Participated in an amicus brief (with the Reporters Committee and other amici) filed with the U.S. Court of Appeals for the Ninth Circuit in Index Newspapers v. U.S. Marshals Service. The case involves an appeal by the Department of Homeland Security to overturn a district court’s injunction prohibiting the use of dispersal orders against journalists, issued in connection with the Department’s response to protests in Portland. The brief supports the injunction, arguing that dispersal orders must be narrowly tailored to accommodate newsgathering and cannot constitutionally be applied to journalists who have not committed an unlawful act other than failure to disperse. The brief asks the Ninth Circuit to affirm the preliminary injunction.