King v. Whitmer CIVIL 20-13134 (E.D. Mich. Aug. 25, 2021) assertion that her allegations amounted to “wild accusations” and “outlandish claims” and therefore, she argued, “reasonable people would not accept” these alleged statements and allegations “as fact but view them only as claims that await testing by courts through the adversary process.” (Id. at PDF Pg 62.) It is not acceptable to support a lawsuit with opinions, which counsel herself claims no reasonable person would accept as fact and which were “inexact, ” “exaggerate[ed], ” and “hyperbole.” Nor is it acceptable to use the federal judiciary as a political forum to satisfy one's political agenda. Such behavior by an attorney in a court of law has consequences. Although the First Amendment may allow Plaintiffs' counsel to say what they desire on social media, in press conferences, or on television, federal courts are reserved for hearing genuine legal disputes which are well-grounded in fact and law. See Saltany v. Reagan, 886 F.2d 438, 440 (D.C. Cir. 1989) (explaining that the circuit court does “not conceive it a proper function of a federal court to serve as a forum for ‘protests,' to the detriment of parties with serious disputes waiting to be heard” and suggesting the same for use as a “political [] forum”); see also Knipe v. Skinner, 19 F.3d 72, 77 (2d Cir. 1994) (affirming the imposition of Rule 11 sanctions where, as the district court found, the filing of the action was “[a]nother creative avenue to beat a dead horse” and the “pursui[t of] a personal agenda against [a government entity]” without a good faith basis). The Court pauses to briefly discuss Plaintiffs' attorneys' attempt to cloak their conduct in this litigation under First Amendment protection. The attorneys have argued: Setting a precedent to sanction an attorney whose case is denied at the district court level on procedural grounds is a grave abuse of the disciplinary process and potentially constitutes intimidation for filing a grievance against the government, which is a core protection of the First Amendment. (ECF No. 112 at Pg ID 4615.) The attorneys have further argued that a sanctions order “would implicate Plaintiffs' and their counsel's First Amendment right of access to the courts.” (ECF No. 93 at Pg ID 4078.) The attorneys are incorrect. An attorney's right to free speech while litigating an action “is extremely circumscribed.” Mezibov v. Allen, 411 F.3d 712, 717, 720-21 (6th Cir. 2005) (quoting Gentile v. State Bar of Nev., 501 U.S. 1030, 1071 (1991)). As the Sixth Circuit explained in Mezibov: It is not surprising that courts have thus far been reluctant to allow the First Amendment to intrude into the courtroom. At first blush, the courtroom seems like the quintessential arena for public debate, but upon closer analysis, it is clear this is not, and never has been, an arena for free debate.... An attorney's speech in court and in motion papers has always been tightly cabined by various procedural and evidentiary rules, along with the heavy hand of judicial discretion.... [and in] [t]he courtroom[, ] . . . the First Amendment rights of everyone (attorneys included) are at their constitutional nadir. Id. at 717 (internal citations omitted) (emphasis in original). Attorneys “voluntarily agree[] to relinquish [their] rights to free expression in [] judicial proceeding[s]” and “voluntarily accept[] almost unconditional restraints on [their] personal speech rights” when before a court. Id. at 719-20. For that reason, the Sixth Circuit has “see[n] no basis for concluding that free speech rights are 39