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CAIR LEGAL DEFENSE FUND

Lena F. Masri (D.C. Bar # 100019) (seeking pro hac vice admission)

Email: lmasri@cair.com

Gadeir I. Abbas (VA Bar # 81161) (seeking pro hac vice admission)

Email: gabbas@cair.com

Carolyn M. Homer (D.C. Bar # 1049145) (seeking pro hac vice admission)

Email: chomer@cair.com

453 New Jersey Ave., SE

Washington, DC 20003

Phone: (202) 742-6420

Fax: (202) 488-0833

KELLY / WARNER, PLLC

8283 N. Hayden Road, Suite 229

Scottsdale, Arizona 85258 

Raeesabbas Mohamed, Esq. (AZ Bar # 027418)

Email: raees@kellywarnerlaw.com

Phone: (480) 331-9397

Fax: (866) 961-4984

Attorneys for Plaintiffs 

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

PHOENIX DIVISION

AMERICAN MUSLIMS FOR PALESTINE

and DR. HATEM BAZIAN 

Plaintiffs,

vs.

ARIZONA STATE UNIVERSITY; ARIZONA 

BOARD OF REGENTS; and MARK 

BRNOVICH, in his official capacity as 

Attorney General of Arizona

Defendants.

Case No. 

COMPLAINT AND JURY DEMAND

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TABLE OF CONTENTS

INTRODUCTION .......................................................................................................1

PARTIES .................................................................................................................2

JURISDICTION & VENUE........................................................................................3

FACTUAL BACKGROUND......................................................................................3

The Israel – Palestine Conflict is a Fraught Issue of International Importance ..........3

Arizona Passes Anti-Boycott, Divestment, and Sanctions Legislation.......................5

Muslim Students Association Invites Pro-Palestine Speakers to Campus Event........6

FIRST CAUSE OF ACTION: VIOLATION OF THE FIRST AND 

FOURTEENTH AMENDMENTS TO THE U.S CONSTITUTION..........................9

PRAYER FOR RELIEF.............................................................................................12

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INTRODUCTION

1. The First Amendment protects the rights of all speakers to advocate for 

all viewpoints on issues of public concern. “If there is any fixed star in our 

constitutional constellation, it is that no official, high or petty, can prescribe what shall 

be orthodox in politics, nationalism, religion, or other matters of opinion or force 

citizens to confess by word or act their faith therein.” West Virginia State Bd. of Educ. 

v. Barnette, 319 U.S. 624, 642 (1943).

2. The conflict between Israel and Palestine is a longstanding issue of 

considerable public concern, both in the United States and internationally, to which 

politicians, professionals, and the press dedicate considerable energy and resources.

3. In 2016, the State of Arizona chose to categorically take Israel’s side in 

this international conflict by adopting Ariz. Rev. Stat. § 35-393. This Act bars the 

State of Arizona from entering into government contracts with companies or persons

who engage in or advocate for economic boycotts of Israel. 

4. On February 22, 2018 the Muslim Students Association of Arizona State 

University invited American Muslims for Palestine and Dr. Hatem Bazian to speak at 

an April 3, 2018 educational event regarding Palestinian perspectives on Middle East 

conflict, including the Boycott, Divestment and Sanctions Movement. Because of the 

Act, however, Arizona State University’s standard outside speaker contract was 

amended in 2016 to contain a “No Boycott of Israel” clause. American Muslims for 

Palestine and Dr. Hatem Bazian cannot agree to that clause. They are therefore barred 

from presenting at the April 3, 2018 campus event solely because they engage in and 

advocate for economic boycotts of Israel as a means to promote Palestinians’ human 

rights.

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5. Arizona’s ban on contracting with any boycotter of Israel constitutes 

viewpoint discrimination that chills constitutionally-protected political advocacy on 

behalf of Palestine. This Court should enjoin enforcement of Ariz. Rev. Stat. § 35-

393 and the “No Boycott of Israel” clause under the First Amendment, thereby 

permitting Plaintiffs to participate in the Muslim Students Association’s event on 

April 3, 2018.

PARTIES

6. Plaintiff AJP Educational Foundation, Inc., doing business as American 

Muslims for Palestine, is a 501(c)(3) non-profit organization committed to educating 

the American public about Palestine’s rich heritage while advocating for Palestinian 

justice. American Muslims for Palestine is headquartered in Bridgeview, Illinois with 

offices in Washington, D.C. and seven state chapters.

7. Plaintiff Dr. Hatem Bazian is a Professor of Islamic Law and Theology 

at Zaytuna College, which he cofounded as the first accredited Muslim liberal arts 

college in the United States. Separately, Dr. Bazian serves as a lecturer and adjunct 

professor at the University of California, Berkeley, where he earned his Ph.D. Dr. 

Bazian founded and chairs American Muslims for Palestine. He is also a cofounder 

of Students for Justice in Palestine. Dr. Bazian is an internationally renowned expert 

on Islamophobia and a leader of the Boycott, Divestment, and Sanctions (“BDS”)

movement in America.

8. Defendant Arizona State University (“ASU”) is a public university 

within the Arizona University System, with its flagship campus located in Tempe, 

Arizona. 

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9. Defendant Arizona Board of Regents is the governing public body for 

the Arizona University System, including Arizona State University. The Arizona 

Board of Regent’s principal place of business is located at 2020 N. Central Ave., Suite 

230 in Phoenix, Arizona.

10. Defendant Mark Brnovich is the Attorney General of Arizona. The 

Attorney General’s principal office is located at 2005 N. Central Ave in Phoenix, AZ. 

He is responsible for enforcing and defending the constitutionality of Arizona law. 

Defendant Brnovich is sued in his official capacity, only.

JURISDICTION & VENUE

11. This Court has subject matter jurisdiction under 28 U.S.C. § 1331 

because this action arises under federal law, namely the First and Fourteenth 

Amendments to the U.S. Constitution.

12. Declaratory relief is authorized by 28 U.S.C. §§ 2201 and 2202.

13. This Court has personal jurisdiction over the Defendants because they 

reside in this district.

14. A substantial part of the events or omissions giving rise to the claims 

alleged in this Complaint occurred in this Judicial District. Venue therefore lies in the 

United States District Court for the District of Arizona pursuant to 28 U.S.C. § 

1391(b)(2).

FACTUAL BACKGROUND

The Israel – Palestine Conflict is a Fraught Issue of International Importance

15. The relationship between Israel and Palestine is one of the most 

significant international political conflicts of the modern era. One of the core disputes 

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within that conflict concerns Israel’s continuing occupation and settlement of 

Palestinian territories, including the West Bank and Golan Heights. 

16. On December 23, 2016, the United Nations Security Council 

unanimously (with the United States abstaining) adopted Resolution 2334. The 

Resolution condemned Israeli settlements in the Occupied Palestinian Territories, and 

reaffirmed that continuing settlements “constitute[e] a flagrant violation under 

international law and a major obstacle to the achievement of the two-State solution 

and a just, lasting and comprehensive peace.” The Resolution additionally 

condemned Israeli violence and human rights abuses against Palestinians.

17. A robust international movement seeks to impose economic pressure on 

Israel to cease its settlement activity in Palestinian Territory. Calling itself “Boycott, 

Divestment, and Sanctions” or “BDS,” the movement seeks the peaceful end of Israeli 

discrimination against and maltreatment of Palestinians. The BDS movement 

specifically encourages economic divestment from institutions that are not in 

compliance with established international law related to the Israeli occupation of 

Palestine.

18. The United States has historically discouraged Israeli settlements as 

“inconsistent with international law.” Overall, however, U.S. policy strongly supports 

Israel, and the U.S. and Israel enjoy close political and economic relationships. These 

friendly relations have tended to soften or mute the United States’ criticism of Israeli 

settlements. The United States abstained from Resolution 2334 due to its political 

support of Israel, and previously vetoed a similar U.N. Resolution in February 2011.

19. The merits of all perspectives in the Israel-Palestinian conflict and the 

U.S.’s respective political positions are robustly and publicly debated by leading 

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politicians, academics, universities, non-profit organizations, businesses, and media 

organizations in the United States and around the world. 

Arizona Passes Anti-Boycott, Divestment, and Sanctions Legislation

20. Because the prevailing political sentiment in the United States favors 

Israel, many U.S. states, private organizations, and public officials view the 

Palestinian-led Boycott, Divestment, and Sanctions movement as a threat to U.S.-

Israel economic relations and Israel’s sovereignty. 

21. This political climate has, in recent years, prompted local and state 

legislatures to consider more than a hundred bills and resolutions aimed at hindering 

the Boycott, Divestment, and Sanctions movement. At least twenty-four states have 

enacted legislation.

22. Arizona is one state to enact anti-Boycott, Divestment, and Sanctions 

measures. On March 17, 2016, Arizona enacted HB 2617, codified at Ariz. Rev. Stat. 

§ 35-393 et. seq. In support of the Act, the legislature found that “Boycotts and related 

tactics have become a tool of economic warfare that threaten the sovereignty and 

security of key allies and trade partners of the United States.” The Legislature then

specifically identified Israel as a subject of threatening boycotts. “The state of Israel 

is the most prominent target of such boycott activity, beginning with the Arab League 

Boycott adopted in 1945, even before Israel’s declaration of independence as the 

reestablished national state of the Jewish people.”

23. The Legislature concluded that “a company’s decision to discriminate 

against Israel, Israeli entities or entities that do business with Israel or in Israel is an 

unsound business practice making the company an unduly risky contracting partner 

or vehicle for investment.”

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24. Based on these findings, Arizona law now prohibits all public entities 

from contracting with any company that boycotts Israel, or any person who may 

induce others to boycott Israel.

25. Specifically, Ariz. Rev. Stat. § 35-393.01 provides:

A. A public entity may not enter into a contract with a company to 

acquire or dispose of services, supplies, information technology or 

construction unless the contract includes a written certification 

that the company is not currently engaged in, and agrees for the 

duration of the contract to not engage in, a boycott of Israel.

B. A public entity may not adopt a procurement, investment or other 

policy that has the effect of inducing or requiring a person or 

company to boycott Israel.

26. The Act defines “boycott” to include “engaging in a refusal to deal, 

terminating business activities or performing other actions that are intended to limit 

commercial relations with Israel.” Ariz. Rev. Stat. § 35-393.

27. To comply with this statutory provision, Arizona agencies and public 

entities including state universities have started including language in their boilerplate 

contracts which bars boycotts of Israel.

Muslim Students Association Invites Pro-Palestine Speakers to Campus Event

28. The Muslim Students Association at Arizona State University seeks to 

engage in interfaith and intellectual dialogue. To that end, it regularly hosts events on 

campus, including inviting guest speakers. Recent events include:

(a) a presentation on the “History of Islam in America” by Ustadh Ubaydullah Evans 

from the American Learning Institute for Muslims; (b) a panel discussion on 

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“Contemporary Perception of Islam” with Imraan Siddiqi, the Executive Director of 

CAIR-Arizona, Imam Yaser Ali, a local attorney, and Imam Anas Hlyahel, a 

contributory author to the popular blog Muslim Matters; and (c) a discussion of 

“Women in Islam: Beyond the Stereotypes” with Amal Fayad, a local counselor and 

Naeema Zaman, a local academic.

29. The political climate of the Middle East, including all facets of the Israeli 

– Palestinian conflict, is of particular interest to the Muslim Students Association and 

its membership. It is also of interest to other professors and students across campus. 

For example, Arizona State University houses the School of Politics and Global 

Studies, the School of Historical, Philosophical, and Religious Studies, the 

Department of Jewish Studies, the Council for Arabic and Islamic Studies, and the 

Center for the Study of Religion and Conflict – all of which may be interested in a 

discussion of Israel and Palestine. 

30. Arizona State University is committed to academic freedom, and to 

providing an open venue for student organizations to invite outside speakers and host

educational events on a wide variety of subjects, and from a wide variety of 

viewpoints. Student organizations have broad authority to create events and choose 

who to invite to speak. Such presentations do not reflect the views of Arizona State 

University itself, but rather those of the individual speakers. For example, the ASU 

chapter of Students for Justice in Palestine has repeatedly hosted an “Apartheid 

Week.” For many years, these students set up a large “Mock Apartheid Wall” on the 

Hayden Lawn filled with art and educational information regarding Palestinian 

perspectives on Israel’s occupation of Palestinian territories, and Israel’s relegation 

of Palestinians to second-class status.

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31. On February 22, 2018, the leadership of the Muslim Students 

Association invited American Muslims for Palestine and the organization’s chairman, 

Dr. Hatem Bazian, to give a guest educational presentation on campus. The 

presentation will be on the BDS movement and is scheduled for April 3, 2018.

32. The Muslim Students Association has issued many invitations and 

scheduled many outside speakers in the past, without incident.

33. To host an event, the Arizona Board of Regents and Arizona State 

University require that student organizations pre-clear the availability of physical 

facilities, and that the outside speaker sign the university’s standard 

“Speaker/Artist/Performer Agreement.”

34. The standard “Speaker/Artist/Performer Agreement” was amended 

sometime after passage of Ariz. Rev. Stat. § 35-393 in March 2016. Paragraph 20 of 

the agreement now reads, in full: “No Boycott of Israel. As required by Arizona 

Revised Statutes § 35-393.01, Entity certifies it is not currently engaged in a boycott 

of Israel and will not engage in a boycott of Israel during the term of this Contract.” 

35. Both American Muslims for Palestine and Dr. Hatem Bazian advocate 

for boycotts of Israel due to Israel’s continuing violations of international law in its 

treatment of Palestinians. Dr. Hatem Bazian and American Muslims for Palestine 

intend to use their speaking opportunity at Arizona State University to educate the 

campus community about the historical context and rationale for the peaceful 

Palestinian Boycott, Divestment, and Sanctions movement.

36. Neither Dr. Hatem Bazian nor American Muslims for Palestine can or 

will sign the contract with the “No Boycott of Israel” provision, which is required by 

state law. As advocates for Palestinian rights and justice, they cannot in good faith 

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certify or state that they do not boycott Israel, and will not engage in a boycott of 

Israel.

37. Dr. Hatem Bazian and American Muslims for Palestine would accept the 

Muslim Students Association’s invitation if the “No Boycott of Israel” clause were 

stricken. They agree to all other contractual terms. The “No Boycott of Israel” 

provision of the ASU’s standard speaker agreement is, to Plaintiffs’ knowledge, the 

only barrier to their participation at the Muslim Student Association’s scheduled April 

3, 2018 event.

FIRST CAUSE OF ACTION 

VIOLATION OF THE FIRST AND FOURTEENTH AMENDMENTS TO 

THE U.S CONSTITUTION

38. Plaintiffs incorporate all of the above paragraphs as though fully set forth 

herein.

39. The First Amendment provides: “Congress shall make no law ... 

abridging the freedom of speech, or of the press.” U.S. CONST. Amend. I.

40. The First Amendment binds the State of Arizona pursuant to the 

incorporation doctrine of the Fourteenth Amendment.

41. Political speech on issues of great national and international importance 

is central to the purposes of the First Amendment. Speech and advocacy related to 

the Israel – Palestine conflict is core political speech on a matter of public concern 

entitled to the highest levels of constitutional protection.

42. Economic boycotts for the purposes of bringing about political change 

are entrenched in American history, beginning with colonial boycotts on British tea. 

Later, the Civil Rights Movement relied heavily on boycotts to combat racism and 

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bring about societal change. The Supreme Court has recognized that non-violent 

boycotts intended to advance civil rights constitute “form[s] of speech or conduct that 

[are] ordinarily entitled to protection under the First and Fourteenth Amendments.” 

NAACP v. Claiborne Hardware Co., 458 U.S. 886 (1982). 

43. The First Amendment protects the rights of speakers to call for and 

participate in economic boycotts as a means of amplifying their message. Joining 

voices together to participate in and call for political boycotts is protected association 

under the First Amendment. 

44. The Arizona Board of Regents and Arizona State University provide a 

limited public forum for student organizations and their sponsored educational events. 

Any “ideologically driven attempts to suppress a particular point of view” within that 

forum “are presumptively unconstitutional.” Rosenberger v. Rector and Visitors of 

the University of Virginia, 515 U.S. 819, 830 (1995).

45. Ariz. Rev. Stat. § 35-393 and the “No Boycott of Israel” clause each 

constitute viewpoint discrimination, because they only bar speech and expression

against Israel, and not speech or expression in favor of Israel or against Palestine. 

46. Ariz. Rev. Stat. § 35-393 and the “No Boycott of Israel” clause each 

constitute content-specific restrictions on speech, because they single out boycotts of 

Israel for disfavored treatment.

47. Ariz. Rev. Stat. § 35-393 and the “No Boycott of Israel” clause each 

constitute speaker-specific restrictions on speech, because they single out government 

contractors who advocate for Palestine and against Israel as specific speakers who 

warrant disfavored treatment.

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48. Ariz. Rev. Stat. § 35-393 and the “No Boycott of Israel” clause each 

impose a prior restraint on speech, by requiring speakers to certify in advance that

they do not and will not engage in a boycott of Israel.

49. Ariz. Rev. Stat. § 35-393 and the “No Boycott of Israel” clause each 

constitute impermissible State attempts to impose conditions on an independent 

contractor on a basis that infringes constitutionally protected freedom of speech.

50. Ariz. Rev. Stat. § 35-393 and the “No Boycott of Israel” clause each 

constitute impermissible State attempts to impose an ideological litmus test or compel 

speech related to government contractors’ political beliefs, associations, and 

expressions.

51. Ariz. Rev. Stat. § 35-393 and the “No Boycott of Israel” clause are each 

substantially overbroad.

52. Ariz. Rev. Stat. § 35-393 and the “No Boycott of Israel” clause are each 

void for vagueness.

53. Both Ariz. Rev. Stat. § 35-393 and the “No Boycott of Israel” clause 

operate to chill the exercise of constitutionally protected speech and associations. 

54. The Arizona Attorney General, Arizona Board of Regents, and Arizona 

State University each lack a compelling or legitimate governmental interest in the 

enforcement of Ariz. Rev. Stat. § 35-393 and the “No Boycott of Israel” clause.

55. Enforcement of Ariz. Rev. Stat. § 35-393 and the “No Boycott of Israel” 

clause does not constitute the least-restrictive means of fulfilling any state interest.

56. Ariz. Rev. Stat. § 35-393 is facially unconstitutional under the First 

Amendment and cannot be enforced against anyone by the Arizona Attorney General.

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57. Ariz. Rev. Stat. § 35-393, as implemented through the “No Boycott of 

Israel” clause in the “Speaker/Artist/Performer Agreement” promulgated by the 

Arizona Board of Regents and Arizona State University, is unconstitutional as applied 

to Plaintiffs and their plans to present, as Palestinian activist speakers, a campus 

discussion on the Israel-Palestine conflict with a on April 3, 2018.

58. Absent an injunction, Plaintiffs will suffer irreparable harm because they 

will be barred by state law and contract from engaging in protected First Amendment 

speech and association on a matter of public concern. Plaintiffs will be chilled in their 

discussion of and advocacy for Palestinian rights, and unable to participate in the ASU 

MSA’s April 3, 2018 event. 

59. If Defendants are not enjoined from enforcing Ariz. Rev. Stat. § 35-393, 

and from including the “No Boycott of Israel” clause in state contracts, Plaintiffs and 

all advocates for Palestine will be effectively prohibited from entering into any 

agreement with the State of Arizona unless they give up the constitutionally-protected 

views that are central to their educational and advocacy missions. 

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs respectfully request the Court enter the following 

relief:

A. Declare Ariz. Rev. Stat. § 35-393 unconstitutional and unenforceable;

B. Issue judgment in Plaintiffs’ favor and against Defendants on all causes 

of action alleged herein;

C. Grant Plaintiffs a preliminary and permanent injunction striking the “No 

Boycott of Israel” clause from their contemplated speaker contract with the 

Arizona Board of Regents and Arizona State University, thereby permitting 

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them to participate in the Muslim Students Association’s planned April 3, 2018 

event regarding the BDS movement. 

D. Enter a preliminary and permanent injunction against Defendants’ 

inclusion of boycott provisions under Ariz. Rev. Stat. § 35-393 in any state 

contract, and against Defendant Attorney General’s continuing enforcement of 

Ariz. Rev. Stat. § 35-393.

E. Declare void any “No Boycott of Israel” clause pursuant to Ariz. Rev. 

Stat. § 35-393 that now exists in any and all contracts between Arizona public 

entities and private companies or persons.

F. Award Plaintiffs their reasonable costs and attorney’s fees pursuant to 42 

U.S.C. § 1988; and

G. Grant such other and further relief as the Court may deem to be just and 

proper.

JURY DEMAND

NOW COME Plaintiffs, by and through their undersigned counsel, and hereby 

demand trial by jury of the above-referenced causes of actions. 

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COMPLAINT

Dated this 28th day of February 2018.

 CAIR LEGAL DEFENSE FUND

By /s/ Lena F. Masri 

 Lena F. Masri (D.C. Bar No. 100019)

 (seeking pro hac vice admission)

 Gadeir I. Abbas (VA Bar No. 81161) 

 (seeking pro hac vice admission)

 Carolyn M. Homer (D.C. Bar No. 1049145)

 (seeking pro hac vice admission)

 453 New Jersey Ave., SE

 Washington, DC 20003

 Phone: (202) 742-6420

 Fax: (202) 488-0833

 KELLY / WARNER, PLLC

By /s/Raees Mohamed 

 Raees Mohamed, Esq. (AZ Bar # 027418)

 8283 N. Hayden Road, Suite 229

 Scottsdale, Arizona 85258

 Phone: (480) 331-9397

 Fax: (866) 961-4984 

 Attorneys for Plaintiffs

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