Moss

FACTS

On October 14, 2004, following a campaign appearance, former President George W. Bush dined at the Jacksonville Inn (the “Inn”) in Jacksonville, Oregon.1 Plaintiffs, who had earlier learned of the President’s plan to visit the Inn, orga- nized a demonstration to express opposition to the President and his policies.

Approximately 200 anti-Bush demonstrators assembled on the sidewalk in front of the Inn around 6:00 p.m. The Presi- dent arrived an hour and fifteen minutes later, entering the Inn’s open air dining patio through a back entrance. Just prior to the President’s arrival, state and local police cleared the alleyway behind the Inn to provide access to the back entrance, and began restricting the movements of some of the demonstrators outside the Inn. At the same time, Defendants permitted dozens of hotel guests and diners to remain inside the Inn without conducting security screening.

Meanwhile, a pro-Bush demonstration had assembled one block west of Plaintiffs’ demonstration. At the time of the 1 The facts stated here, except where noted, are derived from Plaintiffs’ Amended Complaint. MOSS v. U.S. SECRET SERVICE 9069 events at issue in this…