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Pro-Trump Women’s Group Sues To Paint Own Motto On Street Since NYC Painted “Black Lives Matter”

Pro-Trump Women’s Group Sues To Paint Own Motto On Street Since NYC Painted “Black Lives Matter”

Seeks Order prohibiting NYC from “denying plaintiff the timely opportunity to use New York City streets to paint its own political or expressive message”

https://www.youtube.com/watch?v=aRjhJ_TmJlc

New York City Mayor Bill de Blasio, to much fanfare and hoopla, instructed city government to paint on the street outside Trump Tower the words “Black Lives Matter.” He even assisted in the painting (see Featured Image above, via YouTube]

The placement of the paint job in front of Trump Tower was a clearly political statement by de Blasio, who was accompanied by Al Sharpton, among others.

The lettering is described as a “mural” by supporters, while others consider it politicpal graffiti and have attempted to paint it over with blue paint in support of the police.

NYC and de Blasio have studiously protectected the original paint job against such efforts.

In response, Women for America First (WAF), which reasonably could be described as a pro-Trump group though it is technically non-partisan, wants to paint its motto on a street in NYC, arguing that the city, having determined to paint a political message should not discriminate among political messages.

WAF wants the following painted in an equally prominent place: “Engaging, Inspiring and Empowering Women to Make a Difference!”

Here is the letter demand to de Blasio:

https://twitter.com/KylieJaneKremer/status/1283470256598646784

Not surprisingly, NYC has not granted permission. So WAF has filed a suit in federal court demanding the right to paint its own motto. The suit does not demand removal of the Black Lives Matter paint job.

[Note: Ronald Coleman Esq. is co-counsel for WAF in the lawsuit. He also represents Legal Insurrection in unrelated matters.]

The Complaint (pdf.) alleges, among other things, that “BLM is a political movement” and further:

10. The BLM movement is for all practical purposes affiliated with the Democratic Party and notwithstanding expressions of frustration by BLM activists with the leadership of that party, BLM is unquestionably hostile to the Republican Party.

* * *

13. Few politicians have made the commitment to BLM more central to their work in government that the Mayor of the City of New York, defendant Bill De Blasio, who is a Democrat.

* * *

15. As part of that commitment, on the morning of July 9, 2020, New York City employees – including defendant De Blasio – and private citizens began painting “Black Lives Matter” in large, bright yellow letters, as shown below, on Fifth Avenue in front of Trump Tower, a building owned and named after President Donald J. Trump and where he maintains a residence.

16. Upon information and belief, this painting of a public street, described by defendant De Blasio as a “mural,” was undertaken by the New York City Department of Transportation (“DOT”) at an initial cost of approximately $6,000 in funds allocated to the DOT for transportation-related purposes.

17. Pursuant to regulations posted by the City of New York at NYC Park’s website: https://www.nycgovparks.org/art-and-antiquities/temporary-guidelines/murals, citizens and organizations may only submit requests to paint murals in NYC Parks, not on New York City streets.

18. Nonetheless, based on the apparent change of policy concerning murals, on the evening of July 9, 2020, plaintiff submitted a request to defendant de Blasio requesting to paint a message of its own on a New York City street….

* * *

20. By the date hereof, plaintiff still has not received a response from defendant de Blasio regarding this request, which he acknowledged receiving in a press conference on July 23, 2020.

21. When questioned about the request, defendant de Blasio stated that the Black Lives Matter movement “transcends any notion of politics,” and he defended allowing the words to be painted on streets across the city while not approving similar mural requests from groups like the pro-cop Blue Lives Matter. “This is about something much bigger than any one group,” de Blasio added. ““This is about righting a wrong and moving forward. So I think that’s the right approach.”

22. Upon information and belief, the Black Lives Matter organization did not submit a formal request through established channels to submit such requests to paint its mural on Fifth Avenue or other duplicative murals that have subsequently been allowed, by defendants, to be painted on streets throughout New York City.

The Complaint alleges a single Count:

28. Defendants, acting under color of New York law, have deprived and continue to deprive plaintiff of its First Amendment Rights guaranteed by the U.S. Constitution in violation of 42 U.S.C. § 1983, by, inter alia:

a. Allowing New York City streets to be used for the painting of partisan political messages;
b. Denying plaintiff the timely opportunity to use New York City streets to paint its own political or expressive message;
c. Depriving Plaintiff of its right to paint a political or expressive message on a New York City street for reasons that are not narrowly tailored to a compelling government interest;
d. Depriving plaintiff of its right to paint a political or expressive message on a New
York City street for reasons that are not substantially related to an important government interest;
e. Failing to provide a reasonable basis for denying plaintiff the opportunity to paint its political or expressive message on a New York City street;
f. Favoring the viewpoint of the political message painted on Fifth Avenue and other New York City streets over the message plaintiff has requested to paint;
g. Expending DOT funds on painting, maintaining, and endorsing the expressive message of one organization over plaintiff’s message;
h. Failing to provide reasonable, non-arbitrary processes and procedures for timely consideration of plaintiff’s expressive message; and
i. Engaging in preferential political speech in favor of a partisan organization that supports his own political ambitions.

29. Plaintiff is suffering irreparable harm as a direct and proximate result of Defendants’ deprivation of Plaintiff’s First Amendment rights in violation of 42 U.S.C § 1983 and will continue to suffer such irreparable harm unless defendants’ unlawful conduct is enjoined.

30. Plaintiff has no adequate remedy at law.

The Relief Requested is equal access to paint the streets:

WHEREFORE, plaintiff respectfully requests that this Court:
a. Declare defendants’ conduct unconstitutional in violation of plaintiff’s First Amendment Rights and 42 U.S.C. § 1983;
b. Enjoin defendants from continuing to deprive plaintiff of its First Amendment rights as guaranteed by 42 U.S.C. § 1983;
c. Order defendants to issue a permit allowing plaintiff to paint its expressive message on Fifth Avenue at or near defendant’s mural or one of the substantially similar streets plaintiff proposed as reasonable alternatives for the same number of days as the “Black Lives Matter” mural has and will continue to exist on Fifth Avenue;
d. Award attorney’s fees and costs pursuant to 42 U.S.C. § 1988; and
e. Grant any further relief this Court deems just and proper.

Separately, Judicial Watch has sued the District of Columbia in order to paint it’s own message on the street, “Because No One is Above the Law!”:

On June 5, 2020, after days of protests and riots in Washington, DC, led by the Black Lives Matter organization, Mayor Bowser authorized the painting of “Black Lives Matter” on 16th Street NW, and later authorized or allowed “Defund the Police” to be painted alongside it.

On June 10, 2020, Judicial Watch sent a letter requesting permission to paint “Because No One is Above the Law!” in the identical size and coloring of the “Black Lives Matter” painting on another DC street near its headquarters near Capitol Hill. Judicial Watch offered to pay for the cost of the painting and, citing the timely nature of the issue, asked for a response in three days.

Instead, after three weeks of emails with the Mayor’s office, Judicial Watch has yet to receive a substantive response to its street painting request.

The lawsuit alleges that DC officials denied timely, equal access to Judicial Watch to paint its own expressive message and violated federal civil rights law in:

(a) allowing District streets to be used for the painting of expressive messages, which constitutes protected, First Amendment activity, but denying Plaintiff (Judicial Watch) the timely opportunity to paint its expressive message on a District street for reasons that are not narrowly drawn to achieve a compelling government interest; (b) failing to provide a reasonable basis for denying Plaintiff the timely opportunity to paint is expressive message on a District street; (c) favoring the expressive messages painted on 16th Street NW and/or creating the appearance of endorsing those messages to the exclusion of Plaintiff’s message on a related subject matter; and/or (d) failing to provide reasonable, non-arbitrary processes and procedures for timely consideration of Plaintiff’s request to paint an expressive message on District streets.

I don’t think NYC or D.C. are required to permit political messages to be painted on streets. This may turn on whether the “Black Lives Matter” paint job is viewed as political. Considering the video of the anti-Trump message expressed when it was painted and the placement in front of Trump Tower, it’s hard to see how it’s not political.

New York City government having painted one clearly political message on the street, refusing other political messages to be painted in a reasonably similar manner raises legal concerns.

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Comments

There would seem an equal protection violation in there somewhere.

Go WAF!

rabid wombat | July 26, 2020 at 9:41 pm

Make them live to their own rules

democrats are unable to think beyond their own self gratifying agendas. How do people get to the point they operate on sheer emotion? democrats would rather eliminate Conservatives as enemies because they can not debate ideas and principles. And deblasio is not only a democrat, he’s a commie after all, and that’s what commies do, purge their enemies.

Great. More suits needed challenging this mayor’s appropriation of public resources for his own spiteful personal political campaign. Why don’t the business fronting this defacement of public property file some actions?

    Milhouse in reply to Concise. | July 27, 2020 at 8:36 am

    On what grounds? As I understand it, it wasn’t the mayor’s private act, it was the city’s official act, and it owns the streets so it can write whatever it likes on them. Or close them down altogether.

      Ulysses in reply to Milhouse. | July 27, 2020 at 11:50 am

      You write “… it wasn’t the mayor’s private act, it was the city’s official act, and it owns the streets so it can write whatever it likes on them…. ”

      Explain how your words proscribe the City of New York from painting Nazi Swastikas on its public streets.

      Concise in reply to Milhouse. | July 27, 2020 at 5:46 pm

      The grounds cited in the above litigation are a good start. Added to that I might explore every federal, state, and local law against abusing public resources for political purposes. That’s generally illegal. He is abusing his position of pubic trust so saying he is acting officially is an indictment not a defense.

        Milhouse in reply to Concise. | July 27, 2020 at 10:44 pm

        Added to that I might explore every federal, state, and local law against abusing public resources for political purposes.

        There are no such laws.

          Concise in reply to Milhouse. | July 28, 2020 at 9:09 am

          Federal election campaign laws, the Hatch Act, NY Civil Service Law §107, and a vast array of regulations and precedent that remain to be explored. Do you really think a hypothetical republican mayor of NY could have taken such action against a democrat president with no litigious response from the left? If that had happened we would by now have been drowning in injunctions.

          Milhouse in reply to Milhouse. | July 28, 2020 at 10:42 am

          No, Concise, there are no such laws.

          Federal election campaign laws don’t and can’t restrict in any way any person or corporation, even from directly advocating that people vote for or against a specific candidate, let alone a non-partisan message like “Black Lives Matter”.

          The Hatch Act forbids federal employees from engaging in partisan political activity. Not only is the City of New York not a federal employee, but “Black Lives Matter” is not a partisan political slogan.

          Yes, a hypothetical Republican mayor of NY, backed by a hypothetical Republican city council, could have painted a slogan advocating a conservative ideological cause, such as “Choose Life”, and any legal challenge would have been as groundless as the one you’re proposing. If you think otherwise, find a law you think it violates.

          Concise in reply to Milhouse. | July 28, 2020 at 5:51 pm

          Mihouse, you claim categorically that no laws exist that would prohibit public officials from misappropriating taxpayer funded resources for political purposes. Absolutely wrong and I cited a few examples not intended to be necessarily controlling in the NY case. We’re not talking about private individuals or corporations. We’re speaking about elected officials. Why go to the bother of fundraising? Just let the city of NY produce the next chain of Biden 2020 tv ads. As a matte of fact, every sleazeball democrat jurisdiction can just redirect all public expenditures into the DNC, which they probably do more or less in other ways but what the heck let’s just remove any pretense and bring it all out in the open.

          Milhouse in reply to Milhouse. | July 29, 2020 at 1:26 am

          No, Concise, you did not cite any examples that are in any way relevant. All your examples are about a government employee expressing his private opinions using government resources without permission. But we are not talking about that here. We are talking about a government itself expressing its own opinions. There is no dispute that any government is entitled to do that. There’s no misappropriation; the resources belong to the city and it’s entitled to use them.

          Concise in reply to Milhouse. | July 29, 2020 at 11:05 am

          So, for Mayor de blasio, l’etat, c’est moi? The unbridled discretion to interfere in elections which your conclusions led to illustrates your error.

Rather obvious and blatant viewpoint discrimination, here. If Dhimmi-crat apparatchiks open the streets to blatant Dhimmi-crat political messages, then, the public forums should be open to all political viewpoints.

I think Judicial Watch filed the first lawsuit against DC over the same think a couple weeks ago.
And some group in California put in to paint a street in response, but the city removed the blm message to sidestep having to allow a different viewpoint.

Much as I applaud their intention, I think they’re wrong on the law. NYC hasn’t opened Fifth Avenue as “a public fora”. Besides the fact that it would have to be “a public forum”, since there’s only one of it, the complaint itself says that “Upon information and belief, this […] was undertaken by the New York City Department of Transportation”. That makes the slogan the city’s own speech.

Had it been painted by a third party with the city’s permission, then I think they’d have a case; by doing so the city could be argued to have made the street a limited public forum, at least temporarily, and while government regulation of speech in a limited public forum need not be content-neutral it does need to be viewpoint-netural.

But when the government speaks itself, expressing its own opinions, it has not created a forum of any kind, and is under no obligation to let people use its resources to express an opinion it doesn’t agree with. Remember, the city itself has first amendment rights too.

    Dusty Pitts in reply to Milhouse. | July 26, 2020 at 11:11 pm

    The city has used taxpayer funds to express a political opinion.

    That’s a no-no.

    The only way it’s okay is if it is an open forum for diverse opinions — except that the use of taxpayer monies still makes New York’s “slogan” a no-no.

    This isn’t “I &heart; NY.” Properly, a court should already have required De Blasio to reimburse the city and require the city to host alternative messages.

      Milhouse in reply to Dusty Pitts. | July 27, 2020 at 9:22 am

      The city has used taxpayer funds to express a political opinion.

      That’s a no-no.

      No, it isn’t. The city has the right to its own opinions, and to use its resources to express them, and does not have to give anyone else “equal time” to oppose them.

      This is not controversial. Look up “government speech”. Governments, like any other entities, are entitled to their own speech. Consider an official noticeboard at a public school. The administration posts whatever it likes there, and it is not a forum for anyone else. In fact, even if it wants to, it can’t allow anyone to post a religious message there, because it will be mistaken for the school’s own speech.

      This is why the supreme court ruled that specialty license plates are government speech, so the government can reject messages it doesn’t like, such as the Confederate flag, or issue messages it does like, such as “choose life” (though it can’t force motorists to display those messages; they can cover it up if they don’t like it). But it has not yet ruled on vanity plates, and some state courts have ruled that they are private speech.

    GatorGuy in reply to Milhouse. | July 27, 2020 at 3:33 am

    With peace, Mil, the drift of your last paragraph seems ludicrous on its face. Are you sure? Do judicial decisions in similar cases support your view?

    The way I see it, the government speaking is the forum par excellence. It speaks, by our founding documents’ conception and definition, for the people, and never as any kind of interested party, either with or against the people, am I right? Members of the public may attend and comment “at the forum,” as it were. In any case, what else is government business,* other than the public’s; and so, “at what venue” or in what sense does government function, other than “at” or as the forum itself?

    So, I accept the possibility of your conclusion about the cases; they mail fail on the merits, as you suggest. Depending on further information, I may disagree with you, however, about your way or reasoning you use to get there.

    _____________
    * When government speaks, it necessarily does so “at,” and in such a manner as to constitute the forum, because government is officially public in nature. (On this view, there is neither any legitimate nor illegitimate governmental function. There is only governmental, ie, the strictly public-serving function; otherwise, in any given event, it is a non-governmental entity and, therefore, ipso facto, functioning uncivilly, or even criminally.)
    This focus on the literal seems to make sound, intrinsic sense, but am I wrong in the courts’ view of what government is or does, vis-a-vis the reason it exists, when it “speaks”?
    I mean, in the end, does government “speak” in the sense that you or I or any other implicitly constitutionally protected American speaks? I can’t imagine, since the First Amendment and, to the extent of my lay understanding, its legal effects (in relatedly decided cases and controversies) don’t really seem to give a rat’s tongue or cheek about any competing governmental right, if it even exists in this context. Once again, please, if you know of any, do they?

      Milhouse in reply to GatorGuy. | July 27, 2020 at 9:27 am

      Yes, GatorGuy, I’m sure. This is not even slightly controversial. There are any number of decisions affirming that governments are entitled to their own speech. Just look up “government speech” and you’ll find them.

      The way I see it, the government speaking is the forum par excellence

      Sorry, that is just not true.

      It speaks, by our founding documents’ conception and definition, for the people, and never as any kind of interested party, either with or against the people, am I right?

      No, you are not right. Governments are corporate entities, with their own opinions, and they speak only for themselves.

    Concise in reply to Milhouse. | July 27, 2020 at 8:20 am

    Sorry Milhouse but I can’t accept your argument here. there are limits to almost any doctrine and context matters. Could the mayor unilaterally, contrary to any rule or regulation, paint ‘Re-elect De-Blasio” or “Biden 2020” in front of Trump Tower and say well its government speech and perfectly ok?

      Milhouse in reply to Concise. | July 27, 2020 at 9:34 am

      He couldn’t do it “unilaterally, contrary to any rule or regulation”. Nor could he do this BLM sign unilaterally, contrary to any rule or regulation. But he certainly can do it pursuant to the relevant rules and regulations.

      I have not yet seen any news report specify exactly how this sign was made. In fact the letter cited in this post is the first time I’ve seen it reported that it was done by the city itself, at the mayor’s orders. For the purpose of my comment here I’m relying on the plaintiff’s own statement. I’m not familiar with the applicable rules, and how much authority the mayor has to do this sort of thing unilaterally. If he’s exceeded his authority, that’s for the city council to deal with.

      But I don’t think there is any question at all that the city council could indeed vote to paint BIDEN 2020 in front of Trump Tower, and no court could tell them not to. And if the regulations the council has enacted give the mayor this authority then he can do it too.

    Milhouse in reply to Milhouse. | July 27, 2020 at 11:42 am

    PS: I just checked my impression with Eugene Volokh, one of the nation’s foremost experts on the first amendment. He says I’m correct about the first part, that if the city did it it’s government speech and it need not allow anyone else to present a contrary view.

    But he says even if the city allowed an outside group to do it, it would still be government speech and not a limited public forum, so long as it was allowing only those slogans that it itself endorsed. It’s just like the city accepting monuments for a city park from private groups, which the city may do without creating a public forum. See, on that very point, Pleasant Grove City v. Summum.

      Milhouse in reply to Milhouse. | July 27, 2020 at 11:45 am

      From Summum:

      (1) A government entity “is entitled to say what it wishes,” Rosenberger v. Rector and Visitors of Univ. of Va., 515 U. S. 819, 833, and to select the views that it wants to express, see, e.g., Rust v. Sullivan, 500 U. S. 173, 194. It may exercise this same freedom when it receives private assistance for the purpose of delivering a government-controlled message. See Johanns v. Livestock Marketing Assn., 544 U. S. 550, 562.

        GatorGuy in reply to Milhouse. | July 27, 2020 at 1:19 pm

        Thanks very much, Milhouse, for taking the time to carefully inform with key references those of us who are not as trained and skilled in these arguments of the law as you are.

        Having checked out various sources on government speech, especially the LII’s amply referenced discussion, and read a few cases, including Summum, I see your main point much better now. (And I’d readily surmise that having EV’s support of it certainly can’t hurt, to say the least.)

        In this, my updated sense of the present NYC and DC government speech matters, and after all is legally written and decided in these cases, I still feel what I think many in our country feel:

        Too many government agencies are eager, even rabid in their zeal to infringe, say, on the Establishment and Free Exercise clauses of the First Amendment at Christmas time — from what I understand, a constitutionally iffy and unwholesome maneuver as a matter of government speech — and are now just as eager to show their political and ideological stripes by loudly and publicly proclaiming (as a “mural” or on a major intersection’s traffic signal) the speech of a private organization, BLM, which is dedicated most strenuously to the abolition of Judeo-Christian religion’s many cherished and sacredly held values and institutions.

        So, it seems to be a matter of simple fairness, justice, and equity. The law might favor the cities’ right to speak its views with favor, yet, something would still not sit right with most Americans, I’m sure.

        It now looks to me like the cases might boil down to a matter of style, if not law. And it that case, the people reserve the power at the ballot box re whether or not to retain the services of their elected officials. If so, we can only hope such a process is still feasible, and not a complete sham, or we the people and its republic are toast.

          Milhouse in reply to GatorGuy. | July 27, 2020 at 10:50 pm

          Too many government agencies are eager, even rabid in their zeal to infringe, say, on the Establishment and Free Exercise clauses of the First Amendment at Christmas time — from what I understand, a constitutionally iffy and unwholesome maneuver as a matter of government speech

          I’m not sure what you mean by this.

          It now looks to me like the cases might boil down to a matter of style, if not law. And it that case, the people reserve the power at the ballot box re whether or not to retain the services of their elected officials.

          The problem is this is New York, where most voters support the BLM movement and want the city to endorse it.

          Concise in reply to GatorGuy. | July 30, 2020 at 10:58 am

          Don’ apologize. It’s an illegal use of public resources and the mayor should be enjoined.

        Concise in reply to Milhouse. | July 30, 2020 at 11:02 am

        I know you’re interested in the law Milhouse and to further your education let me advise you that it is in fact illegal for the mayor to use gov’t resources as he has to promote his preferred political cause. There is clear precedent that would support an injunction requiring the removal of this mayor’s street graffiti.

      Ulysses in reply to Milhouse. | July 27, 2020 at 2:59 pm

      You want to hang your hat on a case concerning Statutes in a Park written by Justice Alito? Perhaps one day we will say how that works out for you.

      Concise in reply to Milhouse. | July 27, 2020 at 5:49 pm

      With all due respect to Prof Volokh, I doubt the precedent addresses a mayor actively exploiting city resources in aid of a political campaign against the president from an opposing party.

        Milhouse in reply to Concise. | July 27, 2020 at 10:56 pm

        What distinction could you draw? I can’t see any grounds for drawing such a distinction.

        But even if you could somehow distinguish partisan messages from others, “Black Lives Matter” is not a partisan message. It’s political as hell, but not overtly partisan. For instance federal employees are allowed to endorse it on the job without violating the Hatch Act, and 501(c)(3)s and (4)s are allowed to endorse it without losing their tax status.

          Concise in reply to Milhouse. | July 30, 2020 at 10:56 am

          The mayor is illegally using public resources to favor his preferred political issue. There is clear law and precedent in NY (and elsewhere) to support an injunction. I wish some NY taxpayer would file an action to force the removal of this sloganeering in favor of the vile socialist BLM organization.

    Concise in reply to Milhouse. | July 30, 2020 at 10:53 am

    Sorry Milhouse, you are just plain wrong. There are many cases where public agencies and officials have been enjoined from using public resources to promote political issues. There is clear precedent in NY in fact. Neither the mayor nor the NY DOT can avoid these strictures by claiming its “government speech.” The only reason I can see that no NY taxpayer has filed a suit to enjoin this garbage is that its not deemed to be politically advantageous.

I’d like to see 7-Eleven paint “Big Gulp” on the street in front of Bloomberg’s house …

“I don’t think NYC or D.C. are required to permit political messages to be painted on streets.”

The weren’t. But now they have opened their streets as public fora. They have to give other groups equal access.

    Milhouse in reply to Valerie. | July 27, 2020 at 9:35 am

    IF they had opened up a forum (not fora) they would have to be viewpoint-neutral. But they haven’t done that.

To add further insult to already extensive injury, it’s looking increasingly likely that we’re living not only in a post-fact culture, but, with the above-mentioned cases indicating, a post-principle culture as well.

At this rate, a post-rule-of-law, anarchic society is on our doorsteps or, for all intents and purposes, politically here already.

Adding the NYC and DC governments’ disregard of the above-mentioned plaintiffs’ First Amendment rights vis-a-vis 42 USC 1983 to the unceasing abuse with which DCDC Judge Emmet Sullivan refuses to let injustice end and justice be done in LTG Michael Flynn’s federal case, and we can see the Dem-Left-Globee-conducted crescendo building to an election-year climax of selectively decided, unimaginable rights-depriving proportions.

The Durham indictments will have come not a moment too soon — and hopefully, not both a moment too late and a substance too small to matter in this, a time of weakening and even disappearing federalism, law, and the public order.

buckeyeminuteman | July 27, 2020 at 6:45 am

I’m sure John Roberts will weigh in to ensure no such thing is painted.

I would prefer Babies Lives Matter painted in front of every abattoir in the country. Or better yet, let’s keep roadways painted with safety markings only.

I’m surprised that DeBlasio knows how to use a paint roller.

it will go to scotus and roberts will rule a tax upon all (how he convolutes it to do so …we’ll see..) so rules against it.

Baby Lives Matter #HateLovesAbortion

ccscientist | July 29, 2020 at 9:16 pm

Politicians by law are forbidden to use government resources like employee time for campaigning. BLM is a political group (not just a slogan) closely connected to the dem party. Using government resources to favor a BLM message on the street (esp outside trump tower) is a blatant violation of the campaign law.

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