Response of Martin Luther King, Jr., to allegations by the city of Memphis, TN, that he and others were engaged in a conspiracy to incite riots or breaches of the peace, April 4, 1968.
“The defendants are not presently and have never been engaged in any conspiracies as alleged in the complaint.”
Record Group 21: Records of District Courts of the United States
Series: Civil Cases
File Unit: City of Memphis vs Martin Luther King, Jr., et. al., Civil C-68-80
Transcription:
IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TENNESSEE WESTERN DIVISION
CITY OF MEMPHIS,
A Municipal Corporation,
Complainant
VS
MARTIN LUTHER KING, JR., NO. C-68-80
HOSEA WILLIAMS, REVEREND
JAMES BEVEL, REVEREND JAMES
ORANGE, RALPH D. ABERNATHY and
BERNARD LEE, all non-residents
of the State of Tennessee
Defendants
ANSWER
The defendants deny each and every allegation of the complainant except as follows:
The defendant Martin Luther King, Jr. and members of his staff were invited by local ministers to participate in a march held on March 28, 1967. Said march was held under the supervision of local ministers and the responsibility for planning and supervision to maintain order did not rest with these defendants.
The defendant King at the urgent request of local
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march leaders did leave the scene of disorder. At the same time, local leaders made immediate and successful efforts to turn the march back.
The defendants have organized and conducted in many communities utilizing the principals of non-violence numerous marches, none of which have resulted in civil disturbance. The defendants are not presently and have never been engaged in any conspiracies as alleged in the complaint. Defendants have in no way in their private or public statements sponsored, fermented, encouraged and incited riots, mobs or breaches of the peace as alleged in the complaint.
Defendants further state that they have never refused to furnish information concerning marches or plans as such information became available; that in fact said information has been furnished on a continuing basis to local law enforcement officers; that there is no statute or ordinance requiring the issuance of a parade or march permit by police authorities. However, to the extent that there is any custom or practice of submitting plans for parades or marches to police officials for discussion and review, the defendants have and will continue to do so as soon as practical after said plans have been made.
The defendants utilizing their experience have undertaken the following general steps to insure that the march will be non-violent and under control at all times. Limitations will be placed on the number of marchers in each line; parade marshals will be carefully selected and given training in their duties; liaison will be maintained with local law enforcement officers
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and the necessary protection and assistance will be requested; all groups in the community have been contacted to insure the parties in the march will participate on a non-violent basis; a route has been tentatively selected, together with tentative starting and ending times for the march and other necessary organizational steps have been and are continuing to be taken to insure a peaceful march. Steps have further been taken to prohibit the use of signs affixed to sticks or any other object which might be utilized in an improper manner.
Defendant, Martin Luther King, Jr., further states that he has on numerous other occasions received threats or been informed of threats received by others concerning his personal safety; that while all due precautions have been taken, there have been no difficulties encountered as a result of such threats.
Defendants respectfully request that the application for injunction should be denied or in the alternative that the Court permit the march to be held under such reasonable restrictions as may be necessary giving due regard to the defendants and their First Amendment rights.
OF COUNSEL:
JACK GREENBERG
MEL ZAR
10 Columbus Circle
New York, New York
LUCIUS E. BURCH, JR.
LOUIS R. LUCAS
WALTER BAILEY
W. J. MICHAEL CODY
DAVID E. CAYWOOD
CHARLES F. NEWMAN
73 notes
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James Gurney, "The Tartarus Incident," 1982.
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