SUPERIOR COURT OF RIDGEWAY
STATE OF RIDGEWAY,
Plaintiff,
v.
CARNAGECULTURE, Colonel of the
Ridgeway State Police, in his individual
capacity,
Defendants.
Civil Action No. RSC-CV-____
COMPLAINT FOR DECLARATORY RELIEF
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FACTUAL BACKGROUND
1. The Comprehensive Firearms Act, S6-21, 1st. Cong. (2025) (the “CFA”) provides
that persons seeking to own firearms “capably of fully automatic fire * * * [must obtain] an
Advanced Firearms License.” Id. § 5.1(a).
2. Although fully automatic firearms are not considered arms protected under the 2nd
Amendment, Advanced Firearms Licenses (“AFLs”) nonetheless afford citizens the unique
opportunity to enjoy such arms; and holders of AFLs are entitled to due process before they are
deprived of their licenses. CFA, § 5.2(d)(i) (“There shall be due process for the revocation of an
active AFL.”) See also U.S. CONST. amend. XIV (“No State shall * * * deprive any person of life,
liberty, or property without due process of law.”) (emphasis added).
3. The CFA gives the Colonel of the Ridgeway State Police the power to “revoke an
active AFL.” Id. § 5.2(d)
4. Since July 7, 2025, the Colonel has revoked around 73 active AFLs due to the
license holders having one or more arrest records. But these arrest records never resulted in charges
or conviction in a court of law. Moreover, in all 73 cases, the Colonel suspended the license
holders’ AFLs without notice or opportunity for a hearing; only after the AFLs were suspended
were the license holders given the opportunity to submit a statement of appeal. (A true and correct
copy of the AFL revocations is attached hereto as Exhibit A).
PARTIES
5. Plaintiff State of Ridgeway is a sovereign state of the United States.
6. Defendant CarnageCulture is the Colonel of the Ridgeway State Police and is sued
in his individual capacity for declaratory and injunctive relief. Defendant’s actions and omissions
herein are unconstitutional and deprive a substantial number of the State of Ridgeway’s citizens of
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their legal rights under the CFA and the U.S. Constitution.1
JURISDICTION AND VENUE
7. Jurisdiction is conferred on this Court by art. V, § 5 of the Ridgeway Constitution.
The Court’s jurisdiction is invoked in equity and a live controversy exists between Plaintiff State
of Ridgeway and Defendant CarnageCulture.
8. Venue is proper in this Court because a substantial part of the actions or omissions
herein occurred in Ridgeway County, Ridgeway.
CAUSES OF ACTION
Count I: Deprivation of Rights (Procedural Due Process)
In Violation of the U.S. Constitution,
Fifth and/or Fourteenth Amendments
and the Comprehensive Firearms Act
1 R. Stat. § 3115
Against Defendant CarnageCulture, in his Individual Capacity
9. Plaintiff State of Ridgeway repeats and realleges paragraphs 1-8 above.
10. Defendant CarnageCulture is the Colonel of the Ridgeway State Police and acted
under color of law at all times herein.
11. Since July 7, 2025, Defendant CarnageCulture has suspended about 73 active AFLs
1 See, e.g., Ex parte Young, 209 U.S. 123, 160 (1960) (a public official who “comes into conflict
with” the U.S. Constitution “is stripped of his official or representative character, and is subjected
in his person to the consequences of his individual conduct.”) Compare Pennhurst State School
and Hospital v. Halderman, 465 U.S. 89, 153 (BRENNAN, J., dissenting) (“[T]he actions of state
officials are * * * ultra vires in two different types of situations: (1) when the official is engaged
in conduct that the sovereign has not authorized, and (2) when he has engaged in conduct that the
sovereign has forbidden.”) (emphasis added). A sovereign, like any other principal, cannot
authorize its agent to violate the law. When an agent does so, “his actions are considered ultra vires
and he is liable for his own conduct under the law of agency.” Id.
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without prior notice or opportunity for a hearing. After suspension, the former license holders are
given 24 hours to submit a “statement of appeal” to challenge the suspension.
12. Under the CFA and Fourteenth Amendment to the U.S. Constitution, license
holders are entitled to “due process of law” prior to being deprived of their AFLs. CFA, § 5.2(d)(i)
(“There shall be due process for the revocation of an active AFL.”) See also U.S. CONST. amend.
XIV (“No State shall * * * deprive any person of life, liberty, or property without due process of
law.”) (emphasis added).
13. Due process of law requires a pre-deprivation hearing. Mullane v. Central Hanover
Bank & Trust Co., 339 US, at 314 (holding that the deprivation of life, liberty or property must at
a minimum be preceded by “notice and opportunity for hearing appropriate to the nature of the
case.”) So-called post-deprivation hearings are allowed only where quick action by the state is
essential or pre-deprivation hearings are impracticable. See Logan v. Zimmerman Brush Co., 455
U.S. 422, 436 (1982) (pre-deprivation hearing required absent “quick action by the State or the
impracticality of providing any pre-deprivation process”) (emphasis added).
14. Defendant CarnageCulture’s practice of revoking tens of citizens’ AFLs without
prior notice and an opportunity to be heard is not justified by the need for “quick action” by the
state; nor would it be “impractica[ble]” to afford license holders notice and an opportunity to be
heard prior to revoking their AFLs. Id. Accordingly, this conduct is unconstitutional and deprives
the countless citizens of due process under the CFA and the Fourteenth Amendment.
15. The State of Ridgeway has a parens patriae interest in ensuring that its general
population is not deprived of its rights under the CFA and U.S. Constitution. See Alfred L. Snapp
& Son, Inc. v. Puerto Rico ex rel. Barez, 458 U.S. 592, 608 (1982) (“[A] State does have a [parens
patriae] interest, independent of the benefits that might accrue to any particular individual, in
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assuring that the benefits of the federal system are not denied to its general population.”)
(emphasis added). Here, the State has parens patriae standing to sue because a significant
number—around 73 AFL holders—were deprived of their AFLs without the due process rights
afforded to them under both state and federal law.
16. Aside from the state’s parens patriae interests in promoting the general welfare and
rights of its citizens, Defendant CarnageCulture’s aberration from the due process guarantees of
the CFA and U.S. Constitution also cause irreparable injury to the State of Ridgeway’s sovereign
interests. See Maryland v. King, 567 U. S. 1301, 1303 (ROBERTS, C. J., in chambers) (“‘[A]ny time
a State is [prevented] from effectuating statutes enacted by representatives of its people, it suffers
a form of irreparable injury’” (alteration in original)); Chiles v. Thornburgh, 865 F. 2d 1197, 1208
(11th Cir. 1989) (a state has standing to challenge “an injury to its sovereign interest, that is its
ability to exercise its power”).
Count II: Deprivation of Rights (Procedural Due Process)
In Violation of the U.S. Constitution,
Fifth and/or Fourteenth Amendments
1 R. Stat. § 3115
Against Defendant CarnageCulture, in his Individual Capacity
17. Plaintiff State of Ridgeway repeats and realleges paragraphs 1-8 above.
18. Defendant CarnageCulture is the Colonel of the Ridgeway State Police and acted
under color of law at all times herein.
19. Since July 7, 2025, Defendant CarnageCulture has suspended about 73 active AFLs
due to the license holders having one or more arrest records. These arrests did not result in charges
or conviction in a court of law. Nonetheless, Defendant CarnageCulture proceeded to revoke these
individuals’ AFLs. But the “mere fact that a man has been arrested has very little, if any, probative
value in showing that he has engaged in any misconduct.” Schware v. Board of Bar Examiners,
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353 U.S. 232, 241 (1957) Indeed, “an arrest shows nothing more than that someone probably
suspected the person apprehended of an offense.” See Schware v. Board of Bar Examiners, 353
U.S. 232, 241 (1957). Therefore, “[w]hen formal charges are not filed against the arrested person
and he is released without trial, whatever probative force the arrest may have had is normally
dissipated.” Id. See also Menard v. Mitchell, 328 F. Supp. 718, 724 (D.D.C. 1971) (“An arrest
whether made with or without probable cause is to be sure a fact, but one that proves nothing so
far as the actual conduct of the person arrested is concerned.”) (emphasis added.)
20. Under the Equal Protection Clause, states are prohibited from discriminating
against a class of persons based on “arbitrary, unreasonable, or capricious” grounds. Nebbia v. New
York, 291 U.S. 502, 291 U.S. 525 (1934). Defendant CarnageCulture’s practice of revoking
citizens’ AFLs based solely on arrest records is arbitrary, unreasonable, and capricious because
arrests are not proof or indicative of criminal misconduct.
21. The State of Ridgeway has a parens patriae interest in ensuring that its general
population is not deprived of its rights under the U.S. Constitution. See Alfred L. Snapp & Son,
Inc. v. Puerto Rico ex rel. Barez, 458 U.S. 592, 608 (1982) (“[A] State does have a [parens patriae]
interest, independent of the benefits that might accrue to any particular individual, in assuring that
the benefits of the federal system are not denied to its general population.”) (emphasis added).
Here, the State has parens patriae standing to sue because a significant number—around 73 AFL
holders—were deprived of their AFLs in violation of their right to equal protection.
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PRAYER FOR RELIEF
WHEREFORE, Plaintiff State of Ridgeway prays for an order–
A) Declaring that Defendant CarnageCulture’s practice of revoking AFLs without notice
and an opportunity to be heard violates the procedural due process under the Fourteenth
Amendment to the United States Constitution and the CFA, § 5.2(d)(i);
B) Declaring that Defendant CarnageCulture’s practice of revoking AFLs based solely on
unadjudicated arrest records constitutes arbitrary and capricious action in violation of
the Equal Protection Clause of the Fourteenth Amendment;
C) Temporary, preliminarily, and permanently ordering Defendant CarnageCulture, his
officers, employees, agents, servants, contractors, and assigns, to reinstate any AFLs
revoked without procedural due process or based on arrest records;
D) Temporary, preliminarily, and permanently enjoining Defendant CarnageCulture, his
officers, employees, agents, servants, contractors, and assigns, from revoking AFLs
without procedural due process or based on arrest records;
E) Granting such other and further relief as may be just and proper.
Dated: July 14, 2025 Respectfully submitted,
Palmer, Ridgeway
/s/ BrendaPopplewell
BrendaPopplewell
Solicitor General
EffortlessBrit
Deputy Solicitor General
Ridgeway Department of Justice
1 County Annex
Palmer, Ridgeway 33368
