Whether the First Amendment protects a right to receive information from a public library and how the government speech doctrine applies to library collection decisions

conflicts with decisions of other circuits. A majority of the en banc Fifth Circuit held that there is no “right to receive information” from a public library. App. 13. The Third and Sixth Circuits have held the opposite, reasoning that the First Amendment protects “access to a public library, the quintessential locus of the receipt of information.” Kreimer v. Bureau of Police for Town of Morristown, 958 F.2d 1242, 1255 (3d Cir. 1992); see Neinast v. Board of Trustees of Columbus Metropolitan Library, 346 F.3d 585, 591 (6th Cir. 2003). In addition, seven judges in the en banc majority concluded that a “public library’s collection decisions are government speech.” App. 28. By contrast, the Eighth Circuit has rejected the “exten[sion of] the government speech doctrine to the placement and removal of books in public school libraries.” GLBT Youth in Iowa Schools Task Force v. Reynolds, 114 F.4th 660, 667 (8th Cir. 2024). Only this Court can resolve these divisions of authority over the Free Speech Clause’s application to public libraries. 4. The Court regularly grants certiorari to resolve circuit conflicts over the application of the Free Speech Clause to government programs or official actions. See, e.g., Free Speech Coalition, Inc. v. Paxton, 145 S. Ct. 2291 (2025); Lindke v. Freed, 601 U.S. 187 (2024); Shurtleff v. City of Boston, 569 U.S. 243 (2022); Americans for Prosperity v. Bonta, 594 U.S. 595 (2021). And uncertainties about the application of the government speech doctrine have frequently required this Court’s intervention. See, e.g., Shurtleff, 569 U.S. at 251; Walker v. Texas Div., Sons of Confederate Veterans, 576 U.S. 200 (2015); Pleasant Grove City v. Summum, 555 U.S. 460 (2009). Especially given the importance of public libraries to facilitating the spread of ideas and fostering civic engagement, the question presented here warrants the Court’s intervention. 5. The application for a 30-day extension is necessary because Applicants have only recently affiliated undersigned counsel at Cooley LLP. The extension is needed for new counsel to fully familiarize themselves with the record, decision below, and relevant case law, and to allow counsel adequate time to prepare the petition for certiorari. The press of other business and deadlines means these tasks will take several weeks. 6. For these reasons, Applicants request that the due date for their petition for a writ of certiorari be extended to September 22, 2025. Respectfully submitted, By: /s/ Ephraim A. McDowell KATHERINE P. CHIARELLO BOTKIN CHIARELLO CALAF 1209 Nueces St. Austin, TX 78701 (512) 615-2341 ELLEN LEONIDA SIDEMAN & BANCROFT 1 Embarcadero Ctr., Fl. 22 San Francisco, CA 94111 (415) 392-1960 EPHRAIM A. MCDOWELL Counsel of Record ALEXANDER J. KASNER ELIAS S. KIM COooLey LLP 1299 Pennsylvania Ave., N.W. Suite 700 Washington, DC 20004 (202) 842-7800 Dated: July 24, 2025