Swope v. Lubbers

OPINION RE MOTION FOR INJUNC-TIVE AND DECLARATORY RELIEF

Presently before the court are plaintiffs’ requests for declaratory and injunctive re *1329 lief pursuant to Fed.R.Civ.P. 65. Plaintiffs allege that the rights secured them by the First Amendment, and their Fourteenth Amendment rights to due process of law have been violated, and accordingly bring suit under 42 U.S.C. § 1983. Jurisdiction is alleged under 28 U.S.C. §§ 1331 and 1343(3) and (4).

Plaintiffs are students at Grand Valley State College [“Grand Valley”], a publicly-funded state college, 1 and members of the Student Senate of the College. The defendants are, besides the College, members of Grand Valley’s “Board of Control,” Ar-end Lubbers, the President of the College, and Linda Johnson, Dean of Students.

The dispute arises out of the proposed showing of an “X”-rated film on the Grand Valley campus located near Grand Rapids. Each semester, at registration, Grand Valley students pay a “general service fee” of $15.00. This money is commingled with other college funds. Each year, the Grand Valley Student Senate is allocated $60,000 to be spent for extra-curricular student activities, such as the showing of motion pictures. A “Programming Committee” is formed by Student Senate members, and in the fall of 1982 it conducted a survey among Grand Valley students to assess interest in activities the Programming Committee could bring ,to campus. In the survey, ten categories of movies were listed (western, science fiction, etc.). The top three in order were “comedy,” which received 179 votes; “adventure,” 128 votes and “X-rated,” 108 votes.

Typically, in the fall, a proposed schedule of films is presented by the Student Senate to the administration. Some time before a particular film is scheduled to be shown, a student on behalf of the Student Senate would write to Ms. Johnson or one of her assistants and request that funds be issued for the activity in question. Ms. Johnson or a staff member would then direct the college’s Purchasing Department to issue a check to the vendor of the particular activity. The purchase order typically indicated that the money was spent on request of the Student Senate. If a film had been ordered, it was delivered to Ms. Johnson’s office. Prior to February of 1983, no official guidelines had been adopted to guide defendant Johnson on what films she could or could not order.

In the fall of 1982, the Student Senate responded to the student interest reflected in the survey. Twenty-five films were selected. The schedule included only one X-rated film entitled “Inserts.” 2 “Inserts” is a United Artists production starring Richard Dreyfus. Set in the 1930s, the film is about the crisis in the life of a man who had been a famous director of silent motion pictures. With the onset of “talkies” in the 1930s, the demand for silent films quickly evaporated. The film portrays how the director turned to the making of “pornographic” movies. The film was rated “X” on the scale of “suggested guidelines” promulgated by the Motion Picture Association of America. 3 Plaintiffs were subsequently told by defendant Johnson, and one of her administrative assistants, that funds would not be transferred to allow the ordering of “Inserts.” 4

The College does not have a system in effect that ensures prompt judicial determination of the constitutional status of films requested for Student Senate activities. 5

During the ensuing months, the issue of whether or not Grand Valley would allocate $250.00 for the rental of “Inserts” was much debated between plaintiffs and defendants. Plaintiffs repeatedly requested that defendants put their views about “In *1330 serts” in writing, and sought the transfer of funds for “Inserts” again on or about February 14, 1983. 6 The transfer request was again denied. In late February, the Grand Valley Board of Control passed a resolution tacitly addressing the showing of “Inserts.” The Board resolved that, while the College would not “ban” the showing of “X”-rated films on campus, “no institutional funds of this College shall be used by student organizations for the acquisition of X-rated films.... The Administration is directed to review and authorize the expenditure of institutional funds in accordance with this policy.” 7

Plaintiffs state that April 22 is the last possible date on which “Inserts” may be shown this school year. In order to obtain the film in time for the April 22 screening, the rental order must be placed by April 8th. To meet this deadline, plaintiffs filed suit on March 28th, requesting that defendants be enjoined from “refusing to allow” the transfer of funds sufficient to order “Inserts,” and from otherwise interfering with the ordering or showing of the film.

Oral argument was heard by the court on April 4, 1983. The matter has been extensively and ably briefed by counsel.

DISCUSSION

To be entitled to preliminary injunctive relief, plaintiffs must meet the well-established standards of Mason County Medical Ass’n v. Knebel, 563 F.2d 256 (6th Cir.1977), and Roth v. Bank of Commonwealth, 583 F.2d 527 (6th Cir.1978), cert. dismissed, 442 U.S. 925, 99 S.Ct. 2852, 61 L.Ed.2d 292 (1979), to-wit:

“1) Whether the plaintiffs have shown a strong or substantial likelihood or probability of success on the merits;

2) Whether the plaintiffs have shown irreparable injury;

3) Whether the issuance of a preliminary injunction would cause substantial harm to others;

4) Whether the public interest would be served by issuing a preliminary injunction.”

The element of “probability of success” is a key issue in this case. Determining whether plaintiffs will probably succeed with the merits of their claim in turn is controlled to a large extent by the characterization of this dispute. Defendants argue that this is only a “funding” case, and that, as such, it involves no First Amendment rights. The sole issue, in defendants’ view, is whether the Student Senate has the authority to require Grand Valley administrators to disburse funds when the administration has elected not to.

Plaintiffs characterize the dispute very differently. At issue here, they claim, is whether the First and Fourteenth Amendment rights of Grand Valley students should continue to be violated by College administrators. They argue that the practice of selectively disbursing funds set aside for extracurricular student entertainment constitutes a prior restraint that does not pass constitutional muster.

In support of the argument that this is a “funding” case, defendants would analogize the instant dispute to the so-called abortion cases: Maher v. Roe, 432 U.S. 464, 97 S.Ct. 2376, 53 L.Ed.2d 484 (1977); Harris v. McRae, 448 U.S. 297, 100 S.Ct. 2671, 65 L.Ed.2d 784 (1980); and Poelker v. Doe, 432 U.S. 519, 97 S.Ct. 2391, 53 L.Ed.2d 528 (1977). In each case, plaintiffs unsuccessfully contested whether a state entity could, in effect, refuse to fund plaintiffs’ decisions to abort a pregnancy. Defendants stress that the right to have an abortion is constitutionally guaranteed after Roe v. Wade, 410 U.S. 113, 93 S.Ct. 705, 35 L.Ed.2d 147 (1973). Here, they argue, the College has made a decision similar to that made by the government authorities in Roe, Harris, and Poelker: e.g., a decision against funding an activity determined by the authorities to be against the best interests of the institution and those affiliated with it.

If in fact the instant case is a “funding” case like Roe and Poelker, the conduct of the defendants would meet constitutional requirements if it is “rationally” based. In *1331 Harris and Maher, the Supreme Court held that the governmental decision against funding abortions would be invalidated only if it rested on grounds “wholly irrelevant” to the achievement of a “legitimate” governmental objective. 448 U.S. at 322, 100 S.Ct. at 2691.

Defendants advance several reasons to establish a rational basis for their decision not to fund the showing of “Inserts.” Initially, they argue that if they do not fund the rental of “X”-rated films such as “Inserts,” they will better fulfill their responsibilities of maintaining the “quality” of campus activities. This is because defendants have concluded that movies with such a rating, as a group, generally do not meet their standards of the “quality” of activity they want promoted on the Grand Valley campus. Additionally, they note that using the Motion Picture Rating of a film as the criterion for funding is “rational” because it serves the administration’s legitimate interest of saving time and effort over funding decisions, and it also benefits the students because the funding decision is not based on the subjective determination of a campus official.

Whether the defendants’ decision to withhold funds from “X”-rated films is “rationally” based is not an issue here. This is because I find that the cases relied upon by defendants are inapposite. True, funds are at issue in this dispute, but that does not make this a “funding” case. To regard this dispute as a “funding” case would entail ignoring a large body of precedential case law erected to safeguard the First Amendment rights of persons such as these plaintiffs.

A fundamental tenet of constitutional analysis is “ranking” of constitutional rights. Over 20 years ago one scholar explained this ranking of rights as follows:

“Freedom of expression is so vital in its relationship to the objectives of the Constitution that inevitably it must stand in a preferred position. In looking toward the fulfillment of that objective, there are a variety of [doctrinal] devices, to be employed separately or in combination, which enable the courts to express the constitutionally mandated preference for freedom of speech and thought.” 8

Defendants would ignore the settled view that constitutional rights are ranked in a hierarchy, and that differently-ranked rights are protected by rules derived from wholly separate doctrines. The “funding” cases concern the “lower-valued” rights originally said to derive from the “penumbra” of rights expressly guaranteed by the Constitution. Griswold v. Connecticut, 381 U.S. 479, 85 S.Ct. 1678, 14 L.Ed.2d 510 (1965). In the view of the Supreme Court, because the rights implicated in abortion funding cases have a relatively low constitutional status, they may be regulated by rules that meet the “lower” standard of being only “rationally” based. See, e.g., Harris v. McRae, supra 448 U.S. at 322, 100 S.Ct. at 2691.

First Amendment rights, however, have long been regarded as among the most precious. As one court stated, “[i]t needs no citation to suggest that first amendment liberties have been considered among the most important guaranteed to citizens in the Bill of Rights.” American Civil Liberties Union of Virginia, Inc. v. Radford College, 315 F.Supp. 893, 896 (W.D.Va.1970); see also Zamora v. C.B.S., 480 F.Supp. 199, 203 (S.D.Fla.1979).

As a correlative of that “preferred” status, governmental conduct regulating the exercise of First Amendment rights is constitutionally sound only if it passes “strict scrutiny.” As the Supreme Court recently stated, “First Amendment rights are entitled to special constitutional solicitude. Our cases have required the most exacting scrutiny in cases in which a State undertakes to regulate speech.” Widmar v. Vincent, 454 U.S. 263, 102 S.Ct. 269, 277, 70 L.Ed.2d 440 (1981) (emphasis added).

It is my conclusion that this case does in fact involve First Amendment rights. Films convey ideas, and the right to receive the thoughts of others is a right protected by the First Amendment. Here, *1332 by the withholding of funds defendants have effectively ensured that a movie of which they disapprove will not be seen by the students of Grand Valley. The device of stopping funds has kept the film off campus since the fall of 1982 to this day. The label may be “funding,” but the demonstrated effect is censorship. This conclusion is buttressed by comparing this case to factually similar cases.

In Joyner v. Whiting, 477 F.2d 456 (4th Cir.1973), for example, the United States Court of Appeals for the Fourth Circuit prohibited the President of North Carolina Central University from withdrawing all funds from the student-run newspaper. At the time of the lawsuit, NCCU was principally a black institution. The university president cut the funding for a student paper after the paper ran articles “questioning” the increasing number of white students on campus. The newspaper editor and the president of the university student association brought suit for alleged violation of their First and Fourteenth Amendment rights. As in the case at bar, the university did not ban the student publication, and made no objection to its being distributed on the campus. It simply objected to being asked to fund what it believed to be offensive and repugnant material.

The Fourth Circuit Court of Appeals rejected the “funding only” argument advanced by the university, saying:

“Fortunately, we travel through well charted waters to determine whether the permanent denial of financial support to the newspaper because of its editorial policy abridged the freedom of the press. The First Amendment is fully applicable to the states ... and precedent establishes ‘that state colleges and universities are not enclaves immune from [its] sweep.’ A college acting ‘as the instrumentality of the State, may not restrict speech . .. simply because it finds the views expressed by any group to be abhorrent.’ ... It may well be that a college need not establish a campus newspaper, or, if a paper has been established, the college may permanently discontinue publication for reasons Wholly unrelated to the First Amendment. But if a college has a student newspaper, its publication cannot be suppressed because college officials dislike its editorial comment.... This rule is but a simple extension of the precept that freedom of expression may not be infringed by denying a privilege....

The principles reaffirmed in Healy have been extensively applied to strike down every form of censorship of student publications at state-supported institutions. Censorship of constitutionally protected expression cannot be imposed by suspending the editors, suppressing circulation, requiring imprimatur of controversial articles, excising repugnant material, withdrawing financial support, or asserting any other form of censorial oversight based on the institution’s power of the purse.”

[Footnotes and citations omitted.]

For other decisions similarly addressing the First Amendment implications of factually-similar disputes, see, e.g., Healy v. James, 408 U.S. 169, 92 S.Ct. 2338, 33 L.Ed.2d 266 (1972); Brooks v. Auburn University, 412 F.2d 1171 (5th Cir.1979); Barnstone v. University of Houston, 514 F.Supp. 670 (W.D.Tex.1980); Reineke v. Cobb County School District, 484 F.Supp. 1252 (N.D.Ga.1980); Trujillo v. Love, 322 F.Supp. 1266 (D.Colo.1971); Korn v. Elkins, 317 F.Supp. 138 (D.Md.1970); Antonelli v. Hammond, 308 F.Supp. 1329 (D.Mass.1970).

First Amendment principles apply even though the instant defendants have not totally banned the showing of “Inserts” on the Grand Valley campus. Joyner did not treat an absolute ban of the expression of segregationist views from the NCCU campus, but only the termination of funds for the student-run paper that had expressed such views. Similarly, in Widmar v. Vincent, supra, the defendant university sought to keep a religiously-oriented student group from using campus facilities for the group’s meetings. The group was not barred from expressing its views elsewhere on the campus, and no sanctions were aimed at the members. The defendants in Widmar decided not to “subsidize” the religious group *1333 by allowing it the free use of facilities granted other student groups. Even though the restraint placed on the Widmar plaintiffs was not a total ban, the Supreme Court held that the restriction violated the First Amendment rights of the religious group members. Similarly, the cut of funding for the student newspaper at issue in Joyner was not a total ban. The paper in fact continued to appear for a time after the university stopped funding it. The “partial” ban effected in Joyner was nonetheless deemed to violate the First Amendment. As the bar of funds in the instant case constitutes a similar “partial” ban, it too must be tested under the First Amendment.

Defendants have cited Associated Students of Western Kentucky v. Downing, 475 F.2d 1132 (6th Cir.1973) [“Downing"], to demonstrate that the First Amendment is not a factor in the instant case, and that, as a result, plaintiffs will probably not prevail on the merits of their case. In Downing, in contrast to the case presently before the court, the university and a student association had jointly planned and operated a series of educational programs for the benefit and enjoyment of the students. As a part of that program, a. showing of the “experimental” films of John Lennon and Yoko Ono was scheduled. After a preliminary showing of the films, the university cancelled the contract. The Sixth Circuit held, without explanation, that the university’s conduct did not violate constitutional rights of the student-plaintiffs. Downing was determined to be distinguishable from cases where university officials had violated the First Amendment rights of students by censoring student-sponsored programs or by otherwise interfering with the exercise of First Amendment rights. These factual differences appreciably distinguish Downing from the case at bar. .

There is an additional reason for concluding that Downing does not mandate a finding in favor of the instant defendants. It would appear that the reasoning of Downing has been inferentially overruled. In Southeastern Promotions, Ltd. v. Conrad, 486 F.2d 894 (6th Cir.1973) [“Southeastern”], Downing was referred to as “consonant” with the disposition of the Southeastern case. 486 F.2d at 902. Southeastern was subsequently reversed by the Supreme Court. 420 U.S. 546, 95 S.Ct. 1239, 43 L.Ed.2d 448 (1975).

The significance of that reference is that it makes express what would otherwise be implicit in an analysis of these three cases. In Southeastern, the Sixth Circuit validated content-based restrictions on the exercise of First Amendment rights. Those restrictions operated without any reference to the guidelines established for such restrictions in Bantam Books, Inc. v. Sullivan, 372 U.S. 58, 70, 83 S.Ct. 631, 639, 9 L.Ed.2d 584 (1963), and in Freedman v. Maryland, 380 U.S. 51, 58, 85 S.Ct. 734, 738, 13 L.Ed.2d 649 (1965). The Supreme Court reversed the Sixth Circuit for having validated a system of prior restraint that lacked the Bantam Books procedures. The Supreme Court found that the conduct of the Southeastern defendants amounted to censorship, and that it constituted a prior restraint operating in violation of the First Amendment. 420 U.S. at 552-56, 560-62, 95 S.Ct. at 1243-45, 1247-48.

It is evident to me that the conduct held illegal by the Supreme Court in Southeastern is virtually identical to the conduct of the Downing defendants. In Downing, the university barred First Amendment activity on the basis of its content, and without a trace of even one of the procedures required to validate a content-based prior restraint under Bantam Books or Freedman. As the shadow cast over Downing by the Supreme Court’s treatment of Southeastern strikes me as self-evident, and for the factual difference previously described, I conclude that Downing does not require a finding in favor of the defendants in the case at bar.

Defendants have conceded that their procedure does not satisfy the prior restraint requirements of Bantam Books or Southeastern Promotions, Ltd. v. Conrad. 9 It is obvious that defendants have not under *1334 taken judicial proceedings to test the constitutional status of “Inserts,” or that the denial of funds has constituted only a brief ban on the showing of the film. Nor is there any system followed by the college that ensures a prompt, final, judicial resolution of the question here at issue. In fact, there is no system at all, and judicial consideration of the “merits” of “Inserts” hinges still on the initiative of persons other than defendants. As defendants’ treatment of “Inserts” does not satisfy Bantam Books’ or Southeastern Promotions’ requirements, only one other argument could possibly save their conduct from being deemed an illegal prior restraint.

Since the controversy arose, defendants have passed a “Resolution” that flatly prohibits the College from funding the showing of all “X”-rated movies on campus. If the “X” rating was a short-hand label for judicially-defined pornography, then defendants’ content-based discrimination against funding such films could be deemed lawful. This argument must fail, however, since it is well-established that the Motion Picture ratings may not be used as a standard for a determination of constitutional status. Engdahl v. City of Kenosha, Wisc., 317 F.Supp. 1133 (E.D.Wis.1970); Motion Picture Ass’n of America v. Specter, 315 F.Supp. 824 (E.D.Pa.1970). The standards by which the movie industry rates its films do not correspond to the Miller v. California, 413 U.S. 15, 93 S.Ct. 2607, 37 L.Ed.2d 419 (1974), criteria for determining whether an item merits constitutional protection or not. 10 Clearly, defendants’ conduct does not satisfy the Bantam Books’, Southeastern Promotions’ requirements for valid pri- or restraints. In addition, since defendants’ conduct cannot be validated on the ground that the only films affected are per se unentitled to First Amendment protections, I find it highly probable that plaintiffs would succeed on the merits of their First Amendment claim. As a result, I am satisfied that plaintiffs have fulfilled the crucial “probability of success” requirement for injunctive relief.

Plaintiffs have also satisfied the other three requirements conditioning injunctive relief. The requirement of suffering “irreparable injury” absent the requested equitable relief has been satisfied by showing that plaintiffs’ First Amendment rights are jeopardized. The “loss of First Amendment freedoms, for even minimal periods of time, unquestionably constitutes irreparable injury.” Elrod v. Burns, 427 U.S. 347, 96 S.Ct. 2673, 49 L.Ed.2d 547 (1976); Westinghouse Broadcasting Co. v. Dukakis, 409 F.Supp. 895 (D.Mass.1976); Birkenshaw v. Haley, 409 F.Supp. 13 (E.D.Mich.1974).

Plaintiffs have also established that, on balance, they will suffer greater harm if injunctive relief is denied than defendants will if it is granted. Because their First Amendment rights are at stake, plaintiffs may suffer harm of a very serious magnitude. This is a corollary of the high rank held by the First Amendment in the constitutional scale of values discussed earlier. 11 Defendants claim that they will lose some authority if plaintiffs’ relief is granted, and that plaintiffs’ success here will unleash a floodgate of similar demands from other campus groups. However, no authority is relinquished. Pornographic movies that meet the Miller test need not be permitted on campus. In addition, defendants’ arguments are speculative. There is nothing in the record to indicate that similarly-situated groups stand ready to unleash unfounded claims against the College’s treasury.

The last factor to consider is whether the public interest will be advanced by granting the requested relief. I find that it will, principally because the relief here requested is to safeguard the rights traditionally valued so highly by our society.

In sum, plaintiffs have fulfilled the requirements of injunctive relief by showing that they will probably succeed with their substantive claim of violation of their First Amendment rights; that the impending harm is irreparable in nature; that the harm they will suffer absent injunctive re *1335 lief is greater than that defendants will bear when it is granted; and that the public interest will be helped, not hurt, by granting a preliminary injunction in the case at bar. Consequently, an Order will issue directing the defendants to allocate the $250.00 before the passage of the April 8th deadline on the ordering of “Inserts.”

CONCLUSION

We are reminded 12 that originally freedom to speak was deemed a gift from heaven and the Founding Fathers talked about it as a “natural” right of man. This, of course, was in the era of town meetings. A century later, however, Justices Holmes and Brandéis gave the concept a new connotation — the right to hear. “For only by the free flow of ideas does society become enriched. Only by the back and forth of controversy do we gain that capacity for critical analysis which tends to correct errors.”

While I find that defendants must be directed forthwith to allocate $250 for the ordering of the movie, “Inserts,” by the Grand Valley Student Senate, it is appropriate to note certain issues that are not before the court. At issue here was the constitutional validity of defendants’ decision to block or impede the exercise of First Amendment activity, on the basis of its content, without any reference to the standards governing prior restraints. Whether the film “Inserts” is pornographic, within the meaning of Miller v. California, 413 U.S. 15, 93 S.Ct. 2607, 37 L.Ed.2d 419 (1974), was not an issue in this case. In fact, as far as the court is aware, the movie has never been seen by the students seeking the funds nor by any college officials who have denied those funds. I have reached my conclusion about the system of regulation, not about the constitutional status of a particular movie affected by that system. Whether “Inserts” could or should be banned under the Miller standard has neither been raised nor litigated; consequently, that determination, should it be raised, awaits another day.

APPENDIX 1

THE MOVIE RATING SYSTEM

By JACK VALENTI

* * *

HOW IT ALL BEGAN

By the summer of 1966, it had become clear to knowledgeable observers that the U.S. film industry was in radical change. Where the change specifically started, and why, are obscured in a mix of social and economic upheaval.

But change there was.

Perhaps it started in the early 1950s when the Department Of Justice, following a U.S. Supreme Court decision, brought about the divorcement of studio-and-theater ownership. When the big studios relinquished their theaters, the power that existed in my predecessors, Will H. Hays and Eric Johnston, and the Hollywood establishment was forever broken. From that collapse of authority came, slowly, the onward thrust of the filmmaker to garner a larger share in the creative command decisions.

When I became president of the Motion Picture Association of America (MPAA) * , and the Association of Motion Picture and Television Producers (AMPTP) ** , in May 1966, the slippage of Hollywood studio authority over the content of films collided with an avalanching revision of American mores and customs.

The national scene was marked by insurrection on the campus, riots in the streets, rise in women’s liberation, protest of the young, questioning of church, doubts about the institution of marriage, abandonment of old guiding slogans, and the crumbling of social traditions. It would have been foolish to believe that movies, that most creative of art-forms, could have remained *1336 unaffected by the change and torment in our society.

A New Kind of American Movie

The result of all this was the emergency of a “new kind” of American movie — frank and open, and made by filmmakers subject to very few self-imposed restraints.

Almost within weeks in my new duties I was confronted with controversy neither amiable nor fixable. The first issue was the film “Who’s Afraid of Virginia Woolf?”, in which for the first time on the screen the word “screw” and the phrase “hump the hostess” were heard. In company with the MPAA’s general counsel, Louis Nizer, I met with Jack Warner, the legendary chieftain of Warner Bros, and his top aide, Ben Kalmenson. We talked for three hours, and the result was deletion of “screw” and retention of “hump the hostess”, but I was uneasy over the meeting.

It seemed wrong that grown men should be sitting around discussing such matters. More, I was uncomfortable with the thought that this was just the beginning of an unsettling new era in film, in which we would lurch from crisis to crisis, without any suitable solutions in sight.

The second issue surfaced only a few months later. This time it was Metro-Goldwyn-Mayer and the Antonioni film “Blow-Up.” I met with the company head, Bob O’Brien, for this movie also represented a first — the first time a major distributor was marketing a film with nudity in it. The Production Code Administration in California had denied the seal. I backed the decision whereupon MGM distributed the film through a subsidiary company, thereby flouting the voluntary agreement of MPAA member companies that none would distribute a film without a Code seal.

Finally, in April 1968, the U.S. Supreme Court upheld the constitutional power of states and cities to prevent the exposure of children to books and films which could not be denied to adults.

It was plain that the old system of self-regulation, begun with the formulation of MPAA in 1922, had broken down. What few threads holding together the structure created by Will H. Hays had now snapped.

I knew that the mix of new social currents, the irresistible force of creators determined to make “their” films (full of wild candor, groused some social critics), and the possible intrusion of government into the movie arena demanded my immediate action.

Within weeks, discussions of my plan for a movie rating system began with the president of the National Association of Theater Owners (NATO), and with the governing committee of the International Film Importers & Distributors of America (IFIDA), an assembly of independent producers and distributors.

Over the next five months, I held more than 100 hours of meetings with these two organizations, as well as with guilds of actors, writers, directors and producers, with craft unions, with critics, with religious organizations, and wit