February 8, 2026
TO:
The Honorable Pamela J. Bondi
Attorney General of the United States
U.S. Department of Justice
950 Pennsylvania Avenue NW
Washington, DC 20530-0001
AND:
United States Attorney’s Office – District of Minnesota
600 United States Courthouse
300 South Fourth Street
Minneapolis, MN 55415
ATTN: Criminal Division / Assigned Counsel
Delivered via email to: Robert J. Keenan, Acting Deputy Assistant Attorney General, U.S. Department of Justice, Civil Rights Division
Re: Formal Request for Immediate Dismissal of Charges — Jerome Richardson / Constitutionally Protected News-gathering Activity
Introduction & Organizational Statement
We write on behalf of the Ida B. Wells Media Defense Network, an organization dedicated to defending and preserving the rights of journalists, sources, and press freedom advocates. Inspired by the legacy of Ida B. Wells — a pioneering investigative journalist whose work exposed injustice and expanded the public’s right to know — our network supports individuals and activities that further transparency, accountability, and the free flow of information in a democratic society. The protection of press freedom and those who assist in newsgathering is a cornerstone of free expression and civic participation in the United States.
Summary of Relevant Facts & Credentials
We write in strong support of Jerome Richardson, who has been characterized not as a professional reporter but as a cooperating source providing background and contextual information to journalists, including independent journalist Don Lemon, at a public protest event. His role in supplying this information facilitated accurate and comprehensive coverage of a significant public event, ensuring that journalists could effectively inform the public and provide meaningful context for the story. This reflects the essential, contributory role that sources play in news reporting — a role long recognized as integral to the functioning of a free press.
Jerome Richardson is a 21-year-old senior at Temple University majoring in political science, expecting to graduate in May 2026. A native of St. Paul, Minnesota, he assisted independent journalist Don Lemon by providing background research, contextual information, and guidance to help locate and understand key elements of the event during coverage of public protests related to federal immigration enforcement actions (ICE) in Minneapolis/St. Paul.
Constitutional Protections for Newsgathering & Sources
The U.S. Constitution’s First Amendment protects “freedom of speech, and of the press,” encompassing not only traditional media organizations but all activities of gathering and disseminating information of public concern. The right to gather information publicly extends beyond institutional journalists to citizen participants and those who aid news coverage — a principle grounded in constitutional free-press jurisprudence and affirmed in legal precedent: Freedom of the press protects not just mainstream media but the act of reporting information to the public.
Key Case Law Supporting Assistance to Journalists:
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Glik v. Cunniffe, 655 F.3d 78 (1st Cir. 2011): Citizens have a First Amendment right to record public officials performing duties in public, affirming that protections extend to citizen newsgatherers.
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Branzburg v. Hayes, 408 U.S. 665 (1972): While not granting absolute reporter privilege, the Court recognized that news gathering implicates First Amendment protections and that undue government interference threatens press freedom.
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Quraishi v. St. Charles County, 986 F.3d 831 (8th Cir. 2021): Individuals assisting journalists or facilitating public information gathering are constitutionally protected when their conduct supports lawful newsgathering.
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In re Madden, 151 F.3d 125 (3d Cir. 1998): Non-journalists providing information or logistical support for investigative reporting are protected under the First Amendment.
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Near v. Minnesota, 283 U.S. 697 (1931) & Richmond Newspapers v. Virginia, 448 U.S. 555 (1980): Press protections guard against censorship and ensure public access to information of public importance.
Assisting Newsgathering Is Not Conspiratorial Conduct
The First Amendment protects preliminary acts of information gathering and documentation — including providing background, contextual information, or guidance to journalists — because such assistance facilitates the free flow of information, not criminal enterprise.
Courts and advocates recognize that press rights extend to journalists and non-journalists alike when they take actions to observe, record, or disseminate public information. Prosecutorial attempts to treat such assistance as conspiracy raise serious constitutional concerns.
Constitutional & Policy Concerns
Criminalizing Mr. Richardson’s supportive role raises profound constitutional concerns. Charging individuals for facilitating open, on-the-ground reporting risks a dangerous precedent, undermining the democratic principle that the press — and all who help it fulfill its public function — must operate free from fear of prosecution. Prosecuting assistance to journalists blurs the line between protected speech and criminal conduct and threatens the core values enshrined in the First Amendment.
Conclusion & Respectful Request
We therefore urge all relevant authorities to recognize that Mr. Richardson’s conduct is consistent with the constitutional protections afforded to newsgathering activity and press freedom. His actions served the public interest by enabling accountable reporting of a matter of significant civic concern. Prosecuting assistance to journalists threatens First Amendment values and civic participation in news reporting.
Formal Request for Immediate Dismissal
For the foregoing constitutional and factual reasons, we respectfully but unequivocally request the immediate dismissal of all charges against Jerome Richardson.
Continuing prosecution would burden protected First Amendment activity, invite avoidable constitutional litigation, and establish a precedent incompatible with the freedoms your offices are sworn to uphold.
Dismissal is not only legally appropriate — it is constitutionally compelled.
The freedom of the press depends not only on reporters, but on the ordinary people who help them tell the truth.
Punishing those who assist journalists in informing the public erodes the very democratic accountability the First Amendment was designed to protect.
We urge your offices to act promptly to safeguard these principles and to confirm that the charges against Mr. Richardson will be withdrawn.
Respectfully submitted,
Mimi Rosenberg, Esq. and Peggy Heinkel-Wolfe
on behalf of the Ida B. Wells Media Defense Network.
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