True the Vote, Inc. v. Internal Revenue Service

CourtDistrict Court, District of Columbia
DecidedMay 30, 2025
DocketCivil Action No. 2013-0734
StatusPublished

This text of True the Vote, Inc. v. Internal Revenue Service (True the Vote, Inc. v. Internal Revenue 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
True the Vote, Inc. v. Internal Revenue Service, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

) TRUE THE VOTE, INC., ) ) Plaintiff, ) ) Civil Action No. 13-734 (RBW) v. ) ) INTERNAL REVENUE SERVICE, et al., ) ) Defendants. ) )

MEMORANDUM OPINION

The plaintiff, True the Vote, Inc. (“TTV”), brought this civil action against the Internal

Revenue Service (“IRS”), the United States of America, and several IRS officials in their official

capacities, alleging violations of the First Amendment to the United States Constitution, U.S.

Const. amend. I; the Internal Revenue Code, 26 U.S.C. §§ 1–9834; and the Administrative

Procedure Act, 5 U.S.C. §§ 701–706, seeking declaratory and injunctive relief, as well as

monetary damages. See First Amended Verified Complaint for Declaratory Judgment,

Injunctive Relief, and Compensatory, Statutory, and Punitive Damages ¶¶ 139–61, 168–206,

ECF No. 14. Currently pending before the Court is the Bopp Law Firm’s Amended Motion for

Enforcement of Attorney’s Charging Lien (“BLF’s Am. Mot.”), ECF No. 274, filed by the

plaintiff’s current attorney, the Bopp Law Firm, PC (“the BLF”). However, the plaintiff’s

former attorneys—the Public Interest Legal Foundation (“PILF”), f/k/a Act Right Legal

Foundation, and Foley & Lardner LLP (collectively, the “Former Attorneys”) 1—appear to

1 The plaintiff notes that the designation “Former Attorneys” includes The Center for Constitutional Jurisprudence (“CCJ”), who “also formerly represented [the plaintiff.]” Plaintiff’s Motion to Quash PILF’s and Foley’s Attorney’s Charging Lien (“Pl.’s Mot. to Quash”) at 1 n.1. challenge the validity of the BLF’s lien and argues in any event that their charging lien takes

priority over any BLF lien. See The Former At[t]orneys’ Response to The Bopp Law Firm’s

Amended Motion for Enforcement of Attorney’s Charging Lien (“Former Attorneys’ Opp’n”) at

2–3, ECF No. 275. Upon consideration of the submissions from the BLF and the Former

Attorneys, 2 the Court concludes that it must deny the BLF’s motion.

I. BACKGROUND

The Court previously set forth the factual background of this case in its Memorandum

Opinion issued on October 23, 2014, see True the Vote, Inc. v. Internal Revenue Serv. (“True the

Vote I”), 71 F. Supp. 3d 219, 223–25 (D.D.C. 2014) (Walton, J.), aff’d in part, rev’d in part and

remanded, 831 F.3d 551 (D.C. Cir. 2016), and the procedural history of this case in its

subsequent Memorandum Opinions issued on May 30, 2019, see True the Vote, Inc. v. Internal

Revenue Serv. (“True the Vote II”), No. 13-cv-734 (RBW), 2019 WL 230465, at *2 (D.D.C.

May 30, 2019) (Walton, J.), and September 23, 2020, see True the Vote, Inc. v. Internal Revenue

Serv. (“True the Vote III”), No. 13-cv-734 (RBW), 2020 WL 5656694, at *2 (D.D.C. Sept. 23,

2020). Therefore, the Court will not reiterate the factual and procedural background of this case

2 In addition to the filings already identified, the Court considered the following submissions in rendering its decision: (1) the Notice of Attorney’s Charging Lien (“Former Attorneys’ Charging Lien”), ECF No. 142; (2) the Plaintiff’s Motion to Quash PILF’s and Foley’s Attorney’s Charging Lien (“Pl.’s Mot. to Quash”), ECF No. 190; (3) the Former Attorneys’ Response in Opposition to Plaintiff’s Motion to Quash Attorney’s Charging Lien (“Former Attorneys’ Opp’n”), ECF No. 196; (4) the Reply in Support of Plaintiff’s Motion to Quash PILF’s and Foley’s Attorney’s Charging Lien (“Pl.’s Reply in Support of Mot. to Quash”), ECF No. 199; (5) the Notice of Attorney’s Charging Lien (“BLF’s Charging Lien”), ECF No. 216; (6) the Bopp Law Firm’s Motion for Enforcement of Attorney’s Charging Lien (“BLF’s Mot. to Enforce”), ECF No. 229; (7) The Former At[t]orneys’ Supplemental Brief Responding to the Court’s August 15, 2023 Order (“Former Attorneys’ Suppl. Br.”), ECF No. 246; (8) the Supplemental Brief [of the] Non-Party Petitioner[,] The Bopp Law Firm, PC (“BLF’s Suppl. Br.”), ECF No. 247; (9) The Former Attorneys’ Response to the Bopp Law Firm’s Supplemental Brief (“Former Attorneys’ Resp.”), ECF No. 270; (10) the Response of Petitioner[,] The Bopp Law Firm, PC to [the] Former Attorneys’ Supplemental Brief (“BLF’s Resp.”), ECF No. 271; (11) The Bopp Law Firm’s Memorandum of Points and Authorities in Support of its Amended Motion for Enforcement of Attorney’s Charging Lien (“BLF’s Am. Mem.”), ECF No. 274-1; (12) The Former At[t]orneys’ Response to the Bopp Law Firm’s Amended Motion for Enforcement of Attorney’s Charging Lien (“Former Attorneys’ Opp’n to Am. Mot.”), ECF No. 275; and (13) The Bopp Law Firm’s Reply In Support of its Amended Motion for Enforcement of Attorney’s Charging Lien (“BLF’s Reply in Support of Am. Mot.”), ECF No. 276.

2 in full here. The Court will, however, briefly summarize the current procedural posture of the

case relevant to the resolution of the BLF’s pending motion.

On May 5, 2017, the Former Attorneys filed a notice of attorney’s charging lien “based

upon legal services performed and expenses and costs incurred in connection with the

representation of [the p]laintiff . . . in this action.” See Former Attorneys’ Charging Lien at 1,

ECF No. 142. On October 23, 2020, following the Court’s ruling in True the Vote III and the

October 20, 2020 status conference, the plaintiff filed a sealed motion to quash the Former

Attorneys’ charging lien. See Pl.’s Mot. to Quash at 1.

On March 21, 2023, the BLF filed its own notice of attorney’s lien “based upon legal

services performed and expenses and costs incurred in connection with the representation of

[the] plaintiff . . . in this action.” See BLF’s Charging Lien at 1. Then, on June 16, 2023, the

BLF filed a motion for an order to enforce its attorney’s charging lien. See BLF’s Mot. to

Enforce at 1.

On August 15, 2023, the Court issued an Order, see Order at 1 (Aug. 15, 2023), ECF No.

245, concluding that the Former Attorneys’ contract dated December 2017, Pl.’s Mot. to Quash,

Exhibit (“Ex.”) A (Agreement (“December 2017 Agreement”)) at 1–3, ECF No. 190-2,

superseded their prior 2013 contract, id., Ex. C (Legal Services Agreement) at 7–12, ECF No.

190-2; id., Ex. D (Engagement Letter Agreement for Pro Bono Legal Services) at 14–19, ECF

No. 190-2. The Court therefore concluded that the December 2017 Agreement is the operative

agreement in this case. See Order at 3–4 (Aug. 15, 2023). Additionally, the Court held that “the

Former Attorneys have a valid charging lien on the attorneys’ fees awarded by the Court in this

case.” Id. at 6. The Court also ordered, inter alia, that “the plaintiff [be] awarded attorneys’ fees

under the Equal Access to Justice Act [‘EAJA’] in the amount of $788,539.30.” Id.

3 The Court’s August 15, 2023 Order did not resolve the BLF’s motion for an order to

enforce its attorney’s charging lien, but did order the BLF and the Former Attorneys to file

supplemental briefing addressing: (1) “the amount of attorneys’ fees that the attorneys claim are

subject to their respective charging liens[;]” (2) “the priority of the distribution of funds in the

event of competing attorneys’ charging liens;” and (3) “the method by which payment should be

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