Memphis, TN — February 14, 2019.  The Center for Religious Expression (CRE) sent a letter to the City of Memphis today, asking the City to cease foisting arbitrary and oppressive fees on 40 Days for Life, a pro-life organization dedicated to ending abortion through prayer, fasting, and community outreach who seeks to have a small gathering and speech on public sidewalks.

Several times per year, 40 Days for Life holds small gatherings on public sidewalks in Memphis outside of an abortion clinic.  Each event lasts about one hour, during which time, no streets or sidewalks are closed, and passersby can freely and easily walk by.  Despite the non-obstructive nature of this get-together, Memphis is insisting that 40 Days for Life pay $150 in fees for each one-hour event.  The exorbitant fees threaten to shut down 40 Days for Life’s activities.

40 Days for Life contacted CRE, which sent a letter on its behalf, asking Memphis to cease imposing these disproportionate fees on their speech.  The letter explains that while fees might be tolerable for a major event, like a parade that closes several city streets for several hours and requires police coordination, imposing $150 in fees on 40 Days for Life’s small gathering is arbitrary, excessive, and unconstitutional.  For such a small and harmless event, no fee is warranted at all.

“The government cannot impose arbitrary and high costs on the exercise of constitutional rights,” said CRE Chief Counsel Nate Kellum.  “Especially when a small gathering causes no disruption, the law is clear: Free speech should be free.”

Center for Religious Expression is a servant-oriented, non-profit 501(c)(3) Christian legal organization dedicated to the glory of God and the religious freedom of His people.  For more information, visit

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