Shira Perlmutter v. Todd Blanche, Donald Trump Complaint (PDF)

Shira Perlmutter has sued Todd Blanche, Donald Trump, Paul Perkins, and others for her termination as the Register of Copyrights. The PDF of the complaint is below, along with the memorandum in support of their motion for a temporary restraining order.

Here’s the theory of the case: The Librarian of Congress has the authority to remove the Register of Copyrights by statute. Todd Blanche wasn’t properly appointed by President Trump as the Librarian of Congress, which requires advice and consent of Congress (and the Federal Vacancies Reform Act doesn’t authorize here the appointment of an Acting Librarian because the Library of Congress is not an “executive agency”). Therefore, Blanche had no legal authority to terminate Perlmutter from her position as Register of Copyrights. So that termination was null and void. Got that?

The lawyers include Donald Verrilli, the former Solicitor General for President Obama.

Brian D. Netter (D.C. Bar No. 979362) Allyson R. Scher (D.C. Bar No. 1616379) Democracy Forward Foundation

Donald B. Verrilli, Jr. (D.C. Bar. No. 420434), Ginger D. Anders (D.C. Bar No. 494471) MUNGER, TOLLES & OLSON LLP

Kuruvilla J. Olasa (pro hac vice forthcoming) James R. Salzmann (pro hac vice forthcoming) Miranda E. Rehaut (pro hac vice forthcoming) Adeel Mohammadi (pro hac vice forthcoming) MUNGER, TOLLES & OLSON LLP

Excerpts from the Complaint

[other parts omitted]

DOWNLOAD THE COMPLAINT BELOW

DOWNLOAD THE MEMORANDUM IN SUPPORT OF A TEMPORARY RESTRAINING ORDER

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