Movement Architecture: a federal judge let a conspiracy suit proceed alleging American Muslims for Palestine funded and ran the 'spontaneous' campus encampments

For two years, the campus protest movement has pushed one claim. The 2024 encampments, it says, were a spontaneous student awakening. On April 1, 2026, a federal judge in Manhattan let a lawsuit go forward that says the reverse: the encampments were a network that an outside group funded, trained, and ran. The case is Horowitz v. AJP Educational Foundation, Inc. (No. 1:25-cv-03412). U.S. District Judge Andrew L. Carter Jr. of the Southern District of New York (SDNY) denied the motion to dismiss the civil-conspiracy claim. The claim names two groups. The first is AJP Educational Foundation — which does business as American Muslims for Palestine, or AMP. The second is National Students for Justice in Palestine (NSJP) — the national parent that charters the local SJP chapters. The judge wrote that, read most favorably to the plaintiff, “the allegations in the Complaint are sufficient to make out a prima facie case of conspiracy.”

Read that ruling closely, because the gap between what the court did and did not do is the whole story. The court did not find that AMP funded the encampments. It found that the plaintiff alleged it well enough to reach discovery. That plaintiff is Ami Horowitz, a conservative activist filmmaker. His complaint says he was beaten at the City College of New York (CCNY) encampment on April 26, 2024. His complaint alleges that AMP “not only issued directives to the encampments, but it also provided funding, training resources, and social media support.” It alleges that AMP “intentionally participated in the common plan to defend the encampments.” A motion to dismiss tests one thing: whether a story, if true, states a legal claim. Judge Carter ruled that it does.

That is a low bar. It is also the bar that the “spontaneous, leaderless, student-led” story of the encampments was built to make impossible to clear. A federal court has now ruled that it was cleared. The command-and-control architecture of the encampment wave is the live legal question. It is the one thing the movement most needs to keep out of the discovery file.

What the court actually held — and what it did not

A court letting an allegation proceed is the opposite of a court finding a fact. Blur the two, and a real ruling becomes a fake one. So the line has to be drawn hard. At the pleading stage, a judge assumes the complaint’s facts are true. The judge then asks one question: would those facts, if proven, amount to a claim the law recognizes? Judge Carter did exactly that, and no more. He made no finding that AMP issued a single directive, wired a single dollar, or trained a single protester. He held only that the conspiracy allegations — taken as true for the motion — clear the bar to proceed.

The ruling was not a clean win for the plaintiff. Horowitz had pleaded a second theory: that AMP and NSJP aided and abetted the assault and battery on him at CCNY. Judge Carter dismissed that claim. And the court’s most skeptical words attach to that dismissed claim, not to the surviving one. The opinion said the court was “skeptical that Plaintiff could amend” the already-long complaint to revive the aiding-and-abetting theory. It still allowed an amendment attempt by the April 10, 2026 deadline. The conspiracy count survived. The assault-aiding count did not. Anyone who cites this ruling has to keep those two halves apart, or they are misstating it.

The surviving count also has a defined object: the alleged “common plan to defend the encampments.” The dismissed theory was the one tying AMP to Horowitz’s beating. The conspiracy that lived is narrower than the sweeping “funded, trained, and directed.” Discovery is where it gets tested.

The post that brought the ruling to wide attention was written by Eugene Volokh, the law professor behind the Volokh Conspiracy at Reason.

The allegation: a centrally managed network, not a spontaneous one

The marquee phrase in this case is the plaintiff’s, and it has to be labeled as the plaintiff’s. The Dhillon Law Group represents Horowitz. By its account, the complaint alleges that AMP and NSJP “coordinate hundreds of student chapters and affiliates across the United States as part of a centrally managed, nationwide activist network.” That is the allegation the conspiracy claim rests on. At this stage, it is not a proven fact. It is the thing the lawsuit now gets to try to prove.

But the structure that allegation describes does not need the lawsuit to be seen. Sources with no stake in Horowitz’s case have documented it for years. They are pro-Israel research shops, openly so. But they work from the public record, not the complaint. NGO Monitor, one of them, tracks the funding and conduct of advocacy NGOs. It reports that AMP “offers significant support to Students for Justice in Palestine.” AMP does this by “speaking at SJP campus events,” “organizing conferences and seminars for SJP chapters,” and “facilitating the SJP National Convention.” NGO Monitor also notes that AMP’s president, Hatem Bazian, co-founded Students for Justice in Palestine. A group that runs a “student” movement’s national convention — and was led by that movement’s co-founder — is not an arm’s-length bystander. That is the bond the complaint calls a conspiracy and the public record calls an institutional fact.

The money fits the same shape. The Institute for the Study of Global Antisemitism and Policy (ISGAP), a pro-Israel research group, studied National SJP in its May 2024 report. By its count, over $3 million a year flows to NSJP from a web of nonprofits accused of funding Hamas. ISGAP names AMP itself as one of the groups in that web. That figure is ISGAP’s own. It rests on this one report, and no one outside the group has checked it.

The movement’s own paperwork describes a deliberate build, not a spontaneous bloom. NGO Monitor’s funding analysis shows that National SJP runs its money through a fiscal sponsor — an outside nonprofit (the WESPAC Foundation) that holds the group’s funds and legal status. In 2022, National SJP took a $20,000 Sparkplug Foundation grant explicitly to “restructure the student movement.” Its stated aim was to give it “a representative decision-making body, regional and national communication networks, and shared resources, unifying SJPs across North America for the first time.” Movements that are restructured by grant are organized. They are not spontaneous. That is the paper spine under the allegation the court let proceed.

Organized is not the same as in command. These records prove SJP is funded and structured. They do not, on their own, prove that AMP directed the 2024 encampments. That is the exact claim the lawsuit must now try to prove.

Why the spontaneity story was always load-bearing

The encampments were sold as an uprising — leaderless, organic, the student conscience made visible. That framing was not decoration. It was the asset. A spontaneous moral awakening is hard to hold to account. There is no org chart to subpoena, no budget to trace, no defendant to name. But the moment the structure becomes the story, the movement changes. Then come the questions. Who funded it? Who trained it? Who wrote the toolkits, talking points, and legal-defense scripts that appeared, near-identical, on campus after campus? A mood becomes an organization with a paper trail. And organizations can be sued, investigated, and made to disclose.

This is an old playbook, now running in the open on American campuses. The encampment movement traces it to October 7, 2023 — the day Hamas started this war. Its parts are simple: a chosen cause (Palestine), a named enemy (Israel), and an in-group (SJP’s chapters). That in-group needs its structure to look like a feeling, not a chain of command. The Horowitz ruling is a crack in that surface. So is the fact that this is not the only legal pressure on AMP. Three separate tracks now bear on the group, and they must not be merged.

The first is this SDNY conspiracy ruling. The second is entirely distinct. It is an Anti-Terrorism Act suit, filed May 1, 2024 in the Eastern District of Virginia. Nine American and Israeli survivors of the October 7 attack brought it. They are represented by Greenberg Traurig, the National Jewish Advocacy Center, the Schoen Law Firm, and Holtzman Vogel. The suit alleges that AMP and NSJP provide material support to Hamas. The third is a state matter. Virginia Attorney General Jason Miyares opened a charitable-oversight investigation. As The Algemeiner reported in May 2025, a Virginia judge ordered AMP to disclose its funding sources. Three forums, three legal questions, one organization — and its finances and coordinating role are the contested object in all of them.

What this is not

It would be dishonest to overclaim here. AMP and NSJP have not been found liable for anything. The conspiracy allegation may fail at summary judgment or at trial. Discovery may show the “centrally managed network” is looser, or more deniable, than the complaint claims. A court found the claim plausible enough to litigate — not that AMP is guilty. That is a smaller thing, and still a significant one, because the spontaneity story was built to make even that impossible.

The honest verdict is the narrow one, and it holds. The encampment wave’s command-and-control is now a live question in a federal court. The allegation that AMP funded, trained, and coordinated the network has survived a motion to dismiss. The architecture is the story, and the movement knew it before we did.

How we’d be wrong — and what would force a correction

This is an investigation, and it carries its falsifiers on its face. The central claim is bounded. A federal court let a conspiracy allegation proceed past dismissal. It did not find the underlying facts. We would revise or retract if any of the following proved true:

1. The docket in Horowitz v. AJP Educational Foundation (No. 1:25-cv-03412) shows the conspiracy claim was in fact dismissed, not the aiding-and-abetting assault claim. Or it shows the “prima facie case of conspiracy” language has been mischaracterized.
2. The court’s “skeptical that Plaintiff could amend” language in fact attaches to the conspiracy claim — not to the dismissed assault claim.
3. The supporting facts are misattributed or retracted by their publishers: AMP’s role running SJP’s convention and seminars, the ISGAP funding figure, or the WESPAC/Sparkplug restructuring grants.
4. Discovery establishes that the “centrally managed, nationwide activist network” allegation is false. If it does, we will say so as plainly as we said it survived.

Where to check every claim

• The ruling. Eugene Volokh’s April 1, 2026 post at the Volokh Conspiracy on Reason reports it, with the key quotes. Read it for the court’s own words on the “prima facie case of conspiracy” and on the dismissed aiding-and-abetting claim. The docket is Horowitz v. AJP Educational Foundation, Inc., No. 1:25-cv-03412 (S.D.N.Y.); the full opinion sits there on PACER, and we quote it through Volokh’s report until the order is posted publicly.
• The plaintiff’s framing. The Dhillon Law Group’s case page sets out the “centrally managed, nationwide activist network” allegation. Read it as the complaint’s framing, which is what it is.
• The structure underneath, independent of the suit. NGO Monitor’s profile of American Muslims for Palestine documents AMP’s support role to SJP and Bazian’s co-founding of SJP. NGO Monitor’s funding analysis documents WESPAC as National SJP’s fiscal sponsor and the 2022 Sparkplug “restructure the student movement” grant. ISGAP’s May 2024 report documents the over-$3-million-a-year figure for National SJP.
• The separate Virginia track. The Algemeiner’s May 2025 report covers the order compelling AMP to disclose its funding sources.

Read the ruling, then the complaint, then what NGO Monitor and ISGAP documented before any of these lawsuits were filed. Then ask whether “spontaneous” was ever the word for any of it.

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The world does not get safer when an organized campaign calls itself a spontaneous feeling. It gets safer when the structure is named and the funding is traced. It gets safer when the people who built the machine are made to answer for it. The right side here never belonged to those who said “it was just students” while the toolkits arrived on schedule. It belongs to the people willing to ask who wrote the toolkits.

A federal court did not find that AMP funded, trained, and directed the encampments. It found that the claim is plausible enough to be tried. That came over an insistence, repeated for two years, that the encampments were spontaneous, leaderless, and student-led — that there was no one to try. AMP runs SJP’s convention. WESPAC sponsors National SJP. A grant was taken to “restructure the student movement.” Those are not allegations; they are the public record. The allegation is only that the record adds up to a conspiracy. And a federal judge has now ruled it adds up well enough to proceed.

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