2018-08-03T19:20:35-05:00 2017-12-31 680251243 CAMPBELL TAYLOR & COMPANY 3741 DOUGLAS BLVD SUITE 350 ROSEVILLE CA 95661 990 2017-01-01 942197343 PACIFIC LEGAL FOUNDATION PACI 9164197111 930 G STREET SACRAMENTO CA 95814 STEVEN D ANDERSON PRESIDENT & CEO 9164197111 2018-08-02 1 LINDA L HOUSE CPA P00003225 9169293680 2017 2022-09-23 18:48:47Z STEVEN D ANDERSON 930 G STREET SACRAMENTO CA 95814 20281710 0 X PACIFICLEGAL.ORG X 1973 CA PACIFIC LEGAL FOUNDATION LITIGATES NATIONWIDE TO SECURE ALL AMERICANS' INALIENABLE RIGHTS TO LIVE RESPONSIBLY AND PRODUCTIVELY IN THEIR PURSUIT OF HAPPINESS. PLF COMBINES STRATEGIC AND PRINCIPLED LITIGATION, COMMUNICATIONS, AND RESEARCH TO ACHIEVE LANDMARK COURT VICTORIES ENFORCING THE CONSTITUTION'S GUARANTEE OF INDIVIDUAL LIBERTY. 23 23 86 0 0 0 9783403 10159026 167147 2356239 857136 934089 -29548 -72111 10778138 13377243 6000 9000 0 0 7462721 8116168 138215 139322 1395189 2976219 3404294 10583155 11668784 194983 1708459 47864523 53327855 1612643 1300586 46251880 52027269 X PACIFIC LEGAL FOUNDATION LITIGATES NATIONWIDE TO SECURE ALL AMERICANS' INALIENABLE RIGHTS TO LIVE RESPONSIBLY AND PRODUCTIVELY IN THEIR PURSUIT OF HAPPINESS. PLF COMBINES STRATEGIC AND PRINCIPLED LITIGATION, COMMUNICATIONS, AND RESEARCH TO ACHIEVE LANDMARK COURT VICTORIES ENFORCING THE CONSTITUTION'S GUARANTEE OF INDIVIDUAL LIBERTY. 0 0 8594020 9000 2369510 TO PROTECT THE CONSTITUTIONAL RIGHTS OF ALL AMERICANS THROUGH LITIGATION; EDUCATE THE PUBLIC ABOUT ISSUES VITAL TO OUR FREEDOM THROUGH COMMUNICATIONS AND OUTREACH; AND TRAIN CURRENT AND ASPIRING LAWYERS HOW TO DEFEND OUR LIBERTIES IN COURT.PLF ATTORNEYS DIRECTLY REPRESENTED CLIENTS NATIONWIDE IN THE FOLLOWING CASES, FURTHERING THE FOUNDATION'S PRACTICE AREAS IN PROPERTY RIGHTS, FREE SPEECH AND ASSOCIATION, ECONOMIC LIBERTY, EQUAL PROTECTION, AND GOVERNMENT ACCOUNTABILITY. IN ALL CASES, ACTIONS ATTRIBUTED TO PLF WERE DONE BY PLF ATTORNEYS PROPERLY ADMITTED TO EACH JURISDICTION.SEE SCHEDULE O FOR A LIST OF CASES LITIGATED DURING 2017. PROPERTY RIGHTS: A SOCIETY CANNOT FLOURISH AND INDIVIDUALS CANNOT ADVANCE THEIR PRIVATE INTERESTS WITHOUT INDIVIDUAL RIGHTS TO CREATE AND PRODUCTIVELY USE PROPERTY. PLF LITIGATES TO SECURE THE RIGHT TO THE PRODUCTIVE AND ORDINARY USE OF LAND; PREVENT GOVERNMENTS FROM TAKING PROPERTY; FIGHT UNCONSTITUTIONAL OR UNLAWFUL REGULATORY REQUIREMENTS; PROMOTE BALANCE IN ENVIRONMENTAL LAWS; AND STOP UNREASONABLE SEARCHES AND SEIZURES.616 CROFT AVE., LLC V. CITY OF WEST HOLLYWOOD. PLF TOOK OVER REPRESENTATION OF A PROPERTY OWNER WHO WISHED TO DEVELOP A SMALL 11-UNIT CONDOMINIUM IN WEST HOLLYWOOD, CALIFORNIA. THE CITY CONDITIONED THE DEVELOPMENT PERMIT ON PAYMENT OF AN "AFFORDABLE HOUSING" FEE OF OVER $500,000. THE COURT OF APPEAL UPHELD THE ORDINANCE ON THE THEORY THAT THE UNCONSTITUTIONAL CONDITIONS DOCTRINE ESTABLISHED IN NOLLAN V. CALIFORNIA COASTAL COMM'N AND DOLAN V. CITY OF TIGARD DO NOT APPLY TO LEGISLATIVELY-IMPOSED EXACTIONS. PLF PETITIONED THE CALIFORNIA SUPREME COURT AND THE UNITED STATES SUPREME COURT FOR REVIEW, ON THE GROUNDS THAT THE FEE VIOLATES THE FIFTH AMENDMENT'S TAKINGS CLAUSE. BOTH COURTS DENIED REVIEW AND PLF DID NOT RECOVER ANY FEES.BEACH AND BLUFF CONSERVANCY V. CITY OF SOLANA BEACH, CALIFORNIA. REPRESENTED BY PLF, LOCAL HOMEOWNERS CHALLENGED THE TOWN'S ADOPTION OF A LOCAL COASTAL PLAN THAT DEPRIVES THE OWNERS OF THE ABILITY TO PROTECT THEIR HOMES BY ERECTING SEAWALLS TO PREVENT EROSION. IN 2017, PLF FILED APPELLATE BRIEFS AFTER A PARTIALLY SUCCESSFUL MOTION FOR JUDGMENT ON THE PLEADINGS. THE TRIAL COURT HAD AGREED THAT TWO OF THE CITY'S REGULATIONS VIOLATED THE CALIFORNIA COASTAL ACT AND DEFERRED RULING ON OTHER ISSUES UNTIL PROPERTY OWNERS BROUGHT AN AS-APPLIED CHALLENGE. BECAUSE THIS CASE IS ONGOING, IT IS PREMATURE TO SEEK FEES.BENEDETTI V. COUNTY OF MARIN, CALIFORNIA. PLF REPRESENTS A FARMER IN A CHALLENGE TO MARIN COUNTY'S RECENTLY ADOPTED LAND USE PLAN AMENDMENT, WHICH REQUIRES CURRENT AGRICULTURAL USES OF LAND TO REMAIN SUCH IN PERPETUITY. WILLIE BENEDETTI WOULD LIKE TO MAKE PLANS TO RETIRE FROM THE ACTIVE FARMING OF HIS LAND, BUT THE "FORCED FARMING" AMENDMENT WILL NOT ALLOW HIM TO DO SO. TRIAL LEVEL LITIGATION IS STAYED PENDING ADOPTION OF AMENDMENTS TO THE COUNTY LAND USE PLAN. BECAUSE THIS CASE IS PENDING, IT WOULD BE PREMATURE TO SEEK FEES.BUILDING INDUSTRY ASS'N OF THE BAY AREA V. CITY OF OAKLAND, CALIFORNIA. REPRESENTING A TRADE ASSOCIATION OF DEVELOPERS, PLF IS CHALLENGING A CITY ORDINANCE THAT CONDITIONS BUILDING PERMITS ON INSTALLATION OF PUBLIC ART OR AN IN-LIEU FEE TIED TO THE COST OF THE OVERALL DEVELOPMENT. BECAUSE THE CITY'S GENERAL DESIRE FOR PUBLIC ART CANNOT CONSTITUTIONALLY BE BORNE ONLY BY THOSE WHO SEEK BUILDING PERMITS, WHEN SUCH DEVELOPMENT DOES NOT CREATE ANY NEED FOR PUBLIC ART, PLF FILED A COMPLAINT IN FEDERAL COURT ARGUING THAT THE FEE VIOLATES THE FIFTH AMENDMENT. IN 2017, THE LITIGATION STAY WAS LIFTED AND PROCEEDINGS CONTINUED IN THE TRIAL COURT. BECAUSE THE CASE IS ONGOING, IT IS PREMATURE TO SEEK FEES.CALIFORNIA BUILDING INDUSTRY ASS'N (CBIA) V. CITY OF SAN JOSE. REPRESENTING CBIA, PLF ARGUED IN THE CALIFORNIA SUPREME COURT THAT SAN JOSE'S INCLUSIONARY ZONING ORDINANCE VIOLATED THE FIFTH AMENDMENT'S PROHIBITION ON UNCOMPENSATED TAKINGS. THE COURT UPHELD THE ORDINANCE AS A VALID EXERCISE OF THE CITY'S POLICE POWER. PLF PETITIONED THE U.S. SUPREME COURT FOR A WRIT OF CERTIORARI, WHICH WAS DENIED IN JANUARY, 2016. AFFORDABLE HOUSING ADVOCACY GROUPS, DEFENDANT-INTERVENORS IN THE CASE, SUBSEQUENTLY SOUGHT AN AWARD OF ATTORNEYS' FEES FROM CBIA. BECAUSE SUCH AWARDS THREATEN PLAINTIFFS' ABILITY TO PURSUE PUBLIC INTEREST LITIGATION, PLF REPRESENTS CBIA IN OPPOSITION TO THE FEES. THE CASE SETTLED. PLF ITSELF WAS NOT ELIGIBLE TO SEEK FEES AND IS NOT LIABLE TO PAY THEM.CAPISTRANO SHORES LLC V. CAL. COASTAL COMM'N. PLF REPRESENTED THE WILLS FAMILY, MOBILE HOME OWNERS WHO CHALLENGED A CALIFORNIA COASTAL COMMISSION PERMIT CONDITION THAT REQUIRED THEM TO WAIVE THE RIGHT TO BUILD A SEAWALL TO PROTECT THEIR HOME. THE CONDITION WAS PART OF AN ONGOING COMMISSION POLICY TO DISCOURAGE AND ELIMINATE DEVELOPMENT OF PRIVATE PROPERTY ALONG THE BEACH IN CALIFORNIA. PLF SUED BECAUSE THIS UNFAIR DEMAND VIOLATED BOTH THE COASTAL ACT AND THE CALIFORNIA AND U.S. CONSTITUTIONS. PLF AND THE WILLS FAMILY PREVAILED. PLF SOUGHT ATTORNEYS' FEES BUT THE MOTION WAS DENIED AND PLF DID NOT APPEAL. CEDAR POINT NURSERY V. GOULD. REPRESENTING A CALIFORNIA NURSERY, PLF FILED A COMPLAINT CHALLENGING A STATE REGULATION ISSUED BY THE AGRICULTURAL LABOR RELATIONS BOARD THAT ALLOWS UNION ORGANIZERS TO ACCESS AN EMPLOYER'S PREMISES FOR THE PURPOSE OF SOLICITING EMPLOYEES TO JOIN THE UNION. PLF ARGUES THAT THIS IS AN UNCONSTITUTIONAL TAKING AND FURTHER VIOLATES THE FOURTH AMENDMENT'S PROHIBITION ON UNREASONABLE SEIZURES. AFTER A LOSS IN THE TRIAL COURT, PLF APPEALED TO THE NINTH CIRCUIT, FILED BRIEFS, CONDUCTED ORAL ARGUMENT, AND NOW AWAITS DECISION. BECAUSE THE CASE IS ONGOING, IT IS PREMATURE TO SEEK FEES.CHERK FAMILY TRUST V. COUNTY OF MARIN. THE CHERK FAMILY WANTED TO SUPPLEMENT THEIR MODEST RETIREMENT INCOME BY SPLITTING AND SELLING A RESIDENTIAL LOT THEY OWNED IN MARIN COUNTY, CALIFORNIA. THE COUNTY CONDITIONED THEIR PERMIT ON PAYMENT OF A $39,960 "AFFORDABLE HOUSING" FEE. PLF REPRESENTS THE FAMILY IN A CHALLENGE TO THE FEE ORDINANCE AS AN UNCONSTITUTIONAL CONDITION THAT TAKES THEIR PROPERTY IN VIOLATION OF THE FIFTH AMENDMENT. AFTER AN ADVERSE DECISION IN THE TRIAL COURT, PLF APPEALED ON BEHALF OF THE CHERKS. BECAUSE THIS CASE IS ONGOING, IT WOULD BE PREMATURE TO SEEK FEES.GANSON V. CITY OF MARATHON, FLORIDA. THE BEYER FAMILY OWNS A 9-ACRE ISLAND OFF THE FLORIDA COAST THAT WAS RECLASSIFIED FROM A GENERAL ZONING DESIGNATION TO A BIRD ROOKERY THAT PERMITTED NO USE OF THE PROPERTY OTHER THAN CAMPING. INSTEAD OF OFFERING COMPENSATION AS REQUIRED BY THE FIFTH AMENDMENT, THE CITY OFFERED THE BEYERS ONLY TRANSFERABLE DEVELOPMENT CREDITS TOWARD POSSIBLE PURCHASE OF A LIMITED NUMBER OF DEVELOPMENT PERMITS IN OTHER LOCATIONS. PLF TOOK OVER THE CASE TO SEEK REVIEW OF THIS UNCONSTITUTIONAL TAKING BEFORE THE FLORIDA SUPREME COURT. WHEN THAT PETITION WAS DENIED, PLF FILED A PETITION FOR WRIT OF CERTIORARI IN THE U.S. SUPREME COURT. BECAUSE THIS CASE IS ONGOING, IT IS PREMATURE TO SEEK FEES.GARRETT V. CITY OF NEW ORLEANS, LOUISIANA. PLF REPRESENTS HOMEOWNERS IN A FEDERAL TAKINGS/DUE PROCESS LAWSUIT AGAINST THE CITY OF NEW ORLEANS, WHICH DEMOLISHED THEIR PROPERTY WITHOUT NOTICE, HEARING, OR COMPENSATION. THE FEDERAL DISTRICT COURT DISMISSED THEIR CASE ON THE GROUNDS THAT THE WILLIAMSON COUNTY DOCTRINE REQUIRES THEM TO EXHAUST STATE REMEDIES BEFORE BRINGING A FEDERAL CASE. PLF TOOK OVER THE CASE ON APPEAL TO THE FIFTH CIRCUIT COURT OF APPEALS. BECAUSE THE CASE IS ONGOING, IT IS PREMATURE TO SEEK FEES.GOODWIN V. WALTON COUNTY, FLORIDA. THE GOODWIN FAMILY OWNS LAND THAT INCLUDES A PRIVATE BEACH. THEY POSTED SIGNS INDICATING THAT IT WAS PRIVATELY OWNED. HOWEVER, THE COUNTY PASSED AN ORDINANCE OUTLAWING THE SIGNS AND DECLARING THAT THE PUBLIC HAD A RIGHT TO ACCESS THIS PRIVATE LAND. PLF REPRESENTS THE GOODWINS IN A FEDERAL LAWSUIT CLAIMING THAT THE ORDINANCE EFFECTIVELY TAKES THEIR PROPERTY WITHOUT COMPENSATION, IN VIOLATION OF THE FIFTH AMENDMENT. LITIGATION IS ONGOING IN THE DISTRICT COURT. BECAUSE THIS CASE IS ONGOING, IT IS PREMATURE TO SEEK FEES.GREENE V. CALIFORNIA COASTAL COMM'N. PLF REPRESENTS THE GREENE FAMILY IN A CHALLENGE TO THE COASTAL COMMISSION'S DECISION TO IMPOSE TWO CONDITIONS ON THE APPROVAL OF A DEVELOPMENT PERMIT FOR THEIR HOME IN LOS ANGELES. THE FIRST CONDITION REQUIRES A FIVE-FOOT SETBACK FROM THEIR SEAWARD PROPERTY LINE, IN CONFLICT WITH CITY ZONING ORDINANCES AND THE CITY-APPROVED PERMIT. THE SECOND CONDITION REQUIRES THE FAMILY TO WAIVE THEIR CONSTITUTIONAL AND STATUTORY RIGHTS TO CONSTRUCT NECESSARY PROTECTIVE DEVICES, SUCH AS A SEAWALL. TRIAL LEVEL LITIGATION IS ONGOING. BECAUSE THIS CASE IS ONGOING, IT WOULD BE PREMATURE TO SEEK FEES. 8594020 1 1 0 0 0 0 0 0 0 1 1 1 0 0 1 1 1 0 0 0 0 0 0 1 1 0 0 0 1 1 0 0 0 0 0 0 0 0 1 0 0 0 1 0 0 0 0 1 43 0 1 86 1 0 0 0 0 0 0 0 0 0 0 X 23 23 0 0 0 0 0 0 0 1 1 0 0 1 1 1 1 1 1 1 1 0 CA AK AZ FL HI IL KS MD MA MI MN NJ NY OH OR PA SC UT VA WA AR MO NC NH AL CO CT GA KY LA ME MS ND NM OK TN WV WI RI DC X X PACIFIC LEGAL FOUNDATION 9164197111 930 G STREET SACRAMENTO CA 95814 JAMES L CLOUD TRUSTEE 1.00 X 0 0 0 GREG EVANS CHAIR OF THE BOARD 1.00 X X 0 0 0 LEONARD S FRANK SECRETARY-TREASURER 1.00 X X 0 0 0 WILLIAM E RYAN TRUSTEE 1.00 X 0 0 0 BRIAN G CARTWRIGHT VICE CHAIR 1.00 X X 0 0 0 GEORGE KIMBALL TRUSTEE 1.00 X 0 0 0 APRIL J MORRIS TRUSTEE 1.00 X 0 0 0 JERRY WP SCHAUFFLER TRUSTEE 1.00 X 0 0 0 BRUCE C SMITH TRUSTEE 1.00 X 0 0 0 CHARLES W TRAINOR TRUSTEE 1.00 X 0 0 0 RONALD E VAN BUSKIRK TRUSTEE 1.00 X 0 0 0 DONALD JOE WILLIS TRUSTEE 1.00 X 0 0 0 H DIXON MONTAGUE TRUSTEE 1.00 X 0 0 0 JEFFREY E WARREN TRUSTEE 1.00 X 0 0 0 AMY B BOULRIS TRUSTEE 1.00 X 0 0 0 ROSS BORBA JR TRUSTEE 1.00 X 0 0 0 JOHN C HARRIS TRUSTEE 1.00 X 0 0 0 ROBERT D CONNORS TRUSTEE 1.00 X 0 0 0 ALEXANDER F COHEN TRUSTEE 1.00 X 0 0 0 MICHAEL WINER TRUSTEE 1.00 X 0 0 0 ROBERT K BEST TRUSTEE 1.00 X 0 0 0 CAROL P LIEBAU TRUSTEE 1.00 X 0 0 0 JOHN YOO TRUSTEE 1.00 X 0 0 0 STEVEN D ANDERSON PRESIDENT & CEO 37.50 X 413247 0 8034 JAMES S BURLING DIR.LITIGATION,ASST SEC/TR 37.50 X 235681 0 21921 JOHN M GROEN EXECUTIVE VP & GENERAL COUNSEL 37.50 X 255943 0 30268 CHARLES WILCOX IV CHIEF OPERATING OFFICER 37.50 X 168654 0 4948 MREED HOPPER ATTORNEY 37.50 X 188346 0 29698 MERIEM HUBBARD ATTORNEY 37.50 X 179387 0 19840 TODD GAZIANO ATTORNEY 37.50 X 213058 0 19886 DAMIEN SCHIFF ATTORNEY 37.50 X 167995 0 23938 DEBORAH LAFETRA ATTORNEY 37.50 X 164333 0 19408 1986644 0 177941 23 0 1 0 EMERGENT ORDER LLC 3820 SOUTH CONGRESS AVENUE BLDG 2 AUSTIN TX 78704 MARKETING 378791 BLV AGRIBUSINESS 2945 CANONITA DRIVE FALLBROOK CA 920288771 PUBLIC RELATIONS 139322 2 96585 10062441 444800 10159026 COURT AWARDED ATTY FEES 541100 2356239 2356239 2356239 709586 709586 7021508 6797005 224503 224503 224503 22080 96585 107462 -85382 -85382 OTHER INCOME 541100 13271 13271 13271 13377243 2369510 0 848707 9000 9000 648928 504292 103311 41325 6276187 5031789 704051 540347 225407 165513 28217 31677 485685 364299 80611 40775 479961 341603 85158 53200 149498 9889 132628 6981 72663 72663 139322 139322 172934 11348 121552 40034 342609 273889 39943 28777 200958 117504 24038 59416 80110 41021 4692 34397 3903 3120 455 328 288907 230958 33682 24267 84126 67252 9808 7066 PRINTING & PUBLICATIONS 864321 755592 1558 107171 POSTAGE & SHIPPING 333789 109127 14928 209734 OTHER EXPENSES 222597 59855 153017 9725 LITIGATION EXPENSE 189628 189628 398251 308341 69263 20647 11668784 8594020 1679575 1395189 94268 47134 0 47134 2359874 1755259 54066 274090 1180407 2158862 158916 181885 5550903 1926307 3747020 3624596 39020056 43862702 1344184 1470461 47864523 53327855 128811 171387 1483832 1129199 1612643 1300586 X 43085968 48926378 2017624 1775804 1148288 1325087 46251880 52027269 47864523 53327855 X 1708459 4117673 -50743 X X 0 1 X 1 0 X 9115229 12991947 10150428 9809563 10159026 52226193 9115229 12991947 10150428 9809563 10159026 52226193 2610465 49615728 1140253 2831012 839090 857136 934089 6601580 5485 3517 45776 40099 13271 108148 58935921 3415292 0.84190 0.83490 X RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED RESTRICTED 37163941 3636806 4894060 109081 3558264 42027462 34398802 2457552 2660924 102698 2250639 37163941 31681783 3615011 -771897 -126095 34398802 33832814 1634236 1385878 5171145 31681783 27915635 3363705 3995356 1441882 33832814 0.96850 0.03150 0 0 900000 900000 3599895 1035480 2564415 1026769 866588 160181 24239 24239 0 3624596 MUTUAL FUNDS PRIMARILY INVESTED IN DEBT & EQUITY SECURITIES 35981753 F MONEY MARKET ACCOUNTS 2827639 F CORPORATE BONDS 2871260 F GOVERNMENTAL BONDS & SECURITIES 2182050 F 43862702 ACCRUED EXPENSES 368452 LIABILITY UNDER UNITRUST 715637 LEASES PAYABLE 19687 SECTION 125 LIABILITY 3757 ACCRUED BONUS 21500 403(B) LIABILITY 166 1129199 X 17444173 4117673 -50743 4066930 13377243 0 13377243 11668784 0 11668784 0 11668784 PART X, LINE 2: THE FOUNDATION HAS APPLIED THE ACCOUNTING PRINCIPLES RELATED TO ACCOUNTING FOR UNCERTAINTY IN INCOME TAXES AND HAS DETERMINED THAT THERE IS NO MATERIAL IMPACT ON THE CONSOLIDATED FINANCIAL STATEMENTS. WITH SOME EXCEPTIONS, THE FOUNDATION IS NO LONGER SUBJECT TO U.S. FEDERAL AND STATE INCOME TAX EXAMINATIONS BY TAX AUTHORITIES FOR YEARS PRIOR TO 2011. PART XI, LINE 2D - OTHER ADJUSTMENTS: CHANGE IN VALUE OF SPLIT INTEREST AGREEMENTS -50,743. X X X X X X 1 BLV AGRIBUSINESS CONSULTANTS 2945 CANONITA DRIVE FALLBROOK CA 920288771 PERSONAL CONTACT WITH INDIVIDUALS IN CA 0 1205976 139322 1066654 1205976 139322 1066654 AL AK AZ AR CA CO CT DE FL GA HI ID IL IN IA KS KY LA ME MD MA MI MN MS MO MT NE NV NH NJ NM NY NC ND OH OK OR PA RI SC SD TN TX UT VT VA WA WV WI WY DC NAPA EVENT 118225 96585 21640 71209 5 440 440 36253 118665 96585 22080 107462 107462 -85382 SCHEDULE G, PART I, LINE 2B, COLUMN (V) CONTRACTED AT AN HOURLY RATE FOR SERVICES UP TO A MAXIMUM CHARGE IN ANY ONE MONTH. MISCELLANEOUS COSTS WILL BE REIMBURSED. 1 EDUCATION STUDENT WRITING CONTEST-EDUCATION 3 9000 WRITING COMPETION, ARTICLES TO FURTHER PLF LEGAL & LITIGATION PROGRAM X X X X 0 0 0 0 0 0 0 0 0 STEVEN D ANDERSON PRESIDENT & CEO 413247 0 0 0 0 0 0 0 8034 0 421281 0 0 0 JAMES S BURLING DIR.LITIGATION,ASST SEC/TR 235681 0 0 0 0 0 9773 0 12148 0 257602 0 0 0 JOHN M GROEN EXECUTIVE VP & GENERAL COUNSEL 255943 0 0 0 0 0 10566 0 19702 0 286211 0 0 0 CHARLES WILCOX IV CHIEF OPERATING OFFICER 168654 0 0 0 0 0 0 0 4948 0 173602 0 0 0 MREED HOPPER ATTORNEY 188346 0 0 0 0 0 7904 0 21794 0 218044 0 0 0 MERIEM HUBBARD ATTORNEY 179387 0 0 0 0 0 7456 0 12384 0 199227 0 0 0 TODD GAZIANO ATTORNEY 213058 0 0 0 0 0 8787 0 11099 0 232944 0 0 0 DAMIEN SCHIFF ATTORNEY 167995 0 0 0 0 0 6929 0 17009 0 191933 0 0 0 DEBORAH LAFETRA ATTORNEY 164333 0 0 0 0 0 6863 0 12545 0 183741 0 0 0 X 23 224551 NYSE MARKET VALUE X 1 217951 APPRAISAL X WINE & FOOD 2 2298 FAIR MARKET VALUE 0 1 0 FORM 990, PART III, LINE 4A JISSER V. CITY OF PALO ALTO, CALIFORNIA. THE CITY REFUSED TO ALLOW THE JISSER FAMILY TO CLOSE THEIR MOBILE HOME PARK UNLESS THEY PAID MILLIONS OF DOLLARS TO THE TENANTS AS "MITIGATION" FOR HAVING TO MOVE. REPRESENTING THE JISSERS, PLF FILED A LAWSUIT IN FEDERAL COURT CHALLENGING THIS CONDITION AS AN UNCONSTITUTIONAL INFRINGEMENT ON THEIR PROPERTY RIGHTS. THE FEDERAL COURT DISMISSED THE LAWSUIT IN 2016 ON THE GROUNDS THAT THE JISSERS MUST FIRST EXHAUST POTENTIAL STATE COURT REMEDIES AND PLF APPEALED TO THE NINTH CIRCUIT AND FILED APPELLATE BRIEFS. THE CASE SETTLED. PLF DID NOT SEEK OR RECOVER FEES. KINDERACE LLC V. CITY OF SAMMAMISH, WASHINGTON. PLF REPRESENTS PROPERTY OWNERS CHALLENGING A CRITICAL AREA BUFFERS ORDINANCE THAT PRECLUDES DEVELOPMENT OF AN ENTIRE PARCEL AS AN UNCONSTITUTIONAL REGULATORY TAKING. THE CASE PRESENTS THE IMPORTANT ISSUE OF HOW TO DETERMINE THE "RELEVANT PARCEL" IN A CONSTITUTIONAL TAKINGS INQUIRY. AFTER AN ADVERSE RULING IN THE LOWER COURTS, PLF PETITIONED THE WASHINGTON SUPREME COURT FOR REVIEW. THE PETITION WAS DENIED AND PLF FILED A PETITION FOR WRIT OF CERTIORARI IN THE U.S. SUPREME COURT. THE PETITION WAS DENIED. PLF DID NOT SEEK OR RECOVER FEES. KNICK V. SCOTT TOWNSHIP, PENNSYLVANIA. A CITY ORDINANCE PERMITS UNRESTRICTED PUBLIC ACCESS TO ANY PRIVATE PROPERTY THAT MIGHT CONTAIN GRAVES AND AUTHORIZES TOWN AGENTS TO SEARCH THE PROPERTY FOR GRAVES WITHOUT ANY PROBABLY CAUSE TO BELIEVE THAT GRAVES ARE ON THE LAND. PLF REPRESENTS ROSE MARY KNICK, A SINGLE WOMAN WHO LIVES ALONE ON HER PROPERTY WHICH IS ALLEGED TO CONTAIN OLD GRAVES OF MEMBERS OF A NATIVE AMERICAN TRIBE. PLF SUED TO INVALIDATE THE LAW AS AN UNCONSTITUTIONAL INFRINGEMENT OF PROPERTY OWNERS' RIGHT TO EXCLUDE MEMBERS OF THE PUBLIC FROM THEIR LAND, AND A VIOLATION OF THE FOURTH AMENDMENT PROTECTION AGAINST WARRANTLESS SEARCHES. AFTER AN ADVERSE DECISION, PLF FILED A PETITION FOR WRIT OF CERTIORARI IN THE U.S. SUPREME COURT. BECAUSE THIS CASE IS ONGOING, IT IS PREMATURE TO SEEK FEES. LEVIN V. CITY AND COUNTY OF SAN FRANCISCO. PLF REPRESENTS RENTAL PROPERTY OWNERS WHO ARE REQUIRED BY A CITY ORDINANCE TO PAY UP TO HUNDREDS OF THOUSANDS OF DOLLARS TO THEIR TENANTS PRIOR TO EXERCISING THEIR RIGHT TO TAKE THEIR PROPERTY OFF THE MARKET. THE DISTRICT COURT STRUCK DOWN THE ORDINANCE AS VIOLATING THE FIFTH AMENDMENT'S TAKINGS CLAUSE AND THE CITY APPEALED. IN 2016, PLF SUCCESSFULLY DEFENDED THE TRIAL COURT VICTORY IN THE NINTH CIRCUIT COURT OF APPEALS. THE CITY PAID PLF ATTORNEYS' FEES IN THE AMOUNT OF $259,800. LYNCH V. CAL. COASTAL COMM'N. PLF REPRESENTS THE LYNCH FAMILY, WHICH SOUGHT A PERMIT FROM THE COMMISSION TO RECONSTRUCT A STORM-DAMAGED STAIRWAY FROM THEIR BLUFFTOP HOMES TO THE BEACH AND TO FIX A SEAWALL THAT PROTECTS THEIR HOME FROM EROSION. THE COMMISSION CONDITIONED THE PERMIT ON AN EXPIRATION DATE OF 20 YEARS, REQUIRING THE PROPERTY OWNERS TO REAPPLY FOR NEW PERMITS TO CONTINUE THE MAINTENANCE OF THEIR STAIRWAY AND SEAWALL. THE COURTS RULED AGAINST THE LYNCHES ON A "WAIVER" ARGUMENT THAT WAS NOT ARGUED BY THE PARTIES. PLF DID NOT SEEK OR RECOVER FEES. MARQUETTE COUNTY ROAD COMM'N V. U.S. ENVIRONMENTAL PROTECTION AGENCY. COUNTY ROAD 595 IS A PROPOSED 21-MILE ROUTE THAT WOULD ALLOW TRUCKS TO BYPASS BUSY CITY STREETS IN MARQUETTE COUNTY. AS PLANNED AND APPROVED BY STATE OFFICIALS, IT WOULD CUT AIR POLLUTION, INCREASE SAFETY, AND SAVE OVER 450,000 GALLONS OF FUEL YEARLY. YET EPA REGULATORS HAVE BUTTED IN AND IMPOSED A ROADBLOCK, WITH A CONTROVERSIAL CLAIM THAT CR 595 WOULD ADVERSELY IMPACT WETLANDS. PLF REPRESENTS THE COMMISSION TO ARGUE THAT WHERE EPA MAKES CLEAR IT WON'T APPROVE THE ROAD PROJECT NO MATTER WHAT ALTERNATIVES ARE POSED, THE UNRESOLVED EPA OBJECTION UNDER CLEAN WATER ACT SECTION 404(J) CONSTITUTES A FINAL AGENCY ACTION SUBJECT TO JUDICIAL REVIEW. AFTER AN ADVERSE TRIAL COURT DECISION, PLF APPEALED, FILING BRIEFS AND CONDUCTING ORAL ARGUMENT IN THE SIXTH CIRCUIT. BECAUSE THIS CASE IS PENDING, IT WOULD BE PREMATURE TO SEEK FEES. MURR V. STATE OF WISCONSIN. THE MURR SIBLINGS INHERITED TWO LAKEFRONT PARCELS BY THE ST. CROIX RIVER IN WISCONSIN. THEY SOUGHT TO SELL ONE PARCEL TO PAY FOR REPAIRS TO A CABIN ON THE OTHER PARCEL. THE GOVERNMENT FORBADE THE SALE OR ANY PRODUCTIVE USE OF THE VACANT PARCEL AND, TO AVOID LIABILITY FOR AN UNCONSTITUTIONAL TAKING, TREATED BOTH LOTS AS A SINGLE UNIFIED PARCEL. PLF REPRESENTED THE MURR FAMILY BEFORE THE U.S. SUPREME COURT, ARGUING THAT THE GOVERNMENT CANNOT TAKE PROPERTY WITHOUT COMPENSATION SIMPLY BECAUSE THE PROPERTY OWNERS ALSO HAPPEN TO OWN ADJACENT PROPERTY. THE SUPREME COURT RULED AGAINST THE MURRS. PLF DID NOT SEEK OR RECOVER FEES. NATIONAL FEDERATION OF INDEPENDENT BUSINESS V. DOUGHERTY. ON BEHALF OF A COALITION OF SMALL BUSINESS OWNERS, PLF SUED TO CHALLENGE THE SO-CALLED "FAIRFAX MEMO," DISTRIBUTED BY THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION TO ALTER FEDERAL LAW GOVERNING WORKPLACE SAFETY INSPECTIONS TO ALLOW UNION ORGANIZERS TO ACCOMPANY SAFETY INSPECTORS ONTO PRIVATE PREMISES. REPRESENTING NFIB MEMBERS, INCLUDING TWO TEXAS JANITORIAL COMPANIES, PLF ARGUED THAT THIS RULE VIOLATES THE AGENCY'S OWN REGULATIONS THAT REQUIRE UNION REPRESENTATIVES TO CONTRIBUTE IN A RELEVANT AND MEANINGFUL WAY TO THE INSPECTION'S PURPOSE. OSHA SUBSEQUENTLY VOLUNTARILY WITHDREW THE RULE AND PLF DISMISSED THE LAWSUIT. PLF DID NOT SEEK OR RECOVER FEES. NIES V. TOWN OF EMERALD ISLE, NORTH CAROLINA. PLF REPRESENTS A FAMILY CHALLENGING A NORTH CAROLINA STATUTE AND TOWN ORDINANCES THAT REDEFINE AN ENTIRE COASTLINE OF PRIVATELY-OWNED DRY BEACH PARCELS AS A "PUBLIC TRUST" AREA OPEN FOR PUBLIC DRIVING AND ACCESS AS AN UNCONSTITUTIONAL TAKING. ALL PROPERTY OWNERS HAVE A CONSTITUTIONAL RIGHT TO PROTECT THEIR PROPERTY FROM PUBLIC ACCESS AND TO MAINTAIN THEIR RIGHT OF PRIVACY IN THEIR HOMES. IN 2016, PLF REPRESENTED THE NIES FAMILY IN THE NORTH CAROLINA SUPREME COURT. AFTER BRIEFING WAS COMPLETED, THE COURT DISMISSED THE CASE WITH A ONE-LINE ORDER AND DID NOT REACH THE MERITS. PLF PETITIONED FOR A WRIT OF CERTIORARI IN THE U.S. SUPREME COURT. THE PETITION WAS DENIED. PLF DID NOT SEEK OR RECOVER FEES. PACETTA, LLC V. TOWN OF PONCE INLET. AT THE TOWN'S URGING, PACETTA, LLC PURCHASED SEVERAL ADJACENT LOTS OF LAND TO BUILD A MIXED-USE DEVELOPMENT. THE TOWN PROMISED TO AMEND THE LAND USE PLAN TO PERMIT THE PROJECT. ANTI-DEVELOPMENT CANDIDATES WON A MAJORITY AT THE NEXT TOWN COUNCIL MEETING AND THEN REFUSED TO AMEND THE TOWN'S PLAN, RENDERING PACETTA'S HOLDING VALUELESS. PLF SUPPORTED PACETTA AS AMICUS CURIAE THROUGH LOWER COURT PROCEEDINGS AND TOOK OVER DIRECT REPRESENTATION TO PETITION THE FLORIDA SUPREME COURT TO HEAR THIS CASE, WHICH PRESENTS IMPORTANT TAKINGS ISSUES UNDER BOTH STATE AND FEDERAL LAW. BECAUSE THIS CASE IS PENDING, IT WOULD BE PREMATURE TO SEEK FEES. P.I.E., LLC V. DESOTO COUNTY, FLORIDA. PLF REPRESENTS A PROPERTY OWNER ASSERTING A TAKING UNDER FLORIDA'S BERT J. HARRIS ACT. IN THIS CASE, THE OWNER PURCHASED PROPERTY BASED ON LOCAL GOVERNMENT ASSURANCES THAT HE COULD MINE THE LAND, ONLY TO HAVE THE GOVERNMENT REVERSE COURSE AND PASS A LAW PROHIBITING ALL MINING. THE OWNER SUBSEQUENTLY LOST THE LAND IN FORECLOSURE. PLF TOOK THIS CASE OVER ON APPEAL AND IT IS PENDING IN THE FLORIDA COURT OF APPEALS. BECAUSE THIS CASE IS PENDING, IT WOULD BE PREMATURE TO SEEK FEES. PRESERVE RESPONSIBLE SHORELINE MANAGEMENT V. CITY OF BAINBRIDGE ISLAND, WASHINGTON. PLF TOOK OVER REPRESENTATION OF A COALITION OF BAINBRIDGE ISLAND HOMEOWNERS TO CHALLENGE THE CITY'S SHORELINE REGULATIONS AS A VIOLATION OF MULTIPLE STATUTORY AND CONSTITUTIONAL PROVISIONS. BECAUSE THE CASE PRESENTS MANY OF THE ISSUES TO BE HEARD IN OLYMPIC STEWARDSHIP FOUNDATION V. DEPARTMENT OF ECOLOGY IN THE WASHINGTON COURT OF APPEALS, PLF SOUGHT AND RECEIVED A STAY OF THE LITIGATION. THE STAY WAS LIFTED IN 2017 AFTER THE COURT RULED AGAINST PROPERTY OWNERS IN OLYMPIC STEWARDSHIP FOUNDATION AND LITIGATION IS ONGOING. BECAUSE THIS CASE IS PENDING, IT WOULD BE PREMATURE TO SEEK FEES. RAFAELI, LLC V. OAKLAND COUNTY, MICHIGAN. AFTER FILING AN AMICUS BRIEF IN THE APPELLATE COURT, PLF TOOK OVER REPRESENTATION OF RAFAELI, LLC, AND ANDRE OHANESSIAN TO ASK THE MICHIGAN SUPREME COURT TO REVIEW A LOWER COURT DECISION THAT PERMITS COUNTIES TO CONFISCATE ENTIRE PROPERTIES TO SATISFY TAX DEBTS WITHOUT REFUNDING ANY OF THE SURPLUS PROCEEDS OF THE SALE TO THE FORMER OWNER. THIS CONFISCATION VIOLATES THE FEDERAL AND STATE CONSTITUTIONAL PROVISIONS THAT PROHIBIT THE GOVERNMENT FROM TAKING PRIVATE PROPERTY FOR PUBLIC USE WITHOUT JUST COMPENSATION. BECAUSE THIS CASE IS PENDING, IT WOULD BE PREMATURE TO SEEK FEES. FORM 990, PART III, LINE 4A SANTA BARBARA ASSOCIATION OF REALTORS V. CITY OF SANTA BARBARA. THE CITY OF SANTA BARBARA REQUIRES THAT ALL PERSONS WHO TRANSFER RESIDENTIAL PROPERTY SUBMIT AN APPLICATION FOR A ZONING INFORMATION REPORT (ZIR). THE APPLICATION WILL NOT BE APPROVED UNTIL A CITY ZONING INSPECTOR, WHO IS NEITHER A BUILDING INSPECTOR NOR A LICENSED SURVEYOR, CONDUCTS A WARRANTLESS ADMINISTRATIVE SEARCH OF THE INSIDE AND OUTSIDE OF THE RESIDENCE AND ANY OTHER STRUCTURES ON THE PROPERTY. THE CITY USES THIS PROCESS TO DISCOVER ZONING AND PERMITTING VIOLATIONS. PLF REPRESENTS LOCAL REALTORS IN A LAWSUIT CHALLENGING THESE REQUIREMENTS AS UNCONSTITUTIONAL CONDITIONS ON THE RIGHT TO PRIVACY UNDER THE FOURTH AMENDMENT. LITIGATION IS ONGOING IN THE TRIAL COURT. BECAUSE THIS CASE IS PENDING, IT WOULD BE PREMATURE TO SEEK FEES. ST. JOHNS RIVER MANAGEMENT DISTRICT, FLORIDA V. KOONTZ. KOONTZ SUED THE DISTRICT BECAUSE ITS OFF-SITE MITIGATION CONDITIONS TO A PERMIT VIOLATED THE FIFTH AMENDMENT'S TAKING CLAUSE. PLF ATTORNEYS REPRESENTED KOONTZ BEFORE THE UNITED STATES SUPREME COURT AND WON AN IMPORTANT RULING THAT THE DOCTRINES ESTABLISHED IN NOLLAN V. CAL. COASTAL COMM'N AND DOLAN V. TIGARD APPLY TO PERMITS CONDITIONED ON DEDICATIONS OF FEES AS WELL AS INTERESTS IN REAL PROPERTY. PLF SETTLED WITH THE DISTRICT TO RECOVER $800,000 IN FEES, RECEIVING $154,536.30 IN 2016 AND THE REMAINDER OF $645,463.70 IN OCTOBER, 2017. TRAUTWEIN V. CITY OF HIGHLAND, CALIFORNIA. PLF REPRESENTS KARL TRAUTWEIN, WHO OWNS RENTAL PROPERTY IN THE CITY OF HIGHLAND. THE CITY REQUIRES THAT OWNERS OF RENTAL PROPERTY REGISTER THE PROPERTY EVERY TWO YEARS AND THE REGISTRATION PROCESS REQUIRES THE CITY TO CONDUCT A WARRANTLESS INSPECTION OF THE PROPERTY. PLF SUED TO INVALIDATE THE WARRANTLESS ADMINISTRATIVE INSPECTIONS AS AN UNCONSTITUTIONAL CONDITION ON PROPERTY RIGHTS AND A VIOLATION OF THE FOURTH AMENDMENT RIGHTS OF TENANTS TO BE FREE OF UNREASONABLE SEARCHES. THE CITY AGREED TO CHANGE THE LAW AND THE CASE SETTLED. THE SETTLEMENT INCLUDED THE CITY'S PAYMENT OF $20,000 IN ATTORNEYS' FEES TO PLF. WAYSIDE CHURCH V. COUNTY OF VAN BUREN, MICHIGAN. IN MICHIGAN, WHEN LANDOWNERS FAIL TO PAY THEIR PROPERTY TAXES, LOCAL GOVERNMENTS TAKE THE PROPERTY, SELL IT, AND KEEP ALL THE PROFITS-NO MATTER HOW SMALL THE DEBT OR HOW VALUABLE THE PROPERTY. AS A RESULT, LOCAL GOVERNMENTS PROFIT HANDSOMELY OVER THE MISFORTUNE OF THEIR RESIDENTS. FOR EXAMPLE, A FEW YEARS AGO, WAYSIDE CHURCH LOST A PIECE OF LAND WORTH A LITTLE OVER $200,000. EVEN AFTER DEDUCTING OUTSTANDING TAX DEBTS, INTEREST, PENALTIES, AND FEES, VAN BUREN COUNTY MADE $189,250 IN PROFIT BY FORECLOSING AND AUCTIONING THE PROPERTY. HAVING LOST IN THE LOWER COURTS, PLF TOOK OVER REPRESENTATION OF WAYSIDE CHURCH AND OTHERS WHO HAVE LOST THEIR HOMES AND EQUITY TO FILE A PETITION FOR WRIT OF CERTIORARI IN THE U.S. SUPREME COURT. THE COURT DENIED THE PETITION. PLF DID NOT SEEK OR RECOVER FEES. YIM V. CITY OF SEATTLE. PLF REPRESENTS LANDOWNERS OF SMALL RENTAL PROPERTIES IN A CHALLENGE TO SEATTLE'S "FIRST IN TIME" RENTAL ORDINANCE THAT REQUIRES THEM TO RENT THEIR PROPERTY TO THE FIRST QUALIFIED APPLICANT. THIS DEPRIVATION OF THE OWNERS' RIGHT TO CHOOSE THEIR TENANTS TAKES AN IMPORTANT ELEMENT OF THEIR PROPERTY RIGHTS, IN VIOLATION OF THE FIFTH AMENDMENT'S PROTECTION AGAINST TAKINGS WITHOUT JUST COMPENSATION. TRIAL LEVEL LITIGATION IS ONGOING. BECAUSE THIS CASE IS PENDING, IT WOULD BE PREMATURE TO SEEK FEES. PROCEDURAL GUARANTEES: THE CONSTITUTION ESTABLISHES A SEPARATION OF POWERS AND EXPRESS GUARANTEES OF DUE PROCESS. THE FIGHT FOR LIBERTY IS OFTEN A MATTER OF ENSURING THAT THOSE WHO GOVERN US DO NOT EXCEED THEIR CONSTITUTIONALLY LIMITED AUTHORITY WHEN ENACTING AND ENFORCING THE LAW. PLF FIGHTS TO END THE MODERN ADMINISTRATIVE STATE, INCLUDING LIMITING JUDICIAL DEFERENCE TO LEGISLATIVE AND ADMINISTRATIVE JUDGMENTS; RESTORE SEPARATION OF POWERS AGAINST IMPROPER DELEGATION OF AUTHORITY TO BUREAUCRATS; DEFINE THE LIMITED SCOPE OF FEDERAL POWER UNDER THE COMMERCE CLAUSE; REVIVE THE DOCTRINE OF ENUMERATED POWERS; AND ENSURE DUE PROCESS OF LAW. AMERICAN FEDERATION OF AVICULTURE V. U.S. FISH AND WILDLIFE SERVICE. REPRESENTING THE AMERICAN FEDERATION OF AVICULTURE, A NONPROFIT THAT EDUCATES THE PUBLIC AND REPRESENTS THE INTERESTS OF BIRD OWNERS AND BREEDERS, PLF FILED A COMPLAINT IN THE DISTRICT COURT FOR THE DISTRICT OF COLUMBIA TO FORCE THE U.S. FISH AND WILDLIFE SERVICE TO OBEY THE LAW AND ISSUE A DECISION ON THE PETITION TO REMOVE THE GOLDEN PARAKEET FROM THE LIST OF PROTECTED SPECIES UNDER THE ENDANGERED SPECIES ACT. THE GOVERNMENT DEMANDED 41 MONTHS TO DO WHAT THE LAW REQUIRES BE DONE IN 12. WHILE THE FEDERAL GOVERNMENT HAS LIMITED RESOURCES AND MANY SPECIES TO REVIEW, DELISTING THE GOLDEN PARAKEET SHOULD BE DONE PROMPTLY AND IN ACCORDANCE WITH THE LAW. DELISTING THE BIRD WOULD ALLOW AFA'S BREEDERS TO CONTINUE AND EXPAND THEIR CONSERVATION EFFORTS AND FREE THE GOVERNMENT TO FOCUS ON SPECIES THAT ARE ACTUALLY IN DANGER OF EXTINCTION. THE CASE SETTLED AND PLF RECOVERED $469.72 IN COSTS (NO ATTORNEYS' FEES). BONNER COUNTY V. ZINKE. REPRESENTING BONNER COUNTY, IDAHO, AND THE IDAHO SNOWMOBILE ASSOCIATION, PLF SUBMITTED A 60-DAY LETTER OF INTENT TO SUE TO THE AGENCY REGARDING THE U.S. FISH AND WILDLIFE SERVICE'S PROPOSAL TO LIST THE SOUTHERN SELKIRK MOUNTAIN POPULATION OF WOODLAND CARIBOU AS A DISTINCT POPULATION SEGMENT REQUIRING CRITICAL HABITAT DESIGNATION. SUCH DESIGNATIONS PLACE SEVERE RESTRICTIONS ON OTHER LAND USES. THIS LITIGATION IS ON HOLD PENDING GOVERNMENT ACTION. CALIFORNIA CATTLEMEN'S ASS'N V. CALIFORNIA FISH AND GAME COMM'N. PLF REPRESENTS RANCHERS AND FARMERS IN A CHALLENGE TO A STATE ENDANGERED SPECIES LISTING FOR THE GRAY WOLF. THE LISTING HAMSTRINGS LANDOWNERS' EFFORTS TO SAFEGUARD THEIR LIVESTOCK AND THEIR LIVELIHOODS AGAINST THE PREDATORY WOLVES. THE CALIFORNIA LISTING VIOLATES STATE AND FEDERAL LAW BY CONSIDERING ONLY THE NUMBER OF WOLVES WITHIN CALIFORNIA RATHER THAN THE SPECIES' OVERALL NUMBERS THROUGHOUT ITS RANGE IN MUCH OF THE WEST AND NORTHERN MIDWEST. THE LITIGATION IS ONGOING IN THE SAN DIEGO SUPERIOR COURT. BECAUSE THE CASE IS PENDING, IT IS PREMATURE TO SEEK FEES. CALIFORNIA CATTLEMEN'S ASS'N V. CALIFORNIA DEPT. OF FISH AND WILDLIFE. REPRESENTING THE CATTLEMEN'S ASSOCIATION, PLF FILED A PETITION FOR WRIT OF MANDAMUS TO HAVE DECLARED UNLAWFUL THE DEPARTMENT'S FAILURE TO CONDUCT 5-YEAR STATUS REVIEWS OF 233 SPECIES LISTED AS "ENDANGERED OR "THREATENED" UNDER THE CALIFORNIA ENDANGERED SPECIES ACT. BY ABDICATING THESE MANDATORY REVIEWS, THE STATE UNLAWFULLY FAILED TO DETERMINE WHICH SPECIES COULD BE DOWNLISTED, THUS RESTORING GREATER USE OF PROPERTY TO THE LANDOWNERS. TRIAL LEVEL LITIGATION IS ONGOING. BECAUSE THIS CASE IS PENDING, IT WOULD BE PREMATURE TO SEEK FEES. CALIFORNIA CATTLEMEN'S ASS'N V. U.S. FISH AND WILDLIFE SERVICE. PLF REPRESENTS PARTIES CHALLENGING THE DESIGNATION OF CRITICAL HABITAT FOR TWO SPECIES OF THE YELLOW-LEGGED FROG AND YOSEMITE TOAD. THE DESIGNATION COVERS OVER 1.8 MILLION ACRES IN 16 CALIFORNIA COUNTIES. AMONG OTHER THINGS, THE RULE RESTRICTS THE USE OF PUBLIC AND PRIVATE LANDS FOR GRAZING AND TIMBER HARVESTING IMPERILING THE LIVELIHOOD OF FARMERS, RANCHERS, LANDOWNERS, AND LOCAL ENTERPRISES DEPENDENT ON THESE ACTIVITIES. EVEN SCHOOLS ARE AFFECTED THAT DERIVE INCOME FROM TIMBER PRODUCTION. BUT THE FISH AND WILDLIFE SERVICE REFUSED TO CONSIDER THESE IMPACTS OR PROVIDE THE ALTERNATIVES ANALYSIS THE RFA REQUIRES ASSERTING ITS CRITICAL HABITAT REGULATIONS ONLY AFFECT OTHER FEDERAL AGENCIES AND NOT SMALL ENTITIES. TRIAL LEVEL LITIGATION IS ONGOING. BECAUSE THIS CASE IS PENDING, IT WOULD BE PREMATURE TO SEEK FEES. CALIFORNIA SEA URCHIN COMM'N V. JACOBSON. A FEDERAL STATUTE REQUIRES THE U.S. FISH AND WILDLIFE SERVICE TO EXEMPT LAWFUL FISHING ACTIVITIES FROM THE BROAD PROHIBITIONS AGAINST THE INCIDENTAL TAKING OF SEA OTTERS. WHEN THE SERVICE IGNORED THIS CONGRESSIONAL BALANCING OF INTERESTS, PLF SUED ON BEHALF OF SEA URCHIN AND ABALONE DIVERS, LOBSTER TRAPPERS, AND OTHER FISHERMEN WHOSE LIVELIHOOD ARE THREATENED BY SERVICE'S UNILATERAL TERMINATION OF PROTECTION FOR LAWFUL FISHING ACTIVITIES. AFTER LOSING ON SUMMARY JUDGMENT, PLF APPEALED TO THE NINTH CIRCUIT, COMPLETED ALL BRIEFING AND CONDUCTED ORAL ARGUMENT. BECAUSE THIS CASE IS ONGOING, IT IS PREMATURE TO SEEK FEES. CASCADIA WILDLANDS V. OREGON DEPT. OF FISH AND WILDLIFE. PLF INTERVENED ON BEHALF OF THE OREGON CATTLEMEN'S ASSOCIATION AND THE OREGON FARM BUREAU FEDERATION IN DEFENSE OF THE STATE'S DELISTING OF THE GRAY WOLF UNDER THE OREGON ENDANGERED SPECIES LAW. THE LEGISLATURE RATIFIED THE DELISTING, AND THE DEFENDANTS AND INTERVENORS FILED A SUGGESTION OF MOOTNESS, AFTER WHICH THE TRIAL COURT DISMISSED THE LAWSUIT. THE APPELLATE COURT GRANTED THE PLAINTIFFS' PERMISSION TO REINSTATE THEIR APPEAL AND LITIGATION CONTINUES IN THE APPELLATE COURT. BECAUSE THE CASE IS PENDING, IT IS PREMATURE TO SEEK FEES. FORM 990, PART III, LINE 4A CENTER FOR BIOLOGICAL DIVERSITY (CBD) V. ZINKE. CBD SUED THE SECRETARY OF THE INTERIOR BECAUSE CONGRESS USED THE CONGRESSIONAL REVIEW ACT TO RESCIND AN ALASKA WILDLIFE RULE. PLF REPRESENTS ALASKAN SPORTSMEN AND OTHER PARTIES AS INTERVENORS IN SUPPORT OF THE CONSTITUTIONALITY OF THE CONGRESSIONAL REVIEW ACT AND IN SUPPORT OF THE RULE'S RESCISSION. TRIAL LEVEL LITIGATION IS ONGOING. BECAUSE THIS CASE IS PENDING, IT WOULD BE PREMATURE TO SEEK FEES. CENTER FOR ENVIRONMENTAL SCIENCE, ACCURACY AND RELIABILITY V. U.S. DEPT. OF INTERIOR. ON BEHALF OF A BROAD COALITION OF HOME BUILDERS, SOUND SCIENCE, AND PROPERTY RIGHTS ADVOCATES, PLF SUED THE DEPARTMENT OF INTERIOR IN FEDERAL COURT OVER THE AGENCY'S REFUSAL TO DELIST THE COASTAL CALIFORNIA GNATCATCHER FROM THE ENDANGERED SPECIES ACT. THE SERVICE'S DENIAL VIOLATES THE ENDANGERED SPECIES ACT BECAUSE IT FAILS TO ARTICULATE ANY DEFINITION OR STANDARD FOR DETERMINING WHY THE GNATCATCHER PURPORTEDLY CONSTITUTES ITS OWN SUBSPECIES. IT ALSO VIOLATES THE FEDERAL ADVISORY COMMITTEE ACT BECAUSE THE PUBLIC RECEIVED NO NOTICE OR OPPORTUNITY TO PARTICIPATE IN THE PRIVATELY CONVENED PEER REVIEW PANEL, THE FINAL REPORT OF WHICH HEAVILY INFLUENCED THE AGENCY'S DECISION TO REJECT THE DELISTING PETITION. BECAUSE THE CASE IS ONGOING, IT IS PREMATURE TO SEEK FEES. DUARTE NURSERY V. U.S. ARMY CORPS OF ENGINEERS. PLF REPRESENTS JOHN DUARTE AND DUARTE NURSERY, WHICH ALLEGEDLY VIOLATED THE CLEAN WATER ACT WHEN HE PLOWED A DRY FIELD THAT THE GOVERNMENT INSISTS SHOULD BE CONSIDERED A WETLAND, EVEN THOUGH THE ACT EXEMPTS NORMAL FARMING PRACTICES. HE SUED ON THE GROUNDS THAT THE GOVERNMENT VIOLATED HIS PROPERTY RIGHTS AND DUE PROCESS RIGHTS AND THE GOVERNMENT RETALIATED BY FILING A COUNTERCLAIM AGAINST HIM. PLF ARGUES THAT THIS COUNTERCLAIM WAS RETALIATORY AND VIOLATES DUARTE'S FIRST AMENDMENT RIGHT TO PETITION HIS GOVERNMENT. THE CASE SETTLED ON THE EVE OF TRIAL. PLF DID NOT SEEK OR RECOVER FEES. FOSTER V. VILSACK. REPRESENTING THE FOSTER FAMILY, PLF FILED A PETITION FOR WRIT OF CERTIORARI IN THE U.S. SUPREME COURT TO CHALLENGE THE U.S. DEPARTMENT OF AGRICULTURE'S ILLEGAL DETERMINATION THAT 0.8 ACRE OF THEIR SOUTH DAKOTA FARM WAS A FEDERALLY PROTECTED WETLAND THAT THEY COULD NO LONGER FARM. THE CASE RAISED THE IMPORTANT ISSUE OF WHETHER JUDGES SHOULD INTERPRET FEDERAL LAW OR WHETHER JUNIOR BUREAUCRATS COULD ISSUE BINDING INTERPRETATIONS. THE PETITION WAS DENIED. PLF DID NOT SEEK OR RECOVER FEES. GRANAT V. U.S. DEPT. OF AGRICULTURE. REPRESENTING INDIVIDUALS, OUTDOOR-RECREATION ORGANIZATIONS, AND TWO COUNTIES, PLF SUED THE FEDERAL GOVERNMENT TO INVALIDATE A FOREST SERVICE ORDER THAT PROHIBITS MOTORIZED VEHICLES ON THOUSANDS OF PREVIOUSLY ACCESSIBLE TRAILS IN THE PLUMAS NATIONAL FOREST WITHOUT FULFILLING THE PROCEDURAL REQUIREMENTS OF BOTH THE NATIONAL ENVIRONMENTAL PROCEDURE ACT AND THE FOREST SERVICE'S OWN TRAVEL MANAGEMENT RULE. HAD THE FOREST SERVICE FOLLOWED THE LAW, IT WOULD HAVE COORDINATED WITH ALL INTERESTED PARTIES BEFORE DETERMINING HOW BEST TO BALANCE THE ENVIRONMENTAL NEEDS OF THE FOREST WITH THE NEEDS OF DISABLED AND OTHER PEOPLE TO ACCESS THESE PUBLIC LANDS WITH MOTORIZED TRANSPORT. THE TRIAL COURT UPHELD THE ORDER AND THE CASE IS NOW ON APPEAL. BRIEFING CONTINUED THROUGH 2017. BECAUSE THE CASE IS ONGOING, IT IS PREMATURE TO SEEK FEES. IN RE PETITION TO DELIST THE PREBLE'S MEADOW JUMPING MOUSE. ON BEHALF OF A BROAD COALITION OF SOUND SCIENCE AND PROPERTY RIGHTS ADVOCATES, PLF PETITIONED THE FEDERAL GOVERNMENT TO DELIST THE PREBLE'S MEADOW JUMPING MOUSE FROM THE ENDANGERED SPECIES ACT. THE PREBLE'S MOUSE HAS BEEN CONSIDERED ITS OWN SUBSPECIES SINCE THE 1950S, AND HAS BEEN LISTED AS THREATENED SINCE 1998. BUT FOR ALMOST ITS ENTIRE TENURE UNDER THE ENDANGERED SPECIES ACT, THE MOUSE HAS ATTRACTED CONSIDERABLE CONTROVERSY. ONE REASON IS THE SIGNIFICANT NEGATIVE ECONOMIC IMPACT THAT THE LISTING IMPOSES ON PROPERTY OWNERS IN WYOMING AND COLORADO, ESTIMATED TO BE OVER $200 MILLION OVER TWENTY YEARS. ANOTHER REASON IS THE RATHER SLIM SCIENTIFIC BASIS FOR THE SERVICE'S CONCLUSION THAT THE MOUSE COMPRISES ITS OWN LISTABLE SUBSPECIES. BECAUSE THE CASE IS ONGOING, IT IS PREMATURE TO SEEK FEES. IN RE TAXONOMY RULE-MAKING PETITION. ON BEHALF OF AN ARRAY OF AGRICULTURAL INTERESTS, PROPERTY OWNERS, AND SCIENCE-BASED ADVOCACY GROUPS, PLF PETITIONED THE SECRETARIES OF INTERIOR AND COMMERCE AND THEIR DELEGATES THE UNITED STATES FISH AND WILDLIFE SERVICE AND THE NATIONAL MARINE FISHERIES SERVICE TO PRODUCE REGULATORY DEFINITIONS FOR THE TERMS "SPECIES AND "SUBSPECIES" AS USED IN THE ENDANGERED SPECIES ACT. THE GOVERNMENT HAS NOT YET ACTED ON THE PETITION. BECAUSE THIS CASE IS ONGOING, IT IS PREMATURE TO SEEK FEES. JOHNSON V. ENVIRONMENTAL PROTECTION AGENCY. PLF REPRESENTS ANDY JOHNSON, A WYOMING FARMER WHO CREATED A STOCK POND ON HIS LAND TO WATER HIS LIVESTOCK. THE CLEAN WATER ACT EXPRESSLY PERMITS THE CREATION OF SUCH STOCK PONDS, YET THE ENVIRONMENTAL PROTECTION AGENCY ISSUED A COMPLIANCE ORDER DEMANDING THAT JOHNSON FILL IN THE POND AND MAKE OTHER REMEDIATION TO THE LAND TO RESTORE IT TO ITS PRIOR CONDITION. IN 2016, THE CASE WAS RESOLVED BY A CONSENT DECREE. PLF CONTINUED TO MONITOR COMPLIANCE IN 2017. PLF DID NOT SEEK OR RECOVER FEES. MARKLE INTERESTS, LLC V. U.S. FISH AND WILDLIFE SERVICE. PLF FILED A LAWSUIT ON BEHALF OF MARKLE INTERESTS AND OTHER BUSINESSES CHALLENGING A CRITICAL HABITAT DESIGNATION FOR THE DUSKY GOPHER FROG THAT INCLUDED LAND WHERE THE FROG DID NOT LIVE AND COULD NOT LIVE WITHOUT SUBSTANTIAL MODIFICATIONS TO THE LAND THAT THE SERVICE HAS NO POWER TO DEMAND. THE FIFTH CIRCUIT UPHELD THE DESIGNATION, VASTLY EXPANDING THE AREA THAT MAY BE DESIGNATED AS CRITICAL HABITAT AND REDUCING THE ABILITY OF PROPERTY OWNERS TO MAKE PRODUCTIVE USE OF THEIR LAND. IN 2016, PLF FILED A PETITION FOR REHEARING EN BANC. THE PETITION WAS DENIED IN 2017 AND PLF FILED A PETITION FOR A WRIT OF CERTIORARI IN THE U.S. SUPREME COURT. BECAUSE THIS CASE IS PENDING, IT IS PREMATURE TO SEEK FEES. MASSACHUSETTS LOBSTERMEN'S ASSOCIATION V. ROSS. REPRESENTING FISHERMAN AND LOBSTERMEN WHO ARE LOCKED OUT OF VALUABLE FISHING GROUNDS, PLF FILED A COMPLAINT IN FEDERAL DISTRICT COURT TO CHALLENGE PRESIDENT OBAMA'S NORTHEAST CANYONS AND SEAMOUNTS MARINE NATIONAL MONUMENT DESIGNATION UNDER ANTIQUITIES ACT. AN AREA IN THE OCEAN THE SIZE OF CONNECTICUT CANNOT QUALIFY AS A MONUMENT - WHICH THE ACT DESCRIBES AS BEING THE SMALLEST POSSIBLE AREA OF LAND NECESSARY TO PRESERVE AN IMPORTANT RESOURCE. THE MONUMENT DESIGNATION ALSO THREATENS TO UNDERMINE YEARS' WORTH OF EFFORT BY OUR CLIENTS TO PROMOTE SUSTAINABLE FISHING IN THE REGION. BY SHUTTING OFF THE AREA TO FISHERMEN, THE PROCLAMATION FORCES THEM TO RELOCATE FROM THIS HEALTHY FISHERY TO OTHER AREAS THAT ARE LESS SUSTAINABLE. THE CASE IS STAYED PENDING EXECUTIVE ACTION. BECAUSE THIS CASE IS PENDING, IT IS PREMATURE TO SEEK FEES. MORNING STAR PACKING CO. V. CALIFORNIA AIR RESOURCES BOARD. PLF REPRESENTS A COALITION OF CALIFORNIA CITIZENS AND TRADE ASSOCIATIONS CHALLENGING THE AIR RESOURCES BOARD'S CAP-AND-TRADE EMISSIONS AUCTIONS ON THE GROUNDS THAT SUCH AUCTIONS ARE ILLEGAL TAXES UNDER THE STATE CONSTITUTION. THE TAX IS PART OF A RATIONING SCHEME THAT LIMITS CALIFORNIANS' USE OF GASOLINE, DIESEL, COAL, AND NATURAL GAS. THE AUCTION PROCEEDS ARE SPENT ON SPECIAL PROJECTS LIKE HIGH-SPEED RAIL. IN 2016, PLF SUBMITTED BRIEFS TO THE CALIFORNIA COURT OF APPEAL, WHICH ISSUED AN ADVERSE DECISION IN 2017. PLF FILED A PETITION FOR REVIEW IN THE CALIFORNIA SUPREME COURT, WHICH WAS DENIED. PLF DID NOT SEEK OR RECOVER FEES. NEW MEXICO FARM AND LIVESTOCK BUREAU V. JEWELL. PLF CHALLENGED A CRITICAL HABITAT DESIGNATION FOR JAGUAR IN NEW MEXICO ON BEHALF OF PROPERTY OWNERS, FARMERS, AND RANCHERS WHOSE PROPERTY WAS ADVERSELY AFFECTED BY THE DESIGNATION. THE DESIGNATION DID NOT COMPLY WITH GOVERNING STATUTES BECAUSE THERE WAS NO EVIDENCE THAT THE JAGUAR LIVED IN THE DESIGNATED AREAS AT THE TIME OF THE LISTING. IN 2017, PLF CONCLUDED BRIEFING ON A MOTION FOR SUMMARY JUDGMENT IN THE TRIAL COURT. AFTER THE DISTRICT COURT ISSUED AN ADVERSE DECISION, PLF APPEALED. BECAUSE THIS CASE IS PENDING, IT IS PREMATURE TO SEEK FEES. OTERO COUNTY CATTLEMEN'S ASSOCIATION V. U.S. FISH AND WILDLIFE SERVICE. REPRESENTING THE NORTHERN NEW MEXICO STOCKMAN'S ASSOCIATION AND THE OTERO COUNTY CATTLEMEN'S ASSOCIATION, PLF NOTIFIED THE SERVICE OF ITS INTENT TO SUE TO CHALLENGE THE DESIGNATION OF CRITICAL HABITAT FOR THE NEW MEXICO MEADOW JUMPING MOUSE. THE DESIGNATION IS ILLEGAL BECAUSE THE SERVICE FAILED TO PROPERLY CONSIDER THE ECONOMIC IMPACTS OF THE DESIGNATION PRIOR TO ADOPTING THE FINAL RULE. THE SERVICE ALSO FAILED TO EXCLUDE ANY AREAS FROM THE DESIGNATION BASED ON THE SUBSET OF ECONOMIC IMPACTS THAT IT DID CONSIDER. BECAUSE THIS CASE IS ONGOING, IT IS PREMATURE TO SEEK FEES. FORM 990, PART III, LINE 4A PEOPLE V. RINEHART. CALIFORNIA BANS SUCTION DREDGE MINING, EVEN ON FEDERAL LANDS, DESPITE THE FACT THAT CONGRESS ENCOURAGES MINING ON FEDERAL LANDS, AS IT HAS FOR MORE THAN 150 YEARS. THE SUPREME COURT HAS HELD THAT STATES CAN SUPPLEMENT FEDERAL REGULATION OF MINING TO ADDRESS ENVIRONMENTAL IMPACTS. BUT CALIFORNIA CHOSE TO BAN SUCTION DREDGE MINING ENTIRELY. BY TAKING THAT UNPRECEDENTED STEP, CALIFORNIA WENT CROSSED THE LINE BETWEEN SUPPLEMENTING FEDERAL LAW (PERMITTED) AND FRUSTRATING IT (PREEMPTED). THIS CASE WILL DETERMINE HOW CONFLICTS OVER FEDERAL LAND USE WILL BE RESOLVED, THE FUTURE OF ENVIRONMENTAL FEDERALISM, AND THE INCOMES OF MINERS THROUGHOUT THE COUNTRY. REPRESENTING BRANDON RINEHART, PLF FILED A PETITION FOR WRIT OF CERTIORARI ASKING THE SUPREME COURT OF THE UNITED STATES TO DECIDE WHETHER STATES CAN FRUSTRATE FEDERAL LAW BY BANNING FEDERALLY ENCOURAGED ACTIVITIES, LIKE MINING, ON FEDERAL LANDS. BECAUSE THE CASE IS ONGOING, IT IS PREMATURE TO SEEK FEES. PEOPLE FOR THE ETHICAL TREATMENT OF PROPERTY OWNERS V. U.S. FISH AND WILDLIFE SERVICE. BURDENSOME FEDERAL REGULATIONS PREVENT SOUTHEASTERN UTAHANS FROM BUILDING HOMES, STARTING BUSINESSES, OR OTHERWISE USING THEIR PROPERTY IN ORDER TO PROTECT THE UTAH PRAIRIE DOG. BECAUSE THE PRAIRIE DOG LIVES ONLY IN UTAH AND HAS NO COMMERCIAL VALUE, PLF REPRESENTS PROPERTY OWNERS IN A CHALLENGE TO THE REGULATIONS, ARGUING THAT THEY VIOLATE THE CONSTITUTION'S COMMERCE CLAUSE. THE DISTRICT COURT RULED THE REGULATIONS UNCONSTITUTIONAL AND THE GOVERNMENT APPEALED. THE TENTH CIRCUIT COURT OF APPEALS ISSUED AN ADVERSE DECISION AND, IN 2017, PLF FILED A PETITION FOR WRIT OF CERTIORARI IN THE U.S. SUPREME COURT. BECAUSE THE CASE IS ONGOING, IT IS PREMATURE TO SEEK FEES. PETITION RE COASTAL COMMISSION'S SHORELINE PROTECTIVE DEVICE POLICY. REPRESENTING THE COASTAL RIGHTS COMMISSION, PLF FILED A PETITION WITH CALIFORNIA'S OFFICE OF ADMINISTRATIVE LAW CHALLENGING THE STATE COASTAL COMMISSION'S UNDERGROUND REGULATIONS ENACTED WITHOUT PUBLIC NOTICE AND COMMENT IN VIOLATION OF THE COASTAL ACT AND THE ADMINISTRATIVE PROCEDURES ACT. THE CHALLENGED POLICY REQUIRES COASTAL PROPERTY OWNERS TO FORFEIT THEIR RIGHT TO BUILD A SHORELINE PROTECTIVE DEVICE (SUCH AS A SEAWALL OR BLUFF STABILIZATION DEVICE) AS A CONDITION TO OBTAINING A COASTAL DEVELOPMENT PERMIT. BECAUSE THIS ACTION IS ONGOING, IT WOULD BE PREMATURE TO SEEK FEES. SACKETT V. ENVIRONMENTAL PROTECTION AGENCY. AFTER WINNING THE RIGHT FOR THE SACKETTS TO GO TO COURT TO CHALLENGE THE EPA'S ASSERTION OF JURISDICTION OVER ALLEGED WETLANDS ON THEIR PROPERTY IN THE U.S. SUPREME COURT, PLF CONTINUED IN 2017 TO REPRESENT THE SACKETTS ON REMAND. PLF FILED A MOTION FOR SUMMARY JUDGMENT SEEKING A RULING THAT THE SACKETTS' PROPERTY DOES NOT CONTAIN WETLANDS SUBJECT TO REGULATION UNDER THE CLEAN WATER ACT. BECAUSE THIS CASE IS PENDING, IT IS PREMATURE TO SEEK FEES. SAVE CRYSTAL RIVER, INC. V. U.S. FISH AND WILDLIFE SERVICE. REPRESENTING A COALITION OF CRYSTAL RIVER, FLORIDA, RESIDENTS, PLF PETITIONED THE U.S. FISH AND WILDLIFE SERVICE TO COMPLY WITH ITS OWN FINDINGS AND DOWNLIST THE WEST INDIAN MANATEE FROM AN ENDANGERED TO THREATENED SPECIES. IN 2016, THE GOVERNMENT PROPOSED A TIMETABLE TO ISSUE A RULE TO RECLASSIFY THE MANATEE. IT FAILED TO DO SO, AND IN 2017 PLF PREPARED A NEW 60-DAY NOTICE THAT IT WOULD SUE TO ENFORCE THE LAW. THIS LITIGATION BENEFITS THE GENERAL PUBLIC BY EASING RESTRICTIONS ON THE WATERS THEY SEEK TO USE THAT ARE SHARED WITH THE MANATEE AND BY ENSURING THAT GOVERNMENT AGENCIES COMPLY WITH THEIR OWN FINDINGS AND THEIR STATUTORY OBLIGATIONS. THE MANATEES WERE DOWNLISTED ON APRIL 5, 2017. PLF DID NOT SEEK OR RECOVER FEES. TIN CUP, LLC V. U.S. ARMY CORPS OF ENGINEERS. REPRESENTING TIN CUP, A FAMILY-OWNED PIPE FABRICATION BUSINESS, PLF FILED A LAWSUIT CHALLENGING THE "ALASKA SUPPLEMENT" TO THE CORPS' OF ENGINEERS' 1987 WETLANDS DELINEATION MANUAL, ARGUING THAT IT FAILS TO PROVIDE A LEGALLY ADEQUATE STANDARD FOR DETERMINING THE PRESENCE OF WETLANDS UNDER THE CLEAN WATER ACT. PLF ARGUES THAT THE CORPS IMPROPERLY ASSERTED JURISDICTION OVER 200 ACRES OF PERMAFROST ON TIN CUP'S PROPERTY BASED ON AGENCY-PROMULGATED REGIONAL "SUPPLEMENTS" THAT PURPORT TO EXPAND THE CORPS' JURISDICTION OVER VAST SWATHS OF ALASKA. THE DISTRICT COURT UPHELD THE GOVERNMENT ACTION AND PLF APPEALED TO THE NINTH CIRCUIT. BECAUSE THE CASE IS PENDING, IT IS PREMATURE TO SEEK FEES. TOWN OF COOS BAY V. ROSS. THE FEDERAL GOVERNMENT IS TWISTING ENVIRONMENTAL AND EMERGENCY MANAGEMENT LAW TO IMPOSE FEDERAL ZONING CONTROL OVER OREGON'S COASTAL REGIONS AND MUCH OF THE REST OF THE STATE. IN ORDER TO BE ELIGIBLE FOR FEDERAL FLOOD INSURANCE, LOCAL COMMUNITIES WOULD HAVE TO ABSTAIN FROM ECONOMIC DEVELOPMENT-PURPORTEDLY TO PROTECT CERTAIN ENDANGERED SPECIES, EVEN THOUGH, AS A MATTER OF LAW, FEMA AND ITS FLOOD INSURANCE PROGRAM HAVE NO IMPACT ON SPECIES WHATSOEVER. IF FEDERAL BUREAUCRATS CAN MISUSE AN INSURANCE PROGRAM TO TURN THEMSELVES INTO A SUPER ZONING BOARD, ISSUING DECREES HAVING NOTHING TO DO WITH FLOOD CONTROL AND SAFETY, THEY COULD TRY IT IN ANY COMMUNITY WHERE THE PROGRAM OPERATES. PLF REPRESENTS THE TOWN OF COOS BAY IN A LAWSUIT TO TAKE BACK DECISION-MAKING POWER. TRIAL LEVEL LITIGATION IS STAYED PENDING ACTION IN A RELATED CASE. BECAUSE THIS CASE IS PENDING, IT WOULD BE PREMATURE TO SEEK FEES. UNIVERSAL WELDING, INC. V. U.S. ARMY CORPS OF ENGINEERS. PLF REPRESENTS A STEEL AND PIPE FABRICATION BUSINESS IN A CHALLENGE TO CLEAN WATER ACT JURISDICTION OVER ISOLATED WETLANDS IN FAIRBANKS, ALASKA. UNIVERSAL WELDING'S PARCEL DOES NOT ADJOIN ANY NAVIGABLE WATER, ONLY OTHER WETLANDS. THE CORPS' REGULATIONS EXCLUDE WETLANDS-ADJACENT-TO-WETLANDS FROM THE AGENCY'S JURISDICTION. THE DISTRICT COURT UPHELD THE CORPS' ASSERTION OF JURISDICTION AND PLF APPEALED. THE NINTH CIRCUIT COURT OF APPEALS AFFIRMED. PLF DID NOT SEEK OR RECOVER FEES. WASHINGTON CATTLEMEN'S ASS'N V. ENVIRONMENTAL PROTECTION AGENCY. THE EPA ISSUED AN "INTERNAL GUIDANCE" DOCUMENT REDEFINING JURISDICTIONAL WATERS UNDER THE CLEAN WATER ACT IN VIOLATION OF ADMINISTRATIVE PROCEDURE ACT RULE-MAKING PROCEDURES. REPRESENTING A CATTLEMEN'S ASSOCIATION WHOSE MEMBERS ARE ADVERSELY AFFECTED BY THE OVERLY-EXPANSIVE REACH OF THE EPA'S "WOTUS RULE," PLF SUED TO OVERTURN IT. THESE CASES ARE CONSOLIDATED AND PLF, ON BEHALF OF CLIENTS IN THIS AND OTHER CASES, FILED AMICUS BRIEFS IN THOSE CASES WHERE PLF DOES NOT DIRECTLY REPRESENT THE LEAD PLAINTIFFS. IN 2017, PLF SUBMITTED BRIEFS AS RESPONDENT IN THE U.S. SUPREME COURT IN THE CONSOLIDATED CASE OF NATIONAL ASSOCIATION OF MANUFACTURERS V. DEPARTMENT OF DEFENSE. BECAUSE THESE CASES ARE ONGOING, IT IS PREMATURE TO SEEK FEES. WILDEARTH GUARDIANS V. DEPARTMENT OF JUSTICE. PLF INTERVENED IN THIS LAWSUIT ON BEHALF OF THE NEW MEXICO CATTLE GROWERS' ASSOCIATION AND OTHER AGRICULTURAL ORGANIZATIONS TO OPPOSE CERTAIN ENVIRONMENTALIST GROUPS WHO ARE SUING TO RADICALLY EXPAND THE CRIMINAL LIABILITY PROVISIONS OF THE ENDANGERED SPECIES ACT. THE PROPERTY OWNERS ARGUE THAT THE LAWSUIT IS A STARK EXAMPLE OF OVERCRIMINALIZATION - PEOPLE WOULD ACTUALLY GO TO JAIL IF THEY ACCIDENTALLY KILLED AN UNKNOWN, ENDANGERED INSECT WHILE DRIVING DOWN THE HIGHWAY. AFTER AN ADVERSE DECISION FROM THE DISTRICT COURT, PLF APPEALED TO THE NINTH CIRCUIT COURT OF APPEALS AND FILED BRIEFS IN THAT COURT. BECAUSE THIS CASE IS PENDING, IT WOULD BE PREMATURE TO SEEK FEES. PERSONAL LIBERTIES: THE LIBERTY PROTECTED BY THE CONSTITUTION ENCOMPASSES YOUR RIGHT TO BE FREE IN THE ENJOYMENT OF ALL OF YOUR ABILITIES IN THE PURSUIT OF HAPPINESS, INCLUDING THE RIGHT TO EXPRESS YOURSELF IN THOUGHT AND ACTION, TO PURSUE THE OCCUPATION OF YOUR CHOICE, TO LIVE WHERE YOU WANT, AND TO PURSUE THE BEST EDUCATION FOR YOU AND YOUR CHILDREN. PLF LITIGATES TO VINDICATE FREEDOM OF SPEECH AND ASSOCIATION; DEFEND THE RIGHT TO EARN A LIVING; SUPPORT FREEDOM IN EDUCATION; AND UPHOLD EQUAL PROTECTION OF THE LAW, INCLUDING FREEDOM FROM RACIAL DISCRIMINATION. ARMSTRONG V. KADAS, PLF REPRESENTS PARENTS OF A CHILD IN A FAITH-BASED SCHOOL AND AN ASSOCIATION OF CHRISTIAN SCHOOLS IN A CHALLENGE TO A REGULATION IMPLEMENTING MONTANA'S SCHOLARSHIP TAX CREDIT LAW. THE REGULATION FORBIDS RELIGIOUSLY AFFILIATED SCHOOLS FROM PARTICIPATING IN THE TAX CREDIT PROGRAM. PLF CHALLENGED THE REGULATION AS VIOLATING THE FIRST AMENDMENT'S PROTECTION FOR FREEDOM OF RELIGION AND THE FOURTEENTH AMENDMENT'S GUARANTEE OF EQUAL PROTECTION OF THE LAW. THE FEDERAL COURT DISMISSED THE CASE PENDING A STATE COURT'S DECISION IN A RELATED CASE. PLF APPEALED THE ABSTENTION TO THE NINTH CIRCUIT. BECAUSE THIS CASE REMAINS PENDING, IT IS PREMATURE TO SEEK FEES. FORM 990, PART III, LINE 4A ASSOCIATED BUILDERS AND CONTRACTORS-CALIFORNIA COOPERATION COMMITTEE V. BECERRA. REPRESENTING A BUILDING CONTRACTOR TRADE ASSOCIATION, PLF TOOK OVER DIRECT REPRESENTATION ON APPEAL OF A FIRST AMENDMENT CHALLENGE TO A CALIFORNIA LAW WHEREBY CONTRACTORS FOR PUBLIC PROJECTS CAN RECEIVE A PREVAILING WAGE CREDIT FOR CONTRIBUTIONS MADE ONLY TO SELECTED "INDUSTRY ADVANCEMENT FUNDS" THAT ADVOCATE FOR UNION INTERESTS. BECAUSE THIS STATUTE FAVORS SOME EXPRESSIVE VIEWPOINTS OVER OTHERS, THE LAW VIOLATES THE FIRST AMENDMENT. IN 2017, PLF SUBMITTED BRIEFS IN THE NINTH CIRCUIT. BECAUSE THIS CASE REMAINS PENDING, IT IS PREMATURE TO SEEK FEES. BENNIE V. MUNN. PLF TOOK OVER THIS FIRST AMENDMENT CASE TO FILE A PETITION FOR A WRIT OF CERTIORARI IN THE U.S. SUPREME COURT. ROBERT BENNIE IS A BROKER-DEALER AND TEA PARTY ACTIVIST IN NEBRASKA. AFTER MAKING DISPARAGING REMARKS ABOUT PRESIDENT OBAMA, STATE REGULATORS TARGETED BENNIE'S BUSINESS FOR INCREASED SCRUTINY WITH THE INTENT OF SILENCING HIM. THE TRIAL COURT RULED AGAINST HIS FREE SPEECH CLAIMS AND THE APPELLATE COURT REFUSED TO CONDUCT AN INDEPENDENT REVIEW OF HIS CLAIMS. PLF URGED THE HIGH COURT TO TAKE THE CASE TO ENSURE THAT ALL LEVELS OF THE JUDICIARY CAREFULLY CONSIDER THE MERITS OF FIRST AMENDMENT CLAIMS. THE PETITION WAS DENIED. PLF DID NOT SEEK OR RECOVER FEES. CHEF GEOFF'S V. JEFFREY PAINTER. THE STATE OF VIRGINIA SIGNIFICANTLY LIMITS THE LANGUAGE THAT RESTAURANTS CAN USE TO ADVERTISE SPECIALS RELATED TO ALCOHOL PURCHASES. FOR EXAMPLE, THEY MAY NOT ADVERTISE THE ACTUAL PRICE OF A BOTTLE OF WINE OR DESIGNATE "WEDNESDAY WINE NIGHT OR "MARGARITA THURSDAY." PLF REPRESENTS AWARD-WINNING CHEF AND RESTAURANTEER GEOFF TRACY IN A FIRST AMENDMENT CHALLENGE TO THESE STATE LAWS THAT UNLAWFULLY RESTRICT TRUTHFUL SPEECH. BECAUSE THIS CASE IS PENDING, IT WOULD BE PREMATURE TO SEEK FEES. E.L. V. VOLUNTARY INTERDISTRICT CHOICE CORP. REPRESENTING ELEMENTARY SCHOOL STUDENT E.L., AND HIS MOTHER, LA'SHEIKA WHITE, PLF FILED SUIT TO CHALLENGE A COUNTY-TO-CITY SCHOOL TRANSFER POLICY THAT PROHIBITS BLACK STUDENTS RESIDING IN THE COUNTY OF ST. LOUIS FROM TRANSFERRING TO A SCHOOL LOCATED IN THE CITY OF ST. LOUIS AS A VIOLATION OF THE EQUAL PROTECTION CLAUSE. EVERY CHILD SHOULD HAVE AN EQUAL OPPORTUNITY TO ATTEND THE SCHOOL OF HIS OR HER CHOICE, REGARDLESS OF THE COLOR OF HIS OR HER SKIN. THE DISTRICT COURT DISMISSED THE CASE FOR PROCEDURAL REASONS AND PLF APPEALED TO THE EIGHTH CIRCUIT. IN 2017, PLF BRIEFED AND ARGUED THE CASE IN THE EIGHTH CIRCUIT, WHICH AFFIRMED THE LOWER COURT DECISION. PLF THEN FILED A PETITION FOR WRIT OF CERTIORARI IN THE U.S. SUPREME COURT. BECAUSE THIS CASE REMAINS PENDING, IT IS PREMATURE TO SEEK FEES. ELSTER V. CITY OF SEATTLE. A SEATTLE LAW AUTHORIZES THE CITY TO ISSUE "DEMOCRACY VOUCHERS" EVERY ELECTION CYCLE TO RESIDENTS WITHIN THE CITY LIMITS. THE RESIDENTS MAY THEN CONTRIBUTE THESE VOUCHERS TO ELIGIBLE CANDIDATES FOR CITY ELECTED OFFICES. PLF REPRESENTS SEATTLE TAXPAYERS AND PROPERTY OWNERS IN A LAWSUIT CHALLENGING THE VOUCHERS AS VIOLATING THE FIRST AMENDMENT AND EQUAL PROTECTION. THE KING COUNTY SUPERIOR COURT UPHELD THE LAW AND PLF APPEALED. BECAUSE LITIGATION IS ONGOING, IT IS PREMATURE TO SEEK FEES. FONTENOT V. ATTORNEY GENERAL OF OKLAHOMA. PLF REPRESENTS PEGGY FONTENOT, A NATIVE AMERICAN ARTIST WHO SELLS HER HAND-MADE JEWELRY AND ART AT ART SHOWS THROUGHOUT THE COUNTRY. AT THE BEHEST OF POLITICALLY-POWERFUL TRIBES, OKLAHOMA PASSED A LAW THAT PERMITS ONLY MEMBERS OF FEDERALLY-RECOGNIZED TRIBES TO DESCRIBE THEMSELVES OR THEIR ART AS NATIVE AMERICAN. BECAUSE FONTENOT IS A MEMBER OF A VIRGINIA STATE-RECOGNIZED TRIBE, SHE MAY NOT MARKET HER ART AS "INDIAN MADE." PLF FILED A LAWSUIT ON THE GROUNDS THAT THIS LAW VIOLATES THE FIRST AND FOURTEENTH AMENDMENTS. THE CASE IS PENDING IN THE TRIAL COURT. BECAUSE LITIGATION IS ONGOING, IT IS PREMATURE TO SEEK FEES. JOHNSON V. CASSELLIUS. PLF REPRESENTS HIGH SCHOOL STUDENT KAIDEN JOHNSON AND HIS MOTHER IN A FEDERAL EQUAL PROTECTION CHALLENGE TO THE ENFORCEMENT OF A DISCRIMINATORY SEX-BASED CLASSIFICATION IN A MINNESOTA STATUTE THAT PROHIBITS BOYS FROM COMPETING ALONGSIDE FEMALE CLASSMATES ON HIS SCHOOL'S DANCE TEAM. IN 2017, PLF SENT A NOTICE LETTER TO THE SCHOOL DISTRICT SEEKING TO END THIS DISCRIMINATORY PRACTICE AND, WHEN THE DISTRICT FAILED TO RESCIND THE REGULATION, PLF PETITIONED THE FEDERAL DEPARTMENT OF EDUCATION TO COMMENCE AN INVESTIGATION. BECAUSE THE CASE IS ONGOING, IT IS PREMATURE TO SEEK FEES. KRAUSE V. SCHOOL BOARD OF INDIAN RIVER COUNTY, FLORIDA. RISING SENIOR HIGH SCHOOL STUDENT J.P. KRAUSE RAN FOR CLASS PRESIDENT. WITH THE PERMISSION OF HIS AP HISTORY TEACHER, HE DELIVERED A SATIRICAL, 90-SECOND CAMPAIGN SPEECH DURING CLASS, WHICH WAS RECORDED BY A CLASSMATE. HE WON THE ELECTION. ONE OF HIS COMPETITORS THEN CLAIMED THE SPEECH "HARASSED" HER AND THE SCHOOL STRIPPED J.P. OF HIS VICTORY AND DISCIPLINED HIM FOR VIOLATION OF THE SCHOOL'S CODE OF CONDUCT. PLF REPRESENTED J.P. AND HIS MOTHER TO SET THE SCHOOL STRAIGHT ABOUT J.P.'S FIRST AMENDMENT RIGHTS, WHICH DO NOT DISAPPEAR SIMPLY BECAUSE HE IS A STUDENT. AFTER THE CASE GENERATED NATIONAL ATTENTION, THE SCHOOL AGREED TO REINSTATE J.P. AS SENIOR CLASS PRESIDENT AND REMOVE ANY DISCIPLINARY RECORD FROM HIS FILE. PLF DID NOT SEEK OR RECOVER FEES. LIPPMAN V. CITY OF OAKLAND, CALIFORNIA. TOM LIPPMAN IS AN OAKLAND PROPERTY OWNER WHO RENTS A SINGLE-FAMILY RESIDENCE. HE WAS CITED BY THE CITY FOR RELATIVELY MINOR BUILDING CODE VIOLATIONS AND SOUGHT TO APPEAL. PLF FILED SUIT ON HIS BEHALF TO CHALLENGE THE APPELLATE PROCESS, WHICH ALLOWS ONLY HEARING OFFICERS FROM THE SAME DEPARTMENT AS ISSUES THE CITATIONS TO CONSIDER APPEALS AND DOES NOT PERMIT PROPERTY OWNERS TO DEFEND THEMSELVES. THIS VIOLATES STATE LAW AND FUNDAMENTAL FAIRNESS THAT REQUIRES JUDGES TO BE SEPARATE FROM PROSECUTORS. BECAUSE THIS CASE IS ONGOING, IT IS PREMATURE TO SEEK FEES. MINERVA DAIRY V. BRANCEL. PLF REPRESENTS MINERVA DAIRY AND ITS PRESIDENT, ADAM MUELLER, IN A CHALLENGE TO A WISCONSIN LAW THAT BANS BUTTER FROM BEING SOLD WITHIN WISCONSIN IF IT HASN'T FIRST BEEN "GRADED." WISCONSIN'S LAW PREVENTS BUTTER MAKERS OUTSIDE OF WISCONSIN FROM SELLING THEIR PRODUCTS IN THAT STATE UNLESS THEY FIRST GO THROUGH THE ARDUOUS AND COST PROHIBITIVE PROCESS OF GETTING THEIR BUTTER GRADED. THE LAWSUIT ALLEGES THAT WISCONSIN'S LAW VIOLATES THE COMMERCE CLAUSE, AS WELL AS THE DUE PROCESS AND EQUAL PROTECTION CLAUSES OF THE FOURTEENTH AMENDMENT. TRIAL LEVEL LITIGATION IS ONGOING. BECAUSE THIS CASE IS PENDING, IT WOULD BE PREMATURE TO SEEK FEES. MINNESOTA VOTERS ALLIANCE V. MANSKY. PLF REPRESENTS MINNESOTA VOTERS IN A CHALLENGE TO A STATE STATUTE THAT PROHIBITS WEARING "POLITICAL" APPAREL IN OR NEAR A POLLING PLACE. THIS OVERBROAD LAW, WHICH PROHIBITS A T-SHIRT WITH A TEA PARTY OR AFL-CIO LOGO, OR A BUTTON THAT SAYS "PLEASE I.D. ME", VIOLATES THE VOTERS' FIRST AMENDMENT RIGHT OF FREE SPEECH. AFTER THE VOTERS LOST IN THE LOWER COURTS, PLF TOOK OVER THE CASE TO PETITION THE U.S. SUPREME COURT TO REVIEW THE APPELLATE COURT DECISION. THE SUPREME COURT AGREED TO HEAR THE CASE AND MERITS BRIEFING IS ONGOING. BECAUSE THE CASE IS PENDING, IT IS PREMATURE TO SEEK FEES. QUAD KNOPF, INC. V. PUBLIC UTILITIES COMMISSION. PLF REPRESENTS QUAD KNOPF, AN ENVIRONMENTAL PLANNING AND CONSULTING FIRM IN CALIFORNIA THAT CONTRACTS TO PERFORM SERVICES WITH CALIFORNIA PUBLIC UTILITIES COMMISSION. BECAUSE OF THE COMMISSION'S REGULATIONS REQUIRING THAT CONTRACTORS UTILIZE A SET PERCENTAGE OF WOMEN- AND MINORITY-OWNED SUBCONTRACTORS, QUAD KNOPF IS REQUIRED TO SUBCONTRACT WORK THAT COULD BE PERFORMED BY ITS OWN EMPLOYEES. THESE REGULATIONS VIOLATE THE STATE CONSTITUTION'S COMMITMENT TO PUBLIC CONTRACTING WITHOUT REGARD TO THE RACE OR SEX OF CONTRACTORS, ENACTED AS PROPOSITION 209 IN 1996. PLF PETITIONED THE PUBLIC UTILITIES COMMISSION TO RESCIND ITS REGULATIONS TO THE EXTENT THEY OFFER PREFERENTIAL TREATMENT BASED ON RACE AND SEX. BECAUSE THE CASE IS ONGOING, IT IS PREMATURE TO SEEK FEES. SHOCK V. CITY OF SEATTLE, WASHINGTON. THE CITY OF SEATTLE ADOPTED AN INCOME TAX THAT TARGETS THE CITY'S "HIGH-INCOME" RESIDENTS BY IMPOSING A 2.25 PERCENT TAX ON ANY INDIVIDUAL EARNING MORE THAN $250,000, AND AN INITIAL RATE OF 0 PERCENT ON EVERYONE ELSE. SOLD AS A "WEALTH TAX," THE CITY'S ORDINANCE IS A TROJAN HORSE THAT THREATENS THE RIGHTS OF POOR AND MIDDLE CLASS FAMILIES. THE INCOME BANDS AND TAX RATES ARE TEMPORARY. ONCE A SOURCE OF TAX REVENUE OPENS, THE GOVERNMENT WILL MINE IT-MEANING THAT EVERY INCOME LEVEL IS NOW EXPOSED TO NEW TAXES. PLF REPRESENTS SEATTLE RESIDENTS IN A CHALLENGE TO THE CITY'S DISCRIMINATORY "ACHIEVEMENT TAX" THAT VIOLATES THE STATE CONSTITUTION'S PROHIBITION ON INCOME TAXES, AND, WHEN TAXES ARE PERMITTED, REQUIRES UNIFORMITY AMONG CITIZENS. THE TRIAL COURT STRUCK DOWN THE ORDINANCE AND THE CITY WILL APPEAL. BECAUSE THE CASE IS ONGOING, IT IS PREMATURE TO SEEK FEES. FORM 990, PART III, LINE 4A THE BOOK PASSAGE V. BECERRA. BOOK PASSAGE IS A BOOKSTORE THAT HOSTS OVER 700 AUTHOR EVENTS A YEAR-IN WHICH AUTHORS GIVE TALKS, READ PASSAGES, INTERACT WITH READERS, AND SIGN BOOKS. THE OWNER KEEPS COPIES OF SIGNED BOOKS FROM THESE EVENTS TO SELL LATER. BOOK PASSAGE ALSO PROCURES A MONTHLY BOOK CLUB, WHEREIN READERS ARE SENT A FIRST EDITION SIGNED BOOK BY AN UP-AND-COMING AUTHOR. BOOK PASSAGE DOESN'T CHARGE A PREMIUM FOR THE SIGNATURE; ALL OF ITS BOOKS ARE SOLD FOR THEIR COVER PRICE. THE CALIFORNIA LEGISLATURE RECENTLY EXPANDED ITS AUTOGRAPH LAW (WHICH FORMERLY ONLY APPLIED TO SPORTS MEMORABILIA) TO INCLUDE ANY SIGNED ITEM WORTH OVER $5-INCLUDING BOOKS. THIS MAKES IT EXTREMELY RISKY, IF NOT IMPOSSIBLE, FOR BOOK PASSAGE TO CONTINUE SELLING AUTOGRAPHED BOOKS OR HOSTING AUTHOR EVENTS. PLF REPRESENTED BOOK PASSAGE IN A LAWSUIT CHALLENGING THE LAW AS VIOLATING THE FIRST AMENDMENT. THE LEGISLATURE SUBSEQUENTLY PASSED A LAW REPEALING LIABILITY AND PLF DISMISSED THE CASE. PLF DID NOT SEEK OR RECOVER FEES. TWIST ARCHITECTURE V. OREGON BD. OF ARCHITECT EXAMINERS. PLF REPRESENTS DAVID HANSEN, A PARTNER IN TWIST ARCHITECTURE, WHO IS NOT A LICENSED ARCHITECT. HE MAKES HIS LIVING BY MAKING "MARKETING DRAWINGS" - IMAGES TO HELP A DEVELOPMENT COMPANY ATTRACT RETAILERS TO DEVELOPMENTS BY IMAGINING DIFFERENT POSSIBILITIES FOR THE PROJECT. THE DRAWINGS DO NOT INCLUDE SPECIFIC PLANS AND CANNOT BE USED FOR CONSTRUCTION PURPOSES. THE OREGON BOARD OF ARCHITECT EXAMINERS FINED HANSEN AND HIS PARTNER $10,000 EACH FOR PURPORTEDLY PRACTICING ARCHITECTURE WITHOUT A LICENSE. PLF ARGUED TO THE OREGON SUPREME COURT THAT THIS VIOLATES THEIR CONSTITUTIONAL RIGHT TO EARN A LIVING BY RESTRICTING THEIR ACTIVITIES WITHOUT ANY RATIONAL RELATIONSHIP TO PROTECTING PUBLIC HEALTH AND SAFETY. ORAL ARGUMENT WAS HELD IN 2017. THE COURT ISSUED AN ADVERSE DECISION. PLF DID NOT SEEK OR RECOVER FEES. YIM V. CITY OF SEATTLE. PLF REPRESENTS OWNERS OF SEVERAL SMALL RENTAL PROPERTIES TO CHALLENGE THE CONSTITUTIONALITY OF SEATTLE'S "FAIR CHANCE HOUSING ORDINANCE," WHICH RESTRICTS A RESIDENTIAL LANDLORD FROM CONSIDERING A TENANT APPLICANT'S CRIMINAL HISTORY WHEN DECIDING TO WHOM HE OR SHE WILL RENT THE PROPERTY. PLF FILED THE COMPLAINT IN WASHINGTON STATE COURT AND LITIGATION IS ONGOING. BECAUSE THE CASE IS PENDING, IT IS PREMATURE TO SEEK FEES. AMICUS CASES: PLF FILED AMICUS BRIEFS IN THE FOLLOWING CASES, FURTHERING ALL OF THE OBJECTIVES DESCRIBED ABOVE. AMERICAN FURNITURE WAREHOUSE CO. V. TOWN OF GILBERT (ARIZONA COURT OF APPEALS) AMERICANS FOR PROSPERITY FOUNDATION V. BECERRA (NINTH CIRCUIT COURT OF APPEALS) ANDERSON V. METRO. GOV. OF NASHVILLE & DAVIDSON COUNTY (TENNESSEE COURT OF APPEAL) BAY POINT PROPERTIES, INC. V. MISSISSIPPI TRANSPORTATION COMM'N (U.S. SUPREME COURT) BEACH GROUP INVESTMENTS, LLC V. FLORIDA (U.S. SUPREME COURT) BERNINGER V. FEDERAL COMMICATIONS COMMISSION (U.S. SUPREME COURT) BIGGS V. BETLATCH (ARIZONA SUPREME COURT) BLOOMINGDALE'S, INC. V. VITOLO (U.S. SUPREME COURT) BOLING V. PUBLIC EMPLOYMENT RELATIONS BOARD (CALIFORNIA SUPREME COURT) BROTT V. UNITED STATES (U.S. SUPREME COURT) CASCADIA WILDLANDS V. SCOTT TIMBER CO. (NINTH CIRCUIT COURT OF APPEALS) CASINO REINVESTMENT DEVELOPMENT AUTHORITY V. BIRNBAUM (NEW JERSEY COURT OF APPEALS) CHMIELEWSKI V. ST. PETE BEACH, FLORIDA (ELEVENTH CIRCUIT COURT OF APPEALS) CHRISTIE V. NCAA (U.S. SUPREME COURT) CLARK V. CITY OF SEATTLE, WASHINGTON (NINTH CIRCUIT COURT OF APPEALS) DESERT WATER AGENCY V. AGUA CALIENTE BAND OF INDIANS (U.S. SUPREME COURT) DRAKES BAY OYSTER CO. V. CALIFORNIA COASTAL COMMISSION (CALIFORNIA SUPREME COURT) E.I. DUPONT DE NEMOURS AND CO. V. SMILEY (U.S. SUPREME COURT) ENVIRONMENTAL LAW FOUNDATION V. STATE WATER RESOURCES CONTROL BOARD (CAL. COURT OF APPEAL) EPIC SYSTEMS CORP. V. LEWIS (U.S. SUPREME COURT) GUNDERSON V. STATE OF INDIANA (INDIANA SUPREME COURT) HERNANDEZ V. 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