The lawsuit is assigned to United States District Court Judge Amit Mehta, who recently ruled that TRUMP has no immunity from his inciting a riot on January 6, 2021.
Read full text of June 6, 2026 federal court lawsuit in Susan Douglas & Paul Romano v. National Park Service, et al:
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
SUSAN DOUGLAS,
PAUL ROMANO,
Plaintiffs,
v.
NATIONAL PARK SERVICE,
1849 C Street, NW
Washington, DC 20240,
JESSICA BOWRON, in her official capacity
as Acting Director of the National Park
Service,
Civil Action No. _________
1849 C Street, NW
Washington, DC 20240,
JEN NERSESIAN, in her official capacity as
Regional Director, National Capital Region,
National Park Service,
1100 Ohio Drive, SW
Washington, DC 20242,
UNITED STATES DEPARTMENT OF THE
INTERIOR,
1849 C Street, NW
Washington, DC 20240,
DOUG BURGUM, in his official capacity as
Secretary of the United States Department of
the Interior,
1849 C Street, NW
Washington, DC 20240,
Defendants.
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COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF
1. On June 14, 2026, for the first time in this nation’s history, a live sporting event will
be held on the White House grounds—or at least it will if President Donald J. Trump has his way.
Trump’s administration has authorized the Ultimate Fighting Championship (“UFC”), a mixed
martial arts promotion, to put on a night of cage fights on the South Lawn. The plan is for fighters
to conduct the ceremonial weigh-ins and face-offs at the Lincoln Memorial, make pre-fight
walkouts from the Oval Office, and do combat in a massive structure now under construction just
steps from the Executive Residence.
2. This plan is deeply corrupt. The event, billed as “UFC Freedom 250,” is (as the
name suggests) being organized by the UFC, whose chief executive, Dana White, is a close friend
and ally of the President. The President is giving White and his company what none have enjoyed
before: unfettered access to the White House and Lincoln Memorial to stage a private, for-profit
sports event, with all the promotional and branding opportunities that accompany such access.
3. The UFC is not being coy about the event’s pecuniary nature. One executive
recently called it “the greatest earned-marketing tool of all time.” And he is far from the only one
salivating at the business upside. Recent reporting has revealed that the UFC itself is selling VIP
packages for between $1 million and $1.5 million per head. Recent reporting likewise has revealed
that sponsors, like Singaporean cryptocurrency exchange Crypto.com, are clambering over each
other to see their brands plastered adjacent to the Executive Residence and Reflecting Pool. And
the UFC’s broadcast partner, Paramount Skydance—which is run by two other Trump allies, Larry
and David Ellison—has decided that no American will be able to take in this “celebration of
America” without first paying $8.99 plus tax for a Paramount Plus streaming subscription.
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4. Trump, too, has plans to benefit financially: Reporting published in late May
revealed that earlier this spring, he purchased up to $50,000 worth of stock in TKO, UFC’s owner.
5. The ostensible occasion for this spectacle is the semiquincentennial. Dana White
says that the aim is to “to celebrate the 250th birthday of America.” Although June 14, 2026, will
also be Trump’s 80th birthday, White has steadfastly maintained that the timing is just a
coincidence.
6. White has good reason to stick to his story. Federal law tightly restricts private use
of the national capital’s most sacred monumental spaces, which are national parklands. Under the
National Park Service’s (“NPS” or “Park Service”) usual permitting regime, no special events of
any sort, including any sporting events, may be held on the South Lawn or at the Lincoln Memorial.
Nor may structures be erected on the South Lawn without express authorization from Congress
and a thorough environmental review.
7. To authorize UFC Freedom 250 in the face of these constraints, Trump’s
administration appears to be relying on an NPS temporary rule enacted for the semiquincentennial.
Under that temporary rule, the Park Service may disregard its usual permitting regime and
authorize “special events planned, organized, and executed by executive departments and agencies
or the Semiquincentennial Commission for the celebration of the 250th anniversary of American
Independence” to occur on D.C.’s monumental grounds.
8. Plaintiffs bring this case because recent revelations, including in particular
reporting published on June 4, 2026, have made clear that UFC Freedom 250 does not satisfy the
conditions for authorization under the temporary rule. The event is neither “for the celebration of
the 250th anniversary of American Independence” nor, crucially, being “planned, organized, and
executed” by the federal government.
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9. Rather, UFC Freedom 250 is a private, for-profit sporting event being “planned,
organized, and executed” by the UFC, its broadcast partners, and its advertisers, not by the federal
government. And it is not in any material sense a “celebration of the 250th anniversary of American
Independence”
—it is, instead, a celebration of the UFC’s brand and the 80th anniversary of Donald
Trump’s birth. For these reasons, UFC Freedom 250 does not satisfy the strict conditions that must
be satisfied for special semiquincentennial events to occur on the South Lawn or at the Lincoln
Memorial.
10. Defendants’ decision authorizing the structures currently being erected to host UFC
Freedom 250 was likewise unlawful. In particular, the UFC is erecting a 92-foot-tall, 600-ton steel
structure it calls “the Claw” immediately adjacent to the Executive Residence, and is destroying
much of the South Lawn in the process.
11. Any erection of structures on national monumental grounds must be expressly
authorized by Congress, and, insofar as it constitutes a major federal action, must undergo
thorough National Environmental Policy Act (“NEPA”) review. No agency temporary rule may
displace these requirements, neither of which has been satisfied.
12. Plaintiffs are individuals who are being harmed by Defendants’ unlawful acts.
Plaintiff Susan Douglas is a senior citizen activist and organizer who is suffering aesthetic,
physical, expressive, and procedural harms as a result of Defendants’ unlawful acts. Plaintiff Paul
Romano is a Vietnam War veteran who is suffering aesthetic, dignitary, and procedural harms as a
result of Defendants’ unlawful acts.
13. Plaintiffs bring this case to seek judicial relief for their injuries, uphold the rule of
law, and protect our nation’s most cherished monuments from corrupt exploitation.
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PARTIES
14. Plaintiff Susan Douglas is a retired government employee, activist, organizer, and
resident of Alexandria, Virginia. She frequently organizes and attends protests and other events on
the National Mall, at the Lincoln Memorial, and near the White House, and has protested and
testified against alterations to DC’s monumental landscape.
15. Plaintiff Paul Romano is a retired Air Force Sergeant and veteran of the Vietnam
War, a former police officer with the Department of Defense, and a resident of Arlington, Virginia.
He frequently travels along the National Mall and past the White House and Lincoln Memorial as
part of his part-time work as a rideshare driver, and he has protested and testified against alterations
to DC’s monumental landscape.
16. Defendant National Park Service is a bureau within the United States Department
of the Interior. The Park Service administers the White House and President’s Park, the National
Mall, and the memorials of the National Capital Region, and is the agency responsible for issuing
special-event permits and commercial-use authorizations on those lands.
17. Defendant Jessica Bowron is the Acting Director of the National Park Service. The
Director is sued in her official capacity.
18. Defendant Jen Nersesian is the Regional Director of the National Capital Region of
the National Park Service, the official with immediate responsibility for permitting decisions
affecting the lands at issue. The Regional Director is sued in her official capacity.
19. Defendant United States Department of the Interior is the federal department within
which the Park Service sits and which holds ultimate authority over the administration of the lands
at issue.
20. Defendant Doug Burgum is the United States Secretary of the Interior. The
Secretary is sued in his official capacity.
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JURISDICTION AND VENUE
21. This Court has jurisdiction over this action under 28 U.S.C. § 1331 because the
claims alleged arise under the laws of the United States, including the Administrative Procedure
Act, 5 U.S.C. §§ 701–06; the National Park Service’s Organic Act, 40 U.S.C. § 8106; and the
National Environmental Policy Act, 42 U.S.C. § 4321 et seq.
22. This Court may grant declaratory and injunctive relief under 28 U.S.C. §§ 2201–
02, under 5 U.S.C. §§ 705–06, and as a matter of its inherent authority.
23. This Court has personal jurisdiction over Defendants, who are agencies and officers
of the United States sued in their official capacities pursuant to Federal Rule of Civil Procedure
4(i).
24. Venue is proper in this District under 28 U.S.C. § 1391(b) and (e). Defendants are
agencies and officers of the United States sued in their official capacities; a substantial part of the
events giving rise to Plaintiffs’ claims occurred in this District; and the real property that is the
subject of this action is situated in this District.
GENERAL ALLEGATIONS
I. The South Lawn, President’s Park, Lincoln Memorial, and the National Mall are
protected federal parklands at the symbolic heart of the Nation’s capital.
25. President’s Park comprises the White House and its grounds, including the South
Lawn, Lafayette Park, and the Ellipse, together with the surrounding sidewalks.
26. Despite its name, President’s Park does not belong to the President, and may not be
exploited as his whims dictate.
27. Rather, President’s Park is a unit of the National Park System administered by the
National Park Service.
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28. The National Mall and Lincoln Memorial are likewise administered by the National
Park System as a part of its National Mall and Memorial Parks group.
29. Like all national parklands, these cherished national spaces are held and managed
in trust for the public.
30. Under the National Park Service’s Organic Act, the Service must manage the lands
in its care so as to “conserve the scenery, natural and historic objects, and wild life in the System
units and to provide for the enjoyment of the same in such manner and by such means as will leave
them unimpaired for the enjoyment of future generations.” 54 U.S.C. § 100101(a).
II. Federal law and NPS regulations strictly limit private use of the Capital’s national
monumental spaces.
31. To preserve the sanctity and character of Washington’s national monumental
spaces, including President’s Park and the Lincoln Memorial, federal law and regulations strictly
limit their uses.
32. First, under 36 C.F.R. § 7.96, the Park Service’s overarching regulation for the
National Capital Region (the “Capital Region Regulation”), strict permitting restrictions apply to
“special events,” a defined term that includes all “sports events.” 36 C.F.R. § 7.96(g)(1)(ii).
33. In general, “special events may be held only pursuant to a permit issued in
accordance with [the Capital Region Regulation].” 36 C.F.R. § 7.96(g)(2).
34. With respect to “the White House area,” “[n]o permit may be issued authorizing
special events” unless the event (i) is held at the Ellipse or (ii) is the annual commemorative
wreath-laying ceremony in Lafayette Park. 36 C.F.R. § 7.96(g)(3)(i).
35. The Capital Region Regulation defines the “White House area” as the area bounded
by Constitution Ave. NW to the south, H St. NW to the north, 15th St. NW to the east, and 17th
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St. NW to the west. 36 C.F.R. § 7.96(g)(1)(iv). Those boundaries encompass the entirety of
President’s Park, including the South Lawn.
36. With respect to the Lincoln Memorial “special events are not allowed” under any
circumstances, with the single exception of the “official annual commemorative Lincoln birthday
ceremony.” 36 C.F.R. § 7.96(g)(3)(ii)(B).
37. Permits for special events are issued by the Regional Director. 36 C.F.R.
§ 7.96(g)(3), (5)(v). The Regional Director is required to base the determination to issue a permit
on, among other criteria, “[w]hether the activities contemplated for the proposed special event are
in conformity with all applicable laws and regulations.” 36 C.F.R. § 7.96(g)(5)(v)(E).
38. Under the Capital Region Regulation, certain “temporary structures” may be
erected “in connection with permitted… special events,” but such structures must satisfy strict
purpose, preservation, and durational requirements. 36 C.F.R. § 7.96(g)(5)(vi).
39. Second, under 40 U.S.C. § 8106, a provision of the Park Service’s Organic Act, no
“building or structure” may be “erected” on “any reservation, park, or public grounds of the
Federal Government in the District of Columbia” except insofar as authorized by Congress.
40. Third, under the National Environmental Policy Act (“NEPA”), 42 U.S.C.
§ 4332(2)(C), before undertaking any “major Federal action significantly affecting the quality of
the human environment,” the responsible official must prepare either an environmental assessment
or a more comprehensive environmental impact statement.
41. A “major Federal action” is any action that the responsible agency “determines is
subject to substantial Federal control and responsibility.” 42 U.S.C. § 4336e(10)(A). When “the
level of federal involvement in [a] nonfederal project amounts to the creation of a joint venture or
partnership between the federal agency and a non-federal entity, federal courts have considered
8Case 1:26-cv-02016 Document 1 Filed 06/06/26 Page 9 of 35
the arrangement to be a major federal action.” Sierra Club v. DOA, 777 F. Supp. 2d 44, 60 (D.D.C.
2011).
III. A Park Service temporary rule exempts certain government-run “America250”
events from usual regulatory requirements—but only those events, and without
displacing limits on erection of structures or waiving environmental review.
42. On June 17, 2025, NPS published a temporary rule titled “National Capital Region;
America250 Events.” 90 Fed. Reg. 25,498 (June 17, 2025) (RIN 1024-AF06; Docket NPS-2025-
0004) (the “America250 Rule”).
43. The America250 Rule rests on Executive Order 14189 (Jan. 29, 2025), titled
“Celebrating America’s 250th Birthday.”
44. The America250 Rule purports to exempt certain semiquincentennial events from
limits in the Capital Region Regulation.
45. To create that exemption, the America250 Rule added a new subsection, 36 C.F.R.
§ 7.96(g)(8), to the Capital Region Regulation (the “America250 Exemption”).
46. As relevant here, the America250 Exemption provides: “The restrictions,
limitations, closures, prohibitions, priority use designations, and other requirements for special
events . . . do not apply to the ‘America250’ events, which are those special events planned,
organized, and executed by executive departments and agencies or the Semiquincentennial
Commission for the celebration of the 250th anniversary of American Independence.”
47. The America250 Exemption provides a table of requirements affected. Among
other items, that table includes “[t]he prohibition on issuing permits for special events in the White
House area,” “[t]he prohibition on issuing permits for special events within portions of the
Washington Monument, Lincoln Memorial, Jefferson Memorial, and Vietnam Veterans
Memorial,” and “[r]estrictions on the placement of stages and sound amplification equipment at
the Vietnam Veterans Memorial.”
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48. By its plain terms, the America250 Exemption applies only to America250 events
that are “planned, organized, and executed by executive departments and agencies or the
Semiquincentennial Commission.”
49. By its plain terms, the America250 Exemption applies only to events “for the
celebration of the 250th anniversary of American Independence.”
50. In other words, the Exemption does not reach events planned, organized, or
executed by private parties. Nor does it reach events held for private commercial purposes, or for
that matter, for any purposes other than celebration of the semiquincentennial.
51. The America250 Rule does not purport to displace the congressional authorization
requirement for erected structures under 40 U.S.C. § 8106—nor could it, as a temporary rule may
not contradict a duly enacted federal statute.
52. The America250 Rule also does not waive the requirements of the National
Environmental Policy Act.
53. To the contrary, the National Park Service has confirmed that each permit issued
under the Rule “will be subject to the appropriate NEPA process at that time,” and has claimed a
categorical exclusion for the Rule itself on the ground that the Rule “do[es] not directly authorize
any activity.” The obligation to conduct NEPA review therefore attaches to each individual special
event permit.
IV. The Ultimate Fighting Championship is a mixed martial arts promotion that holds
live-action cage-fighting events.
54. Mixed martial arts (“MMA”) is a combat sport that combines elements of boxing,
kickboxing, clinch fighting, stand-up grappling (particularly American folkstyle wrestling),
ground grappling (particularly Brazilian jiu jitsu), and ground strikes.
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55. An MMA bout may conclude in one of several ways. During live action, a fighter
may lose by knockout (when rendered unconscious or otherwise incapacitated), by technical
knockout (when, in the referee’s or the ringside doctor’s judgment, the fighter has suffered too
much damage to safely continue fighting), or by submission (when the fighter taps out to avoid
being choked unconscious or injured by a joint lock).
56. If an MMA fight does not conclude in one of those ways, its outcome is decided by
ringside judges who pick a winner, most often by using a round-by-round “10-point must” system.
Professional MMA fights are typically scheduled for three five-minute rounds, except for title
fights, which are typically scheduled for five five-minute rounds.
57. MMA is notably not a form of scripted professional wrestling. The action—and the
damage inflicted by and on the fighters—is entirely real.
58. The Ultimate Fighting Championship, or UFC, is one of several American MMA
promotion companies, and by far the largest in terms of market share.
59. The UFC is owned and controlled by TKO Group Holdings, Inc. (“TKO”), a
publicly traded corporation that also owns World Wrestling Entertainment, a professional wrestling
company.
60. The UFC holds its fights inside its proprietary “Octagon,” an octagonal cage made
out of six-foot-tall vinyl-coated chain-link fencing. During active fighting, only the two fighters
and a referee, who may stop the fight, are allowed inside the Octagon.
V. President Trump has arranged for the UFC to stage an event on the White House
South Lawn on his 80th birthday.
61. This case arises because President Trump has arranged for the UFC to stage an
MMA event on the South Lawn of the White House.
62. That event, styled “UFC Freedom 250,” is scheduled for Sunday, June 14, 2026.
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63. The fight card is scheduled to feature seven MMA bouts, culminating with two title
fights. The fighters competing in those two “main event” bouts will start their walkouts inside the
Oval Office itself.
64. UFC President and CEO Dana White is a longtime friend and ally of Trump’s, and
introduced Trump before Trump’s speech to the 2024 Republican National Convention. Trump,
for his part, routinely attends UFC events as White’s guest.
65. June 14 happens to be Trump’s 80th birthday.
66. Despite the notable date, and notwithstanding his intimate relationship with Trump,
White has stridently denied that UFC Freedom 250 is meant to be a birthday celebration for the
President. Instead, White has presented the event as a celebration of “the 250th birthday of
America.”
67. White has, however, admitted that the event was “Trump’s idea.”
68. A review of past event dates suggests that the UFC overwhelmingly holds its
domestic events on Saturday nights, not Sunday nights. This is not surprising—UFC events often
end well after midnight Eastern time. Accordingly, the UFC has not held a Sunday night event in
the United States in nearly seven years. The last such event would appear to be “UFC on ESPN:
Ngannou v. Velasquez,” which aired on Sunday, February 17, 2019.
69. July 4, 2026, is a Saturday on a holiday weekend, and, unlike Sunday, June 14, is
America’s actual “250th birthday.” Yet the UFC is not holding an event on that date, whether at
the White House or anywhere else.
VI. The UFC is constructing a massive structure on the South Lawn of the White House.
70. On May 26, 2026, the UFC began constructing a massive structure to house the
UFC Freedom 250 event on the White House South Lawn:
12Case 1:26-cv-02016 Document 1 Filed 06/06/26 Page 13 of 35
The Claw under construction
71. White has referred to this structure as “the Claw.”
72. The Claw, which is constructed primarily out of steel, is 92 feet tall, 154 feet wide,
and weighs 600 tons.
73. The White House Executive Residence, by contrast, is only 70 feet tall at its highest
point. The Claw thus dwarfs the adjacent White House. It is visible from the National Mall to the
south.
74. The Claw’s principal function is to house the Octagon and provide anchor points
for cameras and lighting. It will serve no obvious function once the event has concluded.
75. Nevertheless, on June 3, 2026, President Trump posted a video on TikTok in which
he suggested that the Claw may “never” be taken down. Trump analogized the Claw to Paris’s
Eiffel Tower, which, in his words “was supposed to be taken down immediately after the World’s
Fair, and then they said, you know, we sort of like it.”
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76. To facilitate construction and other preparations for the event, the Park Service has
imposed a 36 C.F.R. § 1.5 temporary closure of “the Ellipse and its side panels, roadways and
sidewalks, E Street and its sidewalks between 15th-17th Streets, First Division Monument and
State Place, Sherman Park, Hamilton Place, and the White House Sidewalk and Lafayette Park.”
That closure went into effect on May 20 and will remain in place until June 28.
77. Construction of the Claw, and other facilities for the event, is causing significant
damage to the White House grounds. White has estimated that it will cost $700,000 to repair the
South Lawn alone.
78. On information and belief, the Park Service has not prepared an environmental
assessment or environmental impact statement to assess the resulting damage. Plaintiffs have not
been able to identify any such assessment on any public docket.
VII. The UFC plans to hold the UFC Freedom 250 weigh-ins at the Lincoln Memorial.
79. Along with the nearby war memorials and Arlington National Cemetery, the
Lincoln Memorial is one of the American republic’s most sacred monuments.
80. The Memorial’s dedication statement, inscribed directly over President Lincoln’s
statue, reads, “In this temple, as in the hearts of the people, for whom he saved the Union, the
memory of Abraham Lincoln is enshrined forever.”
81. The Memorial’s South Chamber is inscribed with Lincoln’s Address at Gettysburg,
which closes with the promise that “government of the people, by the people, for the people, shall
not perish from the Earth.”
82. The Memorial’s North Chamber is inscribed with Lincoln’s Second Inaugural
Address, which closes with Lincoln’s exhortation to a war-weary nation: “With malice toward
none, with charity for all, with firmness in the right as God gives us to see the right, let us strive
on to finish the work we are in, to bind up the nation’s wounds, to care for him who shall have
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borne the battle and for his widow and his orphan, to do all which may achieve and cherish a just
and lasting peace among ourselves and with all nations.”
83. The Memorial’s eighteenth step bears a marker indicating the precise spot from
which Dr. Martin Luther King Jr. delivered his “I Have a Dream” oration during the 1963 March
on Washington.
84. The Lincoln Memorial is part of a larger commemorative complex that also
includes the Vietnam Veterans Memorial—a monument to the American fallen in another war—
located just over a thousand feet away.
85. Taken as a whole, the Memorial is a solemn and moving homage to this nation’s
greatest president, to the millions of soldiers who died to preserve the Union during the Civil War,
and to the emancipation of Black Americans from slavery.
86. Many descriptors might be applied to a UFC weigh-in. “Solemn” and “moving” are
not among them.
87. Instead, because each fighter faces off with his opponent just after weighing in, the
events tend to be raucous, profane, and sometimes violent affairs.
88. For instance, just a few weeks ago, at the UFC 328 weigh in, Sean Strickland called
his opponent Khamzat Chimaev a “son of a whore” and a “bitch.”
89. At UFC 229, Conor McGregor lunged and then threw a kick at his opponent,
Khabib Nurmagomedov. McGregor later referred to Nurmagomedov as a “mad backwards c---”
and taunted Nurmagomedov’s Muslim faith by offering him whiskey.
90. And at UFC 178, after Daniel Cormier shoved Jon Jones prior to their light
heavyweight title fight, a brawl broke out and spilled into the crowd.
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91. The UFC has announced that it will be holding the UFC Freedom 250 ceremonial
weigh-ins and face-offs on the evening of June 13 at the Lincoln Memorial.
92. On information and belief, Defendants have authorized or otherwise allowed the
UFC to use sound equipment as part of the UFC Freedom 250 ceremonial weigh-ins.
93. On information and belief, the UFC intends to use such sound amplification
equipment at a level that will be audible at the Vietnam Veterans Memorial.
VIII. Reporting published on June 4, 2026 reveals that the UFC Freedom 250 event is not
being planned, organized, and executed by any executive agency, department, or the
Semiquincentennial Commission.
94. No executive department or agency is playing a significant role in the planning,
organizing, and executing of UFC Freedom 250.
95. The UFC selected, hired, and, announced the fighters; designed and is supervising
installation of the physical facilities; and will in every material sense execute the festivities on the
nights of June 13 and 14.
96. The only arguable exception will be security, which the Secret Service is
coordinating for all semiquincentennial events. But neither the Secret Service nor any other agency
or department is responsible for the substance of the event.
97. Most damningly, reporting published on June 4, 2026, has established that no
official semiquincentennial commission is planning, organizing, and executing the event, either.
98. There are currently two entities competing for the role of America’s official
semiquincentennial commission.
99. The first, and the one with by far the stronger claim, is the congressionally
authorized commission known colloquially as “America 250.” This is the commission identified
by name in the America250 temporary rule.
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100. The second is a public-private partnership created pursuant to executive order,
known as “Freedom 250.”
101. Freedom 250 is not an official commission; it is instead a “wholly owned
subsidiary” of the National Park Foundation, the National Park Service’s official, congressionally
chartered charity.
102. Previously, Freedom 250 was understood to be the organizing entity responsible for
UFC Freedom 250. For instance, reporting published by USA Today on June 2, 2026, suggested
as much.
103. But reporting published by MS Now on June 4, 2026, revealed otherwise. A
Freedom 250 spokesperson quoted in that reporting “said the White House fight, billed as ‘UFC
Freedom 250,’ is not affiliated with the organization and shares only its branding.”
104. In other words, not even the more legally dubious of the two semiquincentennial
commissions is responsible for planning, organizing, or executing UFC Freedom 250. The event
is, in formal terms, a private undertaking.
IX. The UFC Freedom 250 event is being planned, organized, and executed with all the
hallmarks of a private, for-profit sporting event.
105. In substance as well as formally, UFC Freedom 250 is being planned and operated
as a private, profit-motivated sports promotion.
106. The event is privately financed. Reports have estimated the cost of the event to be
around $60 million. But the UFC has denied that any taxpayer dollars are being spent to front those
costs. White, in particular, has claimed that the UFC is “eating the whole thing,” and that he is
“spending a shitload of money.”
107. Despite White’s claims to the contrary, the event will likely be profitable for UFC
and its partners. White has estimated that the UFC will lose “$30 million” on the event. But recent
17Case 1:26-cv-02016 Document 1 Filed 06/06/26 Page 18 of 35
reporting indicates that the event capacity will be over 4,000, and that the UFC will control up to
a third of the seats. (Another third will be allocated to White House personnel and families. The
remaining third of seats will be available to servicemembers—for free, but only so long as they
have a “waist-to-height ratio under 0.55” and satisfy various other “fitness test” requirements.)
108. The UFC has denied that it is selling any of its share of 1,300 seats. But recent
reporting indicates that the UFC is offering “sponsorship packages” priced at between $1 and $1.5
million per head. “Sponsors” reportedly will receive access to the White House event—i.e., a
seat—VIP access to weigh ins and press conferences, admission to a pre-fight concert by the Zac
Brown Band, and may also receive access to parts of the White House complex of buildings.
Sponsorship packages notably have not been reported to include any conventional sponsorship
benefits, such as advertising or promotional opportunities. The packages thus appear to be dressed
up (and extraordinarily expensive) tickets.
109. If the event’s reported $60 million cost is accurate, the UFC would need to sell just
40 of its $1.5 million “sponsorship packages” to break even—without even accounting for its many
other sources of revenue, such as advertising or broadcaster incentives.
110. Beyond direct profits, the UFC is openly boasting about the enormous long-term
commercial benefits it will realize from hosting an event at two of the Nation’s most iconic
monuments. Mark Shapiro, the President of UFC’s parent company, TKO, recently remarked:
“This is the greatest earned-marketing tool of all time. It’s a once-in-a-generation moment. The
kind of attention, awareness, and sampling we’re going to get from audiences around the world,
on that day alone, will be more than we could get in an entire year.”
111. The UFC’s principal American broadcast partner also stands to benefit. The UFC
recently sold seven years of its broadcast rights to Paramount Skydance Corp., CBS’s parent
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company, for $7.7 billion. UFC cards typically feature both a preliminary card, with up-and-
coming fighters, and a main card, with more established fighters competing to move up the
rankings or, at major events, for a championship belt. The preliminary and main cards are often
broadcast on different platforms. In the case of UFC Freedom 250, reporting indicates that some
preliminary fights will be broadcast to the general public on CBS. But the much more high-profile
main card, featuring two championship fights, will be available only on Paramount’s subscription
streaming platform, Paramount Plus.
112. Paramount Plus subscriptions start at $8.99 per month. UFC Freedom 250 thus
provides Paramount with a banner opportunity to begin recouping some of its extraordinary outlay
for UFC broadcast rights.
113. Advertisers, too, stand to benefit.
114. UFC events typically feature prominent advertiser branding on the Octagon floor
and side padding. The cage at UFC’s May 9, 2026 event in Newark, New Jersey, was typical. It
featured advertising for Monster (an energy drink), Polymarket (a prediction market), Stake (a
gambling platform), Aviator (a video game), and at least five separate alcohol brands, among other
brands:
19Case 1:26-cv-02016 Document 1 Filed 06/06/26 Page 20 of 35
The Octagon floor at UFC 328
115. Similar advertisements run at weigh ins. At the “UFC Vegas 118” weigh-in in June,
2026, advertisements for Paramount, Meta, and MMA Junkie prominently appeared behind the
fighters.
Weigh-in advertisements at UFC Vegas 118
20Case 1:26-cv-02016 Document 1 Filed 06/06/26 Page 21 of 35
116. At UFC Freedom 250, the UFC’s advertisers will have the opportunity to have such
advertising prominently displayed in immediate proximity to the White House. These advertisers
will similarly have the chance to promote themselves at the weigh-in at the Lincoln Memorial.
117. In particular, one of UFC Freedom 250’s lead branding partners is Crypto.com, the
Singaporean cryptocurrency exchange. Crypto.com has announced that it will be providing the
cryptocurrency equivalent of $1 million in performance bonuses to fighters. And Crypto.com’s
logo has been splashed across materials promoting the event—materials that are not subtle about
exploiting the White House imagery for commercial purposes:
Crypto.com promotional materials for UFC Freedom 250
118. In sum, the UFC, its parent company TKO, its broadcast partner Paramount, and its
advertisers are all treating UFC Freedom 250 like they would any other UFC event: as a business
opportunity—or as the President of TKO, put it, as “the greatest earned-marketing tool of all time.”
21Case 1:26-cv-02016 Document 1 Filed 06/06/26 Page 22 of 35
119. The hallmarks of a for-profit sporting spectacle pervade the event: VIP access
offered at premium prices, broadcast on a subscription-only commercial streaming platform, a
private corporate promoter, private financing of the buildout, and private receipt of the proceeds.
120. Trump will also profit from a successful UFC Freedom 250: according to reporting
published in late May, he purchased up to $50,000 worth of TKO stock earlier this spring.
X. By authorizing UFC Freedom 250’s use of the South Lawn and Lincoln Memorial,
the associated access restrictions and closures, and the erection of the Claw—all
without congressional authorization or environmental review—Defendants have
injured plaintiffs.
121. Defendants have authorized UFC Freedom 250 pursuant to the America250
Exemption. That authorization encompasses the event’s use of the South Lawn and Lincoln
Memorial; the ongoing associated construction, including the Claw; and the resulting park and
road closures and access restrictions.
122. As set forth above and below, such authorization is unlawful in several respects.
123. Through their unlawful authorization decisions, Defendants have injured and are
injuring Plaintiffs.
A. Plaintiff Susan Douglas
124. Defendants’ actions have inflicted and continue to inflict aesthetic, physical,
expressive, and procedural injuries on Plaintiff Douglas.
125. Douglas moved to Washington, DC in 1969, attended high school in the District
and college at American University. She worked for several years in the intelligence community,
and lived in Germany for a time in connection with that work, but has otherwise lived exclusively
in the Washington, DC area for over 50 years. She currently lives in Alexandria, Virginia, and is
retired.
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126. Over her decades of residency in the DC region, Douglas has very frequently visited
President’s Park and the Lincoln Memorial. She cherishes those spaces for their aesthetic beauty
and powerful symbolism of the American ideal of, in President Lincoln’s words, “government of,
by, and for the people.”
127. In her retirement, Douglas has devoted herself to activism and organizing, including
in particular activism and organizing aimed at preserving the physical beauty and cultural sanctity
of the national capital and its monuments. As part of her organizing and activism work, Douglas
has helped to plan and organize, and has participated in, a number of recent protests and other
actions near the White House and Lincoln Memorial.
128. On October 24, 2025, Douglas protested the illegal destruction of the East Wing
outside the White House. On February 11, 2026, Douglas attended the Walk for Peace at and
around the Lincoln Memorial, and served for five hours as a volunteer safety marshal. On March
22, as part of planning for the No Kings 3 protest, Douglas helped to scout a protest march route
from Memorial Bridge to the Lincoln Memorial, on to Constitution Gardens, and then passing by
the White House to access the DC Metro. On March 28, Douglas joined 8,000 others in marching
that route for the No Kings 3 protest, which included stopping at the Lincoln Memorial and taking
pictures in front of its iconic façade. On April 7, Douglas protested the illegal war in Iran outside
the White House. On May 1, Douglas attended the May Day Free DC protest at the Washington
Monument, and marched holding a large canvas replica of the U.S. Constitution. On May 21,
Douglas testified against the Memorial Bridge Triumphal Arch at a Commission on Fine Arts
Meeting. From May 24 to 26, Douglas participated in a three-day vigil at the Watergate Steps,
across from the Lincoln Memorial, to protest the Arch.
23Case 1:26-cv-02016 Document 1 Filed 06/06/26 Page 24 of 35
129. Douglas also visited other parts of downtown DC, including the National Mall,
Capitol, and Supreme Court areas, for protests or other activist work on April 1, April 24, May 20,
June 2, and June 4.
130. All in all, Douglas has visited the White House and National Mall areas at least one
time per week since this spring, before construction for UFC Freedom 250 began.
131. Douglas has firm, concrete plans to visit President’s Park and the Lincoln Memorial
in coming weeks. On June 8, Douglas will attend the Moral Monday protest adjacent to the White
House. On June 9, Douglas will be in the White House area to do scouting and preparation work
for a protest planned for June 14. On the evening of June 13, Douglas will walk across the
Memorial Bridge to the Lincoln Memorial to protest President Trump, his disfigurement of the
National Mall, and the UFC Freedom 250 weigh-ins. And on June 14, President Trump’s birthday,
Douglas will attend an anti-Trump protest she is currently planning and organizing. She has been
engaged in planning that protest for two weeks.
132. During her recent past visits to the White House and National Mall, Douglas has
observed the construction connected with UFC Freedom 250, including in particular the so-called
“Claw” currently being erected on the South Lawn. She expects to observe the same structures
during her planned future visits on at least June 8, 9, 13, and 14.
133. For Douglas, the erection of those structures, particularly the Claw, is disfiguring
the iconic memorial landscape of downtown Washington, DC. Douglas has observed that the Claw
dwarfs the adjacent White House and is visible from the National Mall. Douglas finds the Claw
aesthetically hideous, and its erection next to the White House grotesque, particularly when
juxtaposed with the now-ruined East Wing.
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134. The erection of the Claw and other structures for UFC Freedom 250 is causing and
will continue to cause Douglas aesthetic injury by diminishing the personal enjoyment, experience
of beauty, and feelings of national pride she previously experienced when observing the White
House. Douglas similarly anticipates that the erection of structures for the weigh-ins at the Lincoln
Memorial will cause her aesthetic injury when she visits that Memorial on the evening of June 13.
135. Douglas travels to and around downtown Washington by Metro and on foot.
136. Douglas is nearly 70 years old, and has painful osteoarthritis in both knees. Last
year, she underwent 6 months of physical therapy for her knees, and received injections of
Orthovisc to replace lost cartilage. Her medical providers have informed her that she should expect
to have one or both knees replaced in coming years.
137. The UFC Freedom 250-related closures and access restrictions described above
have injured and will continue to injure Douglas by causing her to suffer physical pain. Those
access restrictions make it difficult to anticipate how best to navigate the National Mall and
President’s Park on any given day, and have caused her to have to take circuitous routes different
from those she had planned to reach her destination. She is committed to continuing her activist
and organizing work, notwithstanding the pain walking causes her, and the closures and access
restrictions will substantially magnify the pain she suffers.
138. The closures and access restrictions have also injured and will continue to injure
Douglas by burdening her activism and organizing work and free expression. In particular, as part
of the protests she organizes, she and other activists routinely employ props—for instance, the
canvass replica of the Constitution used for the May Day protest. For the June 14 protest, she and
other activists intend to display caricature-style papier mâché figures of President Trump, Defense
Secretary Hegseth, and other administration figures inside a bamboo “cage.” Alongside that
25Case 1:26-cv-02016 Document 1 Filed 06/06/26 Page 26 of 35
display, they plan to erect a sign reading “The only cage we need.” Such props help them to send
a more powerful, effective symbolic message by attracting significant public and media attention.
For instance, their props were photographed and published by several news outlets after the No
Kings 3 protest.
139. The UFC Freedom 250 closures and access restrictions are making it far more
difficult to plan for and execute transportation of large props on foot. Those props are heavy and
are already difficult to move because of Douglas’s osteoarthritis. The access restrictions have
significantly increased the difficulty, burdening her ability to organize and engage in First
Amendment-protected expression.
140. Douglas has personally participated in opportunities to comment publicly on
projects that affect the physical and cultural landscape of downtown Washington. For instance, on
June 4, she testified at a hearing on the planned Triumphal Arch at the National Capital Planning
Commission.
141. Had there been an opportunity to testify or otherwise provide public comment in
opposition to UFC Freedom 250, including in particular its disfigurement of the White House
façade and destruction of the White House South Lawn, Douglas would have done so.
142. Defendants’ failure to provide an opportunity for Douglas and other members of
the public to provide such public comment has inflicted a procedural injury on Douglas.
B. Plaintiff Paul Romano
143. Defendants’ actions have inflicted and continue to inflict dignitary, aesthetic, and
procedural injuries on Plaintiff Romano.
144. Romano is a Vietnam War veteran, and served in the United States Air Force from
1969 through 1973 as a medevac crew member. He retired as a Sergeant.
26Case 1:26-cv-02016 Document 1 Filed 06/06/26 Page 27 of 35
145. After leaving the military, Romano attended college, worked in private industry,
and served as a police officer for the Department of Defense. As part of that latter work, from 2011
to 2012, he was assigned to drive civilian, military, and intelligence personnel throughout
Afghanistan. He is now largely retired, volunteers, and drives for a ride-sharing company.
146. Romano’s family moved to Arlington, Virginia in 1961. Since then, with the
exception of military service in Vietnam and Afghanistan, he has lived in the Washington, DC area.
He has been active in his community, and previously ran for the Fairfax County Board of
Supervisors. He ran as a Republican.
147. In his current work as a ride-share driver, and to visit family, Romano drives along
the National Mall and past the Lincoln Memorial several times a week. He believes that the
monuments there, including the Vietnam Veterans Memorial and the Lincoln Memorial, are sacred
spaces.
148. In particular, the Vietnam Veterans Memorial honors several men Romano knew
personally, grew up with, and went to school with, who were killed in that war. He has visited the
Memorial twice, and has found both visits to be enormously difficult emotionally.
149. Romano considers the Vietnam Veterans Memorial’s quiet tranquility to be among
its most moving and powerful features. That tranquility both honors the fallen and allows those
who have come to pay their respects an opportunity to reflect and remember without interruption.
150. Romano understands that the UFC Freedom 250 weigh-ins are likely to be loud,
due both to their nature and the likely use of sound amplification equipment. The weigh-ins are
therefore likely to disturb the tranquility of the Vietnam Veterans Memorial, which is located not
far away in the same monumental complex.
27Case 1:26-cv-02016 Document 1 Filed 06/06/26 Page 28 of 35
151. Romano considers such disturbance of the Vietnam Veterans Memorial’s otherwise-
permanent and legally mandated tranquility to be a grave desecration.
152. Defendants, by authorizing UFC Freedom 250 to use the Lincoln Memorial for
purposes that will disturb the Monument’s tranquility, have accordingly inflicted a dignitary injury
on Romano.
153. Romano also cherishes the Lincoln Memorial itself as a moving and powerful
tribute to the servicemembers who fell in the Civil War.
154. In part because of his appreciation for the Lincoln Memorial, Romano has spoken
out against and protested the planned Memorial Bridge Triumphal Arch, which in Romano’s view
will interrupt and deface the physical landscape currently defined by the Lincoln Memorial on one
end and Arlington National Cemetery on the other. On June 4, Romano testified at the National
Capital Planning Commission in opposition to the Arch.
155. Romano considers the Lincoln Memorial’s use for a private, for-profit sporting
event to be both an aesthetic travesty and an offense to his dignity, that of other service members,
and the monument itself.
156. As part of his work as a driver, Romano has driven by the “Claw” structure under
construction on the White House lawn ten to fifteen times.
157. Romano finds the Claw aesthetically and symbolically disgusting. Its presence on
the South Lawn ruins what is otherwise one of the most enjoyable parts of his work as a driver:
the opportunity to appreciate the aesthetic beauty and coherence of President’s Park, the White
House, and the monuments on the National Mall as he drives by them.
158. Defendants, by authorizing UFC Freedom 250 and the Claw, have accordingly
inflicted aesthetic injury on Romano.
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159. Romano has not been afforded an opportunity to testify about UFC Freedom 250,
the Claw and associated construction, or the weigh-in at the Lincoln Memorial. Romano would
have testified given the opportunity.
160. Defendants’ failure to provide an opportunity for Romano and other members of
the public to provide such testimony or public comment has inflicted a procedural injury on
Romano.
COUNT I
VIOLATION OF NPS REGULATIONS
Capital Region Regulation, 36 C.F.R. § 7.96; Administrative Procedure Act, 5 U.S.C. § 706
Plaintiffs incorporate all allegations set forth above and below as though set forth
161. in this paragraph.
162. The National Park Service and the Department of the Interior are “agenc[ies]”
within the meaning of 5 U.S.C. § 551(1).
163. Defendants’ decisions authorizing UFC Freedom 250’s fights to occur on the South
Lawn and the weigh in to occur at the Lincoln Memorial, and authorizing the associated
construction of event facilities, including in particular the Claw, are final agency actions subject
to judicial review under 5 U.S.C. §§ 702, 704, and 706.
164. Under the Capital Region Regulation, special events, including specifically any and
all athletic events, may be held in President’s Park or the Lincoln Memorial only pursuant to a
valid permit issued by the Regional Director. 36 C.F.R. § 7.96(g)(2).
165. The UFC Freedom 250 event at the White House and the Lincoln Memorial weigh-
in do not satisfy the Capital Region Regulation’s usual criteria for a special event permit to issue.
Among other issues, the Regulation authorizes special sporting events only on the Ellipse, not the
South Lawn, and does not authorize special sporting events at the Lincoln Memorial under any
circumstances.
29Case 1:26-cv-02016 Document 1 Filed 06/06/26 Page 30 of 35
166. Accordingly, Defendants’ authorization decisions necessarily rested on the
America250 Exemption set forth in 36 C.F.R. § 7.96(g)(8).
167. That Exemption extends only to “special events planned, organized, and executed
by executive departments and agencies or the Semiquincentennial Commission for the celebration
of the 250th anniversary of American Independence.”
168. The UFC Freedom 250 event is not being “planned, organized, and executed by
executive departments and agencies or the Semiquincentennial Commission.”
169. Rather, both formally and in all practical terms, UFC Freedom 250 is a private, for-
profit fight promotion planned, organized, and executed by a private company. As set forth above,
the UFC, its broadcast partner, and its advertisers are planning, organizing, and executing all
material aspects of the event except security.
170. The UFC Freedom 250 event also is not being held “for the celebration of the 250th
anniversary of American Independence.” Rather, UFC Freedom 250 is being held for the financial
benefit of the UFC, Paramount, and their advertisers, and to celebrate the 80th anniversary of
Donald Trump’s birth.
171. Accordingly, Defendants’ determination that UFC Freedom 250 qualifies for the
America250 Exemption was arbitrary, capricious, an abuse of discretion, and in excess of
authority, because it disregarded the event’s plainly commercial and private character and the
regulation’s plain text.
172. Absent the Exemption, the categorical prohibitions of 36 C.F.R. § 7.96(g)(3) and
the limits of § 7.96(g)(5) both apply, meaning that no permit may lawfully issue to hold a sporting
event on either the South Lawn or at the Lincoln Memorial.
30Case 1:26-cv-02016 Document 1 Filed 06/06/26 Page 31 of 35
173. Defendants’ action nonetheless authorizing the event was therefore “arbitrary,
capricious, an abuse of discretion,” “not in accordance with law,” and “in excess of statutory
jurisdiction, authority, or limitations,” within the meaning of 5 U.S.C. § 706(2)(A) and (C).
174. Defendants’ unlawful action has injured and will injure Plaintiffs as set forth above.
175. Plaintiffs are entitled to an order holding unlawful and setting aside Defendants’
illegal permitting decision.
COUNT II
ERECTING OF STRUCTURES ON FEDERAL PARKLAND WITHOUT
CONGRESSIONAL AUTHORIZATION
Park Service Organic Act, 40 U.S.C. § 8106; Administrative Procedure Act, 5 U.S.C. § 706
176. Plaintiffs incorporate all allegations set forth above and below as though set forth
in this paragraph.
177. The National Park Service and the Department of the Interior are “agenc[ies]”
within the meaning of 5 U.S.C. § 551(1).
178. Defendants’ decisions authorizing the construction of UFC Freedom 250 event
facilities, including in particular the Claw, are final agency actions subject to judicial review under
5 U.S.C. §§ 702, 704, and 706.
179. Under 40 U.S.C. § 8106, a provision of the Park Service’s Organic Act, no structure
may be erected on the public grounds of the District of Columbia under the charge of the National
Park Service except as expressly authorized by Congress.
180. The Claw is a structure.
181. The Claw has been erected on the South Lawn of the White House.
182. Congress has not authorized erection of the Claw on the South Lawn of the White
House.
31Case 1:26-cv-02016 Document 1 Filed 06/06/26 Page 32 of 35
183. Congress has not authorized permanent installation of the Claw on the South Lawn,
as Trump has indicated may be his intention.
184. By authorizing the erection of the Claw without congressional authorization,
Defendants acted contrary to 40 U.S.C. § 8106, and therefore “not in accordance with law” and
“in excess of statutory jurisdiction, authority, or limitations,” within the meaning of 5 U.S.C.
§ 706(2)(A) and (C).
185. Defendants’ unlawful action has injured and will injure Plaintiffs as set forth above.
186. Plaintiffs are entitled to an order holding unlawful and setting aside NPS’s
authorization, and enjoining the erection of the structures and the staging of the event.
COUNT III
(ALTERNATIVE COUNT)
FAILURE TO CONDUCT ENVIRONMENTAL REVIEW
National Environmental Policy Act, 42 U.S.C. § 4332;
Administrative Procedure Act, 5 U.S.C. § 706
Plaintiffs incorporate all allegations set forth above and below as though set forth
187. in this paragraph.
188. Plaintiffs plead this Count in the alternative to Count I, above.
189. The National Park Service and the Department of the Interior are “agenc[ies]”
within the meaning of 5 U.S.C. § 551(1).
190. Defendants’ permitting decision authorizing the construction of UFC Freedom 250
event facilities, including in particular the Claw, is a final agency action subject to judicial review
under 5 U.S.C. §§ 702, 704, and 706.
191. The National Environmental Policy Act requires a federal agency to prepare an
environmental impact statement, or at least an environmental assessment, before undertaking a
“major federal action” significantly affecting the quality of the human environment, unless a valid
categorical exclusion applies. 42 U.S.C. § 4332.
32Case 1:26-cv-02016 Document 1 Filed 06/06/26 Page 33 of 35
192. Plaintiffs’ lead claim, supra Count I, is that UFC Freedom 250 does not constitute
a federal action because it is a private, profit-motivated endeavor.
193. But alternatively, insofar as UFC Freedom 250 is deemed a public-private
partnership that may be authorized under the America250 Exemption, the event likewise
constitutes a major federal action subject to NEPA.
194. The America250 rule did not waive NEPA. To the contrary, it committed each
permit issued under 36 C.F.R. § 7.96(g)(8) to “the appropriate NEPA process at that time.”
195. On information and belief, Defendants authorized the event without an
environmental assessment or environmental impact statement.
196. By authorizing the event in the absence of the environmental review NEPA
requires, Defendants acted “without observance of procedure required by law” and “not in
accordance with law,” within the meaning of 5 U.S.C. § 706(2)(D) and (A).
197. Defendants’ unlawful action has injured and will injure Plaintiffs as set forth above.
198. Plaintiffs are entitled to an order holding unlawful and setting aside Defendants’
authorization pending compliance with NEPA.
COUNT IV
ULTRA VIRES AGENCY ACTION
Non-Statutory
Plaintiffs incorporate all allegations set forth above and below as though set forth
199. in this paragraph.
200. Plaintiffs have a non-statutory cause of action to set aside and enjoin agency action
that is ultra vires and in excess of delegated powers.
201. No constitutional provision, statute, regulation, or other source of law allows
Defendants to authorize private sporting events on the White House South Lawn or at the Lincoln
Memorial.
33Case 1:26-cv-02016 Document 1 Filed 06/06/26 Page 34 of 35
202. Such authorization was therefore ultra vires and, insofar as it is not subject to
challenge under the Administrative Procedure Act, can and should nevertheless be enjoined.
COUNT V
DECLARATORY JUDGMENT
Federal Declaratory Judgment Act, 28 U.S.C. §§ 2201–02
Plaintiffs incorporate all allegations set forth above and below as though set forth
203. in this paragraph.
204. Under the Declaratory Judgment Act, 28 U.S.C. § 2201, this Court may declare the
rights and other legal relations of any interested party seeking such declaration, whether or not
further relief is or could be sought.
205. An actual and justiciable controversy exists between Plaintiffs and Defendants
concerning the lawfulness of Defendants’ authorization of UFC Freedom 250 and the construction
of its facilities on the South Lawn.
206. Plaintiffs are entitled to a judgment declaring that Defendants’ conduct is unlawful,
in excess of statutory authority, and undertaken without the environmental review the law requires.
PRAYER FOR RELIEF
Plaintiffs respectfully request that the Court:
A. Declare unlawful and ultra vires Defendants’ decisions authorizing the organizers
of UFC Freedom 250 to utilize the South Lawn and Lincoln Memorial for a sporting
event, and to erect structures on the South Lawn;
B. Vacate and set aside Defendants’ decision as arbitrary, capricious, or an abuse of
discretion under 5 U.S.C. § 706(2)(A); not in accordance with law under 5 U.S.C.
§ 706(2)(A); in excess of statutory jurisdiction, authority, or limitations, or short of
statutory right under 5 U.S.C. § 706(2)(C); without observance of procedure
required by law under 5 U.S.C. § 706(2)(D); and ultra vires;
34Case 1:26-cv-02016 Document 1 Filed 06/06/26 Page 35 of 35
C. D. E. F. Stay the effect of Defendants’ decisions during the pendency of this lawsuit under
5 U.S.C. § 705;
Temporarily restrain, preliminarily enjoin, and permanently enjoin Defendants
from permitting the organizers of UFC Freedom 250 to utilize the South Lawn and
Lincoln Memorial for a sporting event, and from permitting the organizers of UFC
Freedom 250 to erect structures, including the so-called “Claw,” on the South
Lawn;
Award Plaintiffs their costs and reasonable attorneys’ fees; and
Grant such other and further relief as the Court deems just and proper.
Dated: June 6, 2026 Respectfully submitted,
/s/ Samuel T. Ward-Packard
PUBLIC INTEGRITY PROJECT
Brendan Ballou
D.C. Bar No. 241592
Samuel T. Ward-Packard
D.C. Bar No. 90005484
ballou@publicintegrityproject.org
sam@publicintegrityproject.org
Attorneys for Plaintiffs
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