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The Daily Targum, the student newspaper at Rutgers University and one of the oldest student newspapers in the country, had been funded through a recurring referendum since 1981.  Starting in 2017, the Rutgers Conservative Union pushed to de-fund the paper based on a sense that the Targum did not treat conservative voices equally. In 2019, for the first time since the process was implemented, the Targum failed to meet the 25% vote threshold required to receive funding, resulting in a total loss of student activity funding, amounting to approximately $540,000.

In June 2019, FIREwrote to Rutgers pointing out that the referendum mechanism was unconstitutional under the Supreme Court’s decision in Board of Regents of the University of Wisconsin System v. Southworth. In January 2020, FIREbegan working with Rutgers to reform the policy; those efforts were then placed on hold during the coronavirus pandemic, as no group faces even the potential use of the referendum until 2022.