IN THE SUPREME COURT OF THE STATE OF RIDGEWAY
Nughson, an individual
Plaintiff(s),
v.
bommes, an individual
Defendant(s).
Case No. RSC-CV-290
CIVIL COMPLAINT
COME NOW, the Plaintiff, through the undersigned counsel, hereby file suit against the above captioned
party, and alleges the following:
GENERAL ALLEGATIONS
PLAINTIFF ALLEGES:
1. Title 3, Section 14 of the Ridgeway County Code places overreaching restrictions on the right to
travel freely ingrained in the 14th Amendment of the United States Constitution.
2. The freedom to travel has long been recognized as a basic right afforded to citizens under the
United States Constitution. See Williams v. Fears, 179 U.S. 270, 274 (1900); Twining v. New
Jersey, 211 U.S. 78, 97 (1908); Edwards v. California, 314 U.S. 160, 177 (1941) (concurring
opinion); New York v O’Neill, 359 U.S. 1, 6-8, 12-16 (dissenting opinion) (1959)
3. That such a right ought not to be unconstitutionally restricted by a state statute
4. A pre-enforcement challenge is necessary to protect the rights of citizens of the State and liberties
provided to them. “[W]here threatened action by [the] government is concerned, we do not
require the plaintiff to expose himself to liability before bringing suit to challenge the basis for
the threat” List v. Driehaus, 573 U.S. 149, 159 (2014)
5. The law continues, over time, to infringe on the right to travel freely. “[A]n unconstitutional
action [that] has been taken before surely does not render that action any less constitutional at a
later date.” Powell v. McCormack, 395 U.S. 486, 546-47 (1969).
6. The elements contained in the law are vague and rests upon an uncertain foundation, making it
near impossible for an intelligible person to decide a lawful course of action. “A criminal statute
cannot rest upon an uncertain foundation. The crime, and elements constituting it, must be so
clearly expressed that the ordinary person can intelligibly choose, in advance, what course [it] is
lawful for him to pursue.” Connally v. General Construction Co., 269 U.S. 385, 392 (1926). See
also International Harvester Co. v Kentucky, 234 U.S. 579 (1914).
JURISDICTION
1. The jurisdiction of the Court originates from Art V, Sec IV of the Ridgeway Constitution, which
states “There shall be a Superior court which shall exercise original jurisdiction for all civil and
criminal cases or controversies…”
PRAYERS FOR RELIEF
1. The Plaintiff is seeking non-monetary relief.
i. A declaration from the Court declaring Title 3, Section 14 of the Ridgeway County Code
unconstitutional.
ii. That the Court declare the statute in question unenforceable until changed by legislation or
other lawful means.
iii. Any other relief the Court deems necessary.
Date: April 23, 2022
/s/ALEXJCABOT
Executive Director
RIDGEWAY CIVIL LIBERTIES UNION
1200 Oakfield Road, Suite 452
Palmer, Ridgeway
cabot#0313
Counsel of Record
/s/DAVIDLCLARKE
Staff Attorney
RIDGEWAY CIVIL LIBERTIES UNION
1200 Oakfield Road, Suite 452
Palmer, Ridgeway
xz#5562
Counsel of Record
