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    ICRF v. Maryland Motion to Dismiss: Conclusion PDF Print E-mail

    VI - CONCLUSION

    Plaintiffs have standing to present a controversy which remains alive and vital and in which substantial relief is sought.

    The issues in this case are important to these plaintiffs and important to the constitutional rights of many persons subject to the unlawful conduct of the defendants. The motion to dismiss should be denied.

    Dated: November 15, 1999Respectfully submitted,

    ______________________

    Kendrick Moxon

    MOXON & KOBRIN

    3055 Wilshire Blvd., Ste. 900

    Los Angeles, CA 90010

    (213) 487-4468

    Lee Boothby

    4545 42nd St. NW, Suite 201

    Washington D.C. 20016

    (202) 363-1773

    Eric Lieberman

    RABINOWITZ, BOUDIN, STANDARD, KRINSKY & LIEBERMAN, P.C.

    740 Broadway, 5th Floor

    New York, NY 10003

    (212) 254-1111

    Counsel for Plaintiffs

       

    Association of Data Processing Serv. Orgs., Inc. v. Camp, 397 U.S. 150, 90 S.Ct. 827, 25 L.Ed.2d 184 (1970) (interpreting School District of Abington v. Schempp, 374 U.S. 203, 83 S.Ct. 1560, 10 L.Ed.2d 844 (1963).)19

    Booth v. State of Maryland, 112 F.3d 139 (4th Cir. 1997)28

    California Bankers Ass’n v. Shultz, 416 U.S. 21, 94 S.Ct. 1494, 39 L.Ed.2d 812 (1974)21-22

    Church of Scientology Flag Service Organization v. City of Clearwater, 2 F.3d 1514 (11th Cir. 1993)21

    Church of Scientology of California v. United States, 506 U.S. 9, 113 S.Ct. 447 (1992)26

    CSX Transportation, Inc. v. Board of Public Works of the State of West Virginia, 138 F.3d 537 (4th Cir. 1998).28

    Doremus v. Board of Education, 342 U.S. 429, 72 S.Ct. 39424

    Ex parte Young, 209 U.S. 123, 28 S.Ct. 441 (1908)28

    Flast v. Cohen, 392 U.S. 83, 88 S.Ct. 1942, 20 L.Ed.2d 947 (1968)18

    Flynn v. Sandahl, 58 F.3d 283 (7th Cir. 1995)27

    Green v. Mansour, 474 U.S. 64, 106 S.Ct. 423 (1985).28

    Koenick v. Felton, 190 F.3d 259 (4th Cir.1999)23-25

    Mills v. Green, 159 U.S. 651, 16 S.Ct. 132 (1895)26

    Nasatka v. Delta Scientific Corp., 58 F.3d 1578 (Fed.Cir. 1992), quoting, Flagstaff Medical Center, Inc. v. Sullivan, 962 F.2d 879 (9th Cir. 1992)27-28

    North Carolina Civil Liberties Union, et al. v. Constangy, 751 F.Supp. 552 (W.D. N.C.1990), 947 F.2d 1145 (4th Cir. 1991) . . . . . . . . . . . . . . . . . .22

    North Carolina Civil Liberties Union Legal Foundation v. Constangy,

    947 F.2d 1145 (4th Cir. 1991) 23

    Suhre v. Haywood County, 131 F.3d 1083 (4th Cir. 1997).18

    United States v. Chrysler Corp., 158 F.3d 1350 (D.C.Cir. 1998)27


    OPPOSITION TO DEFENDANTS’ MOTION TO DISMISS


    TABLE OF CONTENTS

    I - INTRODUCTION

    II – STATEMENT OF FACTS

    A. Legislative History of the Cult Task Force Resolution
    B. The Task Force Report Continued the Violations of Plaintiffs’ Constitutional Rights

    III - PLAINTIFFS HAVE STANDING TO BRING THIS ACTION

    IV - THIS ACTION IS NOT MOOT

    V - THE ELEVENTH AMENDMENT IS NOT A BAR TO THIS ACTION

    VI - CONCLUSION