Plaintiffs challenge the federal government’s unwarranted and unlawful decision to designate a musical band’s supporters as a criminal gang, thereby subjecting
them to significant harm, including repeated police harassment and denial of employment. 2.
Among the supporters of almost any group
whether it be a band, sports team, university, political organization or religion
there will be some people who violate
the law. Inevitably, some will do so while sporting the group’s logos or symbols. However,
it is wrong to designate the entire group of supporters as a criminal gang based on the acts of a few. Unfortunately, that is exactly what happened here. 3.
identify as “Juggalos,” or fans of the musical group Insane Clown Posse (“ICP”) and other bands on ICP’s independent record label, Psychopathic Records. Some of ICP’s songs, such as “Juggalo Homies,” “Juggalo Island,” and “Miracles,”
have hopeful, life-affirming themes about the wonders of life and the support that Juggalos give to one anothe
r. Other music, called “horrorcore hip hop,” uses very harsh language to
tell nightmare-like stories with an underlying message that horrible things happen to people who choose evil over good. 4.
Many people view Juggalos as nonconformists because of their musical tastes, their practice of painting their faces to look like clowns, and the distinctive Juggalo symbols
including the “hatchetman” logo –
that they often display on their clothing, jewelry, body art and bumper stickers. Yet when Juggalos come together at concerts or their annual week-long gathering every summer, they know that they are in a community where all people are equal and where they will be accepted and respected for who they are. The unifying theme for Juggalos is that no matter what one
’s economic status, racial