Mytych v. National Park Service

CourtDistrict Court, District of Columbia
DecidedFebruary 5, 2026
DocketCivil Action No. 2025-4291
StatusPublished

This text of Mytych v. National Park Service (Mytych v. National Park Service) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mytych v. National Park Service, (D.D.C. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

DAVID MYTYCH,

Plaintiff,

v. Case No. 1:25-cv-4291 (TNM)

NATIONAL PARK SERVICE, et al.,

Defendants.

MEMORANDUM ORDER

David Mytych helps run a volunteer nonprofit called FLARE USA. For months, FLARE

maintained a demonstration outside Union Station in Washington, D.C., to express its views on

various political issues. FLARE had a National Park Service (“NPS”) permit to do so. But

toward the year’s end, NPS told Mytych and FLARE that a construction project required the

demonstration to move to a nearby park. That order prompted this lawsuit.

Mytych, proceeding pro se, brings claims under the Administrative Procedure Act along

with an ultra vires challenge, arguing that NPS violated the First Amendment and its own

regulations in its treatment of his and FLARE’s activity. He seeks a declaration that NPS acted

unlawfully and a preliminary injunction barring NPS from evicting him and FLARE from the

original demonstration spot.

But a few hurdles prove insurmountable for Mytych. For his claims that NPS violated its

regulations, Mytych has failed to establish standing. Mytych tethers those claims to NPS’s

revocation of a permit, but that permit belonged to FLARE, not him. Mytych must base his

claims on his own legal interests, not those of third parties. For his First Amendment challenge,

Mytych faces a different problem. Though Mytych plausibly alleges standing, he has not shown a likelihood of success on the merits of that claim. NPS adhered to reasonable time, place, and

manner restrictions in relocating the demonstration and temporarily closing the demonstration

spot for construction. The Court thus dismisses some claims for lack of standing and denies the

preliminary injunction motion.

I.

In 1916, Congress established NPS as an agency within the Department of Interior.

National Park Service Organic Act, Ch. 408, § 1, 39 Stat. 535 (1916). NPS’s “purpose is to

conserve” and “provide for the enjoyment of the scenery, natural and historic objects, and wild

life” on NPS land in ways that leave the land “unimpaired for the enjoyment of future

generations.” 54 U.S.C. § 100101(a).

To meet those goals, NPS must sometimes close or limit park areas. Its regulations

specify when and how it may do so. Mytych has no quibble with these regulations. Closures are

permissible, for instance, when “necessary for the maintenance of public health and safety,

protection of environmental or scenic values, protection of natural or cultural resources, aid to

scientific research, implementation of management responsibilities, equitable allocation and use

of facilities, or the avoidance of conflict among visitor use activities.” 36 C.F.R. § 1.5(a).

Before closing a park, NPS must provide a written justification for its decision, except in

emergencies. Id. § 1.5(c). NPS must also notify the public about closures through signs, maps,

publications, or other appropriate methods. Id. § 1.7(a).

Another way NPS regulates park use is through permits. In the D.C. area, one may hold

a demonstration or special event in an NPS-run park only with a valid permit. Id. § 7.96(g).

Once an individual or group submits a permit application, the regulations consider that permit

granted absent a denial within 24 hours of receipt. Id. § 7.96(g)(3).

2 Once granted, though, NPS may revoke a permit on several grounds. Id. § 7.96(g)(4)–

(6). NPS may revoke a demonstration permit, for instance, when that demonstration “cannot

reasonably be accommodated in the particular area,” or if “continuation of the event presents a

clear and present danger to the public safety, good order or health.” Id. § 7.96(g)(4)(vii), (g)(6).

In the former situation, the Regional Director must propose an alternative site to the applicant.

Id. § 7.96(g)(4)(vii)(C).

Consider this case against that backdrop. Mytych helps organize and lead FLARE, a

volunteer nonprofit organization committed to political expression and advocacy about

authoritarianism, impeachment, and constitutional accountability. Compl. ¶¶ 11–12, ECF No. 1.

Since May 2025, FLARE has held a continuous demonstration in Columbus Plaza, a spot in front

of Union Station. Id. ¶ 20. FLARE picked Columbus Plaza for its position as the “main

pedestrian gateway between Union Station and the United States Capitol,” id. ¶ 21, and it

obtained an NPS permit to demonstrate there, id. ¶ 23.

The first sign of conflict came in October 2025, when NPS officials ordered Mytych and

his fellow demonstrators to leave the protest site and to remove equipment and structures

FLARE had set up. Id. ¶ 26; Mytych Decl. ¶ 7, ECF No. 2-1. As Mytych alleges, NPS provided

FLARE a document about the permit revocation, but never signed it. Compl. ¶ 28. At some

point following that notice, officials removed FLARE’s structures and demonstration materials.

Id. ¶¶ 29–31.

The next month, FLARE submitted a new permit application for the same demonstration.

Id. ¶ 36; November Permit Application (“Nov. Perm. App.”) at 30, ECF No. 2-4. Because NPS

did not deny the application within 24-hours, it was “deemed granted.” 36 C.F.R. § 7.96(g)(3);

3 Compl. ¶ 37–39. Shortly after the 24-hour window passed, NPS issued a permit excluding the

use of structures. Compl. ¶ 40.

FLARE and Mytych’s activity continued until December 8, 2025, when an NPS official

“verbally informed” Mytych that he and FLARE would have to vacate Columbus Plaza within

two days “because ‘construction’ was going to start” in the Plaza. Id. ¶ 44. The same official

emailed Mytych confirming that order the next day. Id. ¶ 49; Email at 5, ECF No. 2-4. The

email explained that NPS would close the park “to provide for public safety during a

construction project set to begin [that] week.” Compl. ¶ 49; Email at 5. It also “propose[d]

Stanton Park as an alternative site for [the] demonstration,” and attached a draft permit to the

email “updating the location.” Compl. ¶ 49; Email at 5. Though Stanton Park sits just a few

blocks away from Union Station, Mytych did not “agree[] to or sign the Stanton Park

amendment.” Compl. ¶¶ 53, 56.

NPS’s December actions led Mytych to this Court. He filed a Complaint against NPS,

Deputy Director of Operations Frank Lands, Regional Director Jennifer Nersesian,

Superintendent Kevin Griess, and Deputy Superintendent Chad Tinney (collectively, “NPS”).

Id. at 1. He brings two claims under the Administrative Procedure Act. 5 U.S.C. § 706(2).

First, he alleges that his eviction from Columbus Plaza violated the First Amendment. Compl.

¶¶ 68–69. Second, he claims that NPS violated its own regulations in its treatment of FLARE’s

permits. Id. ¶ 75. Mytych also adds an ultra vires claim again asserting that NPS infringed its

own regulations. Id. ¶¶ 81–82. Mytych moved for a temporary restraining order and preliminary

injunction. Pl.’s Mot., ECF No. 2. He seeks a declaration finding NPS’s actions unlawful and

an injunction prohibiting NPS from evicting him and FLARE from Columbus Plaza or seizing its

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