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RIDGEWAY SUPERIOR COURT
NICKLAUS_S,
Plaintiff,
MATTCERN, in his official capacity
as Colonel of the Ridgeway State Police,
Defendant.
Civil Action No. RSC-CV-3940
DEFENDANT’S ANSWER AND AFFIRMATIVE DEFENSES
Defendant Mattcern (hereinafter “Defendant”) hereby answers Plaintiff’s Complaint—in
response to the numbered paragraphs and sentences of the Complaint—either affirming or
denying as follows:
INTRODUCTION
1. It is admitted that Plaintiff applied for an Advanced Firearms License (“AFL”). It
is also admitted that Plaintiff has various criminal records. However, it is denied that Plaintiff
was unlawfully denied a hearing or an otherwise permissible notice under law.
2. This paragraph is a summary of the governing statute—9 R. Stat. § 411.001–
414.002—and its objective criteria by which applicants are required to satisfy for licensure.
To the extent that an answer is required, we admit that this is the function of the statute.
3. Denied.
4. Admit. Plaintiff seeks various equitable relief, including both declaratory
judgment and injunctive relief.
JURISDICTION AND VENUE
5. Admit.
6. Admit.
PARTIES
7. Admit.
8. Admit.
FACTS
9. Neither admitted nor denied. This paragraph contains a word-for-word recitation
of the Second Amendment, to which no answer is required.
10. Neither admitted nor denied. This paragraph contains a word-for-word recitation
of the Fourteenth Amendment, to which no answer is required.
11. Defendant states that Paragraph 11 contains legal argument and conclusions to
which no response is required.
12. Defendant states that Paragraph 12 contains legal argument and conclusions to
which no response is required.
13. Defendant states that Paragraph 13 contains legal argument and conclusions to
which no response is required.
14. Defendant states that Paragraph 14 contains legal argument and conclusions to
which no response is required.
15. Defendant states that Paragraph 15 contains legal argument and conclusions to
which no response is required.
16. Defendant states that Paragraph 16 contains legal argument and conclusions to
which no response is required.
17. Defendant states that Paragraph 17 contains legal argument and conclusions to
which no response is required.
18. Defendant states that Paragraph 18 contains legal argument and conclusions to
which no response is required.
19. Defendant states that Paragraph 19 contains legal argument and conclusions to
which no response is required.
REGULATORY BACKGROUND
20. Admit.
21. Admit.
22. Admit.
23. Admit.
24. Admit.
25. Admit.
26. Admit.
27. Admit.
28. Admit.
29. It is admitted that the listed criteria are required to possess an AFL, among others.
30. Admit.
31. Admit.
32. It is admitted that Defendant has broad discretion under state law to deny,
blacklist, or otherwise revoke an existing AFL.
FACTUAL BACKGROUND
33. Neither admitted nor denied. Defendant has no knowledge of the present desires
of Plaintiff, nor could he conclusively determine such in the future.
34. Admit.
35. Admit.
36. Admit.
37. Admit.
38. Admit.
39. At the time of filing this complaint, the amount of AFL licenses issued is neither
admitted nor denied. While the database is maintained consistent with state law, recently
issued licenses may not yet appear for public viewing.
40. Admit.
41. Admit.
42. Admit.
43. Admit.
44. Admit.
45. Neither admitted nor denied. A response is not required as Paragraph 45 makes a
legal conclusion to which the Defendant cannot speak to.
46. Admit.
47. Admit.
48. Admit.
49. Admit. Plaintiff met all other objective criteria prescribed by the legislature but
did not satisfy the requirement that he must possess no criminal records.
50. Admit.
51. Admit.
52. Denied.
53. Denied.
54. Neither admitted nor denied. Plaintiff makes a personal conclusion to which
Defendant lacks knowledge to make an admission or denial.
55. Neither admitted nor denied. Plaintiff makes a personal conclusion to which
Defendant lacks knowledge to make an admission or denial.
FIRST CAUSE OF ACTION
56. This paragraph realleges and incorporates all preceding paragraphs. To the extent
a response is required, Defendant incorporates its responses to the preceding paragraphs.
57-66. These paragraphs consist of conclusions of law to which no response is required.
To the extent a response is required, Defendant denies the allegations of these paragraphs.
SECOND CAUSE OF ACTION
67. This paragraph realleges and incorporates all preceding paragraphs. To the extent
a response is required, Defendant incorporates its responses to the preceding paragraphs.
68-78. These paragraphs consist of conclusions of law to which no response is required.
To the extent a response is required, Defendant denies the allegations of these paragraphs.
The remaining paragraphs represent plaintiff’s prayer for relief to which no response is
required. Except to the extent expressly admitted or qualified above, Defendant denies each
and every allegation of the Complaint. Defendant further denies that Plaintiff is entitled to
any relief whatsoever.
First Affirmative Defense
1. The Complaint fails to state a claim upon which relief can be granted.
Second Affirmative Defense
2. A t all times, Defendants acted in good faith and had reasonable grounds for
believing their actions were in compliance with applicable state law.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Defendants pray that their answer be
deemed good and sufficient and all claims by Plaintiff against Defendants be dismissed at a
proper time, with prejudice, and such other and further relief, legal and equitable, including
attorney’s fees, be awarded Defendants.
July 25, 2026 /s/ S. Stickza `
Stickza
Assistant Solicitor General
Ridgeway Department of Justice
Palmer, RW 33368
[email protected]
