UNITED STATES DISTRICT COURT
`DISTRICT OF MARYLAND
`
`Civil Action No. 20-929
`
`LEADERS OF A BEAUTIFUL STRUGGLE
`25 W. Fayette St.
`Baltimore, MD 21201
`
`ERRICKA BRIDGEFORD
`136 Garden Ridge Rd.
`Cantonsville, MD 21228
`
`KEVIN JAMES*
`
`Plaintiffs,
`
`v.
`
`BALTIMORE POLICE DEPARTMENT
`601 East Fayette Street
`Baltimore, MD 21202
`
`MICHAEL S. HARRISON, in his official
`capacity as Baltimore Police Commissioner
`601 East Fayette Street
`Baltimore, MD 21202
`
`Defendants.
`
`COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF
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`1.
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`This lawsuit challenges the Baltimore Police Department’s (“BPD”) deployment
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`of aircraft to conduct long-term, wide-area aerial surveillance of the entire city of Baltimore. The
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`BPD’s mass surveillance system will persistently record the movements of virtually all of
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`Baltimore’s 600,000 residents, including Plaintiffs. This surveillance system presents a novel and
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`society-changing threat to individual privacy and to free association, and it violates the
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`Constitution.
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`* In a concurrently filed motion, Plaintiff Kevin James has requested a waiver of his obligations
`under Local Rule 102.2(a) to provide his home addresses in the caption of this complaint.
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`2.
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`The BPD calls this system the “Aerial Investigation Research” program, or
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`“AIR.” The BPD has contracted with a company, aptly named Persistent Surveillance Systems,
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`LLC (“PSS”), whose planes will fly over Baltimore at least 40 hours a week. Once per second,
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`advanced wide-angle camera systems on those planes will collect images of over 90 percent of
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`the city at a time, creating slow-frame-rate video recordings of pedestrians on sidewalks, parks,
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`driveways, and back yards, and vehicles moving about on public streets and private lots. To
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`Plaintiffs’ knowledge, the BPD has not yet commenced the program.
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`3.
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`The AIR program would put into place the most wide-reaching surveillance
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`dragnet ever employed in an American city, giving the BPD a virtual, visual time machine whose
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`grasp no person can escape. And though the program’s objectives to reduce crime and violence
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`are laudable, the Constitution dictates that this all-seeing and ever-present “eye in the sky” is not
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`an available solution.
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`4.
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`Plaintiffs Leaders of a Beautiful Struggle (“LBS”), Erricka Bridgeford, and Kevin
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`James are Baltimoreans deeply concerned about their community, its relationship with law
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`enforcement, justice, and equality. The ability to associate with others, free from unwarranted
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`government scrutiny, is essential to Plaintiffs’ political activity and advocacy. If the AIR
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`program is permitted to proceed, it will violate Plaintiffs’ privacy rights and burden their
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`freedom of association; it will undermine the ability of LBS to carry out political activities
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`crucial to its mission; and it will hinder Ms. Bridgeford’s and Mr. James’s advocacy and
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`community organizing.
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`5.
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`Through this action, Plaintiffs seek a declaration that the BPD’s policy and
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`practice of persistent aerial surveillance violates their First and Fourth Amendment rights; an
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`injunction against Defendants’ operation of the AIR program; and an order requiring the BPD to
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`destroy the information about them that it has collected in violation of their constitutional rights.
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`JURISDICTION AND VENUE
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`6.
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`This Court has subject matter jurisdiction pursuant to 28 U.S.C. § 1331 and 42
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`U.S.C. § 1983 because this lawsuit alleges violations of the U.S. Constitution.
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`7.
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`The Court has authority to grant declaratory and injunctive relief, and any other
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`appropriate relief, under the Declaratory Judgment Act, 28 U.S.C. §§ 2201–2202, and under the
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`Court’s inherent equitable jurisdiction. A substantial, actual, and continuing controversy exists
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`between the parties with respect to Plaintiffs’ claims for declaratory and injunctive relief.
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`8.
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`Venue is proper in this district pursuant to 28 U.S.C. § 1391(b) because
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`Defendants reside in this district and the events giving rise to the claim occurred in this district.
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`PARTIES
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`9.
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`Plaintiff LBS is a Baltimore-based grassroots think-tank, founded in 2010, that
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`advances the public policy interests of Black people in the city through youth leadership
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`development, political advocacy, and intellectual innovation. LBS’s work addresses historic and
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`structural impediments to Black people’s quality of life, including poverty, violence, and white
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`supremacy in the American political and socio-economic order. To this end, LBS advocates for
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`policing reform, and it has spearheaded numerous legislative efforts aimed at policing
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`accountability. LBS has been a frequent critic of law enforcement’s use of surveillance
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`technologies against Black communities. LBS sues on its own behalf and on behalf of its staff.
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`10.
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`Plaintiff Erricka Bridgeford is a Black activist in Baltimore City, where she was
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`born and raised. Ms. Bridgeford is the co-founder and current co-organizer of Baltimore
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`Ceasefire 365 (“Ceasefire”), a movement that serves as a hub for organizations and citizens to
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`support one another, work together, and share resources with the goal of seeing an end to murder
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`in Baltimore City. Ceasefire organizes quarterly “ceasefire weekends” in the city, and one recent
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`study has shown that these efforts have led to more than a 50% reduction in gun violence in
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`Baltimore while in effect.
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`11.
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`Plaintiff Kevin James is an information-technology professional, hip-hop
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`musician, activist, volunteer Emergency Medical Technician, and community organizer. Mr.
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`James lives in Baltimore City and has lived in the area since 2001, when he joined Teach for
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`America in Baltimore. He has been involved with many grassroots movements in the city,
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`including advocacy related to school funding, housing rights, mental health, and immigration.
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`12.
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`Defendant Baltimore Police Department (“BPD”) is the police department for the
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`City of Baltimore. No state official or agency exercises any supervisory authority over the BPD
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`or the Police Commissioner of the BPD. The BPD operates only within the City of Baltimore.
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`The BPD is the entity responsible for the implementation of the AIR program.
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`13.
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`Defendant Michael S. Harrison is the Police Commissioner of the BPD. He has
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`supervisory authority over all operations of the BPD, including policymaking authority over the
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`AIR program. On behalf of the BPD, Commissioner Harrison signed the contract with PSS to
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`implement the AIR program. He is sued in his official capacity.
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`FACTUAL ALLEGATIONS
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`Background
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`14. Wide-area, persistent aerial surveillance is not entirely new. It was first developed
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`as a military program, named Gorgon Stare, for use over battlefields abroad.
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`15.
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`It is also not entirely new to Baltimore. In 2016, the BPD and PSS initially
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`deployed this technology for several months, keeping it secret from the public, the Mayor of
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`Baltimore, and the city’s prosecutors. It was only after news reports revealed the existence of this
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`system—which led to an overwhelming public outcry—that the BPD halted this surveillance.
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`Ultimately, the BPD recorded more than 300 hours’ worth (and one million images) of the
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`movements of ordinary Baltimoreans as they moved about the city. Although PSS publicly
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`represented that the information it collected would be deleted after 45 days, PSS instead saved all
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`of the recordings indefinitely.
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`16.
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`In September 2019, PSS pitched the BPD on a three-year, $6.6 million revival of
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`the aerial surveillance program. In December 2019, Baltimore Police Commissioner Michael
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`Harrison announced that, despite the program’s “controversial history,” he intended to enter into
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`a contract for a 180-day pilot program of wide-area, persistent aerial surveillance, beginning in
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`the spring of 2020.
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`17.
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`In March 2020, as Baltimoreans were reeling from a State of Emergency
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`declaration by Governor Larry Hogan concerning the fast-evolving coronavirus pandemic, and
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`the shuttering of enormous portions of the local and national economies, the BPD held three
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`public meetings about its imminent aerial surveillance program. The meetings were conceived as
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`steps to assuage the public in the wake of the BPD’s secret aerial surveillance trials with PSS in
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`2016. The first, on March 11, was attended by just 20 people. Two other meetings, rescheduled
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`to March 23 and March 30, were held as online Facebook events, as Baltimoreans were under
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`emergency orders prohibiting gatherings of more than ten people.
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`18.
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`On April 1, 2020, the Baltimore Board of Estimates approved the BPD’s contract
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`with PSS to implement the AIR program (the “Contract”) by a 3-to-2 vote.
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`The AIR Program
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`19.
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`According to the Contract, the BPD will authorize PSS to use its aerial technology
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`and analytics to assist in the investigation of certain crimes in Baltimore during a six-month
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`“pilot” period. The BPD acknowledges that this technology’s “effect on crime has not been
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`analyzed and is unknown.” The cost of the 180-day program, funded by Texas-based
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`philanthropists, is estimated to be $3.69 million.
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`20.
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`Under the AIR program, PSS will fly three manned aircraft over Baltimore
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`equipped with its “Hawkeye Wide Area Imaging System.” While neither the Contract nor
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`Defendants have described that system in detail, PSS’s website describes a “Hawkeye II” system
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`as “consist[ing] of twelve, full color cameras” equipped with a “192 million pixel, full color, geo
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`and ortho rectified airborne wide area surveillance sensor” with a “1/2 meter resolution
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`throughout” its coverage area. Commissioner Harrison explained in his March 30 Facebook Live
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`presentation that the BPD and PSS have “agreed” that resolution of the surveillance cameras will
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`be “one pixel per person,” but the “technology has the ability to upgrade the [image] quality.”
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`According to the Contract, the aircraft over Baltimore will capture one image per second
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`covering up to 32 square miles each, and Commissioner Harrison has stated during his
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`community presentations that the system will capture images of 90 percent of the city at once.
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`The Contract provides that the planes will fly a minimum of 40 hours per week, weather
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`permitting. While the system will not employ infrared or night vision technology, the Contract
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`states that the aerial surveillance cameras are “sensitive enough to capture images at night with
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`ambient City lighting.” Although these images are technically photographs taken from cameras,
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`the high frequency of these photographs, taken once per second, produces data akin to a slow
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`frame-rate video feed.
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`21.
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`Unlike lawful forms of aerial surveillance, the warrantless AIR program subjects
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`Plaintiffs and virtually all of Baltimore’s 600,000 residents to long-term, wide-area, and
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`indiscriminate surveillance that will capture the whole of an individual’s movements and thereby
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`reveal their privacies of life. This surveillance is inescapable, and revelation of private
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`information to the AIR program is involuntary: short of never leaving home when the planes are
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`in the air, there is no way to avoid Defendants’ surveillance system. But even one’s home is not
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`entirely safe from the surveillance, as the AIR program will also inevitably capture movements
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`in the curtilage surrounding homes, including driveways and yards. The data collected through
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`the AIR program will amount to a comprehensive record of the movements of Plaintiffs and
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`nearly everyone in Baltimore—facilitating an unprecedented police power to engage in
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`retrospective location-tracking.
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`22.
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`Although the resolution of the AIR program cameras will be one pixel per
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`person—meaning that an individual cannot immediately be identified through a single image
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`alone—Baltimoreans captured by the surveillance are in no way anonymous. That is the case for
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`at least two reasons.
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`23.
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`First, with persistent aerial surveillance, it will be trivially easy to roll back the
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`tape to trace pedestrians’ or vehicles’ paths to the homes they left in the morning, and roll it
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`forward to the homes they returned to at night, thereby deducing identity. Moreover, it takes only
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`a small number of unique location points to identify even an “anonymous” person. Researchers
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`have shown that, using cell-phone location data, just four points are enough to identify an
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`individual based on their pattern of movements. In short, the AIR program’s ongoing collection
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`of location data every second in Baltimore will yield unique and easily identifiable information
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`about every resident who moves in the city over time, including Plaintiffs.
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`24.
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`Second, as explained in the Contract, the BPD and PSS will link AIR program
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`data with the BPD’s other surveillance technologies to identify individuals in the vicinity of
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`crime scenes, as well as others who have “met with” those individuals. As set forth in the
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`Contract and discussed by Commissioner Harrison in his community presentations, these
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`additional surveillance technologies include automated license plate readers and ground-based,
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`closed-circuit television (“CCTV”) security cameras. Both systems are far-reaching and will
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`readily facilitate identification of individuals of interest to Defendants. And identifying
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`individuals is the entire point of the AIR system technology.
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`25.
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`Particularly in light of the broad scope of data that Defendants will amass through
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`the AIR program, the procedures governing the implementation of the program and the use of the
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`resulting data are weak, vague, and incomplete. These procedures fail to adequately protect
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`Plaintiffs’ rights to privacy and free association.
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`26.
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`In his community presentations, Commissioner Harrison has emphasized that, as a
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`technical matter, PSS will possess the AIR program’s massive trove of aerial imagery and will
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`provide specific data to the BPD only upon request. However, as discussed below, the Contract
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`reveals that BPD and PSS personnel and systems will be deeply intertwined—and that PSS
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`personnel will be responsible for tapping into the BPD’s other surveillance technologies.
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`27.
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`According to the Contract, PSS will employ between 15 and 25 analysts in two
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`seven-hour daily shifts, some of whom may work out of BPD’s “Watch Center to be teamed with
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`a sworn BPD officer or BPD analyst.”
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`28.
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`Upon request by the BPD, PSS analysts will review AIR program data, as well as
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`data from other BPD surveillance technologies, to produce reports for the BPD. The BPD will
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`make requests of PSS in connection with investigations of any of four “Target Crimes”—murder,
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`non-fatal shooting, armed robbery, or car-jacking. In addition, the Baltimore Police
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`Commissioner retains the authority to approve other uses of AIR program data on a case-by-case
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`basis.
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`29.
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`PSS analysts will also produce reports for the BPD in response to alerts from the
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`BPD’s Computer-Aided Dispatch system. PSS analysts will access this system “from monitors in
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`BPD facilities.”
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`30.
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`In creating reports for the BPD, PSS analysts will not only analyze imagery data
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`from the AIR program, but will also “track individuals and vehicles that pass the Baltimore
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`CitiWatch CCTV cameras[,] noting the time the vehicles pass the cameras. [PSS] analysts will
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`access or request CitiWatch camera information[.]” PSS analysts will also use the BPD’s Shot
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`Spotter Acoustic Gunshot Detection System to “speed the identification of the location of active
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`gun shots within the imagery,” “allowing analysts to quickly identify the location and time of
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`gunshots.”
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`31. Within 18 hours of a BPD request or PSS’s notice of a Target Crime on the
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`Computer-Aided Dispatch system, PSS will provide to the BPD an “investigative briefing” that
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`will include “imagery analysis,” “the tracks of vehicles and people to and from the crime scene,”
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`“the location the vehicles and people from the crime[] scene visited after and before the crime,”
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`and “observations of driving patterns and driving behaviors of vehicles from the crime scene
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`prior to and after a crime.”
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`32. Within 72 hours of a BPD request or PSS’s notice of a Target Crime, PSS will
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`provide to the BPD a detailed “Investigation Briefing Report,” which will include “ground-based
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`camera video made available to [PSS] by BPD including but not limited to CitiWatch camera
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`video images of the vehicles and people tracked from the crime scene for the cameras they pass
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`on the way to and from the crime scene.” In addition, the report will include “tracks of people
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`and vehicles that met with people who were tracked from the crime scene and the locations they
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`came from and went to.”
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`33.
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`The Contract contemplates no role for judicial review before, or during any stage
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`of, implementation of the AIR program.
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`34.
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`The standards related to the retention and deletion of AIR program data are both
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`insufficiently protective and unclear. Commissioner Harrison’s cover letter to the Contract, sent
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`to the Baltimore Board of Estimates, states that “[u]nanalyzed imagery data will be stored for 45
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`days[,] after which point it will be deleted during the pilot period.” In his community
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`presentations, Commissioner Harrison has likewise represented that “Data is only stored for up
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`to 45 days during the pilot.” However, the Contract itself merely states that PSS “will retain the
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`AIR imagery data for forty-five (45) days,” without specifying that PSS will in fact purge the
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`data. Notably, during the secret 2016 aerial surveillance trial run, PSS represented that it stored
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`data for only 45 days. But a January 2017 National Police Foundation report found that,
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`following the trial run, PSS simply moved the data to indefinite storage on backup servers.
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`35.
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`At present, according to the Contract, it appears that the lone mechanism for
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`auditing “unauthorized use of the system” is “self-report[ing]” by PSS. Although Commissioner
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`Harrison has stated in his presentations about the AIR program that an independent auditing firm
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`will ensure that the program is used only for its intended purpose, Defendants have not yet
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`identified the firm they or their funders intend to retain.
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`36.
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`In terms of physical security of the AIR program data, which will include
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`information about every Baltimorean, the Contract states that it is left to PSS to “institute
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`physical, technical and policy systems to ensure the integrity of the data it records in its
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`surveillance and analysis.” It is unclear whether these systems are in place, let alone whether
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`they are adequate to protect this highly sensitive information.
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`37.
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`The Contract states one of Defendants’ explicit goals in implementing this
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`experimental pilot surveillance system is to enable BPD to collect and “to test and rigorously
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`evaluate” data to determine whether to permanently implement wide-area aerial surveillance in
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`Baltimore. Although Commissioner Harrison has stated in his presentations about the AIR
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`program that the BPD will work with one of four “research partners” to evaluate the efficacy of
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`the program, Defendants have not yet identified the particular research partner that they or their
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`funders intend to retain.
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`38.
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`The data collected over the coming months will be of severely limited value due
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`to the present circumstances of the COVID-19 pandemic. Due to Maryland’s stay-at-home order,
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`movement and activity are greatly reduced throughout Baltimore. Under these circumstances, the
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`collection of data regarding the impact of the AIR program on the city’s crime rates is effectively
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`useless if meant to inform decisions about the system’s use in times of ordinary city life.
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`PSS’s Activities Are Fairly Attributable to Defendants
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`39.
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`The Contract makes clear that PSS will engage in long-term wide-area aerial
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`surveillance over Baltimore at the BPD’s direction, and that Defendants have delegated policing
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`functions—namely, law enforcement surveillance—that are traditionally reserved for state actors
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`to PSS. Every aspect of the AIR program is conducted pursuant to the Contract, which was
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`negotiated by the BPD and signed by Commissioner Harrison, a final policymaker for the BPD.
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`In the absence of the Contract, PSS would not be collecting imagery for 40 hours each week over
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`90 percent of Baltimore, nor would it be voluntarily submitting “investigative briefings” or
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`“Investigation Briefing Reports” to the BPD. Defendants are affirmatively initiating, directing,
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`encouraging, and facilitating PSS’s surveillance through the AIR program, and PSS is
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`participating in the AIR program to assist law enforcement. Accordingly, Defendants’ and PSS’s
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`conduct is under color of state law, and Defendants are responsible for PSS’s execution of the
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`AIR program.
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`40.
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`As discussed in paragraphs 19 to 38, Defendants have plainly delegated policing
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`functions to PSS, encouraged PSS’s implementation of the AIR program, and established a close
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`nexus between themselves and PSS. In addition to the examples above, several other provisions
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`of the Contract reflect Defendants’ delegation, encouragement, and/or the close nexus between
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`Defendants and PSS, such that PSS’s operation of the AIR program is fairly attributable to
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`Defendants.
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`41.
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`For example, the Contract provides that, “BPD shall provide [PSS] with access to
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`its offices and personnel as are reasonably required for [PSS] to perform its duties and
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`responsibilities under this Agreement.”
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`42.
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`The Contract also provides that, “[t]o the extent of [PSS’s] negligence, [PSS’s]
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`insurance coverage shall be primary insurance as respects the . . . BPD, its elected/appointed
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`officials, employees, and agents.” The BPD also dictates the Best’s rating of the insurers
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`providing coverage to PSS and the BPD.
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`43.
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`The Contract also provides that, if PSS should cease to exist, “custody of all
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`records related to this Agreement will be transferred to BPD.”
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`44.
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`The Contract also provides that, “[a]t any time during business hours and as often
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`as BPD may deem necessary, there shall be made available to BPD for examination, [PSS’s]
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`records with respect to matters covered by this agreement”—including, presumably, data from
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`the AIR program.
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`45.
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`The Contract also provides that, to the extent any images or other materials
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`prepared by PSS under the Contract include material subject to copyright protection, “such
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`materials have been specifically commissioned by BPD.”
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`46.
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`The Contract also provides that PSS “shall obtain prior written approval regarding
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`any advertising, publicity, or promotional materials from the BPD before such advertising,
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`publicity, or materials can be released.” In addition, “BPD will be responsible for answering all
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`media requests related to the operation of the Pilot Program, and [PSS] will notify BPD of any
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`media inquiry made to [PSS].”
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`Plaintiffs
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`Leaders of a Beautiful Struggle
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`47.
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`LBS is a Baltimore-based LLC organization that advances the public policy
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`interests of Black people in the city through youth leadership development, political advocacy,
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`and intellectual innovation. LBS strives to address the complex issues facing Black Baltimore
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`residents in every arena of civil society. To do this, LBS seeks to radically change the discourse
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`around local and regional politics by injecting community voices into political conversations
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`through policy research, advocacy, and community organizing from a grassroots perspective.
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`48.
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`LBS’s staff includes a Chief Executive Officer, a Chief Operating Officer, a
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`Director of Public Policy, a Director of Research, a Cultural Curator, an Events and Projects
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`Manager, and a Bookkeeper, all of whom advance LBS’s activities in Baltimore.
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`49.
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`A central focus of LBS’s work is addressing historic and structural impediments
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`to Black people’s quality of life, including poverty, violence, and white supremacy in the
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`American political and socio-economic order. To this end, LBS has been heavily involved in
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`policing reform and has spearheaded numerous legislative efforts aimed at policing
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`accountability. For example, it helped pass Christopher’s Law, which requires police officers to
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`be trained in CPR, cultural sensitivity, the proper use of force, and interacting with people with
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`physical and cognitive disabilities. During the 2019 Maryland General Assembly, it vigorously
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`fought the creation of a private police force at Johns Hopkins University. And during the 2020
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`Maryland General Assembly, it supported bills focused on restricting police use of force,
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`reforming Maryland’s Law Enforcement Officer Bill of Rights to increase police accountability,
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`and amending Maryland’s public records law to increase transparency and accountability in how
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`departments address police misconduct.
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`50.
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`In addition to its direct political activity, LBS also strives to support activists
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`within its community, through hosting talks, engaging in collaborations with local institutions,
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`and conducting civic engagement trainings.
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`51.
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`An important component of LBS’s advocacy is maintaining close proximity to the
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`communities it represents in order to prioritize the needs of these communities in its agenda-
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`setting. This requires its staff to travel throughout Baltimore, by foot, by bus, and by car.
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`52.
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`The AIR program intrudes on LBS’s and its staff’s reasonable expectations of
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`privacy. In particular, it intrudes on LBS staff’s reasonable expectation of privacy in the whole
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`of their long-term physical movements, by foot, by bus, and by car. The AIR program’s
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`surveillance of these physical movements will capture LBS staff’s privacies of life, thereby
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`comprehensively revealing the private activities of LBS itself.
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`53.
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`The AIR program also infringes on LBS’s and its staff’s freedom to associate
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`privately. If Defendants’ wide-area aerial surveillance program is permitted to proceed, it will
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`undermine and significantly burden LBS’s work. LBS will have to be more cognizant of the
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`individuals and groups with whom it associates, because many of its relationships are private and
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`sensitive. The nature and extent of these relationships are also private and sensitive. The BPD’s
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`continuous, comprehensive aerial recording of LBS staff’s movements throughout Baltimore will
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`force staff to change their behavior to maintain the privacy of their relationships, including by
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`altering the timing of certain meetings and the means by which they travel. This effort will divert
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`time and staff resources from other LBS work. LBS also believes that, as a result of the program,
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`some of its present and future partners will decide not to engage with the organization out of fear
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`the association would provoke government retaliation.
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`Erricka Bridgeford
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`Plaintiff Erricka Bridgeford is a Black activist in Baltimore City, where she was
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`54.
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`born and raised. Ms. Bridgeford has been an involved community activist since the late 1990s,
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`and has focused on a range of social justice issues during that time, in particular abolishing the
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`death penalty and supporting survivors of homicide victims. She currently works full-time as the
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`Director of Training for Community Mediation Maryland, which advances collaborative conflict
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`resolution in Maryland.
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`55. Ms. Bridgeford is also the co-founder and current co-organizer of Baltimore
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`Ceasefire 365 (“Ceasefire”), a movement that serves as a hub for organizations and citizens to
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`support one another, work together, and share resources with the goal of seeing an end to murder
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`in Baltimore City. Ceasefire organizes quarterly “ceasefire weekends” in the city, and one recent
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`study has shown that these efforts have led to more than a 50% reduction in gun violence in
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`Baltimore while in effect.
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`56.
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`As part of her work for Ceasefire, Ms. Bridgeford conducts significant
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`community outreach in neighborhoods throughout Baltimore, including by visiting every murder
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`site in the city within two weeks of the crime occurring—and, on ceasefire weekends, visiting
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`those sites within a day or even a matter of hours.
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`57.
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`The AIR program intrudes on Ms. Bridgeford’s reasonable expectation of privacy
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`in the whole of her long-term physical movements in Baltimore, by foot and by car.
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`58.
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`As part of Ms. Bridgeford’s community organizing and engagement, she often
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`visits and speaks with people in high-crime neighborhoods. The very nature of that work
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`involves visiting murder scenes and talking with people who are processing the trauma
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`associated with being in the vicinity of a murder. Accordingly, if the AIR program is permitted
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`to go forward, Ms. Bridgeford believes it is likely that the program will generate an
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`individualized report about her, pursuant to the terms of the Contract. This warrantless reporting
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`will further intrude on Ms. Bridgeford’s reasonable expectation of privacy.
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`59.
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`The AIR program also infringes on Ms. Bridgeford’s freedom to associate
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`privately. In her work for Ceasefire, Ms. Bridgeford drives from neighborhood to neighborhood
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`throughout Baltimore to engage with communities affected by violence. Once in a neighborhood,
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`she spends two to three hours walking along public streets and parks to interact with community
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`members. She also sometimes walks with people she meets back to their homes to meet their
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`family members and continue the conversation. Under the AIR program, Ms. Bridgeford will
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`have to be far more cognizant of her associations in public, out of concern that each and every
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`association will be captured by the AIR program, and that those associations will subject her to
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`unjustified BPD scrutiny.
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`60.
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`The AIR program will also burden the effectiveness of Ms. Bridgeford’s work as
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`a Ceasefire co-organizer. Ms. Bridgeford believes that some people will likely no longer feel
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`comfortable having private and sensitive conversations with her, given that the very fact of their
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`meeting will be captured by the BPD’s blanket aerial surveillance. Furthermore, Ms. Bridgeford
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`cannot change the timing of her outreach work to avoid surveillance without compromising her
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`work. If she were to only conduct community outreach when the planes are not flying (perhaps at
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`night or during bad weather), she would encounter far less foot traffic on the streets, and she
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`would have far less time in each neighborhood, because she cannot feasibly work every night
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`and all night long. Because people will know definitively that they will be subject to aerial
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`surveillance when associating with Ms. Bridgeford in public or inviting her into their home—and
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`for that reason linked to every other person she meets with—Ms. Bridgeford believes the AIR
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`program will undermine her role as a safe resource within the communities she serves.
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`61.
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`The AIR program’s comprehensive and continuous surveillance will impair Ms.
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`Bridgeford’s work with Ceasefire in still other ways. Ms. Bridgeford believes that awareness of
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`the AIR program will discourage others from volunteering and joining her in the streets to work
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`with Ceasefire, because every association with individuals in high-crime areas will be captured
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`by the BPD. In addition, Ms. Bridgeford anticipates that she will have to shift most of her
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`outreach and conversations to be over the phone, over social media, or over email, which will
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`severely impact the nature and quality of the inherently personal and sensitive work she does
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`through Ceasefire.
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`Kevin James
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`62.
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` Kevin James is an information-technology (“IT”) professional, as well as an
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`activist, community organizer, and hip-hop artist who lives in Baltimore City. He volunteered for
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`many years with the Baltimore Algebra Project to advocate for a number of issues that face
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`Baltimore youth, such as increasing funding for schools and starting a bus pass program. He has
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`also worked with organizations such the United Worker and the Right to Housing Alliance in
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`Baltimore. In addition, Mr. James is a former trained paramedic, and he has periodically
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`volunteered as an Emergency Medical Technician in Baltimore County and as a street medic in
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`Baltimore City during the 2015 protests.
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`63.
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`Currently, Mr. James works full-time for an IT company. In his spare time, he
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`remain