http://www.jointogether.org/news/headli ... -aclu.html
http://www.acluutah.org/uprockcomplaint.pdf
I got a little more information here: http://utahbeehive.blogspot.com/2005/10 ... laint.html
Here's the complaint (pdf) in the Rave suit against the Utah County Sheriff, et al.
FIRST CAUSE OF ACTION
53. The conduct of defendants as set forth above constitutes an illegal search and/or seizure in a violation of the Fourth, Fifth and Fourteenth Amendments to the United States Constitution.
54. Defendants wrongfully entered the Ranch; defendants wrongfully seized that property; defendants wrongfully took control of the activities on the Ranch, ending the concert and ordering concert attendees to leave.
55. The plaintiffs are entitled to declaratory and injunctive relief as a result of that harm.
SECOND CAUSE OF ACTION
56. The conduct of defendants as set forth above constitutes an violation of plaintiffs’ right to be secure on their real property in violation of the Fourth and Fourteenth Amendments of the United States Constitution.
57. The plaintiffs are entitled to declaratory and injunctive relief as a result of that harm.
THIRD CAUSE OF ACTION
58. The conduct of defendants as set forth above constitutes a deprivation of liberty interest without due process in violation of the United States Constitution.
59. Defendants had no authority to order plaintiffs’ patrons and the concert attendees to leave.
60. The plaintiffs are entitled to declaratory and injunctive relief as a result of that harm.
FOURTH CAUSE OF ACTION
61. Utah County Ord. § 13-4-2-1 violates the due process protections of the 5th and 14th Amendments to the United States Constitution as a vague criminal statute.
62. Utah County Ord. § 13-4-2-1 in part requires a permit issued by the defendant County Commissioners for an assembly of two hundred fifty (250) or more people which “can reasonably be expected to continue for twelve (12) or more consecutive hours.” The ordinance contains no guidelines and no criteria to determine whether an event “can reasonably be expected to continue for twelve (12) or more consecutive hours.”
63. The Utah County Ordinance (§ 13-4-2-1) is a criminal ordinance; failure to comply with the ordinance and staging a concert without the requisite permit is a criminal offense.
64. Utah County Ordinance § 13-4-2-1 is unconstitutionally vague in that it does not give clear notice to a reasonable person and members of the public as what conduct constitutes a crime. The Ordinance is unconstitutionally vague in that it does not give notice to law enforcement officers as to the conduct which constitutes a crime. The vaguely worded ordinance allows for arbitrary and capricious application of the ordinance by law enforcement officers. The vaguely worded ordinance chills the plaintiffs’ and others’ right to expression.
65. The plaintiffs are entitled to declaratory and injunctive relief as a result of that harm.
FIFTH CAUSE OF ACTION
66. The conduct of defendants as set forth above constitutes a deprivation of plaintiffs’ right to freedom of association in violation of the United States Constitution.
67. Defendants wrongfully ordered plaintiffs’ patrons, who were lawfully gathered on the Ranch to disperse.
68. The plaintiffs are entitled to declaratory and injunctive relief as a result of that harm.
SIXTH CAUSE OF ACTION
69. The conduct of defendants as set forth above constitutes a deprivation of plaintiffs’ right to free expression in violation of the United States Constitution.
70. The vaguely worded ordinance chills the plaintiffs’ and others’ right to expression.
71. Defendants violated plaintiffs’ right to free expression by silencing the July 16th and August 20th concerts.
72. The plaintiffs are entitled to declaratory and injunctive relief as a result of that harm.
