I. LEAVE TO FILE AN AMICUS IS APPROPRIATE
This Honorable Court has allowed
“provide[s] helpful analysis of the law, ... they have a special interest in the subject matter of the suit, ... or existing counsel is in need of assistance.”
Bryant v. Better Bus. Bureau of Greater Maryland
, 923 F.Supp. 720, 728 (D. Md., 1996). Although only one factor is necessary to justify granting of such leave, all three factors are present here.
A. Mr. Walker Has a Special Interest in the Subject Matter of the Suit
Mr. Walker is a Yale-Law-School-educated attorney who has a deep commitment to freedom of expression and freedom of religion. This is a commitment to something greater than just the First Amendment because, even as incorporated through the Fourteenth Amendment, the First Amendment still only limits
action. It provides no protection against private violence or private threats of violence designed to silence others or to coerce their religious expression. As an attorney, Mr. Walker has helped many persons whose freedom of expression was threatened through abusive lawsuits and threats of such suits. As a citizen, he has helped in protests designed to protect freedom of speech in practical ways.
For instance, Mr. Walker was one of many organizers of the Everyone Draw Mohammed Day protest in 2010. This protest grew up in light of the increasing problem of Islamofascist terrorists threatening to murder any person who was deemed to have blasphemed Mohammed, a central figure in the Islamic faith. According to these terrorists, any depiction of Mohammed, however benign, was blasphemous and they specifically threatened to murder the creators of the TV show
for their inoffensive depiction of Mohammed. Accordingly the participants in the Everyone Draw Mohammed Day protest decided to commit the same “offense” as the creators of
by making their own drawings of Mohammed—some objectively offensive and some not—and thus make it, as a practical matter, impossible to carry through on their threat to kill every person who depicted Mohammed. Mr. Walker proudly participated in this protest and served as a minor organizer in it. In order to better understand