IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
SOUTHERN DIVISION
ACLU STUDENT CHAPTER -
UNIVERSITY OF MARYLAND,
COLLEGE PARR 1
3 120L South Campus Dining Hall
University of Maryland i
College Park, MD 20742
;
and
1
DANIEL M. SINCLAIR,
4230 Knox Road, Apt. 1322 t
South Campus Commons >
College Park, Maryland 20740
;
and
;
REBECCA J. SHEPPARD,
9165 Bourbon Street, Apt. B 1
Laurel, Maryland 20723
i
Plaintiffs,
i
V. > Civil Action No.
1
C.D. MOTE, JR., 1
President, University of Maryland, College Park )
College Park, Maryland 20742
;
Defendant. >
COMPLAINT
Plaintiffs ACLU Student Chapter - University of Maryland, College Park ("ACLU-
UMCP"), Daniel M. Sinclair, and Rebecca J. Sheppard, by their attorneys, for their
against defendant C.D. Mote, Jr. in his capacity as President of University of Maryland,
Park ("UMCP") and in his individual capacity, state as follows:
SNIPPETS:
ACLU STUDENT CHAPTER -UNIVERSITY OF MARYLAND,
120L South Campus Dining Hall
DANIEL M. SINCLAIR,
College Park, Maryland 20740
REBECCA J. SHEPPARD,
Plaintiffs ACLU Student Chapter - University of Maryland, College Park, Daniel M. Sinclair,
the Washington and Baltimore metropolitan areas, and in contrast to universities that UMCP
considers its peers, UMCP prohibits students, faculty, staff, and visitors from engaging in
speaking or distribution of literature in any public place on its sprawling campus,
on free speech activities despite the well-settled rule that a state university campus is a
As the Supreme Court has held, "the precedents of this Court leave
no room for the view that, because of the acknowledged need for order, First Amendment
protections should apply with less force on college campuses than in the community at large."
UMCP's policy and practices also give University officials unfettered discretion to
ACLU-UMCP is a registered student organization at UMCP.
other than those permitted under UMCP regulations.
UMCP policies and practices restrict the ability of ACLU-UMCP to engage in public speaking
viewpoints in which he is interested.
from engaging in free speech activities in public spaces on campus where, and at the times
The mission of UMCP is to be "the State's flagship campus with programs and faculty nationally
34,000 students and almost 12,000 faculty and staff.
UMCP imposes a number of burdensome requirements on student organizations
First Amendment to the United States Constitution because they are not content-neutral,
UMCP's regulations are not narrowly tailored to serve a significant government
officials who determine whether to grant registration to an organization or to grant a permit.
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