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NATIONAL ENDOWMENT FOR THE ARTS V. FINLEY

Amicus Brief: Liberty Counsel (1998)

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NATIONAL ENDOWMENT FOR THE ARTS, ET AL., PETITIONERS v. KAREN FINLEY, ET AL.
No. 97­371
October Term, 1997
January 8, 1998

ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT

BRIEF OF LIBERTY COUNSEL AS AMICUS CURIAE IN SUPPORT OF PETITIONERS

Mathew D. Staver *, Frederick H. Nelson, Nicole Arfaras Kerr, LIBERTY COUNSEL, 1900 Summit Tower Blvd., Suite 560, Orlando, Florida 32810, (407) 875­2100.
* Counsel of Record

TABLE OF AUTHORITIES

CASE LAW:
Blodgett v. Holden, 275 U.S. 142 (1927)
Board of Regents v. Roth, 408 U.S. 564 (1972)
Buckley v. Valeo, 424 U.S. 1 (1976)
Cammarano v. United States, 358 U.S. 498 (1959)
Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984)
Crowell v. Benson, 285 U.S. 22 (1932)
Edward J. DeBartolo Corp. v. Florida Gulf Coast Building & Construction Trades Council, 485 U.S. 568 (1988)
FTC v. American Tobacco Co., 264 U.S. 298 (1924)
FW/PBS v. City of Dallas, 493 U.S. 215 (1990)
Finley v. NEA, 795 F. Supp. 1457 (C.D. Cal. 1992)
Finley v. NEA, 100 F.3d 671 (9th Cir. 1996)
Harris v. McRae, 448 U.S. 297 (1980)
Maher v. Roe, 432 U.S. 464 (1977)
Motor Vehicle Mfrs. Assn. of United States, Inc. v. State Farm Mut. Automobile Ins. Co., 463 U.S. 29 (1983)
NLRB v. Catholic Bishop of Chicago, 440 U.S. 490 (1979)
Regan v. Taxation without Representation of Wash., 461 U.S. 540 (1983)
Rust v. Sullivan, 500 U.S. 173 (1991)
South Dakota v. Dole, 483 U.S. 203 (1987)
United States ex rel. Attorney General v. Delaware & Hudson Co., 213 U.S. 366 (1909)
United States v. Jin Fuey Moy, 241 U.S. 394 (1916)
Webster v. Reproductive Health Services, 492 U.S. 490 (1989)

STATUTES:
20 U.S.C. @ 954(c)(1), (2), (4) ­ (6)
20 U.S.C. @ 954(d)(1)
20 U.S.C. @ 954(h)

OTHER AUTHORITIES:
136 Cong. Rec. H9410­57 (Oct. 11, 1990)
53 Fed. Reg. 2923­2924 (1988)

INTEREST OF AMICUS CURIAE

Liberty Counsel is a non­profit civil liberties education and legal defense organization. (1) Liberty Counsel's activities include educating the public regarding civil liberties and the interaction between law and individual freedoms. As part of advancing Liberty Counsel's purpose, education is provided through interaction with attorneys and members of the academic community, publication of articles and journals in law reviews, providing legal counsel where appropriate, and filing amicus curiae briefs on a variety of issues.

Liberty Counsel is interested in protecting the First Amendment speech/expression rights of individuals. Liberty Counsel is also interested in ensuring that our government utilizes funds in the advancement of our citizen's goals while keeping intact Congressional guidance regarding appropriations for the arts and cultural diversity. Liberty Counsel files this brief in support of the Petitioners with the aim to assist this Court in rendering a reasoned decision regarding the use of taxpayer funds for artistic advancement. Attorney Mathew D. Staver has argued before this Court and herein attempts to lend his assistance in the proper interpretation and application of Congress' approach to grant making through the NEA.

SUMMARY OF ARGUMENT

On its face, the General Standards for Decency provision does not transgress constitutional tenets. This Court has repeatedly held that facial challenges to legislation are generally disfavored and legislation will generally be upheld. In NLRB v. Catholic Bishop of Chicago, 440 U.S. 490, 500 (1979), this Court held that "an Act of Congress ought not be construed to violate the Constitution if any other possible construction remains available." This precept is based on the fact that a decree to declare an Act of Congress unconstitutional "is the gravest and most delicate duty that this Court is called on to perform." Blodgett v. Holden, 275 U.S. 142, 148 (1927) (opinion of Holmes, J.).

In light of the substantial burden which must be met by those presenting a facial challenge to Congressional legislation, this Court should defer to the reasonable interpretation advanced by the NEA. As submitted by the NEA, "decency" and "respect . . . are factors only to the extent that they are implicit in the assessment of artistic merit." Finley v. NEA, 795 F. Supp. 1457, 1470 (C.D. Cal. 1992). This construction does not violate the Constitution and is, therefore, a possible construction to the provision on its face.

The Respondents assert a "property" interest in receiving government subsidies of their artistic expression. This Court has long­recognized the principle that "'the Due Process Clauses generally confer no affirmative right to governmental aid, even where such aid may be necessary to secure life, liberty, or property interests of which the government itself may not deprive the individual.'" Webster v. Reproductive Health Services, 492 U.S. 490, 507 (1989) (quoting DeShaney v. Winnebago County Dept. of Social Services, 489 U.S. 189, 196 (1989)). In rejecting any constitutional violation in Rust v. Sullivan, 500 U.S. 173, 193 (1991), this Court held that, "the Government can, without violating the Constitution, selectively fund a program to encourage certain activities it believes to be in the public interest, without at the same time funding an alternative program which seeks to deal with the problem in another way."

As clearly enunciated in Rust, "when the Government appropriates public funds to establish a program it is entitled to define the limits of that program." Rust, 500 U.S. at 194. An NEA grant is not an "entitlement" which Respondents may claim a property interest. As noted by this Court in Rust, this is not a case of the Government "suppressing a dangerous idea," but of a prohibition on a project grantee or its employees from engaging in activities outside of the project's scope." Rust, 500 U.S. at 194.

TEXT: ARGUMENT

I.

THE GENERAL STANDARDS FOR DECENCY PROVISION IS NOT FACIALLY UNCONSTITUTIONAL IN LIGHT OF THE HIGHER STANDARD APPLIED TO FACIAL CHALLENGES AND BECAUSE THIS COURT'S PRECEDENT HOLDS THAT TRIBUNALS SHOULD DEFER TO THE NEA'S INTERPRETATION OF THE PROVISION.

A.

In A Facial Challenge, The General Standards For Decency Provision Should Be Construed As Constitutional To Avoid The Constitutional Question.

On its face, the General Standards for Decency provision does not transgress constitutional tenets. Respondents must bear a heavy burden in a facial challenge because "facial challenges to legislation are generally disfavored." FW/PBS v. City of Dallas, 493 U.S. 215, 224 (1990). In Rust v. Sullivan, 500 U.S. 173 (1991), this Court noted the unique limitations to a facial challenge. This Court held that "we are concerned only with the question whether, on their face, the regulations are both authorized by the Act and can be construed in such a manner that they can be applied to a set of individuals without infringing upon constitutionally protected rights." Id., at 183. The [Respondents] face a heavy burden in seeking to have the regulations invalidated as facially unconstitutional. "A facial challenge to a legislative Act is, of course, the most difficult challenge to mount successfully, since the challenger must establish that no set of circumstances exists under which the Act would be valid. The fact that [the regulations] might operate unconstitutionally under some conceivable set of circumstances is insufficient to render [them] wholly invalid." Id. (quoting United States v. Salerno, 481 U.S. 739, 745 (1987)).

The General Standards for Decency provision reads:

The Chairperson shall ensure that­
(1) artistic excellence and artistic merit are the criteria by which applications are judged, taking into consideration general standards of decency and respect for the diverse beliefs and values of the American public. 20 U.S.C. @ 954(d)(1).

In the district court, the NEA advanced two possible constructions which avoid constitutional infirmity:

(1) that the decency provision does "not impose content restrictions on NEA grant decisions," but "merely implements a method for selecting review panel members" and, alternatively, (2) that "decency" and "respect . . . are factors only to the extent that they are implicit in the assessment of artistic merit." Finley v. NEA, 795 F. Supp. 1457, 1470 (C.D. Cal. 1992).

On its face, the provision supports a constitutional construction. In NLRB v. Catholic Bishop of Chicago, 440 U.S. 490, 500 (1979), this Court held that "an Act of Congress ought not be construed to violate the Constitution if any other possible construction remains available." Under this canon of statutory construction, "'the elementary rule is that every reasonable construction must be resorted to, in order to save a statute from unconstitutionality.'" Edward J. DeBartolo Corp. v. Florida Gulf Coast Building & Construction Trades Council, 485 U.S. 568, 575 (1988) (quoting Hooper v. California, 155 U.S. 648, 657 (1895)). The axiom articulated in Hooper is a categorical one ­­ "as between two possible interpretations of a statute, by one of which it would be unconstitutional and by the other valid, our plain duty is to adopt that which will save the Act." Blodgett v. Holden, 275 U.S. 142, 148 (1927) (opinion of Holmes, J.).

In the Ninth Circuit, the panel majority gave the provision an implausible construction in order to elevate this issue into a constitutional controversy. The Ninth Circuit held that rather than merely take "decency and respect" into consideration, as the provision reads on its face, the NEA is commanded to use "decency and respect" as the conclusive standard for awarding grants. Finley v. NEA, 100 F.3d 671, 680 (9th Cir. 1996).

On the contrary, the terms of the provision merely provide criteria for awarding grants. As with any artistic award, some criteria must be established to determine which artist will carry away the prize. For the Academy Awards, the criteria is simply based upon the artistic merit of the production ­­ thereby reflecting appreciation of the artist's work. In the music industry as well, the criteria is largely based upon sales of the recording ­­ thereby reflecting the general public's appreciation of the artist's work. The district court held that artistic decisions are by their nature unavoidably subject to aesthetic criteria such as "artistic merit" and "artistic excellence". Finley, 795 F. Supp. at 1475.

Central to the decision that one artist wins is the concurrent decision that another artist must lose. Not every film or recording may win "Best Picture" or "Single of the Year". (2) These decisions must have some criteria. Criteria for artistic expression does not prohibit "taking into consideration general standards of decency and respect" when awarding a prize. As submitted by the NEA, "decency" and "respect . . . are factors only to the extent that they are implicit in the assessment of artistic merit." Finley, 795 F. Supp. at 1470. This construction does not violate the Constitution and is, therefore, a possible construction to the provision on its face.

This Court has traditionally held that when the validity of an Act of Congress is drawn into question, "it is a cardinal principle that this Court will first ascertain whether a construction of the statute is fairly possible by which the question may be avoided." Crowell v. Benson, 285 U.S. 22, 62 (1932). This precept is based on the fact that a decree to declare an Act of Congress unconstitutional "is the gravest and most delicate duty that this Court is called on to perform." Blodgett, 275 U.S. at 148. As early as 1895 (Hooper) and to date, this Court cultivated the corollary doctrine that Congressional statutes "must be construed, if fairly possible, so as to avoid not only the conclusion that it is unconstitutional but also grave doubts upon that score." United States v. Jin Fuey Moy, 241 U.S. 394, 401 (1916); see also United States ex rel. Attorney General v. Delaware & Hudson Co., 213 U.S. 366 (1909). This Court has, by convention and practice, historically assumed that Congress legislates in the light of constitutional limitations. FTC v. American Tobacco Co., 264 U.S. 298, 305­307 (1924).

The uniqueness of a facial challenge to the provision at issue should move this Court to determine the provision is constitutionally sound and, therefore, avoid the question entirely. The lower court's disregard of this Court's long precedent of deferring to the validity of Congressional legislation should not be upheld. This Court should reverse the Ninth Circuit's opinion and find the provision is not, on its face, constitutionally infirm.

B. The General Standards For Decency Provision Should Be Construed As Constitutional Because This Court's Precedent Holds That Tribunals Should Defer To The NEA'S Interpretation Of The Provision.

In Rust, this Court reviewed a regulation which authorized the Secretary to make grants pursuant to Title X of the Public Health Service Act ("Act") in the realm of family planning projects. Under the Act, however, "none of the funds appropriated . . . [could] be used in programs where abortion is a method of family planning." Rust, 500 U.S. at 178. Like this case, new regulations were later promulgated to provide "operational guidance" on "how to preserve the distinction between Title X programs and abortion as a method of family planning." Id., at 179 (quoting 53 Fed.Reg. 2923­2924 (1988)). Like this case, the regulations merely clarified Congress' intent. In Rust, the regulations affirmed that the grants should be used "only to support preventive family planning services." Rust, 500 U.S. at 179. Much like this case, the Rust case presented a facial challenge to the regulations on the grounds that they "violate the First and Fifth Amendment rights of Title X clients and the First Amendment rights of Title X health providers." Id., at 181.

Most important in this case, this Court held in Rust that deference must be afforded to agencies when ambiguity is present. In this case, both the district court and court of appeals held the regulation is facially invalid because of vagueness concerns and because it allows an overbroad grant of discretion in interpreting the regulation. In Rust, however, this Court held that, "we need not dwell on the plain language of the statute because we agree with every court to have addressed the issue that the language is ambiguous." Id., at 184. Like Rust, the lower courts have determined the language at issue is ambiguous (thereby vague) and unconstitutional.

Citing Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984), however, this Court held in Rust that under a facial challenge, "substantial deference is accorded to the interpretation of the authorizing statute by the agency authorized with administering it." Chevron, 467 U.S. at 844. In Chevron, this Court stated, "the question for the court is whether the agency's [interpretation] is based on a permissible construction of the statute." Id., at 842­843. Noting the "broad language" within the Act, this Court rejected the facial challenge in Rust, noting that "we are unable to say that the Secretary's construction of the prohibition in @ 1008 to require a ban on counseling, referral, and advocacy within the Title X project is impermissible." Rust, 500 U.S. at 184.

In the district court, the NEA argued that "decency" and "respect . . . are factors only to the extent that they are implicit in the assessment of artistic merit." Finley, 795 F. Supp. at 1470. The district court rejected this interpretation, holding that the NEA's construction was not entitled to deference because it was "manifestly contrary to congressional intent." Id., at 1470 (quoting Chevron, 467 U.S. at 844). The Ninth Circuit contended that:

And turning to the legislative history, as we do to interpret an ambiguously worded statute, makes it clear that Congress intended to change the standard NEA applied in judging applications for funding, not simply to ask the NEA to consider the problem. NEA had been attacked for funding controversial artists and art works. Criticism had focused on a series of photographs by Robert Mapplethorpe objected to as homoerotic images, and on a photograph by Andres Serrano criticized as blasphemous. The "decency and respect" provision was enacted in direct response to this controversy and was specifically designed to prevent the funding of similar art works. Members of Congress noted that the "decency and respect" provision would prevent the funding of similar works in the future. 136 Cong. Rec. H9410­57 (Oct. 11, 1990). Finley, 100 F.3d at 676­77 (footnote omitted).

This Court's holding in Chevron is enlightening in respect to the Ninth Circuit's assertion that political forces motivated the NEA's (or Congress') revised approach to grant making. In Chevron, this Court rejected the argument that an agency's interpretation "is not entitled to deference because it represents a sharp break with prior interpretations." Chevron, 467 U.S. at 862. An agency is not required to "'establish rules of conduct to last forever,'" Motor Vehicle Mfrs. Assn. of United States, Inc. v. State Farm Mut. Automobile Ins. Co., 463 U.S. 29, 42 (1983) (quoting American Trucking Assns., Inc. v. Atchison, T. & S.F.R. Co., 387 U.S. 397, 416 (1967); NLRB v. Curtin Matheson Scientific, Inc., 494 U.S. 775 (1990)), but rather "must be given ample latitude to 'adapt [its] rules and policies to the demands of changing circumstances.'" Motor Vehicle Mfrs., supra, 463 U.S. at 42 (quoting Permian Basin Area Rate Cases, 390 U.S. 747, 784 (1968)). In Rust, this Court followed its reasoning in Chevron by upholding the Secretary's decision, noting that:

in the wake of the critical reports of the General Accounting Office (GAO) and the Office of the Inspector General (OIG), the prior policy failed to implement properly the statute and that it was necessary to provide "'clear and operational guidance' to grantees about how to preserve the distinction between Title X programs and abortion as a method of family planning." 53 Fed. Reg. 2923­2924 (1988). He also determined that the new regulations are more in keeping with the original intent of the statute, are justified by client experience under the prior policy, and are supported by a shift in attitude against the "elimination of unborn children by abortion." We believe that these justifications are sufficient to support the Secretary's revised approach. Rust, 500 U.S. at 187.

Noting the unique limitations of a facial challenge, this Court held in Rust that great deference must be afforded to the agency charged with administering the program at issue. As held in Rust, an agency's interpretation need not be the only possible interpretation, it must simply be one which is not contrary to Congressional intent. "When placed in context . . . the statements fall short of evidencing a congressional intent that would render the Secretary's interpretation of the statute impermissible. While [Respondents'] interpretation of the legislative history may be a permissible one, it is by no means the only one, and it is certainly not the one found by the Secretary." Id., at 189.

Like Rust, the Respondents face a heavy burden in seeking to have the provision invalidated as facially unconstitutional because a facial challenge to a legislative Act is the most difficult challenge to mount successfully. The "challenger must establish that no set of circumstances exists under which the Act would be valid. The fact that [the regulations] might operate unconstitutionally under some conceivable set of circumstances is insufficient to render [them] wholly invalid." Rust, 500 U.S. at 183. Like Rust, the NEA should be allowed the necessary discretion to administer the grants­in­aid program pursuant to Congress' intent and should be allowed the deference accorded to other federal agencies in interpreting the provision.

II.

THE GENERAL STANDARDS FOR DECENCY PROVISION IS NOT FACIALLY UNCONSTITUTIONAL BECAUSE NO PERSON OR ENTITY MAY CLAIM AN "ENTITLEMENT" TO THE AWARD OF A GRANT.

In this case, the Respondents assert a "property" interest in receiving government subsidies of their artistic expression. In order for an artist to possess a "property" interest in an NEA grant, the artist must first "have a legitimate claim of entitlement to it." Board of Regents v. Roth, 408 U.S. 564, 567 (1972). This Court has long­recognized the principle that "'the Due Process Clauses generally confer no affirmative right to governmental aid, even where such aid may be necessary to secure life, liberty, or property interests of which the government itself may not deprive the individual.'" Webster v. Reproductive Health Services, 492 U.S. 490, 507 (1989) (quoting DeShaney v. Winnebago County Dept. of Social Services, 489 U.S. 189, 196 (1989)).

"The Government has no constitutional duty to subsidize an activity merely because the activity is constitutionally protected . . . ." Rust v. Sullivan, 500 U.S. 173, 182 (1991). This Court has repeatedly instructed that the Constitution is not violated when Congress subsidizes some speech, but not all speech. Rust, supra; Regan v. Taxation without Representation of Wash., 461 U.S. 540 (1983); Harris v. McRae, 448 U.S. 297 (1980); Maher v. Roe, 432 U.S. 464 (1977); Buckley v. Valeo, 424 U.S. 1 (1976).

In rejecting any constitutional violation in Rust, this Court held that, "the Government can, without violating the Constitution, selectively fund a program to encourage certain activities it believes to be in the public interest, without at the same time funding an alternative program which seeks to deal with the problem in another way." Rust, 500 U.S. at 193. In Regan, this Court held that Congress could refuse to subsidize the lobbying activities of certain organizations by prohibiting them from using tax­deductible contributions, holding that such organizations remained free "to receive deductible contributions to support . . . nonlobbying activities." Regan, 461 U.S. at 545. "[A] legislature's decision not to subsidize the exercise of a fundamental right does not infringe the right." Id. at 549. In Maher, this Court reviewed a state welfare regulation under which Medicaid recipients received payments for medical services related to childbirth, but not for nontherapeutic abortions. This Court refused the assertion that such unequal subsidization violated the Constitution, holding that the government may "make a value judgment favoring childbirth over abortion, and . . . implement that judgment by the allocation of public funds." Maher, 432 U.S. at 474.

In funding one artist and not another, "the Government has not discriminated on the basis of viewpoint; it has merely chosen to fund one activity to the exclusion of the other." Rust, 500 U.S. at 193. See also Cammarano v. United States, 358 U.S. 498, 513 (1959). The NEA grant program was conceived to provide grants for works that are "of significant merit" or are "of substantial artistic and cultural significance". 20 U.S.C. @ 954(c)(1), (2), (4) ­ (6). A grant awarded by the NEA is not an "entitlement" that an artist may assert is a vested claim, but is limited to specific criteria and demanding reporting requirements. 20 U.S.C. @ 954(h). Merely refusing a grant application does not forbid any conduct or artistic expression. As this Court has held, a "refusal to fund protected activity, without more, cannot be equated with the imposition of a 'penalty' on that activity." McRae, 448 U.S. at 317, n.19. "There is a basic difference between direct state interference with a protected activity and state encouragement of an alternative activity consonant with legislative policy." Maher, 432 U.S. at 475.

To hold that the Government unconstitutionally discriminates on the basis of viewpoint when it chooses to fund a program dedicated to advance certain permissible goals, because the program in advancing those goals necessarily discourages alternative goals, would render numerous Government programs constitutionally suspect. Rust, 500 U.S. at 194.

Like the argument rebuffed by this Court in Rust, the Respondents' assertions "ultimately boil down to the position that if the government chooses to subsidize one protected right, it must subsidize analogous counterpart rights. But the Court has soundly rejected that proposition." Id., at 194. (citing Regan, 461 U.S. 540; McRae, 448 U.S. 297; and Maher, 432 U.S. 464.). As clearly enunciated in Rust, "when the Government appropriates public funds to establish a program it is entitled to define the limits of that program." Rust, 500 U.S. at 194.

An NEA grant is not an "entitlement" which Respondents may claim a property interest. On the contrary, the NEA grants­in­aid program merely established limited funding for limited artistic ventures. As noted by this Court in Rust and Regan, this is not a case of the Government "suppressing a dangerous idea," but of a prohibition on a project grantee or its employees from engaging in activities outside of the project's scope." Rust, 500 U.S. at 194; Regan, 461 U.S. at 548. (3) "The condition that federal funds will be used only to further the purposes of a grant does not violate constitutional rights." Rust, 500 U.S. at 198.

CONCLUSION

For the forgoing reasons, the opinion of the Ninth Circuit Court of Appeals should be reversed.

Respectfully submitted,
Mathew D. Staver *, Frederick H. Nelson, Nicole Arfaras Kerr, LIBERTY COUNSEL, 1900 Summit Tower Blvd., Suite 560, Orlando, Florida 32810, (407) 875­2100
* Counsel of Record
January 9, 1998


NOTES

(1) Liberty Counsel files this brief with the consent of all parties. The letters granting consent of the parties are attached hereto with the filing of this brief. Counsel for a party did not author this brief in whole or in part. No person or entity, other than Amicus Curiae, its members, or its counsel made a monetary contribution to the preparation and submission of this brief. A grant application is pending with the Alliance Defense Fund in Phoenix, Arizona, but no funds have been received. Return to text

(2) Most important, as explained more fully below, artists are not "entitled" to win a grant, just as no artist is "entitled" to an Oscar. Return to text

(3) This Court has recognized that Congress' power "to allocate funds for public purposes includes an ancillary power to ensure that those funds are properly applied to the prescribed use." South Dakota v. Dole, 483 U.S. 203, 207­209 (1987) (upholding against Tenth Amendment challenge requirement that States raise drinking age as condition to receipt of federal highway funds). Return to text


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