Petition for Rehearing — Scott Douglas Ora, Petitioner v. Hollywood Chamber of Commerce
Supreme Court briefApr 9, 2024
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In the
'upreme Court of the Ilniteb iptateo
SCOTT DOUGLAS ORA, INDIVIDUALLY, AND IN HIS
DERIVATIVE CAPACITY AS TRUSTEE OF THE LEO ROBIN
TRUST, ON BEHALF OF THE LEO ROBIN TRUST,
Petitioner,
v.
HOLLYWOOD CHAMBER OF COMMERCE,
HOLLYWOOD CHAMBER'S BOARD OF DIRECTORS,
HOLLYWOOD WALK OF FAME AND
WALK OF FAME COMMITTEE,
Respondents.
On Petition for a Writ of Certiorari to the
Court of Appeals of the State of California for the
Second Appellate District, Division Two
PETITION FOR REHEARING
Scott Douglas Ora
Petitioner Pro Se
4735 Sepulveda Blvd. Apt. 460
Sherman Oaks, CA 91403
(818) 618-2572
sdo007@aol.com
April 4, 2024
SUPREME COURT PRESS
•
(888) 958-5705
•
BOSTON, MASSACHUSETTS
1
TABLE OF CONTENTS
Page
TABLE OF AUTHORITIES
iii
PETITION FOR REHEARING
1
GROUNDS FOR: REHEARING
1
ANALYSIS REGARDING STANDARD OF PROOF
AND QUESTIONING BY JUSTICE SAMUEL ALITO
DURING ORAL ARGUMENT FOR FORMER
PRESIDENT'S TRUMP COLORADO CASE BEFORE
THE U.S. SUPREME COURT VALIDATES THE
REHEARING OF THIS CASE
1
THE NEWS THAT MARTHA REEVES APPEARED
TO BE GRANTED A WAIVER ON HER JOURNEY
TO GET HER STAR ON THE HOLLYWOOD WALK
OF FAME SUPPORTS THE REHEARING OF THIS
CASE
6
THE NEW IMPORTANT DEVELOPMENTS THAT
FOLLOWED THE PETITIONER'S WRIT OF
CERTIORARI TIP THE BALANCE SQUARELY TO
GRANT A PETITION FOR REHEARING AND WRIT
OF CERTIORARI TO PROTECT THE STATEWIDE
AND NATIONWIDE HISTORICAL AND CULTURAL
INTERESTS
10
CONCLUSION
13
RULE 44.2 CERTIFICATE
14
11
TABLE OF CONTENTS — Continued
Page
REHEARING APPENDIX
TABLE OF CONTENTS
APPENDIX A:
A Transcript (Excerpt) of Questioning by
Justice Samuel Alito During Oral Argument
in the Supreme Court of the United States,
Trump v. Anderson, Case No. 23-719
(February 8, 2024)
Reh.App. la
APPENDIX B:
Donald J. Trump's Brief Regarding Standard
of Proof for the Proceeding in the Denver
District Court, Colorado,
Anderson v. Griswold, Case No. 2023CV32577,
District Court, City and County of Denver
(Nov. 17, 2023)
Reh.App.5a
APPENDIX C:
Business Insider Reported on Mar 26, 2023 the
News Story Singer Martha Reeves of Motown's
Martha and the Vandellas Is Fundraising to
Get Her Star on the Hollywood Walk of Fame
—and Has 3 Months to Secure Her Spot by
Taylor Ardrey
Reh.App.18a
APPENDIX D:
The Hollywood Chamber of Commerce Makes
Announcement on March 21, 2024 That Martha
Reeves' Star Induction Ceremony Will Be on
March 27, 2024 in the Press Release Fans Will
Be 'Dancing In The Street" When Entertainer
Martha Reeves Is Honored With Star On The
Hollywood Walk Of Fame
Reh.App.21a
111
TABLE OF AUTHORITIES
Page
CASES
Anderson v. Griswold,
Case No. 2023CV32577
(Deny. Dist. Ct. Nov. 17, 2023)
2, 4, 6, 11, 12
Armstrong v. Manzo,
380 U.S. 545 (1965)
3, 11
City of Ukiah v. Fones,
64 Ca1.2d 104 (1966)
9
Conservatorship of 0.B.,
9 Ca1.5th 989 (2020)
5
DuBeck v. California Physicians' Service,
234 Cal.App.4th 1254 (2015)
9
Goldberg v. Kelly,
397 U.S. 254 (1970)
3, 5
Grannis v. Ordean,
234 U.S. 385 (1914)
4
Mathews v. Eldridge,
424 U.S. 319 (1976)
3, 4, 6
Morgan v. United States,
298 U.S. 468 (1936)
3
Morrissey v. Brewer,
408 U.S. 471 (1972)
6
Rucker v. WCAB,
82 Cal. App. 4th 151 (2000)
3
Santosky v. Kramer,
455 U.S. 745 (1982)
3
Trump v. Anderson,
No. 23-719, 601 U.S.
(2024)
1, 6, 12
iv
TABLE OF AUTHORITIES - Continued
Page
CONSTITUTIONAL PROVISIONS
U.S. Const. amend. V
5, 6
U.S. Const. amend. VU
5, 10
U.S. Const. amend. XIV
2, 5, 6, 10
JUDICIAL RULES
Sup. Ct. R. 44.2
1, 14
MISCELLANEOUS
Henry J. Friendly,
Some Kind of Hearing,
123 U. PA. L. REV. 1267 (1975)
4
Taylor Ardrey
Singer Martha Reeves of Motown's
Martha and the Vandellas is fundraising
to get her star on the Hollywood Walk of
Fame — and has 3 months to secure her
spot, BUSINESS INSIDER (Mar 26, 2023)
7
PETITION FOR REHEARING
To THE HONORABLE JUSTICES OF THE SUPREME
COURT OF THE UNITED STATES:
Pursuant to Supreme Court Rule 44.2, Petitioner
respectfully seeks petition for rehearing of the Court's
March 18, 2024 order denying the writ of certiorari.
This Court's Rule 44.2 authorizes a petition for rehearing based on "intervening circumstances of substantial
or controlling effect or to other substantial grounds
not previously presented." There are intervening
high-profile cases with similar constitutional issues
that substantially impact the case at bar—the perfect
vehicle for an ordinary person deserving the same
due process rights as the rich and powerful.
GROUNDS FOR REHEARING
I.
ANALYSIS REGARDING STANDARD OF PROOF AND
QUESTIONING BY JUSTICE SAMUEL ALITO DURING
ORAL ARGUMENT FOR FORMER PRESIDENT'S
TRUMP COLORADO CASE BEFORE THE U.S.
SUPREME COURT VALIDATES THE REHEARING OF
THIS CASE
A common theme among many of the actions
against former President Trump is the standard of
proof. In Trump v. Anderson, No. 23-719, 601 U.S.
(March 4, 2024), the U.S. Supreme Court granted
certiorari to a case brought by a group of Colorado
electors, where the Supreme Court of the State of
Colorado considered whether former President Trump
2
could appear on the Colorado Republican presidential
primary ballot. The electors claimed that Trump was
disqualified under Section Three of the Fourteenth
Amendment, which prohibits anyone who has engaged
in insurrection against the U.S. Constitution from
holding office. The U.S. Supreme Court ruled that
states cannot remove Trump from ballot for
insurrection.
In the oral argument before the Court, the
Honorable Justice Samuel Alito skillfully pressed Jason
Murray, of Denver, the attorney on behalf of Anderson
and respondents on what the U.S. Supreme Court
should do if different states adjudicate Trump's
conduct differently based on different standards of
proof. Justice Alito's questions are directed at
procedural due process in an effort to fashion due
process in the circumstances. Justice Alito posed this
line of questions:
"Would we have to decide what is appropriate standard of proof?" "Would we give any
deference to these findings by state court
judges, some of whom may be elected? Would
we have to have our own trial?" The attorney
Murray responded, "No, your honor, thiS court
takes the evidentiary record as it's given...."
(Reh.App., infra, 3a)
In Anderson v. Griswold, Case No. 2023CV32577
'(Deny. Dist. Ct. Nov. 17, 2023), the Denver District
Court found'after
evidence
that. Trump engaged-in. insurrection 6.S.. those tents
.
are used'in Section Three but that Section Three dOes
not apply to'the. PreSident...TnliS the 'court ‘denied.:the
getition„,:,,Trump's brief regarding standard of proof
3
for the proceeding in the Denver District Court,
Colorado provides bedrock analysis and authorities:
To determine which standard of proof is
appropriate, the Court in Santosky [Santosky
v. Kramer, 455 U.S. 745, 754-755 (1982)]
applied a "straight-forward consideration of
the factors identified in Eldridge [Mathews
v. Eldridge, 424 U.S. 319, 335 (1976)] to
determine whether a particular standard of
proof in a particular proceeding satisfies due
process." The factors are "the private interests
affected by the proceeding; the risk of error
created by the State's chosen procedure; and
the countervailing governmental interest supporting use of the challenged procedure."
Importantly, "[t]he extent to which procedural
due process must be afforded the recipient
is influenced by the extent to which he may
be 'condemned to suffer grievous loss."'
[Goldberg v. Kelly, 397 U.S. 254, 262-263
(1970)] "Whether the loss threatened by a
particular type of proceeding is sufficiently
grave to warrant more than average certainty
on the part of the factfinder turns on both
the nature of the private interest threatened
and the permanency of the threatened loss."
[Id.]
(Reh.App., infra, 9a)
The central issue in many of these cases is "the
opportunity to be heard." This is the same issue and
class of cases presented in Petitioner's writ including
Armstrong v. Manzo, 380 U.S. 545, 552 (1965), Rucker
v. WCAB (2000) 82 Cal. App. 4th 151 and Morgan v.
United States, 298 U.S. 468 (1936). In Armstrong v.
4
Manzo, after the Supreme Court of Texas refused an
application for writ of error, the U.S. Supreme Court
held: "A fundamental requirement of due process is
`the opportunity to be heard."' Grannis v. Ordean, 234
U.S. 385, 394.
The analysis in Anderson v. Griswold regarding
whether a particular standard of proof in a particular proceeding satisfies due process validates the
reasoning in Petitioner's writ. The test with the factors
established in Eldridge are stated, "the private interests affected by the proceeding; the risk of error
created by the State's chosen procedure; and the
countervailing governmental interest supporting use
of the challenged procedure."
This is the identical formula that was set forth
in Petitioner's writ but identified as the "trifactor
balancing analysis" from Judge Friendly's "Some Kind
of Hearing." Henry J. Friendly, Some Kind of Hearing,
123 U. PA. L. REV. 1267, 1277-87 (1975), which slightly
preceded the decision in Eldridge.
The application of the trifactor balancing analysis
makes this a compelling case worthy of certiorari.
The balancing analysis to determine the type of
process due in the initial adjudication would at a
minimum mandate for Appellant the opportunity to
be heard. The risk of an erroneous deprivation of
protected interests through the procedures actually
utilized is a low bar to meet given the Appellant was
precluded any opportunity to be heard. The rationale
for the probable value of added or substitute procedural
safeguards is demonstrated more comprehensively in
the writ. (Cert., pp. 14-15)
5
The risk of an erroneous deprivation of Appellant's rights in the proceeding was heightened because
the procedures employed by the Court of Appeal were
such that it simultaneously served as the factfinder and
the reviewing court. The Court of Appeal frustrated
the purpose stated in Goldberg: "[t]he extent to
which procedural due process must be afforded the
recipient is influenced by the extent to which he may
be 'condemned to suffer grievous loss."' The Appellant's
inalienable Fifth, Seventh and Fourteenth Amendment
rights were erroneously deprived.
The court in Conservatorship of O.B. (2020) 9 Cal.
5th 989, 1012 held that "logic, policy, and precedent
require the appellate court to account for the heightened
standard of proof. Logically, whether evidence is "of
ponderable legal significance" cannot be properly evaluated without accounting for a heightened standard
of proof that applied in the trial court...." The Court of
Appeal thwarted the stated objective "for a heightened standard of proof that applied in the trial court."
What's clear from the landmark case Conservatorship
of O.B. is that the role of the Court of Appeal is one of
review of the trial court's finding. Thus, the Court of
Appeal demonstrably violated the due process rights
of Appellant by simultaneously serving as the
factfinder and the reviewing court. (Cert., pp. 32-33)
This begs the question on how should've the Court
of Appeal proceeded since there was never any finding
by the trial court on the waiver of the conditions
precedent by the Hollywood Chamber. "Once it is
determined that due process applies, the question
remains what process is due. It has been said so often
by this Court and others as not to require citation of
authority that due process is flexible and calls for
6
such procedural protections as the particular situation
demands." Morrissey v. Brewer, 408 U.S. 471 (1972).
(Cert., p. 33)
Like in Trump v. Anderson where Justice Alito's
questions are targeted at procedural due process in
an effort to craft due process in the circumstances,
the Court of Appeal here should've addressed due
process with the same due diligence and remanded
the case back to the trial court with instructions to
make a determination as the factfinder whether or
not Plaintiff met the "clear and convincing" standard.
Whether it be the name Trump on a ballot as in
Anderson v. Griswold or a star with Robin's name on
the Hollywood Walk of Fame, they have constitutionally guaranteed rights. "Procedural due process
imposes constraints on court decisions which deprive
individuals of "liberty" or "property" interests within
the meaning of the Due Process Clause of the Fifth
or Fourteenth Amendment." Mathews v. Eldridge.
II. THE NEWS THAT MARTHA REEVES APPEARED TO
BE GRANTED A WAIVER ON HER JOURNEY TO GET
HER STAR ON THE HOLLYWOOD WALK OF FAME
SUPPORTS THE REHEARING OF THIS CASE
The news that Martha Reeves appeared to be
granted a waiver on her journey to get her star on the
Hollywood Walk of Fame is a comparable situation to
the waiver in the instant case. However, unlike here,
the Hollywood Chamber is honoring the waiver granted
to Reeves so that she had her star installed on March
27, 2024 on the Hollywood Walk of Fame. (Reh.App.
21a) The circumstances of Reeves' star was reported
by numerous news outlets including Business Insider
on Mar 26, 2023 by Taylor Ardrey in her news story
7
Singer Martha Reeves of Motown's Martha and the
Vandellas is fundraising to get her star on the
Hollywood Walk of Fame — and has 3 months to
secure her spot:
Martha Reeves of the famed Motown girl
group Martha and the Vandellas is fundraising to get her star on the illustrious
Hollywood Walk of Fame—and has just
under three months left to get it done.
The singer... was tapped to receive a star on
the Hollywood Walk of Fame in 2021 after
being nominated by an ex-manager, The
Detroit Free Press reported.
During that time, she was under the impression that the manager was going to handle
the cost of the star and that her induction
ceremony would be in 2022, per the report.
The cost of the star is $55,000, according to
the Hollywood Walk of Fame's website, which
is used for the star installation and maintenance. Now in a bind, and under new management, her team created a fundraiser to help
gather enough money by June to secure her
spot for next year, according to the Free Press.
"If we do not make a sizeable indentation to
our goal, it is likely that Martha's Hollywood
Star selection will be withdrawn, and we
will have to start the nomination process all
over again (which could take several years),"
Reeves' current manager, Chris Roe, wrote on
the campaign page. "Since she was nominated
and chosen in 2021, as part of the Class of
2022, we have very little time. There is a
8
time limit to receive your star after being
selected."...
"Martha's former representation got in over
their heads on this," Roe told the Free Press.
"They didn't realize how hard it would be
and wasted a year of fundraising time. Now
we're down to the wire."
(Reh.App., infra, 18a-20a).
With this background on the star awarded to
Reeves on the Hollywood Walk of Fame and the
subsequent fundraising efforts to pay for the star,
here is an explanation of the waiver. The conditions
precedent stated in the Hollywood Walk of Fame
Nomination for Selection provide that "1. It is understood that the cost of installing a star in the Walk of
Fame upon approval is... [$55,000]** and the sponsor
of the nominee accepts the responsibility for arranging
for payment to the Hollywood Historic Trust..."
(Cert., App.135a)
Based on the terms of the contract, the $55,000
was due "upon approval" at the time the star was
awarded back in June of 2021. According to Business
Insider, "Now in a bind, and under new management,
her team created a fundraiser to help gather enough
money by June [2023] to secure her spot for next year
[2024], according to the [Detroit] Free Press." (See
supra on p.7).
This means that the payment came in 2023,
approximately two years after it was due in 2021.
The only way this could occur is with a waiver by the
Hollywood Chamber to allow the payment to be after
the time stated in the terms of the contract.
9
The waiver of performance of conditions precedent for Robin's star by the Hollywood Chamber is
comparable to that with the waiver of performance of
condition precedent for Reeves' star by the Hollywood
Chamber. In the case of Reeves' star, the Hollywood
Chamber granted a waiver when the new sponsor
needed more time beyond the due date in the contract
for fundraising to pay for the star. In the case of
Robin's star, the Hollywood Chamber granted a
waiver to Petitioner, the new sponsor, when the former
sponsors, actor Bob Hope and Mrs. Robin, either was
not informed or died.
Plaintiff alleged in the FAC the. relinquishment
of the conditions precedent by the Hollywood Chamber
in allegation no. 72:
On July 17, 2018, Ms. Martinez sent Ora an
email where she stipulated, "From what I
gather you are now willing to have the
star dedication happen with a ceremony??
There is the sponsorship fee involved of
[$]40,000.00. Please let me know when you
would like to do the ceremony and once you
give me a date we can move forward...
Please let me know if you do want to move
forward." (3 CT 749.).
(Cert., pp. 29-30)
Appellant should have prevailed because he met
the burden of proof standard that there was a "waiver
of a right... by clear and convincing evidence." (City
of Ukiah v. Fones (1966) 64 Ca1.2d 104, 107-108).
Further, Appellant should succeed as matter of
law under DuBeck v. California Physicians' Service
(2015) 234 Cal.App.4th 1254, 1265, which held "Waiver
10
is ordinarily a question for the trier of fact; `[h]owever,
where there are no disputed facts and only one reasonable inference may be drawn, the issue can be determined as a matter of law."'
If there are disputed facts and different reasonable
inferences may be drawn, then a jury is the trier of
fact, not the Court of Appeal. It would be up to the trier
of fact to consider all of the facts including Reeves
being granted a waiver for her star on the Hollywood
Walk of Fame.
Whether a star is awarded to a recording artist
from Motown or a songwriter from Tin Pan Alley, they
have constitutionally guaranteed rights under the
Seventh and Fourteenth Amendments. The judicial
system demands "equal protection of the laws." The
Hollywood Chamber honored the waiver granted to
Reeves so that she received her star on the Hollywood
Walk of Fame. The Hollywood Chamber failed to honor
the waiver granted to Robin so that he never received
his star on the Hollywood Walk of Fame. The Court
of Appeal's decision egregiously violated Petitioner's
due process rights and sacred right to a jury trial.
III. THE NEW IMPORTANT DEVELOPMENTS THAT
FOLLOWED THE PETITIONER'S WRIT OF
CERTIORARI TIP THE BALANCE SQUARELY TO
GRANT A PETITION FOR REHEARING AND WRIT
OF CERTIORARI TO PROTECT THE STATEWIDE
AND NATIONWIDE HISTORICAL AND CULTURAL
INTERESTS
The new important developments that followed
Petitioner's writ of certiorari warrant consideration for
granting a rehearing given the high-stakes which
11
impact the statewide and nationwide historical and
cultural interests.
Before the new developments, a sum up of where
things stand. During the trial court proceedings,
Plaintiff repeatedly argued the absolute waiver of
performance of conditions precedent by the Hollywood
Chamber. The waiver issue was never fleshed out
earlier because the trial court failed to acknowledge,
overlooked and/or avoided this salient legal argument.
The Hollywood Chamber ducked the waiver issue
until its response in the Court of Appeal with a terse
two sentence statement with no analysis of the facts
and no authorities cited to support its conclusion.
The California courts have been carrying the
water for their elitist-municipal-brethren Hollywood
Chamber and trampled the due process rights of
Petitioner. The waiver issue had become the firewall
of the Court of Appeal after giving up on the contract
issues relied upon by the trial court and Hollywood
Chamber.
The only way the Court of Appeal had to champion
its cause and win the waiver issue was to flagrantly
torpedo the Petitioner's proven factual allegations
without a hearing at the eleventh hour; but the court
did indeed lose its way. In Armstrong v. Manzo, the
U.S. Supreme Court held: "A fundamental requirement of due process is "the opportunity to be heard."
Petitioner was never allowed the opportunity to be
heard—truly anathema to the rule of law.
Petitioner has presented new developments that
tip the balance squarely for granting a petition for
rehearing. The analysis in Anderson v. Griswold
regarding whether a standard of proof applied in a
12
proceeding satisfies due process lends support to the
reasoning in Petitioner's writ. Further, Justice Alito's
questions in Trump v. Anderson in an effort to craft
due process in that case should be a guidepost how
the case here should be managed. Finally, the news
that Reeves was granted a waiver to get her star is
relevant context for the trier of fact to consider in
determining whether Petitioner met the burden of
proof "clear and convincing" standard to prove the
Hollywood Chamber waived performance of the
conditions precedent for the star awarded to Robin.
Given the new developments, the case here is an
exceptional candidate for grant, vacate, and remand
(GVR) on rehearing. The basis of this GVR is not
triggered by a new Supreme Court decision. However,
the same general principles could be applied to the
reasoning. What was reasoned in Trump v. Anderson
and Anderson v. Griswold applies mutatis mutandis
to the case at bar. The question in Anderson v.
Griswold whether a standard of proof applied in a
proceeding satisfies due process presents a similar
constitutional question to the one raised here.
Granting rehearing and GVR in light of the reasoning
in these cases justifies consideration here.
13
CONCLUSION
For the foregoing reasons, Petitioner respectfully
requests this Honorable Court to grant rehearing and
the petition for a writ of certiorari and, alternatively,
a GVR to protect the statewide and nationwide
historical and cultural interests.
Executed in Sherman Oaks, California
Respectfully submitted,
4
4eritt, rktle04,-
Scott Douglas Ora
Petitioner Pro Se
4735 Sepulveda Blvd. Apt. 460
Sherman Oaks, CA. 91403
(818) 618-2572
sdo007@aol.com
April 4, 2024
14
RULE 44.2 CERTIFICATE
I hereby certify, under penalty of perjury, that
this petition for rehearing is presented in good faith
and not for delay, and that it is restricted to the
grounds specified in Supreme Court Rule 44.2.
Petitioner
April 4, 2024
REHEARING APPENDIX
TABLE OF CONTENTS
APPENDIX A:
A Transcript (Excerpt) of Questioning by
Justice Samuel Alito During Oral Argument
in the Supreme Court of the United States,
Trump v. Anderson, Case No. 23-719
(February 8, 2024)
Reh.App. la
APPENDIX B:
Donald J. Trump's Brief Regarding Standard
of Proof for the Proceeding in the Denver
District Court, Colorado,
Anderson v. Griswold, Case No. 2023CV32577,
District Court, City and County of Denver
(Nov. 17, 2023)
Reh.App.5a
APPENDIX C:
Business Insider Reported on Mar 26, 2023 the
News Story Singer Martha Reeves of Motown's
Martha and the Vandellas Is Fundraising to
Get Her Star on the Hollywood Walk of
Fame—and Has 3 Months to Secure Her Spot
by Taylor Ardrey
Reh.App.18a
APPENDIX D:
The Hollywood Chamber of Commerce Makes
Announcement on March 21, 2024 That Martha
Reeves' Star Induction Ceremony Will Be on
March 27, 2024 in the Press Release Fans Will
Be "Dancing In The Street" When Entertainer
Martha Reeves Is Honored With Star On The
Hollywood Walk Of Fame
Reh.App.21a
Reh.App.la
APPENDIX A:
A TRANSCRIPT (EXCERPT) OF
QUESTIONING BY JUSTICE SAMUEL AUTO
DURING ORAL ARGUMENT IN THE
SUPREME COURT OF THE UNITED STATES,
TRUMP v. ANDERSON, CASE NO. 23-719
(FEBRUARY 8, 2024)
SUPREME COURT OF THE UNITED STATES
DONALD J. TRUMP,
Petitioner,
v.
NORMA ANDERSON, ET AL.,
Respondents.
No. 23-719
Washington, D.C.
Thursday, February 8, 2024
Pages: 1 through 140
Place: Washington, D.C.
Date: February 8, 2024
HERITAGE REPORTING CORPORATION
Official Reporters
1220 L Street, N.W., Suite 206
Washington, D.C. 20005
(202) 628-4888
www.hrccourtreporters.com
Reh.App.2a
IN THE SUPREME COURT OF
THE UNITED STATES
DONALD J. TRUMP,
Petitioner,
v.
NORMA ANDERSON, ET AL.,
Respondents.
No. 23-719
Washington, D.C.
Thursday, February 8, 2024
The above-entitled matter came on for oral argument before the Supreme Court of the United States
at 10:08 a.m.
APPEARANCES:
JONATHAN F. MITCHELL, ESQUIRE, Austin,
Texas; on behalf of the Petitioner.
JASON C. MURRAY, ESQUIRE, Denver, Colorado; on behalf of Respondents Anderson, et al.
SHANNON W. STEVENSON, Solicitor General,
Denver, Colorado; on behalf of Respondent
Griswold.
Reh.App.3a
PROCEEDINGS
(10:08 a.m.)
CHIEF JUSTICE ROBERTS: We'll hear argument
this morning in Case 23-719, Trump versus
Anderson.
[
JUSTICE ALITO: Let me come back to the question of
what we would do if we were—if different states
had adjudicated the question of whether former
President Trump is an insurrectionist using a
different record, different rulings on the admissibility of evidence, perhaps different standards of
proof. Then what would we do?
MR. MURRAY: Ultimately, this Court would—first of
all, if there were deficiencies in the record, the
Court could either refuse to hear the case or it
could decide on the basis of deficiencies of the
record.
JUSTICE ALITO: Well, would we have to decide what
is the appropriate rule of evidence that should be
applied in this—in this case? Would we have to
decide what is the appropriate standard of proof?
Would we give any deference to these findings by
state court judges, some of whom may be elected?
Would we have to have our own trial?
MR. MURRAY: No, Your Honor. This Court takes the
evidentiary record as—as it's given. And, here, we
have an evidentiary record that all the parties
agree is sufficient for a decision in—in this case.
And then, as—as I discussed earlier, there's a
possibility of a Bose Corp. independent review of
the facts, but, ultimately, what we have here is
Reh.App.4a
an insurrection that was incited in plain sight
for all to see.
JUSTICE AUTO: Yeah, but you're really not answering my question. It's not helpful if you don't do
that.
We have—suppose we have two different records,
two different bodies of evidence, two different
rulings on questions of admissibility, two different
standards of proof, two different sets of fact
findings by two different judges or maybe multiple
judges in multiple states.
Then what do we do?
MR. MURRAY: Well, first, this Court would set the
legal standard, and then it would decide which
view of the record was—was correct, I think,
under that—if—if this Court had two cases—
[
Reh.App.5a
APPENDIX B:
DONALD J. TRUMP'S BRIEF
REGARDING STANDARD OF PROOF
FOR THE PROCEEDING IN THE DENVER
DISTRICT COURT, COLORADO,
ANDERSON v. GRISWOLD,
CASE NO. 2023CV32577, DISTRICT COURT,
CITY AND COUNTY OF DENVER
(NOV. 17, 2023)
DISTRICT COURT
CITY AND COUNTY OF DENVER, COLORADO
1437 Bannock Street, Room 256
Denver, CO 80202
Phone: (303) 606-2300
NORMA ANDERSON, MICHELLE PRIOLA,
CLAUDINE CMARADA, KRISTA KAFER, KATHI
WRIGHT, and CHRISTOPHER CASTILIAN,
Petitioners,
JENA GRISWOLD, in her official capacity
as Colorado Secretary of State, and
DONALD J. TRUMP,
Respondents.
Case Number: 2023CV32577
Division/Courtroom: 209
Reh.App.6a
Attorneys for Respondent Donald J. Trump:
Scott E. Gessler (28944), sgessler@gesslerblue.com
Geoffrey N. Blue (32684), gblue@gesslerblue.com
Justin T. North (56437), jnorth@gesslerblue.com
Gessler Blue LLC
7350 E. Progress Pl., Suite 100
Greenwood Village, CO 80111
Tel: (720) 839-6637 or (303) 906-1050
DONALD J. TRUMP'S BRIEF
REGARDING STANDARD OF PROOF
IN THIS PROCEEDING
Respondent and Intervenor Donald J. Trump
hereby files this brief regarding the appropriate
standard of proof for the hearing commencing on
October 30, 2023. Under case law of both the United
States Supreme Court and the Colorado Supreme
Court, Petitioners must satisfy the "clear and
convincing evidence" standard of proof to receive the
relief they desire, because they seek the absolute
deprivation of the First and Fourteenth Amendment
rights of President Trump and Colorado voters.
I. The "clear and convincing evidence"
standard is the minimum standard of proof
required when constitutional rights are at
stake.
The standard of proof used in any proceeding is
fundamentally a due process issue. While Section 14-1204(4) specifies that "[t]he party filing the challenge
has the burden to sustain the challenge by a
preponderance of the evidence," this statutory standard
of proof is not dispositive because courts must always
Reh.App.7a
apply the appropriate standard of proof as a matter
of federal law: "The 'minimum requirements [of procedural due process] being a matter of federal law,
they are not diminished by the fact that the State
may have specified its own procedures that it may
deem adequate for determining the preconditions to
adverse official action."'1 Furthermore, "the degree of
proof required in a particular type of proceeding 'is
the kind of question has traditionally been left to the
judiciary to resolve.'2
"The function of a standard of proof, as that
concept is embodied in the Due Process Clause and in
the realm of factfinding, is to 'instruct the factfinder
concerning the degree of confidence our society thinks
he should have in the correctness of factual conclusions
for a particular type of adjudication."'3 "In any given
proceeding, the minimum standard of proof tolerated
by the due process requirement reflects not only the
weight of the private and public interests affected,
but also a societal judgment about how the risk of
error should be distributed between the litigants."4
On this basis, the Supreme Court in Addington v.
Texas explained which circumstances are appropriate
for each of the three standards of proof.
1 Santosky v. Kramer, 455 U.S. 745, 755 (1982) (quoting Vitek v.
Jones, 445 U.S. 480, 491 (1980)).
2 Id. at 755-56 (quoting Wood by v. INS, 385 U.S. 276 (1966)).
3 Addington v. Texas, 441 U.S. 418, 423 (1979) (quoting In re
Winship, 397 U.S. 358, 370, 90 S.Ct. 1068, 1075, 25 L.Ed.2d 368
(1970) (Harlan, J., concurring).
4 Santosky, 455 U.S. at 754-755.
Reh.App.8a
"Preponderance of the evidence" is appropriate
for "the typical civil case involving a monetary
dispute between private parties" because "society has
a minimal concern with the outcome of such private
suites" and the litigants should "thus share the risk
of error in roughly equal fashion."5
"Clear and convincing evidence" is appropriate
when "[t]he interests at stake . . . are deemed to be
more substantial than mere loss of money" and a
higher standard of proof would be necessary "to protect
particularly important individual interests in various
civil cases."6 To that end, "the Court has deemed this
level of certainty necessary to preserve fundamental
fairness in a variety of government-initiated proceedings that threaten the individual involved with 'a
significant deprivation of liberty' or `stigma.'"7
The "beyond a reasonable doubt" standard is
appropriate in criminal cases, where "the interests of
the defendant are of such magnitude that historically
and without any explicit constitutional requirements
they have been protected by standards of proof
designed to exclude as nearly as possible the likelihood
of an erroneous judgment," because in those circumstances "our society imposes almost the entire risk of
error upon itself."8
5 Addington, 441 U.S. at 423.
6 Id. at 424.
7 Santosky, 455 U.S. at 756 (quoting Addington, 441 U.S. at
425, 426).
8 Addington, 441 U.S. at 423-24.
Reh.App.9a
To determine which standard of proof is appropriate, the Court in Santosky applied a "straightforward consideration of the factors identified in
Eldrige to determine whether a particular standard
of proof in a particular proceeding satisfies due
process."9 The factors are "the private interests affected
by the proceeding; the risk of error created by the
State's chosen procedure; and the countervailing
governmental interest supporting use of the challenged
procedure."10 Importantly, "[t]he extent to which procedural due process must be afforded the recipient is
influenced by the extent to which he may be
`condemned to suffer grievous loss."'11 "Whether the
loss threatened by a particular type of proceeding is
sufficiently grave to warrant more than average
certainty on the part of the factfinder turns on both
the nature of the private interest threatened and the
permanency of the threatened loss."12
The Supreme Court has consistently applied this
analysis when defendants' important or fundamental
constitutional rights are at-stake, finding that the
clear and convincing evidence standard is necessary
to provide due process in proceedings concerning
termination of parental rights13 and involuntary psychiatric commitment.14
9 Santosky, 455 U.S. at 754.
10 Id. (citing Mathews v. Eldridge, 424 U.S. 319, 335 (1976)).
11 Id. at 758 (Goldberg v. Kelly, 397 U.S. 254, 262-263 (1970)).
12 Id.
13 See Santosky, 455 U.S. 745.
14 See M.L.B. v. S.L.J., 519 U.S. 102 (1996).
Reh.App.10a
In the First Amendment context, such as this
case which implicates President Trump's First
Amendment rights to free speech and petition, this
analysis has lead the Supreme Court to require that
a public official prove by clear and convincing proof
that a speaker's defamatory statements were made
with knowledge or the reckless disregard of their
falsity.15 The point of this higher standard is to give
freedom of speech the necessary "'breathing space'
essential to their fruitful exercise."16
The Colorado Supreme Court also uses this
framework to determine the appropriate standard of
proof in various cases:17
Previously, we held that the three-factor
analysis in Eldridge was an appropriate
tool to assess the question of "what process
is due" parties facing termination of parental
rights. In A.M.D., we employed the Eldridge
balancing test to determine whether the
Due Process Clause mandated a stricter
standard of proof at the adjudicatory and
termination hearings. There, we determined
that the private interests of the parents in
preserving their rights were "commanding."
15 BE&K Constr. Co. v. NLRB, 536 US 516, 531 (2002).
16 Id., citing Gertz v. Robert Welch, Inc., 418 U.S. 323, 342
(1974).
17 See People in Interest of A. M. D., 648 P.2d 625 (Colo. 1982);
A.M. v. A.C., 2013 CO 16, ¶ 32, 296 P.3d 1026, 1035-36, as
modified on denial of reh'g (Mar. 18, 2013); E.R.S. v. O.D.A.,
779 P.2d 844, 847-48 (Colo. 1989); In re D.I.S., 249 P.3d 775,
785 (Colo. 2011); L.L. v. People, 10 P.3d 1271, 1276 (Colo. 2000);
People in Int. of O.E.P., 654 P.2d 312, 315 (Colo. 1982).
Reh.App.1 la
We discussed that the risk of error at stake
was the "risk of erroneous fact finding." The
government's interests, we held, included
the parens patriae- interest in preserving
and promoting the well-being of the child
and the interest in reducing the fiscal and
administrative burdens that come with a
higher burden of proof. We also discussed,
however, that a higher burden of proof at
the adjudicatory stage could highlight the
adversarial nature of the process, replacing
the State's role as a "helping intervenor"
with that of an "adversary of the parents,
bent on the permanent destruction of their
relationship with the child."
For these reasons, we concluded that the
government's "substantial" interests went
beyond its pecuniary stake. Balancing those
interests against one another in the context
of each hearing, we concluded that fairness
required a clear and convincing standard at
the termination hearing but only a preponderance of the evidence standard at the
adjudicatory hearing.18
Both the United States Supreme Court and the
Colorado Supreme Court have consistently found
that whenever constitutional rights are at stake, the
18 A.M. v. A.C., 2013 CO 16, ¶ 32, as modified on denial of reh'g
(Mar. 18, 2013) (paragraph breaks added) (relying on People in
Interest of A. M. D., 648 P.2d 625 (Colo. 1982)) (internal
citations omitted).
Reh.App.12a
appropriate standard of proof is either clear and
convincing evidence or higher.19
An evaluation of the Eldridge factors under
Santosky shows that the appropriate standard of
proof is clear and convincing evidence, so that
President Trump and those who seek to vote for him
may be afforded due process.
II. The appropriate standard of proof is "clear
and convincing evidence" because important
constitutional rights would be permanently
damaged by an error.
The appropriate standard of proof in this proceeding is "clear and convincing evidence" because
Petitioners' requested relief would permanently deprive
President Trump and Colorado voters of their
important constitutional rights regarding freedom of
association and voting. All three factors of the
Santosky analysis indicate that due process requires
the "clear and convincing evidence standard."
19 See Santosky, 455 U.S. 745 (clear and convincing evidence
needed before terminating parental rights); M.L.B., 519 U.S.
102 (same); Addington v. Texas, 441 U.S. 418 (clear and
convincing evidence needed before involuntarily committing
defendant to psychiatric hospital); In re Winship, 397 U.S. 358
(1970) (beyond a reasonable doubt standard necessary for
juvenile delinquency proceeding); People in Interest of A. M. D.,
648 P.2d 625 (Colo. 1982) (applying Santosky to hold that clear
and convincing evidence is needed before termination parental
rights); A.M. v. A.C., 2013 CO 16 (same); People in Int. of
O.E.P., 654 P.2d 312 (Colo. 1982) (preponderance of the evidence
standard was acceptable in parental neglect determination
because no constitutional rights were threatened, unlike in an
action to terminate parental rights).
Reh.App.13a
First, the private interests at stake are significant. Petitioners here seek to have President Trump
declared permanently ineligible for access to the
ballot in Colorado for any federal or state office.
Unlike a purely monetary interest that merits only a
preponderance of the evidence standard of proof,20
the interests threatened in this case are important
First and Fourteenth Amendment constitutional rights
related to freedom of association.21 The Colorado
Supreme Court has directly recognized that "restrictions on a political organization's access to an election
ballot burden two fundamental rights: 'the right of
individuals to associate for the advancement of political
beliefs, and the right of qualified voters, regardless of
their political persuasion, to cast their votes effectively."'22 And "ballot access restrictions imposed on
candidates necessarily implicate voters' freedom of
association by limiting the field of candidates from
which the voters might choose.23
Second, the Government's interest in regulating
its elections is not harmed by using the "clear and
convincing evidence" standard and are actually
preserved. While the Government does have an
20 See Addington, 441 U.S. at 423.
21 Colorado Libertarian Party v. Sec'y of State of Co/o., 817
P.2d 998, 1002 (Colo. 1991).
22 Id. (quoting Williams v. Rhodes, 393 U.S. 23, 30 (1968));
accord Munro v. Socialist Workers Party, 479 U.S. 189, 193
(1986); Illinois State Bd. of Elections v. Socialist Workers Party,
440 U.S. 173, 184 (1979); National Prohibition Party v. State,
752 P.2d 80, 83 (Colo.1988).
23 Id. (citing Anderson v. Celebrezze, 460 U.S. 780, 787-88
(1983).
Reh.App.14a
interest in regulating its election to ensure they are
'fair and honest and if some sort of order, rather than
chaos, is to accompany the democratic processes,'"24
this interest must be balanced against the effect of
those regulations on the rights of candidates, political
organizations, and voters.25
Unlike election regulations which impose a surmountable hurdle to would-be candidates that can be
overcome by patience, effort, or savvy, such as the
one-year disaffiliation requirement for independent
candidates, the government action Petitioners seek
here would permanently bar President Trump from
the ballot, including of course access to the ballot for the
2024 election. Whereas regulations like the disaffiliation requirement provide a clear benefit to the government by cutting down on chaos that would be caused
by candidates continuing intra-party on the general
election ballot,26 President Trump's permanent disqualification does not present an unambiguous regulatory benefit to the Government's administration of
elections. To the degree the Government has an interest
in substantively evaluating the constitutional qualifications of presidential candidates under Section
Three in order to keep disqualified candidates off the
ballot (which President Trump has disputed in separate
briefing), this interest is only in keeping off candidates
who are actually disqualified.
24 Colorado Libertarian Party, 817 P.2d at 1002 (quoting Storer
v. Brown, 41 U.S. 724, 730 (1974)).
25 Id. at 1001-02.
26 Id. at 1003.
Reh.App.15a
The Government has no interest in keeping candidates off the ballot who are qualified—especially on a
permanent basis. Accordingly, the "clear and
convincing evidence" serves the Government's interest
here by reducing the risk of an erroneous permanent
bar on an otherwise qualified candidate. Given the
limited procedures for resolving Petitioners' challenge
and the insurmountable nature of the disability they
seek to impose on President Trump, the governmental
interest in only prohibiting truly disqualified candidates from the ballot is aided by the heightened
standard of proof. And the Colorado General Assembly
has explicitly stated that the Election Code "shall be
liberally construed so that all eligible electors may be
permitted to vote."27 This interest is not served by
erroneously barring a qualified and popular candidate
from the ballot forever. Thus, requiring Petitioners
to meet the "clear and convincing evidence" standard
before permanently banning President Trump from
the ballot is in the interests of both the Government
and President Trump.
Third, the risk of erroneous deprivation of President Trump and Colorado voters' rights in this proceeding is heightened because of its abbreviated procedures.
Petitioners have chosen to proceed under Section 113's
expedited procedures, preventing President Trump's
use of the discovery process, putting him under significant time-constraints while they have had over a
year to prepare, and affording him severely limited
procedures for appeal. Because of these procedural
pressures, President Trump and Colorado voters face
a real risk that their important First and Fourteenth
27 C.R.S. § 1-1-103(1).
Reh.App.16a
Amendment rights will be erroneously deprived without
adequate remedy. Furthermore, the hearing requires
the Court to go into deep and uncharted constitutional
waters regarding how to apply Section Three of the
Fourteenth Amendment to a former President.
This combination of limited procedures for establishing and adjudicating complex factual issues related
to the events of January 6, 2021, the Court's need to
decide novel constitutional issues, and an abridged
appeals process presents a distinct risk of an erroneous
judgment. This risk of error is all the more severe
because Petitioners seek a permanent prohibition on
President Trump's ballot access. A risk of an erroneous
permanent deprivation of constitutional rights, particularly when that risk is magnified by procedures that
remove traditional due process safeguards, necessitates
a higher standard of proof.28
28 See Santosky, 455 U.S. at 761-64 (finding a higher standard
of proof was necessary when procedural limitations meant that
parents' rights were subject to termination based on complex,
subjective, or otherwise imprecise standards).
Reh.App.17a
Conclusion
The Court has a duty to ensure that the First
and Fourteenth Amendment rights of President Trump
and Colorado voters are protected by sufficient process.
Applying the "clear and convincing" standard of proof
protects against an erroneous deprivation of these
rights while serving the governmental interests.
Accordingly, the Court must require Petitioners to meet
this higher standard of proof for the relief they seek.
Respectfully submitted this 25th day of October
2023,
GESSLER BLUE LLC
/s/ Geoffrey N. Blue
Reh.App.18a
APPENDIX C:
BUSINESS INSIDER REPORTED ON MAR 26,
2023 THE NEWS STORY SINGER MARTHA
REEVES OF MOTOWN'S MARTHA AND THE
VANDELLAS IS FUNDRAISING TO GET HER
STAR ON THE HOLLYWOOD WALK OF
FAME—AND HAS 3 MONTHS TO SECURE
HER SPOT BY TAYLOR ARDREY
Singer Martha Reeves of Motown's Martha and
the Vandellas is fundraising to get her star on
the Hollywood Walk of Fame — and has 3 months
to secure her spot
Taylor Ardrey Mar 26, 2023, 12:52 PM PDT
Singer Martha Reeves and the Vandellas perform
on stage during Day 2 of the Vintage at Goodwood
Festival on August 14, 2010 in Chichester, England
(Chris Jackson/Getty Images for
Vintage at Goodwood)
Reh.App.19a
Singer Martha Reeves is raising money to receive
a star on the Hollywood Walk of Fame.
She was nominated in 2021 and thought the cost
would be covered by her former manager.
Now, as the Detroit Free Press reported, her team
is trying to raise $55,000 by June.
Martha Reeves of the famed Motown girl group
Martha and the Vandellas is fundraising to get her
star on the illustrious Hollywood Walk of Fame —
and has just under three months left to get it done.
The singer, known for hits "Dancing in the Street"
and "Come And Get These Memories," was tapped to
receive a star on the Hollywood Walk of Fame in
2021 after being nominated by an ex-manager, The
Detroit Free Press reported.
During that time, she was under the impression
that the manager was going to handle the cost of the
star and that her induction ceremony would be in
2022, per the report.
The cost of the star is $55,000, according to the
Hollywood Walk of Fame's website, which is used for
the star installation and maintenance. Now in a
bind, and under new management, her team created
a fundraiser to help gather enough money by June to
secure her spot for next year, according to the Free
Press.
"If we do not make a sizeable indentation to our
goal, it is likely that Martha's Hollywood Star
selection will be withdrawn, and we will have to
start the nomination process all over again (which
could take several years)," Reeves' current manager,
Reh.App.20a
Chris Roe, wrote on the campaign page. "Since she
was nominated and chosen in 2021, as part of the
Class of 2022, we have very little time. There is a
time limit to receive your star after being selected."
Detroit Free Press reported that some celebrities
have record labels or movie production studios behind
them to take care of the costs while others sometimes
have to crowdfund.
For instance, last year, legendary "Everything
Everywhere All At Once" actor James Hong received
a star on the Hollywood Walk of Fame after fellow
actor Daniel Dae Kim raised the money back in 2020,
according to The Los Angeles Times.
In addition, as the Free Press noted, money was
crowdfunded for Motown music group The Funk
Brothers, who got their sidewalk star in 2013.
"Martha's former representation got in over their
heads on this," Roe told the Free Press. "They didn't
realize how hard it would be and wasted a year of
fundraising time. Now we're down to the wire."
Reh.App.21a
APPENDIX D:
THE HOLLYWOOD CHAMBER OF
COMMERCE MAKES ANNOUNCEMENT ON
MARCH 21, 2024 THAT MARTHA REEVES'
STAR INDUCTION CEREMONY WILL BE ON
MARCH 27, 2024 IN THE PRESS RELEASE
FANS WILL BE "DANCING IN THE STREET"
WHEN ENTERTAINER MARTHA REEVES IS
HONORED WITH STAR ON THE
HOLLYWOOD WALK OF FAME
Fans Will Be "Dancing in the Street" When
Entertainer Martha Reeves Is Honored with
Star on the Hollywood Walk of Fame
WHO I HONOREE Martha Reeves
GUEST SPEAKERS
Berry Gordy, Smokey Robinson and
William "Mickey" Stevenson
EMCEE
Angelique Jackson,
Variety Senior Entertainment Correspondent
WHAT
Dedication of the 2,776th star on the Hollywood
Walk of Fame
WHEN Wednesday, March 27, at 11:30 AM PT
WHERE 7080 Hollywood Boulevard
WATCH LIVE
The event will live streamed exclusively at
walkoffame.com
Reh.App .22a
Performer Martha Reeves will be honored on
March 27, with the 2,776th star on the Hollywood
Walk of Fame. The star will be unveiled at 7080
Hollywood Boulevard. Reeves will be awarded her
star in the category of Recording. Speakers joining
emcee Angelique Jackson will be Berry Gordy,
Smokey Robinson, and William "Mickey" Stevenson.
The Hollywood Chamber of Commerce administers the legendary Hollywood Walk of Fame for the
City of Los Angeles and has proudly hosted globally
iconic ceremonies for decades. Millions of people from
here and around the world have visited this cultural
landmark since 1960.
ABOUT OUR HONOREE
"We are very proud to honor Martha Reeves with
a star on the Hollywood Walk of Fame. It is wonderful
to see that her legacy and contributions to the music
world will be recognized" stated Walk of Fame
Producer, Ana Martinez. "Being a Motown great, it is
fitting that her star will be on the strip where many
iconic Motown acts such as: The Supremes, Stevie
Wonder, The Temptations and The Miracles have also
been honored with their own stars!" added Martinez.
Martha Reeves has made her imprint in the
history books and in pop culture for her string of hit
Motown songs in the 1960's and early 1970's including
such hits as "Dancing in the Street," "My Baby Loves
Me", "Come and Get These Memories", "Nowhere to
Run", "Quick Sand", "(Love is Like a) Heatwave,"
"Jimmy Mack" and "Bless You," Martha was front
and center as the lead singer of the legendary Motown
girl group, Martha Reeves and the Vandellas.
Reh.App.23a
During the 1970's and 1980's Martha recorded as
a solo artist releasing a handful of critically acclaimed
albums on the MCA, Fantasy, Phonarama and ARISTA
labels. Her first solo album in 1974, the self-titled
classic was produced by legendary record producer,
Richard Perry.
While born in Alabama, Reeves moved to Detroit
with her family as a baby and has become a fixture
in the Motor City. She even served as an elected
councilwoman for the city from 2005 to 2009. In 2007
she fought to rename the road in front of Hitsville
USA on West Grand Blvd. (Now the Motown Museum)
Berry Gordy Jr. Boulevard after Motown's founder.
Martha continues to perform concerts and club
dates both solo and with the Vandellas (currently her
sisters, Lois and Delphine). Martha and the Vandellas
were Grammy nominated in 1964 for Best R&B
Performance for their hit, "Heat Wave". In 1999,
"Dancing in the Street" was inducted into the Grammy
Hall of Fame. She was inducted into the Rock and
Roll Hall of Fame in 1995 and is also the recipient of
the Dinah Washington Award, a Rhythm n' Blues
Foundation Pioneer Award, a Black Woman in Publishing Legends Award, and has been inducted in the
Alabama Soul, Rock and Roll and Vocal Group Hall
of Fame. Martha Reeves and the Vandellas are listed
among Rolling Stone magazine's 100 Immortal Artists
of all time.
2023 marked Martha's 60th anniversary of her
first two albums with Motown both from 1963, "Come
and Get These Memories" and "Heat Wave".
Reeves has been actively involved in charity work
with the Shriners and Boys Town, demonstrating her
Reh.App .24a
dedication to making a positive impact on the community through her philanthropic endeavors.
###
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This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.