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Searchable text of UFC’s lawsuit against New York

By Zach Arnold | November 15, 2011

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Judge Wood, November 15th, 2011

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

Plaintiffs: Jon Jones, Gina Carano, Frankie Edgar, Matt Hamill, Brian Stann, Zuffa LLC d/b/a Ultimate Fighting Championship, Danielle Hobeika, Beth Hurrle, Donna Hurrle, Steve Kardian, Joseph Lozito, Erik Owings, Chris Reitz, and Jennifer Santiago

-against-

Defendants: Eric T. Schneiderman, in his official capacity as Attorney General of the State of New York, and Cyrus R. Vance, Jr. in his official capacity as District Attorney for the County of New York

Plaintiffs, on knowledge with respect to their own acts, and on information and belief with respect to all other matters, challenge the constitutionality of New York’s ban on the performance of professional mixed martial arts before live audiences.

FIRST CAUSE OF ACTION

THE LIVE PROFESSIONAL MMA BAN IS UNCONSTITUTIONAL AS APPLIED TO PLAINTIFFS
(First Amendment to the Constitution of the United States)

Plaintiffs repeat and reallege each and every allegation contained in paragraphs 1 through 234 as if fully set forth herein.

At all times relevant herein, Defendants have acted, and are acting, under color of state law.

The First Amendment to the Constitution of the United States states, in relevant part, that “Congress shall make no law.. . abridging the freedom of speech ….” U.S. Const. amend. I. By operation of the Fourteenth Amendment to the Constitution of the United States, the First Amendment applies equally to laws passed by the several states, including the State of New York.

The Live Professional MMA Ban bars professional MMA in front of live audiences based on its content. The legislative history of the Ban, including innumerable statements by legislators and other public officials before and since the Ban took effect, make plain that the Ban was adopted in response to what was perceived to be the violent message of MMA. As such, the Ban is a content-based restriction on constitutionally protected speech.

As set out in great detail above, live professional MMA—and all of the related aspects before and after a fight itself—has an expressive content that fighters intend to convey and that fans understand and perceive. This unique communicative process cannot happen live in New York because of the Live Professional MMA Ban.

Live professional MMA is clearly intended and understood as public entertainment and, as such, is expressive activity protected by the First Amendment. That the real purpose of the Ban on live professional MMA was to squelch its expressive element is evident throughout the legislative history, during which legislators and other public officials repeatedly made clear that the purpose of the Ban was to prevent what they perceived as the violent message of MMA.

But for the Ban, promoters such as Plaintiff UFC would produce live MMA events; operators of venues in New York, such as Madison Square Garden, would host live professional MMA events; Plaintiff fighters would fight in them; Plaintiff fans would attend them; and members of the media, would broadcast those events or broadcast, print, and distribute news and stories about those events.

The Live Professional MMA Ban is a content-based restriction on speech and expressive conduct aimed directly at prohibiting the message the State of New York believes is conveyed by the expressive conduct of professional MMA fighters. As the foregoing makes clear, New York misperceives the proper message of MMA. Nonetheless, live professional MMA as described above constitutes entertainment and expressive conduct. Plaintiffs challenge the Ban as applied to them.

New York remains free to regulate live professional MMA, as have most other states. It is the complete ban on professional MMA before live audiences that is unconstitutional.

SECOND CAUSE OF ACTION
THE LIVE PROFESSIONAL MMA BAN IS UNCONSTITUTIONALLY OVERBROAD AND FACIALLY INVALID
(First Amendment to the Constitution of the United States)

Plaintiffs repeat and reallege each and every allegation contained in paragraphs 1 through 243 as if fully set forth herein.

At all times relevant herein, Defendants have acted, and are acting, under color of state law.

The Live Professional MMA Ban is written so broadly that, in addition to prohibiting the constitutionally protected activity of professional MMA fighters and fans, it also prohibits myriad other forms of speech and expression that are protected by the First Amendment, both inside and outside of New York.

The Live Professional MMA Ban broadly prohibits: (1) any professional MMA matches from being “conducted, held or given” within New York, (2) “advancing” professional MMA in New York, or (3) “profiting from” professional MMA in New York. A person who violates the Live Professional MMA Ban is subject to criminal and/or civil penalties. N.Y. Unconsol. Law § 8905-a(2), (3). 248. Section 3(a) of the Live Professional MMA Ban makes it a crime if a person “knowingly advances or profits from a combative sport activity [i.e., MMA]….” Id. § 8905-a(3)(a).

As to “advances,” Section 3(b) states that “[a] person advances a combative sport activity when, acting other than as a spectator, he or she engages in conduct which materially aids any combative sport.” Id. § 8905-a(3)(b) (emphasis added). “Materially aids,” in turn is defined in extraordinarily sweeping terms. Such conduct:

[IJncludes but is not limited to conduct directed toward the creation, establishment or performance of a combative sport, toward the acquisition or maintenance of premises, paraphernalia, equipment or apparatus therefor, toward the solicitation or inducement of persons to attend or participate therein, toward the actual conduct of the performance thereof, toward the arrangement of any of its financial or promotional phases, or toward any other phase of a combative sport.

Id. (emphasis added).

The Live Professional MMA Ban also prohibits any person from "profiting" from a combative sport activity. In Section 3(c), the Live Professional MMA Ban states that a person "profits" from a combative sport activity "when he or she accepts or receives money or other property with intent to participate in the proceeds of a combative sport activity, or pursuant to an agreement or understanding with any person whereby he or she participates or is to participate in the proceeds of a combative sport activity." Id. § 8905-a(3)(c).

It is a violation of the First Amendment to criminalize protected speech. Given the Ban's sweeping prohibition, it reaches, and has the likelihood of chilling, protected speech and conduct. The Ban is substantially overbroad and facially invalid.

The following are just some examples of conduct and speech that appear to fall within the broad language of the Ban, yet clearly are protected by the First Amendment:

• Writing to state officials asking them to repeal the Live Professional MMA Ban because they want live professional MMA events to be lawful in New York.

• Lecturing at a New York college or university, speaking about the long tradition of MMA and its effect on modem culture, such as the lecture given in 2008 at New York University's Stem School of Business by alumnus and CEO and Chairman of Plaintiff Zuffa, Lorenzo Fertitta, regardinn MMA, UFC, The Ultimate Fighter, and the growth of MMA worldwide.

• A local artist selling t-shirts emblazoned with pro-MMA slogans.

• Producing video of out-of-state professional MMA bouts in New York.

• An MMA fan printing a newspaper for distribution in New York, or writing for a blog available in New York, regarding upcoming professional fights and encouraging readers to attend them, such as the Gals Guide to MMA blog founded, written, and maintained by Plaintiffs Beth Hurrle and Donna Hurrle, or The Fight Lawyer blog founded and written by a New York attorney.

• A writer for a New York newspaper who, through his/her descriptive prose, motivates readers to watch and attend professional MMA matches, such as Michael Brick and Justin Porter of The New York Times, and George Willis of the New York Post."

A musician who advocates for the repeal of the Live Professional MMA Ban during a concert at Madison Square Garden, such as James Murphy of LCD Soundsystem, who stated at a live show in Madison Square Garden: "Hey, New York, why don't you allow mixed martial arts?

• A bar or restaurant holding a "UFC Fight Night" for its patrons to come watch MMA, including Manhattan's Playwright Tavern, The House of Brews, Third & Long, Jack Demsey's, Legends Bar & Grill, and many other New York bars that show UFC matches for their patrons.

• UFC "viewing parties" at Madison Square Garden.

• Professional MMA fighters holding autograph sessions for fans within New York.

• Litigating this lawsuit.

• Broadcasting PPV professional MMA events held outside the State on New York television channels, or showing The Ultimate Fighter on Spike TV within New York. PPV professional MMA matches are shown regularly by cable and satellite television providers in New York, including Cablevision, Time Warner Cable, DirecTV, Dish Network, and Verizon FiOS.

• Handing out promotional flyers encouraging fans to go to an out-of-state professional MMA fight.

• Advertising professional MMA events that will be held out-of-state, such as the UFC's billboard advertisements in Times Square.

• The "MMA World Expo" hosted by Manhattan's Jacob Javits Convention Center.

The above list of constitutionally protected activities identifies just a few of the many activities that the broad Live Professional MMA Ban impermissibly restrains.

Because of the Live Professional MMA Ban's gross overbreadth, individuals and entities engaging in protected conduct are liable for prosecution and may be chilled from engaging in such protected conduct.

THIRD CAUSE OF ACTION
THE LIVE PROFESSIONAL MMA BAN IS UNCONSTITUTIONALLY VAGUE
(Due Process Clause of the Constitution of the United States)

Plaintiffs repeat and reallege each and every allegation contained in paragraphs 1 through 254 as if fully set forth herein.

At all times relevant herein, Defendants have acted, and are acting, under color of state law.

The Due Process Clause of the Constitution of the United States prohibits the imposition of sanctions, or threat of imposing those sanctions, if the law is so unclear that a person of ordinary intelligence cannot know what is prohibited. Sufficient notice of what the law prohibits is particularly required where, as with the Live Professional MMA Ban, the sanctions imposed are criminal.

The Live Professional MMA Ban is written with such breadth and lack of clarity that citizens of New York, including a number of the Plaintiffs, are unable to tell what is illegal in New York, what is permitted, what they have the liberty to do, and what they may not do.

Thus, the Live Professional MMA Ban is unconstitutionally vague on its face.

Section 2 of the Ban states that "[n]o combative sport shall be conducted, held or given within the state of New York.” N.Y. Unconsol. Law § 8905-a(2). Both criminal penalties and civil liability are imposed upon “a person who knowingly advances or profits from a combative sport activity.” Id. § 8905-a(3).

What constitutes a “combative sport” is vague. Section 1 of the Ban states that “[a] `combative sport’ shall mean any professional match or exhibition other than boxing, sparring, wrestling or martial arts wherein the contestants deliver, or are not forbidden by the applicable rules thereof from delivering kicks, punches or blows of any kind to the body of an opponent or opponents.” Id. § 8905-a(1). The statute then lists certain organizations whose “professional match[es] or exhibition[s]” are permitted martial arts.

As its legislative history suggests, the Live Professional MMA Ban traps within it numerous forms and exercises of martial arts, in addition to MMA. Senator Franz Leichter of Manhattan tried to make this problem clear to the bill’s sponsor, Senator Goodman, during debate: “I think some of our schools have martial arts exhibits. Clubs have martial arts exhibits that in no way have any relationship or reference to these particular [statutorily-identified] organizations, and it would seem to me that you’re now raising a question whether these martial arts activities can proceed. ,89 Senator Goodman responded by pointing to the statutory exemptions for some martial arts groups. But Senator Leichter understood what the bill’s sponsor apparently did not: this provision of the Ban does nothing to address any confusion regarding martial arts not under the auspices of the organizations enumerated in the statute, such as school or other club martial arts. Senator Leichter was prescient when he said: “I think that this bill may come back to create some problems for us…. I think that we ought to be more careful, frankly, than we are in this bill.”

Neither the statute nor the NY Athletic Commission’s extensive regulations define the term “professional match or exhibition,” although this is the triggering provision for the Ban. The “combative sport activity” that is the target of the Ban is defined with respect to “professional match or exhibition.”

New York State officials are unable to shed clarity on the Ban’s breadth, taking the position—seemingly contrary to the plain language of the statute—that the Ban applies to all performances of MMA, even by amateurs in venues where no alcohol is served, and for which there is no compensation for the fighters. For instance, in a July 18, 2011 article in The Wall Street Journal describing underground MMA in New York, one MMA promoter claimed that because “the fighters aren’t paid and alcohol isn’t served,” his lawyers assured him that his events were legal.91 As reported in the article, however, Lisa MacSpadden, Deputy Secretary of State for Communications and Community Affairs, said via email that “paid or unpaid, and regardless of whether alcohol is served, mixed martial arts exhibitions and matches are illegal in the state of New York.” She added that if the state “is tipped off far enough in advance of a planned match or exhibition, then legal counsel will investigate the matter and issue a `cease and desist’ letter informing the involved parties that the activity is illegal.”

Further confusing matters is the stance taken by the NY Athletic Commission: that even amateur MMA competitions are prohibited. When asked to comment on the unpaid amateur MMA bouts produced by the same promoter noted above, a spokesperson for the NY Athletic Commission “responded by referring to the [Ban] and saying that it would track down and close the show if it knew about it in advance.”

And in 2007, Ron Scott Stevens, then-Chair of the NY Athletic Commission said that MMA fights, regardless of whether the fighters are paid or not, are “most likely illegal” and “if [the Athletic Commission] find[s] out about them, then [the Athletic Commission] move[s] to stop them.”93 The phrase “most likely illegal” is in and of itself telling. If the NY Athletic Commission does not know what the Ban covers, how is anyone else supposed to?

It is unclear what the position taken by the NY Athletic Commission actually means. Does the Ban apply to an exposition of martial arts during a show at the Javits Center, where the fighters are not paid for that exposition? Does the Ban include a match in which the athletes and promoters are paid but agree to donate their winnings to charity? Does the Ban apply to contestants who are only compensated for “winning” a match and not their “participation” in the match? What if a fighter who fights for free is paid by an advertiser for wearing its brand of clothing or its insignia during a fight? Some of these have occurred already in New York.

Because of the vagueness of the Ban, MMA promoters who would otherwise produce amateur MMA matches in New York, where the fighters are not paid and no alcohol is served, are unable to do so for fear of being shut down by the NY Athletic Commission and facing civil liability and/or criminal prosecution. For example, NINA promoters do not promote even amateur fights in New York because of the lack of clarity in Live Professional MMA Ban and positions taken by the NY Athletic Commission on the issue.

Similarly, amateur MMA fighters, including Plaintiffs Hobeika and Reitz, would compete in amateur MMA bouts in New York but for the Ban and the fear that they will face civil liability and/or criminal prosecution.

In another example of the Ban’s facial vagueness, Section 3(c) states that a person “profits” from a combative sport activity if that person shares in the proceeds of such activity. N.Y. Unconsol. Law § 8905-a(3)(c). Under this section, does a New York company, or a company with offices in New York, violate the Ban by televising or otherwise portraying in New York live professional MMA matches that do not occur in New York? This occurs with regard to many national MMA promotions.

Most vague are the statutory prohibitions in Section 3(a) that make it criminal for a person to “knowingly advance[] or profit[] from a combative sport activity.” Id. § 8905- a(3)(a). The statute contains a laundry list of such conduct, which “includes but is not limited to conduct directed toward the creation, establishment or performance of a combative sport” and numerous other activities. Id. § 8905-a(3)(b). The following are just a sample of activities that either occur in New York or in which parties would like to engage, but that arguably are covered by the Ban:

• Amateur athletes training in New York to become professional MMA fighters, and their trainers.
• Professional fighters training in New York for out-of-state matches.
• Gym owners in New York who profit from training professional MMA fighters. • Selling tickets online to out-of-state professional MMA bouts.
• Advertising in New York a professional match held out-of-state. Selling any professional MMA paraphernalia, including T-shirts, onesies for babies, and action figures, toys, or games.

There is nothing ephemeral about these questions. Countless businesses and individual proprietors currently do these things in New York. All are arguably within the ambit of the Ban and, thus, all are potentially subject to civil and criminal liability.

Indeed, a number of these questions surfaced but were not resolved during legislative consideration of the Live Professional MMA Ban. Senator Richard Dollinger of Rochester, for example, highlighted the vagueness of the statute, saying that he was concerned by “the issue is that Pay Per View, the television implications and the question of to what extent you can be a promoter in New York State even though the fight occurs some place else. Senator Dollinger expressed willingness “to give the final punch to ultimate fighting” but expressed doubt whether the bill was clear enough: “this bill could use a little further drafting to better define exactly what we’re trying to weed out of the process.”95 Similarly, Senator Leichter said, “[I]t’s not a carefully drafted bill because certainly your reading of this bill would seem to imply that any activity in this state related to ultimate fighting, wherever, in Alabama, New Jersey, and so on, could be a criminal act.”

If the legislators who enacted the Ban—some of whom fully supported the elimination of MMA—do not know what the Ban means, the public cannot be expected to know. If the statute is so unclear that even the NY Athletic Commission’s interpretations of it differ, people cannot know if their conduct is criminal or not.

The Ban is thus unconstitutionally vague.

FOURTH CAUSE OF ACTION
THE LIVE PROFESSIONAL MMA BAN VIOLATES PLAINTIFFS’ RIGHTS TO EQUAL PROTECTION OF THE LAWS
(Fourteenth Amendment to the Constitution of the United States)

Plaintiffs repeat and reallege each and every allegation contained in paragraphs 1 through 275 as if fully set forth herein.

At all times relevant herein, Defendants have acted, and are acting, under color of state law.

But for the Live Professional MMA Ban, Plaintiff fighters would fight in New York, Plaintiff UFC would promote live events in New York, Plaintiff fans would come watch live professional events in New York, and Plaintiffs in media would cover and/or work on media of live professional fights in New York.

MMA is as safe as, or safer than, a variety of other sporting events and inherently dangerous activities that are permissible in New York, yet the live performance of MMA is singled out and treated differently than those sports, events, and activities.

The Fourteenth Amendment to the Constitution of the United States provides that “no state shall deny to any person … the equal protection of the laws.” U.S. Const. amend. XIV (the “Equal Protection Clause”). This provision has been held to protect individuals and corporate entities alike.

The essential mandate of the Equal Protection Clause is that “likes” shall be treated alike. Although as a general matter courts are deferential to legislative judgments in the economic sphere, still those judgments must be rational and based in actual facts.

As discussed above, at the time the Live Professional MMA Ban was enacted, MMA was unregulated and in its infancy. Even so, the legislative history is virtually devoid of information regarding the safety of professional MMA relative to other activities that are perfectly legal in New York, some of them sporting events and some of them not.

More important, the testimony of medical professionals before the state legislature indicated that boxing—which was and remains entirely legal in New York—was more dangerous than MMA. The hearing at which these medical professionals testified was the sole evidence-gathering event of the legislature’s consideration of the Ban.

Since the time of the Ban’s enactment, and certainly now, there has been ample medical and scientific evidence that other activities and sporting events, such as boxing, football, ice hockey, downhill skiing, equestrian activities and sports, rodeos, and walking on a tightrope over Niagara Falls, are as or more dangerous than MMA.

Any claim that MMA is so dangerous that it requires banning, rather than regulating, is belied by the Ban itself—and, in particular, what the Ban does not say. The practice of MMA is widespread in New York. Countless gyms offer MMA training, to individuals from the very young to the adult. Undoubtedly, MMA matches occur every day in the state. Yet, none of this is illegal. If MMA is so dangerous, then certainly the Ban could have been drafted so as to prohibit all MMA activities. Yet, the Ban prohibits only live professional MMA. Moreover, it is unclear whether amateur matches are entirely legal under the Ban. Although the Ban, by its plain words, does not appear to cover amateur MMA, the NY Athletic Commission and some State officials—in clear demonstration of the Ban’s vagueness—have taken a contrary position. Thus, arguably, matches by complete amateurs with no requisites of training or safety are entirely lawful, while the matches of professionals—attendant with numerous rules and safeguards—are not.

Further, the Ban explicitly exempts a variety of martial arts, including judo, tae kwon do, karate, and kenpo. There is no basis whatsoever in the legislative history for discriminating between these sports and MMA, and the medical evidence supports no such discrimination. Indeed, MMA essentially is a combination of martial arts, all of which are allowed and regulated in New York. Individually, they are all legal; together, they are banned.

It is simply irrational to ban only live professional MMA which is regulated throughout the United States—on safety grounds, and yet permit MMA’s component martial arts, as well as many other sporting events and other activities far more dangerous than professional MMA.

The Live Professional MMA Ban violates the Equal Protection Clause in that it discriminates for no rational reason.

It is also irrational under the Equal Protection Clause to ban live professional MMA because of its perceived message. Even assuming the message of MMA is solely one of violence, which it is not, and even assuming that banning it because of this message is lawful under the First Amendment, which it is not, still there are numerous other activities neither regulated by nor banned by New York that send blatant messages of violence.

In fact, during the Senate debate over the Live Professional MMA Ban, the bill’s sponsor was explicitly asked about professional wrestling, which operates without rules. Senator Goodman responded that “[t]he whole thing is obviously a sham for entertainment purposes and what seems to be happening is not happening at all. It’s an illusion, a chimera.i97 But not everyone watching professional wrestling—particularly the children on whom the opponents of MMA focus so heavily—know it is “a sham for entertainment purposes.” Nor is it clear why that matters: viewers watch professional wrestling for violence that exceeds that of MMA, while lacking much of the professional restraint and skillful competition of MMA. Professional wrestling both appears to be more violent, and is in fact more dangerous, than MMA. According to Professor Cheever, even though professional wrestling is “entertainment,” its message of brutality is targeted and marketed to kids, who, developmentally, do not understand the differences between real violence and fake violence.

Numerous activities and materials in New York State are drenched in messages of violence—from first-person shooter video games, to violent movies and lyrics in pop music, to graphic network news—yet, the New York legislature singled out live professional MMA as the one activity sending an impermissible message.

Thus, on grounds of message as well, the Live Professional MMA Ban violates the Equal Protection Clause in that it discriminates for no rational reason.

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Topics: MMA, Media, UFC, Zach Arnold | 12 Comments » | Permalink | Trackback |

12 Responses to “Searchable text of UFC’s lawsuit against New York”

  1. 45 Huddle says:

    I don’t know if this will be successful, but it’s an interesting way to go about it. The UFC tried to work with lawmakers, and it failed. This seems like a logical next step.

    We all know MMA will be sanctioned in New York eventually…. just depends on when.

  2. Michael Rome says:

    All the press is for the first cause of action. But the heart of the lawsuit is the second cause of action.

  3. Steveo says:

    All seems sound and vaild to me, everyone knows its a revenge deal by the culinary union for union breaking in Nevada.. Which makes the whole ban invalid and illegal. :D

  4. RST says:

    Pretty slick.

    :)

    I’m not sure if I admire it or despise it.
    But at worst it does seem like fair game.

  5. Alan Conceicao says:

    I’d love to hear what prior rulings exist that make people outside the MMA bubble believe it has a snowball’s chance in hell.

  6. Chris says:

    Cute, but this lawsuit will go nowhere.

  7. Michael Rome says:

    They have a good case for a vagueness claim, which is their second cause of action. The law bans “advancing MMA.” This could mean anything from putting up a UFC billboard in Times Square to standing outside the legislature with a sign that says “legalize MMA now.” The latter is unquestionably protected speech, and the law is so vaguely written that it is unclear whether it is allowed or not. As they point out in the complaint, even filing this suit might be criminal activity under the law.

    The first claim is novel but I don’t see it having much traction.

  8. edub says:

    http://mmajunkie.com/news/26124/ufc-on-fox-peaks-with-8-8-million-viewers-for-velasquez-dos-santos-title-fight.mma

    So all that talk about the fight not having as many viewers as Kimbo were completely off base, we have a new most watched fight in American MMA history.

  9. Zack says:

    The big question is will that fight turn new viewers into PPV buys and will they tune in next time. Of course the first show was going to pop a huge number.

    • Light23 says:

      I don’t think a badass one minute KO is going to turn anybody off. If they were tuning in, that’s probably the sort of thing they wanted to see.

  10. Chris says:

    Zach,

    The Sonnen dog and pony show is so tired at this point. God bless you for listening to that drivel.

  11. [...] Fight Opinion has Searchable text of UFC’s lawsuit against New York so you can get up to snuff with what is happening [...]

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