Page 145 - Aug 2019 BOG Book_Neat

Case 2:19-cv-11962 Document 1 Filed 08/01/19 Page 1 of 21

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF LOUISIANA

RANDY BOUDREAUX,
Case No. __________________
Plaintiff,

v. CIVIL RIGHTS COMPLAINT
FOR INJUNCTIVE AND

LOUISIANA STATE BAR ASSOCIATION, a DECLARATORY RELIEF
Louisiana Nonprofit Corporation;

LOUISIANA SUPREME COURT; 42 U.S.C. § 1983 (Freedom of
BERNETTE J. JOHNSON, Chief Justice of the Speech)

Louisiana Supreme Court; 42 U.S.C. § 1983 (Freedom of
JOHN DOE, successor to the Honorable Greg Association)

Guidry as Associate Justice of the Louisiana 42 U.S.C. § 1988 (Attorney Fees)
Supreme Court for the First District;

SCOTT J. CRICHTON, Associate Justice of the

Louisiana Supreme Court for the Second District;
JAMES T. GENOVESE, Associate Justice of the

Louisiana Supreme Court for the Third District;
MARCUS R. CLARK, Associate Justice of the
Louisiana Supreme Court for the Fourth District;
JEFFERSON D. HUGHES, III, Associate Justice

of the Louisiana Supreme Court for the Fifth
District;

JOHN L. WEIMER, Associate Justice of the
Louisiana Supreme Court for the Sixth District.

1. This civil rights lawsuit seeks injunctive and declaratory relief to prevent

unconstitutional coerced speech and association. The State of Louisiana requires attorneys
Defendant.

to join, associate with, and pay dues to the Louisiana State Bar Association (“LSBA”) in

order to practice their chosen profession in the state. The LSBA then uses those compelled

dues to engage in political and ideological speech, including advocacy on issues of public

COMPLAINT – Page 1