NATIONAL ACTION



Manufactured Housing in the United States

There are about 10 million families living in manufactured homes and more than a third live in the nation's 50,000 manufactured home communities. Two thirds of the new affordable housing developed is manufactured, with comparable quality to traditional, stick-built homes and at half the cost. More people call parks home than all project-based subsidized housing and 90 percent are homeowners. However, homeowners face a range of challenges to maintaining this housing option:


APAC's National Organizing Project

APAC is the nation’s largest organization of manufactured home park residents and is the leading the charge to preserve and protect these communities in Minnesota. Since 2006, APAC has worked to also strengthen resident leadership, organizing, and advocacy in other states, including:


Other State and National Home Owner Associations

Around the country, a number of successful strategies have been developed for overcoming these challenges. Making these solutions a reality requires a base of strong, committed leaders. It requires a clear, shared vision rising from the homeowners. It requires strong local, state, and national homeowner associations and it means forging a nationwide movement to preserve these manufactured home communities.

Visit our links page to find out more about groups working in other states and nationally.

NMHOA (formerly MHOAA) National Conventions

More than half the states have statewide homeownership associations, but communication among them has been limited. In 2007, 2008, 2009, and 2015 APAC had the privilege of hosting (and in 2010 helping to organize) the national conventions of the National Manufactured Home Owners Association (NMHOA) as a way of sharing resident expertise and resources.

NMHOA National Convention



All Parks Alliance for Change (APAC) is proud to be a dues paying member of the National Manufactured Home Owners Association (NMHOA).

  • NMHOA is the nation-wide membership based organization representing and advocating for manufactured home owners.

  • Mission: The mission of the National Manufactured Home Owners Association (NMHOA) is to promote, represent, preserve, and enhance the rights and interests of manufactured home-owners throughout the United States.

  • Vision: Among the basic principles fought for by the founding fathers of this country was that of basic property rights. The owner of a manufactured home shares the same tangible investment as does the owner of a one-bedroom condominium or a fifty-room mansion. NMHOA looks forward to the day when the owner of the manufactured home is accorded the same rights and privileges as the other property owners. First and foremost is the sense of security in their community. Safeguards must be in place to ensure the home-owner’s community is safe from sale and closure without the opportunity of the community to participate in its own self determination. If self determination is not achievable, home-owners should receive fair and just compensation as a result of such actions.

  • Values: If all people lived by the Golden Rule, there would be little need to discuss values and principles. As an organization, we value the principle of treating others the way we would like to be treated. We believe in dealing honestly and treating each other with civility and kindness. We expect the same of those outside our organization and forgive the shortcomings of those who do not meet our expectations. We embrace, endorse, and celebrate our diversity. We reach out to those who we may perceive may be different from ourselves. We seek understanding and to understand. This is not limited to our gender, ethnic, cultural, and religious diversity. It extends to the diversity of thought and ideas. We encourage creativity and looking for new ways to solve old and new problems.

To learn more about MHOAA’s mission, vision, values, and other information, please click here.

APAC in NMHOA
APAC has also had the honor of being invited to both conduct the majority of the planning for the NMHOA national conventions and to participate in the development and strengthening of the organization itself.

For questions about APAC’s involvement with NMHOA or earlier conventions, please contact Dave Anderson.
Email: dave@allparksallianceforchange.org or call: 1-855-361-2722

For questions about NMHOA as an organization or to join NMHOA, please visit the NMHOA website.

2015 NMHOA National Convention


NMHOA 2015 Annual Convention


October 24-25, 2015
Minneapolis, Minnesota

The NMHOA Board of Directors announced the 2015 Annual Convention of the National Manufactured Home Owners Association will be held in Minneapolis, Minnesota from Saturday, October 24 to Sunday, October 25.

NMHOA’s annual conventions have traditionally been a time for home owners from across the country to meet together to learn from each other and from other experts about how best to address common issues facing manufactured home owners. The 2015 Annual Convention will not disappoint – there will be something for everyone – returning attendees as well as new members coming for the first time.

NMHOA hopes to provide stipends to support the attendance of two attendees from each member state. Others from member states are of course encouraged to attend as well. In addition, NMHOA state association members who are also members of CFED’s Lead Organization group will have an opportunity to attend CFED’s conference on October 26-28, after the NMHOA Annual Convention.

More details will follow as the program is shaped to accommodate the interests of manufactured home owners but rest assured that NMHOA will provide the quality programming we’ve been complimented for in the past.

2010 MHOAA National Convention

The 2010 MHOAA National Convention will be held October 22-23 in Salt Lake City, Utah.

More Details to follow.

2009 MHOAA National Convention


The 2009 MHOAA national convention took place on September 11th & 12th in Seattle, WA. The convention was a collaboration between APAC and Washington's Association of Manufactured Home Owners (AMHO). More information about AMHO can be found at: www.wamho.org



Any questions regarding the convention may be directed to Dave Anderson at dave@allparksallianceforchange.org or call toll free 1-855-361-2722.

2008 MHOAA National Convention


National Leaders Converge in Minnesota

This year’s Manufactured Homeowners Association of America (MHOAA) national convention was a fantastic success! With over 100 participants, the 2008 convention was the best attended MHOAA event to date– an increase of over 30% from last year and up 60% from the year before. Residents from 25 different homeowner groups and representatives from 24 allied organizations came together in Bloomington, Minnesota, from over 25 states to exchange expertise, ideas, history, energy, and new friendships for two days during the weekend of October 3rd and 4th.

[slideshow]

We conducted in-depth surveys with homeowners from across the nation to determine what they hoped to gain from a national meeting of the minds; and this year’s list of topics was challenging, broad, and invigorating! We benefited from homeowner and ally expertise across the nation to develop workshops, panels, and motivational speakers around issues of:

  • Building Multi-Racial Alliances – The Path to Power
  • Park preservation strategies – including: the Federal Fair Housing Act (FFHA), zoning, resident owned communities, and more.
  • Members – how to maintain, increase, and activate!
  • Fear factor – stories & methods of dealing with intimidation, harassment, & retaliation
  • Organizing in Latino communities
  • Legislation – sharing from other states, passing your own, analysis of national possibilities
  • MHOAA as a strong national organization
  • Developing regional working groups
  • Money – grant writing, fundraisers, member dues, and more
  • Organizing tools – power analysis, leadership styles, etc.
  • Law enforcement & compliance
  • Media strategies
  • State homeowners association development

      Find a full agenda and list of speakers in the attachment below.

      Generous funding from CFED provided full and partial scholarships to over 40 homeowners – granting the means by which many participants were able to attend, including dozens of new voices. A particularly key point of growth at this convention was the presence of out of state resident leaders and allies with whom, until now, APAC leadership and staff have had limited or no interactions.

      The convention wouldn’t have been the same without their input and presence, and we thank both the homeowners for taking the time and CFED for recognizing that homeowners are the key voice in the mobile justice movement.

      The following are links to the session notes and handouts. However, this year's convention did not produce a high volume of notes. If you have questions about a particular workshop, please contact one of the panelists as listed on the "Notes, Simplified Agenda, PDF" attachment below.

      2008 MHOAA National Convention Scholarship

      Attention: The scholarship deadline has been extended to FRIDAY, AUGUST 1st!

      Please read these instructions and complete ALL forms prior to AUGUST 1, 2008. Failure to do so may result in loss of scholarship.

      Board Approval

      The scholarship will be awarded to the state homeowners’ association (HOA); rather than on an individual basis. Each state HOA may qualify for up to two scholarships. The board of said state HOA must demonstrate organizational support of the individuals homeowners attending from their group or state. As such, the board must fill out the form below in order for the scholarship to be approved.

      When considering who to send from your organization, we recommend that individual(s) are interested in and able to:
      - share information from their own state;
      - listen to and retain information gained at the convention; and
      - commit to reporting back any information or contacts gathered at the convention for the benefit of those who could not attend.

      Types of Scholarships

      There is a limited pool of money potentially available to cover the following costs: travel expenses (airfare or gas), lodging fees (hotel costs), and the conference registration fee. To reduce costs, all scholarship recipients should expect to share a room. S/he may choose her/his own roommate, or, if there is no preference, we will pick someone of the same gender. If the recipient has concerns about this, please contact the APAC office to discuss.

      Please note that any portion of these expenses that you are able to pay for yourself will result in monies available for those that cannot cover any of their costs. The less you are able to accept, the more homeowners we can bring to the convention.

      MHOAA Membership

      It is required that all recipients apply for MHOAA membership. To receive a scholarship, your organization must have filled out a MHOAA membership form and paid their first year’s dues. The MHOAA membership application can be found on the MHOAA website at: MHOAA Application for Membership

      MHOAA membership is $75 for the first year, and $150 each year thereafter. A copy of the filled out application and the check to MHOAA will be required as evidence of having applied.

2007 MHOAA National Convention


On behalf of All Parks Alliance for Change, we thank you for attending the 2007 National Convention of the Manufactured Home Owners Association of America on September 14-16, 2007. It was our pleasure to play host and we are grateful that so many people went to the time and trouble to not only attend but to contribute so much to the event. The theme for the convention was "Build A Vision. Build A Base. Build A Movement." It was our intention for this event that it provide a first step in crafting a national homeowner vision and establishing priorities for base building and movement building. We are off to a great start!

[slideshow]

By all accounts, this was the best MHOAA convention ever! There were nearly 70 people, mostly residents, from about 20 states. There was a wide-ranging set of speakers and panels that all drew strong attendance and featured 31 presenters, again mostly residents. Everyone had a chance to pick up new information and form new relationships. Just as importantly, we left with a set of identified goals and actions, as well as the following strategic vision:

  • Home owners set the agenda on issues that affect them.
  • State HOAs have the resources to be effective.
  • Park prejudice eliminated as a set of structural and institutional biases.
  • No stigma associated with manufactured home living.
  • Resident ownership of the land.
  • Fair rent for affordable housing.

Some of the action steps identified to act on this vision during the next year, included:

  • Producing coverage of the manufactured home owners’ plight during the presidential campaign.
  • Setting up a communication network for MHOAA and member organizations.
  • Making active contact with all state HOAs.
  • Hiring a MHOAA grant writer and providing grant writing assistance.
  • Implementing the “APAC model” (adequate resources, paid staff, strong organizing, etc.) in three additional states.
  • Proposing or supporting federal public policy change.
  • Increasing racial and other diversity within MHOAA and at next year’s national convention.
  • Developing a system for generating 30 or more phone calls whenever the media uses the “T” word.
  • State HOAs encouraging at least three more nonprofits to provide technical assistance for ROCs.

Ultimately, this vision and these goals are only as meaningful as our follow through. It is important to ensure prompt, regular and consistent follow up to take advantage of this enthusiasm and momentum. Enclosed you will find information that should be of assistance in following up – or catching up, for those of you unable to attend – with various people and organizations. We have put together the contact information for all attendees, all other materials generated for and from the convention, and typed up the notes from the sessions.

Some of the follow up steps we could all take together include:

  • Dedicating web space to national home owner association work, including details and updates on the strategic plan’s vision, strategy, goals, and actions.
  • Establishing regular communication systems for MHOAA and member organizations, including newsletters, conference calls, list serves, bulletin boards, blogs, chat rooms, etc.
  • Providing oversight through the MHOAA board of directors, which includes establishing regular monthly meetings, and identifying concrete steps each month to advance the strategic plan.
  • Engaging a broad range of home owners in implementing the strategic plan by identifying individual commitments, conducting follow up, and providing regular updates.
  • Conducting active outreach to involve all state HOAs in the ongoing development and implementation of the strategic plan.
  • Identifying capacity building needs and resources for MHOAA and member organizations, as well as directly meeting some of those needs through training, advise, support, etc.

APAC is currently in the process of completing an organizing manual and training curriculum; covering topics such as establishing a shared vision, building a constituent base, developing leadership, forming homeowner associations, formulating strategies and tactics, developing messaging strategies, and advancing policy change. We anticipate releasing this book both online and in print in November 2007.

Thank-you again for attending the 2007 MHOAA national convention in Minnesota! We look forward to our continued work together for Mobile Justice!

[DISCLAIMER: The notes, which are available for download below, are simply what happened to be written down by a leader in any given session and are necessarily incomplete. We have included the speaker or panelists names for each session, please contact them for more complete information if you are interested in "de-coding" any particular subject. The convention book is available for download here.

2007 MHOAA National Convention Announcement & Materials

September 14-16, 2007
Ramada Mall of America
Bloomington, MN

More than 10 million American families live in manufactured homes and more than a third of them live in the nation’s 50,000 manufactured home parks. Two thirds of new affordable housing is manufactured, with comparable quality to traditional, stick-built homes and at half the cost. More people call parks home than all project-based subsidized housing and 90 percent are homeowners.

However, homeowners face a range of challenges to maintaining this housing option:

• Increasing land values and redevelopment pressures
• Lack of park owner reinvestment and deteriorating infrastructure
• Rising rents and home financing interest rates that reduce affordability
• Few resources dedicated to solving these problems and increasing homeowner rights

Around the country, there are homeowners, housing and consumer advocates, developers of affordable housing, policy makers, and others with solutions to share. Making these solutions a reality requires a base of strong, committed leaders. It requires a clear, shared vision rising from the homeowners. It requires strong local, state, and national homeowner associations and it means forging a nationwide movement for justice.

North Dakota Resident Organizing



Background

In early 2016, within a few months of their first meeting, Fargo residents formed the Fargo Area Park Resident Association (FAPRA). In 2019, Fargo and Bismarck residents, with some outreach to Grand Forks residents, started forming the North Dakota Manufactured Home Owners Association (NMHOA), although the process has been slowed by the pandemic. Prior to these efforts, no groups had existed in North Dakota that specifically advocated for the rights of manufactured home park residents. The organizations began with support from the National Manufactured Home Owners Association (NMHOA) and All Parks Alliance for Change (APAC), the association from Minnesota's park residents.

Fargo Area Park Resident Association (FAPRA)

The group is made up of manufactured home park residents in the Fargo area, and they’ve already accomplished much despite limited resources, with some assistance from APAC and NMHOA:

  • In 2016, residents from several mobile home parks meet to form the Fargo Area Park Resident Association (FAPRA), an organization that brings together people from throughout the city to work on the shared concerns of park residents.
  • FAPRA established monthly meetings to discuss ways of improving life in Fargo’s mobile home parks and takes actions in between meetings to promote both responsible home ownership and responsible park management.
  • Since 2016, FAPRA has worked with Fargo Cass Public Health to inspect the city’s parks and enforce corrections to some of the most obvious problems facing Fargo area parks, including potholes.
  • In 2017, FAPRA worked with Fargo-area state legislators to introduce a bill that would limit the reasons for eviction from a mobile home park to only those that represent good cause.
  • In 2017, FAPRA worked with Legal Services of North Dakota, All Parks Alliance for Change (APAC), and the National Manufactured Home Owners Association (NMHOA) to draft a legal rights handbook that explains in plain English the state laws that apply to mobile homes, mobile home parks, and tenant-landlord laws related to renting a lot.
  • In 2018, FAPRA met with city and county officials to discuss resident concerns. The discussions included a city commissioner, the police department, and the county sheriff’s office.
  • In 2019, FAPRA worked with Fargo-area state legislators to introduce two bills that would protect residents from eviction without good cause, non-renewal of their leases without cause, unfair utility billing practices, park liens placed on residents’ homes, and retaliation for filing a complaint or exercising their legal rights.


North Dakota Manufactured Home Owners Association (NDMHOA)

NDMHOA is the statewide organization for manufactured (mobile) home park residents. The North Dakota Department of Health licenses 400 park communities throughout the state. The organization represents one out of every 10 households in the state. We are long-time, self-sufficient home owners. Since 2019, residents have, with the help of APAC and NMHOA, have begun to make progress for residents, including:

  • In 2019, residents from several mobile home parks met to form the North Dakota Manufactured Home Owners Association (MDMHOA), an organization that brings together people from throughout the state to work on the shared concerns of park residents.
  • NDMHOA established monthly meetings to discuss ways of improving life in the state’s mobile home parks and takes actions in between meetings to promote both responsible home ownership and responsible park management.
  • NDMHOA organized legal rights workshops, in conjunction with Legal Services of North Dakota, to educate residents about their rights and respond to actions being taken by Havenpark Capital.
  • In 2021, NDMHOA worked with state legislators to introduce two bills that would protect residents from eviction without good cause, non-renewal of their leases without cause, park liens placed on residents’ homes, and retaliation for filing a complaint or exercising their legal rights.


North Dakota Mobile & Manufactured Home Park Handbook (2017)

Another accomplishment of FAPRA, APAC and NMHOA is the creation of a comprehensive guide to the relevant laws for manufactured home park residents in Fargo. The guide includes information from tenant landlord law, discrimination law, and the regulations for manufactured home parks in an easy-to-read and easy-to-reference (most of the information includes citations) format. An attorney from Legal Services of North Dakota assisted with the creation of the guide.


Click the LINK below for a PDF version of the guide.

North Dakota Mobile & Manufactured Home Park Handbook (2017) (pdf)

Northwest Region Project


Working with the Northwest Area Foundation, APAC began a National Resident Organizing Project in December 2006. The project's goal is to build inclusive decision-making and organizing capacity for manufactured home communities in the foundation's eight-state region as a strategy for placing residents in the driver's seat of advancing their rights and securing long-term community preservation. As the project continues, APAC will develop and provide:

Organizing Resources
APAC is finalizing training curricula and an organizing manual that will be shared with all the states in the northwest region, covering topics such as establishing a shared vision, building a constituent base, developing leadership, forming homeowner associations, formulating strategies and tactics, developing messaging strategies, and advancing policy change. These materials will be produced not only for homeowners and homeowner associations, but for nonprofit professionals to better understand resident concerns and how to effectively work with them, including housing and consumer advocates, public interest law firms, community housing development organizations, and others. They will be available in print and on our web site.

Targeted In-State Training, Networking and Support
The involves identifying target states for one-year of in-state training, networking and support based on need, interest and commitment. We will conduct a series of three to five day on-site training and goal-setting sessions in each of the states. All members of our staff will be available for follow up and questions throughout the year, but we will also designate a primary contact.


Idaho

Relevant State Laws
www.legislature.idaho.gov

Manufactured Home Parks
www.mobilehomeparkstore.com/directory/listidaho.htm

Demographic Information
www.indicators.nwaf.org/DrawRegion.aspx?RegionID=16000&IndicatorID=100014

Key Organizations

  • Idaho Legal Aid Services
  • AARP Idaho
  • Idaho Housing & Finance Authority
  • Inter Mountain Fair Housing Council
  • Neighborhood Housing Services
  • SAGE Community Resources

Iowa

Manufactured Home Parks
www.mobilehomeparkstore.com/directory/listiowa.htm

Demographic Information
www.indicators.nwaf.org/DrawRegion.aspx?RegionID=19000

Key Organizations

  • Community Housing Initiatives
  • Iowa Coalition for Housing & the Homeless
  • Iowa Legal Aid
  • Neighborhood Finance Corp
  • Terrace Heights Residents Association

Montana

Relevant State Laws
http://data.opi.state.mt.us/bills/mca/70/24/70-24-436.htm

Manufactured Home Parks
www.mobilehomeparkstore.com/directory/listmontana.htm

Demographic Information
www.indicators.nwaf.org/DrawRegion.aspx?IndicatorID=100014&RegionID=30000

Key Organizations

  • Alliance for Building Communities
  • Human Resources Development Council District 7
  • Montana Home Choice Coalition/AWARE
  • Montana HomeOwnership Network, NeighborWorks
  • Montana Legal Services Association
  • Montana People's Action
  • Neighborhood Housing Services Inc. of Great Falls
  • Working for Equality and Economic Liberation

North Dakota

Relevant State Laws
www.legis.nd.gov/cencode/t23c10.pdf

Manufactured Home Parks
www.mobilehomeparkstore.com/directory/listnorthdakotamhp.htm

Demographic Information
www.indicators.nwaf.org/DrawRegion.aspx?IndicatorID=100014&RegionID=38000

Key Organizations

  • People Escaping Poverty Project
  • CommunityWorks North Dakota
  • Minot Mobile Home Tenants Association Inc

Oregon

Relevant State Laws
www.leg.state.or.us/ors/090.html

Manufactured Home Parks
www.mobilehomeparkstore.com/directory/listoregon.htm

Demographic Information
www.indicators.nwaf.org/DrawRegion.aspx?IndicatorID=100014&RegionID=41000

Key Organizations

  • Oregon State Mobile Home Owners Association
  • Oregon Manufactured Homeowners United
  • Community And Shelter Assistance Corporation (CASA of Oregon)
  • Lane County Legal Aid Services
  • NeighborImpact
  • Portland Housing Center
  • Umpqua CDC
  • Willamette Neighborhood Housing Services

South Dakota

Manufactured Home Parks
www.mobilehomeparkstore.com/directory/listsouthdakotamhp.htm

Demographic Information
www.indicators.nwaf.org/DrawRegion.aspx?IndicatorID=100014&RegionID=46000

Key Organizations

  • Neighborhood Housing Services of the Black Hills, Inc

Washington

Relevant State Laws
http://apps.leg.wa.gov/RCW/default.aspx?cite=59.20

Manufactured Home Parks
www.mobilehomeparkstore.com/directory/listwashingtonmhps.htm

Demographic Information
www.indicators.nwaf.org/DrawRegion.aspx?IndicatorID=100014&RegionID=53000

Key Organizations

  • Columbia Legal Services
  • Mobile Home Owners of America, Inc. (MHOA)
  • SOS Homeowner’s Association
  • Central Area Development Association
  • Community Frameworks
  • HomeSight
  • Low Income Housing Institute
  • NeighborWorks of Grays Harbor County
  • Northwest Federation of Community Organizations




Tammy Hoth Stands Up for Resident Rights and Charges are Dropped!

45-Year Old Mother and Community Leader Arrested for Exercising Her First Amendment Rights



Early January of 2008, Montana community leader Tammy Hoth turned herself in in response to a warrant for her arrest issued by the Billings, MT police department. Ms. Hoth was handcuffed, searched, had her fingerprints and mug shot taken, and was released on a bond posted at nearly $600. If convicted, she faced a maximum penalty of $500, and six months in jail.

Her imprisonable crime? Passing out leaflets in Casa Village Manufactured Home Community. The leaflets advertised a meeting where residents could learn about their legal rights and strategize how to improve their community. Officially, Ms. Hoth’s “crime,” pressed by Casa Village manager Susie Cole, was Criminal Trespass to Property (Section 45-6-203(1)(b), Montana Code Annotated).

Ms. Hoth is a 45 year old single mother who has been working with her neighbors in Red Lodge, Montana to purchase her own park and to form the state's first manufactured housing cooperative. Additionally, Tammy has been volunteering her time to help other manufactured home park residents become aware of their rights, and of opportunities to own not only their homes, but the land as well. She has led workshops to educate over 175 residents of manufactured home parks. Recently, her own park, Mountain Springs Villa, received a grant nearing half a million dollars to renovate and move their newly formed cooperative.

Ms. Hoth was targeted by park owners and the City for simply passing out information – an act clearly protected by her First Amendment rights. The unfortunate message from the City of Billings is clear – if you live in a manufactured home park, it is a crime for anyone to inform you of your rights, or contact you in person for any reason.

If the statute is read literally, it gives park owners absolute control over the type of information residents have access to and who may or may not enter. Under this argument, if a park owner didn't like your grandmother she or he could put your grandmother in jail for visiting you.

There is, in fact, case law (see Folgueras v. Hassle, Marsh v. Alabama) related to this issue. As an example, Folgueras v Hassle (related to migrant workers living as tenants on the owner's land) concluded:

"The fundamental underlying principle is simply that…real property ownership does not vest the owner with dominion over the lives of those people living on his property. They are…citizens of the United States and tenants. As such they are entitled to the kinds of communications, associations, and friendships guaranteed to all citizens, and secured by the Constitution. The owner's property rights do not divest the migrants of these rights."

Determined to stand up for herself and the rights of all residents, Ms. Hoth pled not guilty and requested a public defender and a jury trial. During the following five months, Ms. Hoth used her vacation time and paid out of pocket for gas to go to a variety of hearings and calendar calls at the Billings court house, an hour and a half drive from her home in Red Lodge, MT.

APAC assisted Ms. Hoth in generating statewide press coverage; a national call-in campaign to the city attorney and mayor of Billings that generated dozens of calls and emails from organizations and residents alike; and nearly 200 post cards to the city attorney and mayor. APAC also assisted Ms. Hoth in finding many local allies, including Montana People’s Action, neighborhood organizations, other manufactured home communities, church members, and current and former state congresspeople.

On Friday, May 2nd, Ms. Hoth called the APAC office with the good news that Susie Cole had agreed to drop the charges against her, if Ms. Hoth signed paperwork agreeing not to enter Casa Village for a period of one year. Ms. Hoth agreed to this condition, knowing that as she was still able to meet with Casa Village residents outside of the park it would not impede her continued commitment to inform and organize interested Casa Village residents.

Although Ms. Hoth is no longer in danger of imprisonment, the danger still exists for any persons trying to inform and organize residents in any capacity; be this a get out the vote drive or a resident meeting. Montana, like many states, and unlike Minnesota (see MN Statute 327C.13), does not have a statewide freedom of expression law. North Dakota does not have this protection either, an important freedom to note as we are starting a three year organizing project in the state. Without the ability to inform and organize, concerned persons, including APAC staff and leaders, are risking arrest every time they step into a park in one of these states. Furthermore, if residents in states with few protections are to have a real shot at gaining rights such as relocation compensation, right of first refusal, and protection from retaliation; it is clear that first step will have to be to gain freedom of expression. There are lots of Susie Coles out there.