Professional Documents
Culture Documents
Knight Institute v. Trump
Knight Institute v. Trump
Plaintiffs,
v.
Defendants.
Introduction
source of news and information about the government, and an important public forum for speech
by, to, and about the President. In an effort to suppress dissent in this forum, Defendants have
excludedblockedTwitter users who have criticized the President or his policies. This
2. As the Supreme Court recognized just a few weeks ago, social media platforms
like Facebook and Twitter provide perhaps the most powerful mechanisms available to a private
citizen to make his or her voice heard. Packingham v. North Carolina, slip op. at 8, 582 U.S.
____ (2017). These platforms have been revolution[ary], not least because they have
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directly with their constituents. Governors in all 50 States and almost every Member of
Congress have set up [Twitter] accounts for this purpose, id. at 5, allowing citizens to petition
their elected representatives and otherwise engage with them in a direct manner, id. at 8. Twitter
enables ordinary citizens to speak directly to public officials and to listen to and debate others
about public issues, in much the same way they could if they were gathered on a sidewalk or in a
3. Because of the way the President and his aides use the @realDonaldTrump
Twitter account, the account is a public forum under the First Amendment. Defendants have
made the account accessible to all, taking advantage of Twitters interactive platform to directly
engage the Presidents 33 million followers. The Presidents tweets routinely generate tens of
thousands of comments in the vibrant discussion forums associated with each of the Presidents
tweets. Further, Defendants have promoted the Presidents Twitter account as a key channel for
official communication. Defendants use the account to make formal announcements, defend the
Presidents official actions, report on meetings with foreign leaders, and promote the
administrations positions on health care, immigration, foreign affairs, and other matters. The
Presidents advisors have stated that tweets from @realDonaldTrump are official statements,
and they have been treated as such by politicians, world leaders, the National Archive and
4. Plaintiffs include individuals from across the country who have been blocked
from the @realDonaldTrump account because of opinions they expressed in replies to the
Presidents tweets. Because of their criticism of the President, these Plaintiffs have been
prevented or impeded from viewing the Presidents tweets, from replying to the tweets, from
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viewing the discussions associated with the tweets, and from participating in those discussions.
Defendants actions violate the First Amendment rights of these individual Plaintiffs as well as
those of other Twitter users, like Plaintiff Knight First Amendment Institute, that follow the
@realDonaldTrump account and are now deprived of their right to read the speech of the
5. Plaintiffs respectfully ask that the Court declare that the viewpoint-based
exclusion of the individual Plaintiffs violates the First Amendment, and order the Defendants to
6. This Court has jurisdiction over this action pursuant to 28 U.S.C. 1331 and 28
U.S.C. 22012202.
substantial part of the events giving rise to this claim occurred in this District, and each
Parties
Institute) is a section 501(c)(3) organization based in New York, NY that works to defend and
strengthen the freedoms of speech and the press in the digital age through strategic litigation,
research, and public education. The Knight Institutes staff operates a Twitter account under the
handle @knightcolumbia.
political consultant. She operates a verified Twitter account under the handle @rpbp.
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10. Plaintiff Philip Cohen, who resides in Takoma Park, MD, is a professor of
sociology at the University of Maryland, College Park. He operates a verified Twitter account
11. Plaintiff Holly Figueroa, who resides in Mercer Island, WA, is a political
organizer and songwriter. She operates a verified Twitter account under the handle
@AynRandPaulRyan.
12. Plaintiff Eugene Gu, who resides in Nashville, TN, is a resident in general surgery
at Vanderbilt University Medical Center and the CEO of Ganogen Research Institute. He
13. Plaintiff Brandon Neely, who resides in Tomball, TX, is a police officer. He
14. Plaintiff Joseph Papp, who resides in Bethel Park, PA, is a former professional
road cyclist and current anti-doping advocate and author. He operates a verified Twitter account
15. Plaintiff Nicholas Pappas, who resides in New York City, is a comic and writer.
16. Defendant Donald Trump is President of the United States and is sued in his
official capacity only. President Trump operates and/or oversees the operation of a verified
Twitter account under the handle @realDonaldTrump. The President and/or his subordinates
have blocked all of the Plaintiffs except the Knight First Amendment Institute from this account.
17. Defendant Sean Spicer is the White House Press Secretary and Acting
Communications Director and is sued in his official capacity only. Mr. Spicer directs or
1For ease of reference, Plaintiffs other than the Knight Institute are referred to herein as the
Individual Plaintiffs, collectively.
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coordinates all White House communications. Upon information and belief, Mr. Spicer has the
18. Defendant Daniel Scavino is the White House Social Media Director and
Assistant to the President and is sued in his official capacity only. Mr. Scavino posts messages on
behalf of President Trump to @realDonaldTrump and other social media accounts, including
@POTUS and @WhiteHouse. Upon information and belief, Mr. Scavino has the ability to block
Factual Allegations
A. Twitter
19. Twitter is a social media platform with more than 300 million active users
worldwide, including some 70 million in the United States. The platform allows users to publish
short messages, to republish or respond to others messages, and to interact with other Twitter
users in relation to those messages. Speech posted on Twitter ranges from personal insult to
poetry, but particularly relevant here is that a significant amount of speech posted on the platform
20. Users. A Twitter user is an individual who has created an account on the
platform. A user can post tweets, up to 140 characters in length, to a webpage on Twitter that is
attached to the users account. Tweets can include photographs, videos, and links. Some Twitter
users do not tweeti.e., publish messagesat all. Others publish hundreds of messages a day.
21. Timelines. A Twitter users webpage displays all tweets generated by the user,
with the most recent tweets appearing at the top of the page. This display is known as a users
timeline. When a user generates a tweet, the timeline updates immediately to include that
tweet. Anyone who can view a users public Twitter webpage can see the users timeline. Below
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22. A Twitter user must have an account name, which is an @ symbol followed by a
unique identifier (e.g., @realDonaldTrump), and a descriptive name (e.g., Donald J. Trump). The
account name is called the users handle. Alongside the handle, a users webpage will display
the date the user joined Twitter and a button that invites others to Tweet to the user. (This
button is visible only to other Twitter users.) A users Twitter webpage may also include a short
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biographical description; a profile picture, such as a headshot; a header image, which appears
as a banner at the top of the webpage; the users location; a button labeled Message, which
allows two users to correspond privately; and a small sample of photographs and videos posted
to the users timeline, which link to a full gallery. Thus, part of the webpage for
23. Tweets. An individual tweet comprises the tweeted content (i.e., the message,
including any embedded photograph, video, or link), the users account name (with a link to the
users Twitter webpage), the users profile picture, the date and time the tweet was generated,
and the number of times the tweet has been replied to ( ), retweeted by ( ), or liked by ( )
other users. Thus, a recent tweet from @realDonaldTrump looks like this:
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24. By default, Twitter webpages and their associated timelines are visible to
everyone with internet access, including those who are not Twitter users. However, although
non-users can view users Twitter webpages, they cannot interact with users on the Twitter
platform.
25. Following. Twitter users can subscribe to other users messages by following
those users accounts. Users see all tweets posted or retweeted by accounts they have followed.
This display is labeled Home on Twitters site, but it is often referred to as a users feed.
26. Verification. Twitter permits users to establish accounts under their real names or
pseudonyms. Users who want to establish that they are who they claim to be can ask Twitter to
verify their accounts. When an account is verified, a blue badge with a checkmark appears next
to the users name on his or her Twitter page and on each tweet the user posts.
27. Retweeting. Beyond publishing tweets to their followers, Twitter users can engage
with one another in a variety of ways. For example, they can retweeti.e., republishthe
tweets of other users, either by publishing them directly to their own followers or by quoting
them in their own tweets. When a user retweets a tweet, it appears on the users timeline in the
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same form as it did on the original users timeline, but with a notation indicating that the post
28. Replying. A Twitter user can also reply to other users tweets. Like any other
tweet, a reply can be up to 140 characters in length and can include photographs, videos, and
links. When a user replies to a tweet, the reply appears on the users timeline under a tab labeled
Tweets & replies. The reply will also appear on the original users feed in a comment thread
under the tweet that prompted the reply. Other users replies to the same tweet will appear in the
same comment thread. Reply tweets by verified users, reply tweets by users with a large number
of followers, and tweets that are favorited and retweeted by large numbers of users generally
29. Comment threads. A Twitter user can also reply to other replies. A user whose
tweet generates replies will see the replies below his or her original tweet, with any replies-to-
replies nested below the replies to which they respond. The collection of replies and replies-to-
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platform in large part because of comment threads, which reflect multiple overlapping
conversations among and across groups of users. Below is a recent @realDonaldTrump tweet
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30. Favoriting. A Twitter user can also favorite or like another users tweet by
clicking on the heart icon that appears under the tweet. By liking a tweet, a user may mean to
31. Mentioning. A Twitter user can also mention another user by including the other
users Twitter handle in a tweet. A Twitter user mentioned by another user will receive a
32. Tweets, retweets, replies, likes, and mentions are controlled by the user who
generates them. No other Twitter user can alter the content of any retweet or reply, either before
or after it is posted. Twitter users cannot prescreen tweets, replies, likes, or mentions that
33. Protected tweets. Because all Twitter webpages are by default visible to all
Twitter users and to anyone with access to the internet, users who wish to limit who can see and
interact with their tweets must affirmatively protect their tweets. Other users who wish to view
protected tweets must request access from the user who has protected her tweets. Protected
tweets do not appear in third-party search engines, and they are searchable only on Twitter, and
34. Blocking. A user whose account is public (i.e. not protected) but who wants to
make his or her tweets invisible to another user can do so by blocking that user. (Twitter
provides users with the capability to block other users, but, importantly, it is the users themselves
who decide whether to make use of this capability.) A user who blocks another user prevents the
blocked user from interacting with the first users account on the Twitter platform. A blocked
user cannot see or reply to the blocking users tweets, view the blocking users list of followers
or followed accounts, or use the Twitter platform to search for the blocking users tweets. The
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blocking user will not be notified if the blocked user mentions her; nor will the blocking user see
35. If the blocked user attempts to follow the blocking user, or to access the Twitter
webpage from which the user is blocked, the user will see a message indicating that the other
user has blocked him or her from following the account and viewing the tweets associated with
the account. This is an example of a notification from Twitter that a user has been blocked:
36. Donald Trump established @realDonaldTrump in May 2009 and used the account
for several years to engage with his followers about politics, celebrities, golf, and his business
interests, among other topics. After his inauguration in January 2017, he began to use the account
as an instrument of his presidency, and today he and his aides use it almost exclusively as a
channel for communicating with the public about his administration. Because of the way he uses
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the account, President Trumps tweets have become an important source of news and information
about the government, and the comment threads associated with the tweets have become
important forums for speech by, to, and about the President.
37. President Trump presents the account to the public as one that he operates in his
official capacity rather than his personal one. The Twitter page associated with the account is
registered to Donald J. Trump, 45th President of the United States of America, Washington,
D.C. The account bears a blue badge indicating that it has been verified by Twitter. On July 7,
2017, the header photograph showed an American flag. Over the past few weeks, the header
photograph has shown images of President Trump performing his official duties, such as making
a speech to the Department of Energy, flanked by Vice President Mike Pence and Secretary of
38. The @realDonaldTrump account is accessible to the public at large without regard
to political affiliation or any other limiting criteria. President Trump has not protected his
tweets, and anyone who wants to follow the account can do so. He has not issued any rule or
statement purporting to limit (by form or subject matter) the speech of those who reply to his
tweets. The account has 33 million followers14 million more than @POTUS and 19 million
more than @WhiteHouse. The only users who cannot follow @realDonaldTrump are those
39. President Trump and his aides have made clear that they consider statements
President Trump tweeted from @realDonaldTrump, My use of social media is not Presidential
its MODERN DAY PRESIDENTIAL. A month earlier, White House Press Secretary Sean
Spicer stated at a press conference that tweets from President Trump should be understood as
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official statements by the President of the United States. On June 23, 2017, the White House
responded to a request from the House Permanent Select Committee on Intelligence for official
White House records by referring the Committee to the Presidents statement made on Twitter
on June 22, 2017. The White House social media director, Dan Scavino, promotes
President Donald J. Trump . . . communicat[es] directly with you, the American people! The
@WhiteHouse accounts description directs Twitter users to Follow for the latest from
@POTUS @realDonaldTrump and his Administration. Further, tweets from @POTUS are
retweeted by @POTUS.
40. With the assistance of his aides, President Trump uses @realDonaldTrump, often
multiple times a day, to announce, describe, and defend his policies; to promote his
political leaders; to publicize state visits; and to challenge media organizations whose coverage
of his Administration he believes to be unfair. President Trump sometimes uses the account to
announce official decisions and policies before those decisions and policies are announced
through other official channels. For example, the President used @realDonaldTrump to announce
on June 7, 2017, for the first time, that he intended to nominate Christopher Wray for the position
of FBI director. Likewise, on June 22, 2017, he used @realDonaldTrump to acknowledge for the
first time that he did not possess tapes of conversations with former FBI Director James Comey.
41. White House aides assist President Trump in operating the @realDonaldTrump
account, including by drafting and posting tweets to the account. According to news reports,
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President Trump also sometimes dictates tweets to White House Director of Social Media Dan
42. Federal agencies and the federal courts treat President Trumps statements on
has advised the White House that the Presidents tweets from @realDonaldTrump, like those
from @POTUS, are official records that must be preserved under the Presidential Records Act.
The Ninth Circuit cited one of the Presidents tweets in striking down Executive Order 13,780,
the order that temporarily suspends nationals of certain countries from entering the United States.
Hawaii v. Trump, 859 F.3d 741, 773 n.14 (9th Cir. 2017), cert. granted sub nom. Trump v. Intl
Refugee Assistance Project, No. 16-1436, 2017 WL 2722580 (U.S. June 26, 2017). In citing the
tweet, the Ninth Circuit observed that the White House Press Secretary had indicated that the
tweets about London Mayor Sadiq Khan and the June 4, 2017 London Bridge terrorist attack
ultimately resulted in the indefinite deferral of President Trumps planned state visit to Great
relations with Qatar, a longstanding ally of the United States, prompted a public response from
the Qatari Foreign Minister. A series of tweets from @realDonaldTrump insisting that Mexico
should pay for a wall along the U.S.Mexico border caused the Mexican President Enrique Pea
Nieto to cancel a previously planned meeting with President Trump shortly after his
inauguration.
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44. Because of the way in which President Trump uses @realDonaldTrump, the
account has become an important channel for news about the presidency and the U.S.
government. Those who are blocked from the account are impeded in their ability to learn
45. The comment threads associated with tweets from @realDonaldTrump are
important forums for discussion and debate about the President, the Presidents decisions, and
account is a kind of digital town hall in which the President and his aides use the tweet function
to communicate news and information to the public, and members of the public use the reply
function to respond to the President and his aides and exchange views with one another..
46. The Individual Plaintiffs are Twitter users who have been blocked by one or more
of the Defendants from the @realDonaldTrump account because they criticized the President or
his policies. Defendants blocking of the Individual Plaintiffs from the @realDonaldTrump
account prevents or impedes the Individual Plaintiffs from viewing the Presidents tweets; from
replying to these tweets; from viewing the comment threads associated with these tweets; and
imposes an unconstitutional restriction on their right to access statements that Defendants are
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otherwise making available to the public at large. It also imposes an unconstitutional restriction
Rebecca Buckwalter
48. Plaintiff Rebecca Buckwalter is a writer and legal analyst. Her writing on politics
and law has been published by, among other outlets, the Democracy Journal, CNN, NPR, The
Atlantic, and Politico. Ms. Buckwalter operates a verified Twitter account, @rpbp, which has
Before she was blocked, she monitored President Trumps tweets closely. She often responded to
tweets from @realDonaldTrump, and she was an active participant in the comment threads. She
would post links to her own writing when she believed pieces she had written were relevant to
the topics being discussed. Some of her tweets directed at the @realDonaldTrump account
50. One or more of the Defendants blocked Ms. Buckwalter from the
@realDonaldTrump account on June 6, 2017. At 8:15 that morning, President Trump tweeted,
Sorry folks, but if I would have relied on the Fake News of CNN, NBC, ABC, CBS washpost or
nytimes, I would have had ZERO chance winning WH. Ms. Buckwalter replied, To be fair you
didnt win the WH: Russia won it for you. Ms. Buckwalters reply tweet received 9,033 likes
and 3,371 retweets. Soon thereafter, Ms. Buckwalter discovered she had been blocked from the
@realDonaldTrump account.
prevents or impedes her from viewing the Presidents tweets; from replying to these tweets; from
viewing the comment threads associated with these tweets; and from participating in the
comment threads.
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Philip Cohen
College Park. He holds a PhD in Sociology from the University of Maryland and was formerly a
Professor of Sociology at the University of North Carolina, Chapel Hill. He published a book in
2014 entitled The Family: Diversity, Inequality and Social Change. Professor Cohen operates a
announced his campaign for the presidency. Before he was blocked, Professor Cohen often
responded to tweets from @realDonaldTrump, and he was an active participant in the comment
threads.
54. One or more of the Defendants blocked Professor Cohen from the
@realDonaldTrump account on June 6, 2017. At 8:44 that evening, President Trump tweeted,
#ICYMI [In Case You Missed It] Announcement of Air Traffic Control Initiative Watch with
a link to an announcement of his Air Traffic Control Initiative. Professor Cohen replied with a
tweet showing a photograph of the President with these words superimposed on the photograph:
Corrupt Incompetent Authoritarian. And then there are the policies. Resist. Professor Cohens
tweet received 307 likes and 35 retweets. About 15 minutes later, Professor Cohen discovered he
prevents or impedes him from viewing the Presidents tweets; from replying to these tweets;
from viewing the comment threads associated with these tweets; and from participating in the
comment threads.
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Holly Figueroa
56. Plaintiff Holly Figueroa is a national political organizer and songwriter who lives
57. Ms. Figueroa began following @realDonaldTrump soon after Donald Trump
became President. She programmed her phone to alert her whenever the President tweets, and
frequently responded to many of his tweets with critical remarks, caustic retorts, funny photos,
and memes. Her replies to @realDonaldTrump have earned her a significant following on
Twitter. Many of her tweets in reply to @realDonaldTrump receive thousands of likes and
retweets, and they often appear at or near the top of the @realDonaldTrump comment threads.
58. One or more of the Defendants blocked Ms. Figueroa from the
@realDonaldTrump account on May 28, 2017. That morning, addressing the previous weeks
terrorist attack in Manchester, England, President Trump tweeted: British Prime Minister May
was very angry that the info the U.K. gave to the U.S. about Manchester was leaked. Gave me
full details! Ms. Figueroa replied to the President in a series of tweets, including one that
contained an image of the Pope looking incredulously at President Trump, along with the
statement This is pretty much how the whole world sees you. #AMJoy #SundayMorning. Her
reply received 15,000 likes and 5,300 retweets. Later that evening, she discovered that she had
been blocked.
prevents or impedes her from viewing the Presidents tweets; from replying to these tweets; from
viewing the comment threads associated with these tweets; and from participating in the
comment threads. Ms. Figueroa uses a third-party application to read and respond to the
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Presidents tweets, but using the application is burdensome and the application is only partly
effective.
Eugene Gu
Medical Center and the CEO of Ganogen Research Institute. Dr. Gu operates a Twitter account,
replied to tweets from @realDonaldTrump with critical and sometimes satirical remarks. Some
of Dr. Gus replies to @realDonaldTrump received thousands of likes and appeared on Twitter
Moments, which are Twitter-created accounts of current events that incorporate popular tweets.
62. One or more of the Defendants blocked Dr. Gu from the @realDonaldTrump
account on June 18, 2017. At 4:02 AM that morning, President Trump tweeted: The new
Rasmussen Poll, one of the most accurate in the 2016 Election, just out with a Trump 50%
Approval Rating. Thats higher than Os #s! At 4:12 AM, Dr. Gu replied: Covfefe: The same
guy who doesnt proofread his Twitter handles the nuclear button. Dr. Gus tweet received 2,900
likes and 239 retweets. Dr. Gu discovered he had been blocked from the @realDonaldTrump
impedes him from viewing the Presidents tweets; from replying to these tweets; from viewing
the comment threads associated with these tweets; and from participating in the comment
threads.
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Brandon Neely
64. Plaintiff Brandon Neely is a police officer in Houston, Texas. He is a veteran who
served in Iraq in 2003 and worked as a guard at Guantanamo Bay in 2002. He operates a verified
65. Mr. Neely began following the @realDonaldTrump account soon after Donald
Trump announced his campaign for the presidency. After the election, Mr. Neely became a
frequent critic of the President on Twitter, and some of his replies to @realDonaldTrump
generated hundreds of likes and retweets. Some of Mr. Neelys tweets were cited on websites
such as The New Civil Rights Movement and The Daily Caller. Mr. Neelys tweets often
appeared near the top of the comment threads associated with tweets from @realDonaldTrump.
66. One or more of the Defendants blocked Mr. Neely from the @realDonaldTrump
account on June 12, 2017. That morning, President Trump tweeted: Congratulations! First new
Coal Mine of Trump Era Opens in Pennsylvania. He included a link to a Fox News article about
the opening of the mine. Mr. Neely replied: Congrats and now black lung wont be covered
under #TrumpCare. The tweet received 3,334 likes and 341 retweets. Mr. Neely discovered that
he had been blocked from the @realDonaldTrump account the following day.
prevents or impedes him from viewing the Presidents tweets; from replying to these tweets;
from viewing the comment threads associated with these tweets; and from participating in the
comment threads. Mr. Neely has used a third-party application to read and respond to the
Presidents tweets, but using the application is burdensome and the application is only partly
effective.
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Joseph Papp
68. Plaintiff Joseph Papp is a former professional road cyclist and current anti-doping
advocate, author, and speaker. He operates a verified Twitter account, @joepabike, which has
69. Mr. Papp monitors the @realDonaldTrump account closely and is an active
participant in the comment threads. His replies to @realDonaldTrump have been featured or
quoted in numerous media articles describing citizen response to President Trump, and some of
70. One or more of the Defendants blocked Mr. Papp from the @realDonaldTrump
account on or about June 3, 2017. At 12:35 on June 3, President Trump tweeted a video of his
weekly presidential address with the hashtag #WeeklyAddress. At 12:36 and 12:39, Mr. Papp
replied to the President with a pair of linked tweets stating, Greetings from Pittsburgh, Sir., and
Why didnt you attend your #PittsburghNotParis rally in DC, Sir? The second tweet received
335 likes and 34 retweets. On June 4, Mr. Papp discovered he had been blocked.
71. Defendants blocking of Mr. Papp from the @realDonaldTrump account prevents
or impedes him from viewing the Presidents tweets; from replying to these tweets; from viewing
the comment threads associated with these tweets; and from participating in the comment
threads.
Nick Pappas
72. Plaintiff Nick Pappas is a comic and writer. He operates a verified Twitter
73. Mr. Pappas has followed the @realDonaldTrump account since 2016. Before he
was blocked, Mr. Pappas replies to @realDonaldTrump often received thousands of likes and
retweets.
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74. One or more of the Defendants blocked Mr. Pappas from the @realDonaldTrump
account on June 5, 2017. That morning, President Trump tweeted: The Justice Dept. should ask
for an expedited hearing of the watered down Travel Ban before the Supreme Court - & seek
much tougher version! and In any event we are EXTREME VETTING people coming into the
U.S. in order to keep our country safe. The courts are slow and political! Mr. Pappas replied:
Trump is right. The government should protect the people. Thats why the courts are protecting
us from him. Mr. Pappas tweet received 395 retweets and 1,181 likes. Mr. Pappas discovered
that he had been blocked from the @realDonaldTrump account later that day.
prevents or impedes him from viewing the Presidents tweets; from replying to these tweets;
from viewing the comment threads associated with these tweets; and from participating in the
comment threads.
organization that works to defend and strengthen the freedoms of speech and the press in the
digital age through strategic litigation, research, and public education. Staff at the Knight First
Amendment Institute operate a Twitter account under the handle @knightcolumbia, and this
77. Unlike the Individual Plaintiffs, the Knight Institute has not been blocked from
the @realDonaldTrump account. It can access the Presidents tweets on the same terms as other
users, it can reply to the President directly, and it can participate fully in comment threads. The
viewpoint-based exclusion of the Individual Plaintiffs from this forum, however, prevents the
Knight Institute and other forum participants from hearing the speech that the Individual
Plaintiffs would have engaged in had they not been blocked. Defendants viewpoint-based
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blocking of the Individual Plaintiffs violates the Knight Institutes First Amendment rights by
distorting the expressive forum in which the Knight Institute and other non-blocked users
participate.
Cause of Action
78. Plaintiffs repeat the allegations set forth above as if fully set forth herein.
account violates the First Amendment because it imposes a viewpoint-based restriction on the
account violates the First Amendment because it imposes a viewpoint-based restriction on the
Individual Plaintiffs access to official statements the President otherwise makes available to the
general public.
account violates the First Amendment because it imposes a viewpoint-based restriction on the
account violates the First Amendment because it imposes a viewpoint-based restriction on the
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@realDonaldTrump account, and prohibiting Defendants from blocking the Individual Plaintiffs
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