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UNITED STATES DISTRICT COURT
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WESTERN DISTRICT OF WASHINGTON
10 AT SEATTLE
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COLLEGE REPUBLICANS OF THE
12 UNIVERSITY OF WASHINGTON;
NO. ___________________
CHEVY SWANSON, an Individual,
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DECLARATION OF CHEVY
14 Plaintiffs, SWANSON IN SUPPORT OF
COMPLAINT
15 vs.
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ANA MARI CAUCE, in her official capacity
17 as president of the University of Washington;
GERALD J. BALDASTY, in his official
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capacity as provost and executive vice
19 president; RENE SINGLETON, individually
and in her official capacity as assistant
20 director, Student Activities; CHRISTINA
21 COOP, individually and in her official
capacity as senior activities advisor, Student
22 Activities; JOHN N. VINSON, individually
and in his official capacity as Chief of the
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University of Washington, Seattle, Police
24 Department; CRAIG WILSON individually
and in his official capacity as University of
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25 Washington, Seattle, Police Department Patrol
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26 Commander; and DOES 1-25;
27 Defendants.
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DECLARATION OF CHEVY SWANSON –
Case No:
Case 2:18-cv-00189 Document 1-1 Filed 02/06/18 Page 2 of 7
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2 I, Chevy Swanson, declare as follows:
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1. I am a Plaintiff in this lawsuit, a resident of Seattle, Washington, and president of the
4 plaintiff College Republicans (“College Republicans”) of the University of Washington. The
5 following facts and circumstances are personally known to me, and if called upon to do so, I could
6 and would competently testify as to them.
7 2. This declaration is presented in support of Plaintiffs’ Complaint.
8 3. In January 2017, the College Republicans hosted an event featuring political
9 provocateur Milo Yiannopolous in Kane Hall on the UW Seattle campus. The event drew a significant
negative reaction from some members of the Seattle community who contacted the University desiring
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the event be cancelled.
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4. I was event coordinator for the College Republicans and directly involved in planning
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for the Yiannopolous event. I, along with other club members, met multiple times with campus
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administrators who were our planning advisors. Initially, our advisors estimated security, building
14 rental, equipment and staffing would cost us $1,000. In subsequent meetings, we were given a revised
15 estimate of $5,000 and then $7,000. At no time, did the administration officials explain the rising cost
16 estimates except to say that because they were expecting heightened protests, the cost of security
17 would increase to cover additional officers.
18 5. On the night of January 20, 2017, approximately 400 people gathered in Red Square to
cue up for the Yiannopolous event. At approximately 5 p.m., a number of black-clad individuals
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wearing masks and carrying sticks and flagpoles showed up breaking bricks, attempting to bust down
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barricades and harassing people.
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6. At approximately 7 p.m. an altercation occurred in which a protester was shot. Two
22 people were charged with assaulting the protester. The College Republicans raised money to cover the
23 security fees through a gofundme campaign. After the event, the College Republicans received an
24 invoice from the University for $9,121, which they paid from the money received from the gofundme
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25 campaign. However, the College Republicans did not plan other events in 2017 due to their inability
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26 to cover the exorbitant security costs they anticipated needing.
27 7. As a result of the Yiannopolous event requiring substantial security, the University
adopted a “Safety and Security Protocols for Events” policy. The policy states:
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DECLARATION OF CHEVY SWANSON –
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1 The University of Washington allows student organizations, other non-academic
University groups, and non-University groups to use campus facilities for sponsored
2 events. Campus rules and policies that govern these events are designed to support and
3 facilitate safe and successful activities in venues owned and operated by the University.
(See WAC 478-136-060)
4 Because the safety, security, and physical well-being of our campus community is of
paramount concern to the University, it is the responsibility of any person or organization
5 requesting the use of university facilities to comply with all applicable University policies,
6 procedures, rules and regulations, and applicable local, state and federal laws, including
but not limited to fire, health and safety regulations. This protocol will help facilitate such
7 compliance.
8 When the use of campus facilities involves events, activities, and programs that are likely
9 to significantly affect campus safety, security, and operation, the University will perform
an analysis of all event factors. This could result in additional conditions and requirements
10 placed on the host organization in order to maintain the safety and security of all organizing
parties, guests attending, and the broader campus community. Safety and security concerns
11 may include, but are not limited to, history or examples of violence, bodily harm, property
12 damage, significant disruption of campus operations, and those actions prohibited by the
campus code of conduct and state and federal law.
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During the planning process, host organizations or groups are responsible for making the
14 University aware of any known histories and/or issues of safety and security concerns. The
15 University (i.e., venue coordinator and UWPD) may review all event details and logistics
to determine necessary safety and security protocols. Additionally, if previously unknown
16 or new safety and security concerns arise during the planning process, the University will
review the event details and may alter any conditions and requirements. Any determination
17 by authorized campus officials will be based on an assessment of credible information other
18 than the content or viewpoints anticipated to be expressed during the event. Other events
taking place on or near campus will be taken into consideration in the security review.
19 Required security measures may include, but are not limited to, adjusting the venue, date,
and timing of the event; providing additional law enforcement; imposing access controls
20 or security checkpoints limiting costumes or items carried; and/or creating buffer zones
21 around the venue.
22 The host organization or group will be required to pay costs of reasonable event security
as determined in advance by the University. These costs include, but are not limited to
23 security personnel, costs to secure the venue from damage, and special equipment as
24 determined by law enforcement. Security fees will be based on standard and approved
recharge rates for UWPD, other security personnel, and associated equipment costs or
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25 rentals. Should the University place supplementary security protocols prior to or during the
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event to provide adequate security to help mitigate any originally unforeseen security
26 concerns, additional security fees may be charged to host organizations or groups. Host
27 organizations are financially responsible for damage, inside or outside of the venue, caused
by members of their organization or their invitees.
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DECLARATION OF CHEVY SWANSON –
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1 The University reserves the right, in rare circumstances, to cancel an event if based on
information available it is reasonably believed that there is a credible threat which
2 unreasonably places the campus community at risk of harm.1
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8. In October 2017, an individual associated with Patriot Prayer, Kyle Broussard,
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contacted me offering to have the group’s founder and leader, Joey Gibson, come to the campus on
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November 22, 2017, for an indoor speaking event. Patriot Prayer is an informal group of evangelical
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Christians formed and led by Gibson to convey a message of peace. Its Facebook page says it is about
7 “using the power of love and prayer to fight the corruption both in the government and citizen levels
8 that seek to gain power through division and deception.” 2 Despite this description, Gibson has been
9 the target of physical assault by Antifa and similar violent left-wing activist groups who label him a
10 white supremacist and Nazi.
11 9. In October 2017, I, along with other members of the College Republicans, met with
12 Defendant Renee Singleton, assistant director of Student Activities, and Christina Coop, senior
activities advisor for Student Activities, to discuss planning for the Patriot Prayer event. Defendant
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Singleton told me that security costs would be high due to security concerns. Singleton also told me
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that Patriot Prayer is a controversial group and would present major security problems. Based on those
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representations, the College Republicans decided not to move forward with the event.
16 10. In January 2018, we discussed holding a Patriot Prayer event outdoors to defray the
17 costs associated with room, equipment and some of the security costs. We reached out to Gibson to
18 inquire about scheduling an outdoor event in February 2018.
19 11. I met again with campus advisors to discuss planning for a February outdoor event. On
20 February 1, 2018, Defendant Craig Wilson, Patrol Commander with the UW Seattle Police
21 Department, told me the cost of security would be $17,000 due to expected violent protests. Wilson
did not explicitly detail the reasons for such a large security fee. No other group has been charged such
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an excessively large security fee in the past. See, e.g. Exh. 1, a true and correct copy of UWPD Security
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1 Safety and Security Protocols for Events: Safety and Security Protocols for Events Sponsored by
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Student Organizations, Non-Academic University Users, and Non-University Users with Potential to
27 Disrupt Campus Security, Safety and Operation; [Link]
guide/safety-and-security-protocols-for-events/.
28 2 [Link]
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DECLARATION OF CHEVY SWANSON –
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