constitutional Duties and Potential Personal Liability
Ms. Bryant, We are attorneys at Mountain States Legal Foundation, a non-profit law firm that protects and defends the United States Constitution. Our mission is to secure the rights of Americans to live freely throughout the country, by litigating the cause for freedom. We have been contacted by Young Americans for Freedom (“YAF”), a chapter affiliate of Young America’s Foundation. YAF is a registered student organization at UCLA (the “University”), and entitled to host events on campus; yet the University has failed to approve and facilitate YAF’s planned May 15, 2024 on-campus event featuring speaker Robert Spencer. Given that the event is only two weeks away, and that the window for adequate pre-event publicity is rapidly closing, we ask that you instruct the University’s staff to issue an immediate approval for the talk to go forward. We further ask that you respond to this letter by May 3, 2024, confirming (1) that the University will comply with its obligations to avoid viewpoint discrimination under the First Amendment; (2) that the University will not enable an illegal “heckler’s veto” by leftwing activists who may react violently to YAF’s presentation; and (3) that the University understands its officials are personally liable for their ongoing unconstitutional conduct. Analysis On April 16, 2024—a month prior to the planned date—YAF informed University officials that it would host Mr. Spencer’s presentation. YAF has submitted all necessary applications and forms, and has provided all information
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