LAW OF PROTEST

LAW OF PROTEST

The full text of this Foreword can be found by clicking the PDF link to the left.

“To protest against injustice is the foundation of all our American democracy.”

— Justice Thurgood Marshall. 1 Thurgood Marshall, Hist. (Oct. 29, 2009), https://www.history.com/‌‌‌‌‌‌articles‌/‌‌‌‌thur‌‌g‌ood-marshall [https://perma.cc/H9HK-EQD4] (last updated Mar. 5, 2025). While the exact source of this quote is unknown, it has been widely attributed to Justice Marshall. Karen J. Pita Loor, The Expressive Fourth Amendment, 94 S. Cal. L. Rev. 1311, 1316 & n.25 (2021).

Protests have long been part of the social and political fabric of the United States. 2 See ACLU of Ill., Know Your Right to Protest in Chicago 2 (2015), https://‌www.aclu-il.org‌/‌sites/‌default/‌files/‌know_your_right_to_protest_in_chicago.pdf [https://‌perma.cc/‌TM4U-ST2Y] (“[T]he right to protest is deeply woven into the fabric of our federal and state constitutions . . . .”). From the colonial era 3 See, e.g., Etienne C. Toussaint, Afrofuturism in Protest: Dissent and Revolution, 125 Colum. L. Rev. 1375, 1384 (2025) (“The Stono Rebellion, also known as Cato’s Conspiracy, took place in South Carolina in 1739 and stands as one of the largest uprisings of enslaved people in British North America.”); The Boston Tea Party, Hist. (Nov. 24, 2009), https://www.history.com/this-day-in-history/december-16/the-boston-tea-party [https://‌perma.cc/P2UB-L9MV] (last updated Mar. 14, 2025) (“The midnight raid, popu­larly known as the ‘Boston Tea Party,’ was in protest of the British Parliament’s Tea Act of 1773, a bill designed to save the faltering East India Company . . . .”); The Journey to Emancipation: The Germantown Protest, 1688, Smithsonian Nat’l Museum Afr. Am. Hist. & Culture, https://nmaahc.si.edu/explore/stories/journey-emancipation-germantown-‌protest-1688 [https:‌‌‌‌‌‌‌‌‌//perma.cc/8BWT-82D3] (last visited Apr. 2, 2025) (“One of the ear­liest recorded actions toward ending slavery was taken by a small group of Quakers in Germantown, Pennsylvania Colony, in 1688.”). to the present day, 4 See, e.g., Jared Hamernick, Toward a Nonviolent State, 2021 U. Ill. L. Rev. Online 77, 78, https://illinoislawrev.web.illinois.edu/wp-content/uploads/2021/04/‌Hamernick‌.pdf [https://perma.cc/VGN8-QTXN] (discussing the “protests on an unprec­edented scale . . . in all fifty states” sparked by the brutal, public killing of George Floyd on May 25, 2020); George Chidi & Andrew Roth, Pro-Palestinian Protesters March Before Dem­ocratic Convention: ‘This Is About Morality’, The Guardian (Aug. 19, 2024), https://‌www.theguardian.com/us-news/article/2024/aug/19/pro-palestinian-protest-de‌mocratic-convention [https://perma.cc/2HPV-RJVL]; Kelly McCleary & Holly Yan, Protests Spread Across the US After the Supreme Court Overturns the Constitutional Right to Abortion, CNN, https://www.cnn.com/2022/06/27/us/supreme-court-over‌turns-roe-v-wade-monday [https://perma.cc/7GDX-ZVRP] (last updated June 27, 2022). protest move­ments have helped shape the nation’s trajectory. Protest is not just an act of dissent but an essential expression and practice of democracy that chal­lenges abuses of power. 5 See, e.g., Sarah Kunstler, The Right to Occupy—Occupy Wall Street and the First Amendment, 39 Fordham Urb. L.J. 989, 991–92 (2012) (“The idea that demonstrators were willing to literally put their lives and bodies on the line, to physically occupy Wall Street and . . . call attention to disparities in wealth and power, awakened a national dis­course about the role of government . . . . To occupy these spaces was to transform them.”). Indeed, major social jus­tice victories—the abolition of chattel slavery, 6 See Toussaint, supra note 3, at 1393–94 (discussing the “powerful tradition of pro­test” maintained by enslaved people that “contributed to the eventual dismantling of slav­ery”); Manisha Sinha, The Heart of the Abolition Movement, Yale Univ. Press
(June 30, 2020), https://yalebooks.yale.edu/2020/06/30/the-heart-of-the-abolition-movement/ [https://‌perma‌.‌cc‌/‌FP9A-9ADG] (“[T]he American abolitionist moment unfolded in a hundred-year drama in law, politics, literature, and on-the-ground activism.”).
the expansion of suffrage to women, 7 See Courtney Lauren Anderson, Activismitis, 14 Ne. U. L. Rev. 185, 205 (2022) (“The Women’s Suffrage movement accomplished its goal of obtaining women’s right to vote. . . . Women in the suffrage movement . . . marched down streets during parades which they organized, held pageants, picketed the White House, and pressured not only the country’s citizens, but the government.”). the enactment of the New Deal, 8 See James N. Gregory, A Summer of Protest, Unemployment and Presidential Politics—Welcome to 1932, The Conversation (July 1, 2020), https://theconver‌sation‌.com/a-summer-of-protest-unemployment-and-presidential-politics-welcome-to-1932-1409‌18 [https://perma.cc/3HHZ-TFHZ] (“The early New Deal would race to provide debt relief for farmers and homeowners, jobs for the unemployed, and public works pro­jects – part of what demonstrators had been demanding for years.”). the passage of the Civil Rights Act, 9 See John G. Stewart, When Democracy Worked: Reflections on the Passage of the Civil Rights Act of 1964, 59 N.Y. L. Sch. L. Rev. 145, 151–54, 171 (2014–2015) (describing the enactment of the Civil Rights Act of 1964 against the backdrop of the civil rights activ­ism of the 1960s, in particular the March on Washington and Martin Luther King, Jr.’s “I Have a Dream” speech). the start of the LGBTQ rights movement, 10 See Marsha Johnson, Sylvia Rivera, and the History of Pride Month, Smithsonian (June 7, 2021), https://www.si.edu/stories/marsha-johnson-sylvia-rivera-and-history-pride-month [https://perma.cc/K78Y-A3XK] (“The first Pride parades marked the anniversary of the Stonewall uprising, when police raided the Stonewall Inn on Christopher Street in New York City after midnight on June 28, 1969.”). and more—were won in large part due to protest movements that opposed the extant status quo.

Despite their foundational role, protests in this country have been met with fierce opposition, police as well as popular violence, and politi­cal backlash. 11 See Jamillah Bowman Williams, Naomi Mezey & Lisa Singh, #BlackLivesMatter: From Protest to Policy, 28 Wm. & Mary J. Race, Gender & Soc. Just. 103, 105–06, 145–46 (2021) (discussing public backlash on social media and regressive legislation that “fol­lowed the protest movement and the renewed demands for racial justice”); see also Stewart, supra note 9, at 149 (referring to the “police dogs and fire hoses” used to “dis­pers[e] young pro­testors, many of elementary-school age, coupled with mass arrests of youthful demonstrators that filled the [Birmingham] city jail”). The First Amendment guarantees the rights to free speech and peaceable assembly. 12 U.S. Const. amend. I (“Congress shall make no law . . . abridging the freedom of speech . . . or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances.”). Yet the legal history of protests and gov­ernment responses to them has not always aligned with the spirit of the First Amendment: Many movements have faced suppression through state-sponsored violence 13 See Sandhya Kajeepeta & Daniel K. N. Johnson, NAACP LDF Thurgood Marshall Inst., Police and Protests: The Inequity of Police Responses to Racial Justice Demonstrations 3–5 (2023), https://tminstituteldf.org/wp-content/uploads/2023/10/Pol‌ice-and-Protests‌_PDF-3.pdf [https://perma.cc/V9MN-95VU] (discussing police responses to racial justice protests during the civil rights movement in the 1960s and the Black Lives Matter movement in 2020). as well as legal (and extralegal) restrictions. 14 See Amber Baylor, Unexceptional Protest, 70 UCLA L. Rev. 716, 718–19 (2023) (discussing how antiprotest criminal laws are “often introduced in the aftermath of pro­tests that are depicted as unsanctioned or appear to lawmakers as insufficiently con­trolled”); Williams et al., supra note 11, at 146 (“[I]t is not surprising that while the policy gains of the BLM movement have been relatively modest nationally, the influx of reaction­ary legislation has been comparably dramatic; this outsized reaction is not out of step with American history.”); Char Adams, Experts Call ‘Anti-Protest’ Bills a Backlash to 2020’s Racial Reckon­ing, NBC News (May 18, 2021), https://www.nbcnews.com/news/‌nbcblk/‌experts-call-anti-protest-bills-backlash-2020-s-ra‌cial-reckoning-n1267781 (on file with the Columbia Law Review) (“[T]here have been twice as many proposals to quell demon-strations in 2021’s legislative sessions than in any other year . . . .”). True, multiple major Supreme Court decisions have protected the rights of protesters and developed a jurisprudence identifying the core, and some outer limits, 15 See, e.g., Hill v. Colorado, 530 U.S. 703, 714 (2000) (upholding a law creating buffer zones around healthcare facilities that restricted sidewalk counseling about abor­tion and abortion alternatives); Feiner v. New York, 340 U.S. 315, 317–18, 321 (1951) (declining to reverse a “conviction in the name of free speech” when the defendant twice ignored police officers’ requests to stop delivering an inflammatory speech and they arrested him in order to “prevent it from resulting in a fight” (internal quotation marks omitted)). of the right to protest. 16 See Rachel Moran, Overbroad Protest Laws, 125 Colum. L. Rev. 1197, 1206 nn.40–45 (2025) (compiling Supreme Court cases recognizing “protest activity—by both individuals and crowds and in the form of picketing, marches, boycotts, placards, flag-burning, and more—as a form of protected expression” (footnotes omitted)). But existing First Amendment law remains murky and does not always provide a clear answer when it comes to an individual protester’s rights. 17 See Justin Hansford, Lecture, The Sankofa Principle in Protest Law, 125 Colum. L. Rev. 1029, 1030 (2025) (“First Amendment jurisprudence is complex and often obscure . . . .”); Steven J. Heyman, The Dark Side of the Force: The Legacy of Justice Holmes for First Amendment Jurisprudence, 19 Wm. & Mary Bill Rts. J. 661, 663 (2011) (describing “something deeply paradoxical about modern First Amendment juris­pru­dence” in which constitutional free speech protections promote fundamental values in some cases while undermining those same values in others); Urooba Abid & Vera Eidelman, The Supreme Court Declined a Protestors’ Rights Case. Here’s What You Need to Know., ACLU (Apr. 22, 2024), https://‌www.aclu.org/‌‌news‌/criminal-law-reform/the-supreme-court-declined-a-protestors-rights-case-heres-what-you-need-to-know [https://‌perma.cc‌/D5‌AM-LVUB] (analyzing the legal implications of the Supreme Court’s denial of an appeal in a case brought by a police officer against DeRay Mckesson, a promi­nent civil rights activist). Furthermore, the existence of a formal legal right—even if it might offer retroactive relief (e.g., damages)—may not actually protect a protester against adverse state action. 18 See, e.g., Mark Berman & Emily Wax-Thibodeaux, Police Keep Using Force Against Peaceful Protesters, Prompting Sustained Criticism About Tactics and Training, Wash. Post (June 4, 2020), https://www.washingtonpost.com/national/police-keep-using-force-‌against-peaceful-protesters-prompting-sustained-criticism-about-tactics-and-training/‌2020/‌‌06/03/5d2f51d4-a5cf-11ea-bb20-ebf0921f3bbd_story.html (on file with the Columbia Law Review) (“While some incidents have led to discipline for officers involved, the wave of epi­sodes has just as often gone unpunished and prompted still more criticism of law enforce­ment and questions about why they have reacted by firing gas, rubber bullets and driving into protesters.”); A Look at the People Ensnared in Trump’s Campaign
Against Pro-Palestinian Activism at US Colleges, AP News (Apr. 1, 2025), https:// ap‌news.com/article/‌immigration-detainees-students-ozturk-khalil-78f544fb2c8b593c88a0c1f‌0e0ad9c5f (on file with the Columbia Law Review) (“Since President Donald Trump took office, the U.S. gov­ernment has used its immigration enforcement powers to crack down on international stu­dents and scholars at several American universities who had partici­pated in pro-Palestinian demonstrations or criticized Israel over its military action in Gaza.”).

Consider the history of protest at this university. Columbia University has a long tradition of both protests and protest backlash. 19 Isha Banerjee & Emily Pickering, What Makes Columbia the ‘Activist Ivy’?, Colum. Spectator (May 6, 2025), https://www.columbiaspectator.com/news/2025/05/06‌/what-makes-columbia-the-activist-ivy [https://perma.cc/2YC8-YQVU] (“The cycle of encourag­ing activism and then cracking down on it has made Columbia the epicenter of student movements throughout history.” (internal quotation marks omitted) (quoting Maryam Alwan, Columbia undergraduate student)). Columbia stu­dents have used their voices to take on global issues, includ­ing the Vietnam War, South Africa’s apartheid regime, sexual and gen­der-based violence, and climate change. 20 See Mark Prussin, Columbia University Has a Long History of Campus Protests. Here’s a Look Back at Some of Them., CBS News (Apr. 22, 2024), https://‌www.cbs‌news.com/newyork/news/columbia-past-protests/ [https://perma.cc/NR‌6A-3ES‌W]. As Mahmoud Khalil, a Columbia alumnus who was targeted and detained by federal immigra­tion officials for his participation in pro-Palestine protests, explains:
If anything, my detention is a testament to the strength of the stu­dent movement in shifting public opinion toward Palestinian liberation. Stu­dents have long been at the forefront of change – leading the charge against the Vietnam war, standing on the frontlines of the civil rights movement, and driving the struggle against apartheid in South Africa. Today, too, even if the public has yet to fully grasp it, it is students who steer us toward truth and justice.
Mahmoud Khalil, Opinion, I Am a Palestinian Political Prisoner in the US. I Am Being Targeted for My Activism, The Guardian (Mar. 19, 2025), https:// www.the‌guard‌ian.com/‌commentisfree/2025/mar/19/mahmoud-khalil-statement [https://perma.cc/PY‌B8-DZ‌PA].
One of the most significant moments in Columbia’s history came in 1968, when students occupied several campus buildings to protest U.S. participation in the Vietnam War and the construction of a university gymnasium in Morningside Park that the local community opposed. 21 See Prussin, supra note 20; Jennifer Schuessler, At Columbia, Revisiting the Revolutionary Students of 1968, N.Y. Times (Mar. 21, 2018), https://‌www.nytimes.com‌/‌2018/03/21/arts/columbia-university-1968-protest.html (on file with the Columbia Law Review) (describing student activists as “united by opposition to plans to build a university gym in a nearby public park and by Columbia’s involvement in weapons research”). In 2024, evoking parallels to 1968, 22 See Bill Chappell, In Columbia University’s Protests of 1968 and 2024, What’s Similar—And Different, NPR (Apr. 26, 2024), https://www.npr.org/2024/04‌/26/1247527512/columbia-university-protests-1968-2024-history [https://perma.cc/W9N‌L-5Z6V] (“A takeover of Columbia University’s South Lawn by pro-Palestinian students last week is draw­ing comparisons to 1968 — another time when police were called to clear protesting stu­dents from the campus.”); Azad Essa, Columbia University Students Stage Vietnam-Era Anti-War Protests for Gaza, Middle E. Eye (Apr. 17, 2024), https://‌www.middleeasteye.net/news/columbia-university-students-stage-vietnam-style-anti-war-encampment-gaza (on file with the Columbia Law Review). pro-Palestine, antigenocide 23 See Essa, supra note 22 (“The Gaza solidarity encampment is the latest student-led action at Columbia geared to force administrators to divest from companies and insti­tutions they deem to be profiteering from Israel’s ‘apartheid, genocide and occupation’ in Palestine.”); see also Amnesty International Investigation Concludes Israel Is
Committing Genocide Against Palestinians in Gaza, Amnesty Int’l (Dec. 5, 2024), https://www.amnesty‌.org/en/latest/news/2024/12/amnesty-international-concludes-is‌rael-is-committing-genocide-against-palestinians-in-gaza/[https://perma.cc/DKC4-6QPZ] (“Amnesty Interna­tional’s report demonstrates that Israel has carried out acts prohib­ited under the Genocide Convention, with the specific intent to destroy Palestinians in Gaza. These acts include kill­ings, causing serious bodily or mental harm and deliberately inflict­ing . . . conditions of life calculated to bring about their physical destruction.” (internal quotation marks omitted) (quoting Agnès Callamard, Sec’y Gen. of Amnesty Int’l)).
students at Columbia organized mass pro­tests, held classroom sit-ins, constructed two encampments, and occupied a campus building. 24 See, e.g., Sarah Huddleston & Maya Stahl, Pro-Palestinian Protesters Repitch Encampment on South Lawn During Annual Alumni Reunion, Colum. Spectator (May 31, 2024), https://www.columbiaspectator.com/news/2024/05/31/pro-palestinian-protesters‌-repitch-encampment-‌on-south-lawn-during-annual-alumni-reunion/ [https://‌perma.cc/‌2‌UE5-UZHQ] (last updated June 1, 2024) (describing the two encampments on Columbia’s campus, which “spark[ed] worldwide protests on University campuses,” and pro-Palestine protesters’ occupation of Hamilton Hall); Rebecca Massel, Dozens of Pro-Palestinian Protesters Picket on First Day of Classes, Colum. Spectator (Sept. 4, 2024), https://www.columbiaspectator.com/news/2024/09/04/‌dozens-of-pro-palestinian-protest‌ers-picket-on-first-day-of-classes/ [https://perma.cc/T49S-2KN8] (describing a picket and classroom sit-in students organized).

At times during its history, Columbia University has taken aggres­sive action to suppress student dissent. 25 Columbia is not the only university that has acted against its student protesters. See Sunita Patel, Policing Campus Protest, 125 Colum. L. Rev. 1277, 1297–317 (2025) (chronicling actions taken against student protesters at numerous universities across the country, including U.C. Berkeley, Dartmouth, and North Carolina A&T University). This Foreword spotlights Columbia because its attempts to suppress student dissent have gar­nered national attention, see, e.g., infra notes 26–28 and accompanying text, and because it is where this Symposium was hosted, see infra text accompanying note 30. In 1936, Columbia expelled Robert Burke and two other students who led an anti-Nazi demonstra­tion. 26 See Columbia Hears Plea for Expelled Student, N.Y. Times (Sept. 25, 1936), https://timesmachine.nytimes.com/timesmachine/1936/09/25/87998077.html?pageNumber=19 (on file with the Columbia Law Review). Burke stated that his expulsion presented the question of “whether the president, dean and trustees of Columbia will tell me what to think and do or whether I shall do what I think is right.” 27 Id. (internal quotation marks omitted) (quoting Robert Burke). In 2024, then-Columbia President Minouche Shafik suspended students participating in a pro-Palestine encampment and subsequently authorized the New York Police Department to forcibly sweep the encampment and arrest over 100 stu­dents. 28 Maya Stahl, Sarah Huddleston & Shea Vance, Shafik Authorizes NYPD to Sweep ‘Gaza Solidarity Encampment,’ Officers in Riot Gear Arrest Over 100, Colum.
Spectator (Apr. 18, 2024), https://www.columbiaspectator.com/‌news/‌2024/04/18/‌shafik-autho‌rizes‌-nypd-to-sweep-gaza-solidarity-encampment-officers-in-riot-gear-arrest-over‌-100/ [https://‌perma.cc/C75W-9FGB] (last updated Apr. 19, 2024) (“This is the largest instance of mass arrests to be made on campus since 1968, when the NYPD arrested hun­dreds of students occupying Hamilton Hall and used excessive force in detaining students protesting against the Vietnam War and the planned construction of a gymnasium in Morningside Park.”).
These two episodes, nearly a century apart, demonstrate how Columbia has at times deployed both internal disciplinary processes and external governmental actors against its students. 29 Between 1968 and 2024, Columbia did not involve external law enforcement when responding to student protesters. See David Pozen, Norm Breaking at Columbia, Balkinization (Apr. 19, 2024), https://balkin.blogspot.com/2024/04/norm-breaking-at-columbia.html [https://perma.cc/WA4R-CA9X] (arguing that “President Shafik’s deci­sion to invite the NYPD on campus to arrest students” in 2024 broke with “a norm of police noninvolvement” that had persisted since 1968 despite “scores” of student protests through­out that period). Columbia still utilized internal disciplinary processes against student activ­ists between 1968 and 2024. See id. (“Some of these [post-1968] protests led to disciplinary code charges. None elicited a criminal law enforcement response.”); see also Sarah Huddleston & Maya Stahl, Inside Columbia’s Surveillance and Disciplinary Operation for Student Protesters, Colum. Spectator (Sept. 12, 2024), https://www.‌colum‌bia‌spectator.com/news/2024/09/12/inside-columbias-surveillance-and-disciplinary-oper‌a‌ti‌on‌-for-student-protesters-3/[https://perma.cc/WF69-Q3CQ] (describing “some of the many ways Columbia and Barnard have employed surveillance measures to identify and discipline dozens of students accused of violating University policies for participating in campus protests”).

Against this backdrop, the editors of the Columbia Law Review con­vened a Symposium on the law of protest. 30 Behind the Scenes: ‘Columbia Law Review’ Symposium Explores the Law of Protest, Columbia L. Sch. (Feb. 26, 2025), https://www.law.columbia.edu/‌news/archive/‌behind-scenes-columbia-law-review-symposium-explores-law-protest [https://perma.cc/‌E2‌S9-UW8P] [hereinafter Behind the Scenes] The editors of the Review are themselves no strangers to protest. See Ayaan Ali, Columbia Law Review Student Editors to Strike After Directors Intervene With Article on Nakba, Colum. Spectator (June 7, 2024), https://www.columbia‌‌spectator‌.com/‌‌news/‌2024/06/‌07‌/columbia-law-review-student-editors-to-strike-after-directors-intervene-with-article‌-on-na‌kba/ [https://perma.cc/5JEH-LST‌K]. This Symposium brought together legal scholars, practitioners, students, and community members to critically examine the current legal and political frameworks that shape protest law, reflect on how these frameworks have developed, and imagine possibilities for future change. The day-long conference on November 15, 2024, featured four panels and was bookended by two keynote speakers. 31 Behind the Scenes, supra note 30. The event opened with a lecture from Professor Justin Hansford, who dis­cussed his experience as a legal observer during the protests following the 2014 killing of Michael Brown in Ferguson, Missouri. 32 See id. Professor Hansford’s Lecture is published as part of this Symposium Issue. Hansford, supra note 17. Hansford then drew on two critical race theory concepts—interest convergence and the “critique of neutrality rhetoric”—using them as a lens to better understand protest law. 33 See Hansford, supra note 17, at 1030, 1032, 1040 (“[W]e can clarify our understanding by framing our reading of protest law with fundamental critical race theory concepts.”).

Next, Professors Tabatha Abu El-Haj, Evelyn Douek, Jeremy Kessler, and Eugene Volokh, as well as Charles F. Walker, a former law firm part­ner and pro bono co-chair, discussed “Protests and the Constitution,” focusing on the First Amendment. This panel addressed the Amendment’s speech–conduct distinction, hate speech, online content moderation, and the reg­ulation of public versus private universities. The pan­elists also reacted 34 See Behind the Scenes, supra note 30 (“The panels not only offered dynamic conversations and Q&As for an audience of students and academics, but also provided val­uable feedback for the authors, whose pieces were still in the process of being edited.”). to Abu El-Haj’s Symposium piece, A Right of Peaceable Assembly, in which she proposes an independent Assembly Clause doctrine, distinct from the existing free speech doctrine derived from the First Amendment’s Speech Clause. 35 Tabatha Abu El-Haj, A Right of Peaceable Assembly, 125 Colum. L. Rev. 1049, 1096 (2025) (“An independent Assembly Clause doctrine would not just be consistent with the text and the Founders’ original understanding but would allow for the development of a coherent jurisprudence capable of distinguishing between protected and unprotected assemblies in relation to assembly’s distinct contribution to self-governance.”). She argues assembly doc­trine provides a more apt framework for balancing protesters’ rights against social costsby recognizing that the public’s act of gathering and taking up space itself possesses political value, separate from the protest’s expressive message. 36 See id. at 1054 (“Freed of the wholly expressive account of assembly, it becomes possible to understand why an independent Assembly Clause doctrine is warranted and could make a material difference for those who gather in public.”).

The second panel examined “Protests Through History.” 37 Behind the Scenes, supra note 30. Professors Deborah Dinner, Bernard E. Harcourt, Karuna Mantena, Dylan C. Penningroth, and Etienne Toussaint discussed common trends in racial justice, gender equality, and anti-war movements, as well as the lessons that can be drawn from historical protest movements and the responses they encountered. Toussaint’s Symposium piece, Afrofuturism in Protest: Dissent and Revolution, chronicles the his­tory of Black protest movements in the United States from the colonial era to the twenty-first century and examines these movements’ philosophical underpinnings. 38 Toussaint, supra note 3, at 1382–83. He argues that the Black radical tradition reveals protest to be not just a right, but a moral impera­tive, and illustrates how modern protest movements can draw inspiration from that tradition. 39 Id. at 1453–64.

Professors Grant Christensen, Elora Mukherjee, Karen J. Pita Loor, and Gali Racabi, as well as law student Kevin McCarthy, spoke together on the third panel, titled “Who Protests, and Where? Examining Protest Spaces.” 40 Behind the Scenes, supra note 30. Each panelist offered their perspective on a particular type of protest or protester: Christensen discussed protests on indigenous reser­vations; McCarthy discussed protests by incarcerated individuals; Mukherjee discussed the unique considerations noncitizen protesters must face; Loor discussed racial justice protests and policing; and Racabi discussed labor strikes and workers as protesters. The panelists compared how protests in different spaces are regulated and examined what makes each type of protest more likely to shift public sentiment or secure insti­tu­tional concessions. Christensen’s Symposium piece, The Right to Protest in Indian Country, asserts that between the three potential sovereigns impli­cated by protests on indigenous lands—the tribe, the state govern­ment, and the federal government—tribal governments should be the sole regu­lator of these protests. 41 See Grant Christensen, The Right to Protest in Indian Country, 125 Colum. L. Rev. 1139, 1153–78 (2025). He then explores how tribes have his­torically reg­ulated protests and argues for tribes to take a measured approach to pro­test regulation despite not being bound by U.S. constitu­tional restraints in the same way as a state or federal government. 42 See id. at 1178–91.

The fourth and final panel, “Policing Protests,” featured Professors Amber Baylor, Jenny Carroll, Rachel Moran, and Sunita Patel as well as Nick Robinson, a senior legal adviser at the International Center for Not-for-Profit Law. 43 Behind the Scenes, supra note 30. The panelists discussed the regulation and policing of protests, including the passage of new antiprotest laws as a reaction to pro­test movements, the disproportionate impact that protest laws have on marginalized people, and the legal remedies available when protest regu­lators violate protesters’ constitutional or statutory rights. The panel­ists also commented on Moran’s 44 Moran, supra note 16. and Patel’s 45 Patel, supra note 25. Symposium pieces. Moran’s piece, Overbroad Protest Laws, examines the First Amendment’s overbreadth doctrine as it applies to protest laws and identifies the harms of overbroad protest laws. 46 Moran, supra note 16, at 1204–06. She also enumerates five characteristic fea­tures of potentially overbroad protest laws and uses them to analyze the constitutionality of several recent protest laws. 47 Id. at 1217–24 (identifying the five features); see also id. at 1255–61 (applying the five “features of overbroad protest laws . . . [to] four laws enacted since 2020 to assess them for potential overbreadth”). Patel’s piece, Policing Campus Protest, discusses the various approaches universities have taken to regulating campus protests throughout history, identifying inter­nal and external pressures on university regulators and analyzing three recurring tactics that campus police use when policing protests. 48 Patel, supra note 25, at 1293–317. Near the end of the piece, she shares some historical examples of when cam­pus admin­istrators opted to negotiate with, rather than punish, student protesters, suggesting that these moments might provide a lesson for universities going forward. 49 Id. at 1373 (“[Some university presidents] knew headlines, criticism, and poten-tially more demonstrations would follow massive police repression, so they chose negotia­tion over crackdown. These historic examples could serve as lessons for today’s uni­versity presidents and students.”).

The conference concluded with a keynote address by Derecka Purnell, a movement lawyer and activist. 50 Behind the Scenes, supra note 30. Purnell explored the relation­ship between movement lawyering and out-on-the-street activism, identi­fy­ing a tension between working within a system and seeking to radically change a system from the outside. 51 See id. For more about Purnell’s journey and insight as a protester, specifically within the police abolition movement but also in support of a wide variety of causes, see generally Derecka Purnell, Becoming Abolitionists: Police, Protests, and the Pursuit of Freedom (2021).

This Symposium Issue of the Columbia Law Review features the five pieces described above, as well as Hansford’s lecture. The Issue inten­tion­ally places these six works of scholarship, each examining aspects of pro­test law, in dialogue with each other. A few examples help illustrate this. Abu El-Haj, Hansford, and Moran each take different approaches to addressing shortcomings in existing First Amendment doctrine. 52 See Abu El-Haj, supra note 35, at 1096–122 (developing “[a]n independent Assembly Clause doctrine”); Hansford, supra note 17, at 1030–31 (employing “critical race theory concepts” to “illuminate . . . a framework for effectively analyzing the past, present, and future of First Amendment law regarding protests”); Moran, supra note 16, at 1217–24 (identifying “five features of potentially overbroad laws drawn from the [Supreme] Court’s overbreadth juris­prudence”). Patel and Toussaint both turn to history as they illustrate how campus protest polic­ing and the Black protest tradition developed. 53 See Patel, supra note 25, at section 1293–305; Toussaint, supra note 3, at 1381–82 (“By examin­ing historical instances of Black resistance, from slavery revolts to contemporary move­ments, and analyzing them through an Afrofuturist lens, this Piece reveals three core dimensions of Black protest . . . .”). Perhaps these scholars are employing the Sankofa principle Hansford writes about. See Hansford, supra note 17, at 1032 (“The Sankofa prin­ciple counsels the wis­dom of predicating future action on past patterns.”). Christensen, Moran, and Patel address the issue of protest regulation—discussing who should regulate protests and how they should do so. 54 See Christensen, supra note 41, at 1153–78 (surveying the “three competing sover­eigns: tribes, states, and the federal government” and arguing “only Indian tribes . . . [should] govern[] protests that occur in Indian country”); Moran, supra note 16, at 1261–68 (discussing the “harms of overbroad laws in the context of protest-related arrests and prosecutions”); Patel, supra note 25, at 1335–65 (discussing “features of campus policing in response to protests”). Abu El-Haj and Toussaint both propose new frameworks for understanding protests as a part of our society: the political value of a public assembly and protest as a moral imperative. 55 See Abu El-Haj, supra note 35, at 1053 (“Being together physically and socially con­tributes to democracy in ways that are distinct from the contribution of public discourse.”); Toussaint, supra note 3, at 1422 (“[R]esistance is not just a right but a duty—a necessary response to systemic injustice.”). This list of connections and throughlines is not exhaustive. Each scholar’s contribution seeks to spur further thought, dis­cussion, and scholarship in the field of protest law.

Finally, in addition to engaging with pressing legal and philosophi­cal questions surrounding the law of protest, this Symposium fostered a sense of community among the scholars, practitioners, students, and activists it brought together. 56 Behind the Scenes, supra note 30 (describing “how a symposium can bring peo­ple together to talk and [show] how scholarship can be collaborative and purposeful” (internal quotation marks omitted) (quoting Shaunak Puri, Symp. & Book Rev. Ed., Colum. L. Rev.)). In that way, the Symposium mirrored the protests it examined: Protesters come together with a shared goal—to challenge injustice and demand accountability—and in doing so, they, too, develop a feeling of community. 57 See Angela Y. Davis, Freedom Is a Constant Struggle: Ferguson, Palestine, and the Foundations of a Movement 1–2 (Frank Barat ed., 2016) (discussing the “dangers of indi­vidualism” and the strength of collective action in “[p]rogressive struggles”). That feeling is one of the most power­ful, inspiring, and sustaining aspects of any protest. 58 See Radhule Weininger, Do Demonstrations Make a Difference?, Santa Barbara Indep. (Apr. 10, 2025), https://www.independent.com/2025/04/10/do-demonstrations-make‌-a-difference/ [https://perma.cc/Y2UQ-ERQP] (“[Political and social demonstrations] build solidarity and community, making us feel connected and less afraid.”); see also, e.g., Emily Chen & Joyce Zhang, ‘Solidarity Materialized’: A Look Into the Art and Community Born Out of the ‘Gaza Solidarity Encampment’, Colum. Spectator (Apr. 28, 2024), https://www.columbiaspectator.com/arts-and-culture/2024/04‌/28/‌solidarity-materialized-a-look-into-the-art-and-community-born-out-of-the-gaza-solidar‌ity-encampment/ [https://perma.cc/S43S-BJYG]. There is an energy that emanates from collective action, reverberating through chants and slogans, transcending differences in background, ideology, or personal experience. Protesters forge connec­tions with one another that are not simply tactical but deeply empathetic, human, and long-lasting. 59 See Deepa Iyer, We Too Sing America: South Asian, Arab, Muslim, and Sikh Immigrants Shape Our Multiracial Future 167 (2015) (“Many racial justice activists say that engaging in conversations and dialogues with one another about our experiences with racial identity, oppression, and injustice can help us understand that we have linked fates and futures.”). Ulti­mately, protests reinforce the notion that no one is alone in their strug­gle: Together, in solidarity, all share a com­mitment to making the world better today and for future generations.