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SUPERIOR COURT OF THE STATE OF RIDGEWAY
FOR THE DISTRICT OF RIDGEWAY
RIDGEWAY NATIONAL RIFLE
ASSOCIATION, INC., a Ridgeway
licensed corporation;
SAGE03X, an individual and resident of
Ridgeway County;
ANTHONYPANCI, an individual and
resident of Ridgeway County, and;
TOMDONOVANSMITH, an individual
and resident of Ridgeway County;
Plaintiffs,
v.
LARGETITANIC2, in his official
capacity as Governor of the State of
Ridgeway;
TECHIEY, in his official capacity as the
Attorney General of the State of
Ridgeway;
MATTXTRO, in his official capacity as
the Colonel of the Ridgeway State
Police;
Defendants.
Case No. RSC-CV-881
COMPLAINT FOR DECLARATORY
AND INJUNCTIVE RELIEF
COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF
Plaintiffs Ridgeway National Rifle Association, sage03x, AnthonyPanci, and
TomDonovanSmith (collectively “Plaintiffs”), file this action against the above-titled
Defendants, in their official capacities as state officials responsible under Ridgeway law to
administer, and enforce its laws governing the bearing of common firearms for defense of self,
and other lawful pursuits. Plaintiffs seek declaratory judgment that the State Firearms Act
(hereinafter “S3-10” or “the Act”), and as otherwise set forth, is unconstitutional under the
Second and Fourteenth Amendments to the United States Constitution. Plaintiffs, in addition,
also seek injunctive relief to compel the State of Ridgeway, its employees, and its agents from
administering the invalid limitations of the act. Plaintiffs, for their claims against the State of
Ridgeway, allege the following.
INTRODUCTION
1. The Second Amendment to the United States Constitution guarantees “the right of the
people to keep and bear arms.” U.S. Const. Amend. II. Under this constitutional
provision, the people of the State of Ridgeway have a fundamental, constitutionally
guaranteed right to keep and bear common firearms for the defense of self and family and
other lawful pursuits. The Supreme Court, in New York State Rifle & Pistol Ass’n, Inc. v.
Bruen, 142 S. Ct. 2111 (2022), reaffirmed the text of the Second Amendment, holding
that it protects equally the right to keep arms in the home and the right to bear them in
public. “Nothing in the Second Amendment’s text draws a home/public distinction with
respect to the right to keep and bear arms.” Id. at 2134; see also id. at 2135 (The Second
Amendment “guarantees an ‘individual right to possess and carry weapons in case of
confrontation,’ and confrontation can surely take place outside the home.”) (quoting
District of Columbia v. Heller, 554 U.S. 570, 592 (2008)).
2. The State of Ridgeway, however, has enacted—permitting the Defendants the authority to
enforce—a prohibition on the possession of different firearms, tendentiously labeled
“dangerous weapons” by ordinary citizens, making it a crime for law-abiding citizens to
exercise their fundamental right to keep and bear such arms. The State’s highly limited
set of exemptions for persons and purposes from its blanket ban does not allow typical
law-abiding citizens to keep and bear these common firearms. The State’s enactment, and
the Defendants’ enforcement of the prohibition on common automatic firearms,
tendentiously and inaccurately labeled dangerous weapons, and certain magazines
arbitrarily deemed to be of “greater than 15 rounds.”
3. To challenge this law, there must be a demonstrated “justiciable controversy,” as set by
the Supreme Court in Susan B. Anthony List v. Driehaus, 573 U.S. 149 (2014).
Establishing this requisite to bring forth a suit concerns the injury-in-fact requirement
which helps to ensure that the plaintiff has a “personal stake in the outcome of the
controversy.” Warth v. Seldin, 422 U. S. 490, 498 (1975) (internal quotation marks
omitted), and that there is an injury sufficient to satisfy Article III which must be
“concrete and particularized” and “actual or imminent, not ‘conjectural’ or
‘hypothetical.’” Lujan v. Defenders of Wildlife, 504 U.S. 555. The exception to the
holding in Lujan, however, renders that an allegation of future injury may suffice if the
threatened injury is “certainly impending,” or there is a “ ‘substantial risk’ that the harm
will occur.” Clapper v. Amnesty Int'l USA, 568 U.S. 398 (2013) (citing Whitmore v.
Arkansas, 495 U.S. 149, 158 (1990)). With the passage of S3-10, the Plaintiffs are subject
to their commonly used, and usual weapons being stripped from them by the State of
Ridgeway; thus negating their Second Amendment to the United States Constitution.
4. The plain text of the Second Amendment covers the conduct the Plaintiffs wish to engage
in because “[it] extends, prima facie, to all instruments that constitute bearable arms,
even those that were not in existence at the time of the founding.” Bruen, supra at 2132
(quoting District of Columbia v. Heller, 554 U.S. 570 (2008)). The State of Ridgeway,
“[t]o justify its regulation,” must demonstrate “that the regulation is consistent with this
Nation’s tradition of firearm regulation.” Id. at 2126. Defendants simply can not
demonstrate any such tradition. Heller and Bruen have established the only historical
tradition that can remove a firearm from the Second Amendment’s protective scope: the
tradition of banning dangerous and unusual weapons. Heller, 554 U.S. at 627; Bruen, 142
S. Ct. at 2143.
5. To be banned, a firearm must be both dangerous and unusual. Caetano v. Massachusetts,
577 U.S. 411, 417 (2016) (Alito, J., concurring). A weapon is—whether it be a BB gun,
an objectively weaker firearm, or an automatic rifle—always inherently dangerous. This
distinctive trait, however, does not negate the right to bear arms because the Second
Amendment applies to all arms that are in common use, that are not unusual, and that are
used for lawful purposes regardless of their perceived danger, and as such, the State’s ban
on automatic rifles and weapons with carrying capacity of 15 rounds is unlawful.
6. Plaintiffs are individuals and non-profit organizations whose members, and constituents
will be directly impacted by S3-10. Like the three Ridgeway National Rifle Association
plaintiffs in this case, all people who possessed an automatic firearm in the State of
Ridgeway immediately suffered harm under S3-10 in that they are not able to possess any
of their automatic firearms, and are mandated to turn such firearms into the Ridgeway
State Police or face potential prosecution. These people are also affected by S3-10 in that
it strips them of their right to bear arms freely under the Second Amendment to the
United States Constitution. Plaintiffs seek a declaratory judgment that S3-10 violates
their or their members’ constitutional and statutory rights to bear arms, as well as an
injunction preliminarily and permanently enjoining enforcement of S3-10 by Defendants.
PARTIES
7. Plaintiff Sage03x (hereinafter “Mr. Sage” or “Plaintiff one”) is a citizen of the United
States and resident of the State of Ridgeway. He is legally eligible under state law to
possess and acquire firearms. Mr. Sage is a member of the Ridgeway National Rifle
Association. He actively resides in the City of Palmer.
8. Plaintiff AnthonyPanci (hereinafter “Mr. Panci” or “Plaintiff two”) is a citizen of the
United States and resident of the State of Ridgeway. He is legally eligible under state law
to possess and acquire firearms. Mr. Panci is a member of the Ridgeway National Rifle
Association. He actively resides in the City of Palmer.
9. Plaintiff TomDonovanSmith (hereinafter “Mr. Smith” or “Plaintiff three”) is a Citizen of
the United States and Resident of the State of Ridgeway. He is legally eligible under state
law to possess and acquire firearms. Mr. Smith is a member of the Ridgeway National
Rifle Association. He actively resides in the City of Palmer.
10. Plaintiff Ridgeway National Rifle Association (hereinafter “the NRA” or “RNRA”) is a
group formed within the State of Ridgeway to defend, support, and fight for the right to
bear arms to be extended to all Residents of the State of Ridgeway. The restrictions
placed upon the possession of an automatic firearm in this case are a proximate indication
of the NRA’s core mission. The NRA's goals are bolstered with the support of hundreds
of members who actively reside in the State of Ridgeway. The Plaintiffs Sage03x,
AnthonyPanci, and TomDonovanSmith are all dedicated members of the Ridgeway
National Rifle Association, who contribute to the goals of the NRA. These three
individuals are among the hundreds who are directly affected by the enactment of S3-10,
which prohibits them from possessing any fully automatic firearm, along with any
firearm with a capacity of over 15 rounds.
11. In Whole Woman's Health v. Jackson, 595 U.S. ___ (2021), the Supreme Court held that
because the Defendants in the lower court were “necessary components [of the
challenged law],” and “play[ed] a clear role in the enforcement of the law,” that they are
“proper defendants.” Id. at 42. In this case, the facts are similar; the State Firearms Act
requires integral state actors for its provisions to be fully effectuated by the State of
Ridgeway, thus situating these Defendants appropriately.
12. Defendant largeTitantic2 (“Defendant Large” or “Governor Large” or “the Governor”) is
sued in his official capacity as the Governor of the State of Ridgeway. Pursuant to Article
II, Section 3 of the State Constitution, “[t]he Supreme Executive power” is exercised by
Defendant Large in his official capacity as Governor. Article IV, Section 1 also provides
that it is the duty of Defendant Large to “take care that the laws be faithfully executed.”
Governor Large is a person within the meaning of 1 R. Stat. § 3201 and was acting under
color of state law at all times relevant to this complaint.
13. Defendant Techiey (“Defendant Techiey” or “Attorney General Techiey” or “Attorney
General”) is sued in his official capacity as the Attorney General of the State of
Ridgeway. As Attorney General, he is responsible for enforcing the State’s laws and has
concurrent authority within the State Attorney’s Office to initiate prosecutions on behalf
of the People of Ridgeway. See 2 R. Stat. § 2101. This authority includes the authority to
enforce the State’s general prohibition on the possession of common automatic firearms
and ammunition magazines.
14. Defendant Mattxtro (“Defendant Mattxtro” or “Colonel Mattxtro” or “Colonel of the
State Police”) is sued in his official capacity as Colonel of the Ridgeway State Police. As
Colonel of the State Police, Mattxtro is responsible for managing and controlling
enforcement of the State’s criminal laws by the State Police, see 6 R. Stat. § 1107,
including the State’s general prohibition on the possession of common automatic firearms
and ammunition magazines.
JURISDICTION AND VENUE
15. This Court has jurisdiction pursuant to Article V, Section IV of the Constitution of the
State of Ridgeway.
16. Venue is proper in this Court because the incident took place within Ridgeway County.
FACTUAL ALLEGATIONS
I. The Plaintiffs
17. Plaintiff Ridgeway National Rifle Association is a licensed corporation within the State
of Ridgeway, formed as a medium for all persons who engage similar interests in
defending their constitutional right to bear arms under the State of Ridgeway.
18. The NRA is a reputable organization that has seasoned firearm advocacy in the State of
Ridgeway since its humble beginnings, attaining over one hundred supporters, and
members of the organization.
19. The NRA represents the interests of its members in all disputes of firearm rights,
defending their constitutional rights through thick and thin. To rise to its defensive status,
the NRA filed suit alongside several of its members to challenge the constitutionality of
S3-10.
20. Plaintiff Sage03x is a leading member of the Ridgeway NRA.
21. Up until the passage of S3-10, Mr. Sage was a zealous advocate for the possession of
automatic firearms and amassed a crowd with similar advancements.
22. Mr. Sage, as a licensed firearm holder, legally possessed several automatic weapons (and
ammunition required) prior to the passing of S3-10.
23. With the enactment of the Act, however, Mr. Sage’s goals—alongside his constituents'
goals—were practically shattered. Their constitutional right to bear arms is now bare–and
essentially baseless.
24. To date, Mr. Sage—nor his fellow advocates, can possess any weapon (including an
automatic rifle) with a single magazine capacity greater than 15 rounds.
25. Plaintiff AnthonyPanci and TomDonovanSmith are members of the Ridgeway NRA.
26. Mr. Panci and Mr. Smith have continuously possessed and advocated the ownership of all
weapons in the State of Ridgeway—including automatic firearms.
27. Mr. Panci and Mr. Smith are similarly situated with the repercussions of the regulation of
automatic firearms. They now, along with countless others, have to turn in their firearms
or face the consequences of criminal charges.
28. S3-10 prevents Mr. Panci and Mr. Smith from purchasing, owning, or using automatic
firearms, even if they were used for lawful purposes such as hunting or self-defense.
29. S3-10 also limits their ability to participate in shooting competitions or other events
where automatic firearms are used.
30. Mr. Panci and Mr. Smith are targeted and discriminated against as responsible gun
owners, who are being punished for the actions of criminals who misuse firearms.
31. S3-10 exhibits no impact on the criminal use of automatic firearms, as criminals have a
tendency to disobey the law notwithstanding.
32. S3-10 is an infringement of their constitutional rights and a form of government
overreach.
33. The act has led Mr. Panci and Mr. Smith to file a suit to challenge the constitutionality of
the Act and fight against further gun control measures.
II. Ridgeway’s Unconstitutional Automatic Firearm Ban
34. On January 19, 2023, Ridgeway enacted a ban on so-called “dangerous weapons,” which
are—in fact—common automatic firearms. The act further criminalized the possession of
“[a]ny weapon that is fully automatic,” and “[a]ny weapon which is able to receive and
operate with a magazine containing more than 15 rounds.” State Firearms Act, S3-10 §§
4.1 (2022).
35. The criminal prohibition applies to all persons within the State of Ridgeway and only
exempts peace officers from its ambit in hopes of fighting back “against the[...]surge [of]
criminal activity across the state.” Exact words from the Governor in a subsequent press
release after the passage of S3-10.
36. Any ordinary person in Ridgeway who legally possessed an automatic weapon before the
law’s enactment must now turn over their firearms to Troopers of the Ridgeway State
Police, or face criminal charges for Unlawful Possession of a Firearm; a charge with
consequential repercussions, accompanied by 15 minutes of incarceration or a $350 fine.
Rid. State Crim. Code § 5.01.
37. Among other prohibitions created and enforced by S3-10 the State of Ridgeway
furthermore made it a criminal offense to possess “any weapon[…] able to receive[…]a
magazine containing more than 15 rounds.”
38. Any ordinary, law-abiding Resident of the State of Ridgeway who was in legal
possession of a magazine before the law’s enactment must deliver it to a Trooper of the
Ridgeway State Police.
39. The Magazine Bans applies to the people of the State of Ridgeway and only exempts
peace officers from its ambit.
40. The State’s ban on automatic firearms is not accorded well with the historical tradition of
firearm regulation. In fact,
41. The regulation of automatic firearms is based on a false premise that they are inherently
more dangerous than other types of firearms. In reality, however, any firearm can be
dangerous if misused, and the type of firearm used in a crime is not the root cause of the
problem, as it is complex and multifaceted.
42. The State’s role is to protect the rights of its Residents, not to infringe upon them. By
enacting S3-10, the State of Ridgeway is sending a message to its Residents that their
rights and freedoms are not valued and that the government does not trust them to
exercise their rights responsibly.
A. The Firearms Banned by the Act are Not Unusual
43. Among several underlying components of S3-10, the Act explicitly prohibits “dangerous
weapons” and bans both automatic firearms and firearms with the capacity to accept a
magazine holding more than fifteen rounds of ammunition.
44. S3-10 forbids Residents from possessing or carrying specific firearms as distributed
throughout the State, which is defined to include:
a. All automatic firearms, including firearms that operate with over 15 rounds:
i. The Solami;
(I) 30 Bullets of .45 ACP
ii. Micro;
(I) 30 Bullets of .45 ACP
iii. Stetson M1;
(I) 15 Rounds of 5.56
45. The State’s ban is subject to review because it broadly prohibits common automatic
firearms that have—since the origin of the State of Ridgeway—been commonly used for
lawful purposes (e.g., self-defense, range shooting, etc.)
46. The firearms classified as “fully automatic” are all ordinary automatic rifles. Insomuch
that they differentiate from other fully automatic rifles (e.g., a Stetson M2-A), their
distinguishable traits make them easier, more reliable, and safer to use. All things
considered, even if the firearms are classified from a separate group of “fully automatic,”
they simply can not be prohibited because they are not dangerous, nor unusual.
47. Firearms classified, and banned as “fully automatic” through S3-10 are—for lack of
better terms—common on several aspects: (1) The fully automatic firearms are
categorically common, as they are all automatic in their function and operation; (2) they
are characteristically common, provided that they are all popular configurations of
firearms (e.g., rifles) with common characteristics; and (3) the firearms are
jurisdictionally common, lawful to use in the bulk of most states and throughout the
relevancy of its history, for a wide range of previously aforementioned purposes.
48. The relative dangerousness of a weapon is irrelevant when the weapon belongs to a class
of arms commonly used for lawful purposes. The sole purpose of the Ridgeway National
Rifle Association is to advocate and espouse for the Residents of Ridgeway that lawfully
possess and utilize firearms. The entire purpose of the Act, which is to suppress criminals
from obtaining firearms, will be moot against those who already seek to violate the law.
49. S3-10’s ban on delivering, selling, or purchasing an assault weapon is, consequently, a
ban on keeping and bearing automatic firearms that are commonly possessed and used for
lawful purposes, including self-defense in and outside of the home.
B. The State Firearms Act Imposes Inconsistent Firearm Regulations of
Historical Tradition
50. S3-10 bases its regulations by providing the inconsistency of statutes surrounding
firearms and the clear demand for solutions to solve the rising usage of deadly weapons,
however, the S3-10 refuses to acknowledge historical dilemmas that are contradictory to
its’ regulations put forth.
51. The right to bear arms, as provided in the Second Amendment, for the sole purpose of
self-defense is proven to be protected by the Constitution even if the arms provided are
not consistent with the provisions of the Second Amendment.
52. Instead of acknowledging exceptions for self-defense, S3-10 insists on the ban of
automatic firearms that can be intended for the protection of the safety and defense of the
citizens of the State.
C. The Statute Criminalizes Chronic and Important Means of Self-Defense
53. S3-10’s ban on automatic firearms and firearms with a capacity of over 15 rounds
engages in a clear conflict with the Second Amendment to the United States, and the
basic means of self-defense.
54. Criminalizing the possession of fully automatic rifles would disproportionately affect
law-abiding citizens while doing little to prevent criminals from obtaining these weapons
through illegal means.
55. Plaintiffs, who possessed the prohibited firearms, are now in a constant state of concern;
they have no reasonably adequate means to protect themselves against criminals who
manage to gain access to or are dealt overpowering police-grade weapons with a much
higher potential to inflict serious harm when compared to the weapons Plaintiffs are
legally allowed to possess.
56. Plaintiffs are now prohibited from bearing arms freely without ramifications from the
State of Ridgeway, its employees, agents, or officers.
57. The very goal that the Ridgeway National Rifle Association was advocating for has been
encroached upon with the passage of S3-10. Their hundreds of members—including the
plaintiffs—are now without any adequate means of self-defense, and are now separated
from their Second and Fourteenth Amendment rights to the United States Constitution.
D. Plaintiffs Are At Imminent Threat of Enforcement of the Act
58. Plaintiffs, who are gun-owning citizens of the State of Ridgeway, file this suit to not only
challenge S3-10 but to prevent the threat of its enforcement.
59. The passing of S3-10 was followed by a subsequent forty-eight-hour amnesty for all
persons to turn in any firearms that are classified as illegal under the Act.
60. Any person who has failed to adhere to the mandate is found to be “committing a
criminal offense,” and as such, “may be charged with the appropriate crime.” State
Firearms Act, S3-10 § 6(d) (2022).
61. The plaintiffs, as immense advocates for firearms, continue to possess the prohibited
automatic rifles, as is their constitutional right.
62. The plaintiffs have a vested interest in using these rifles for proficiency training and
self-defense, and the State Firearms Act unjustly restricts their ability to do so.
63. The plaintiffs are—according to S3-10—in the sphere of many individuals who have
refused to yield their Second Amendment rights to an unjustified and unconstitutional
seizure of firearms; subjecting them to dire repercussions.
64. Plaintiffs are essentially classified and treated as habitual criminals for simply exercising
their Second Amendment right to bear arms.
65. The immediate threat of criminal charges or prosecution for possessing the firearms poses
a significant threat to their constitutionally protected rights.
66. No individual's right, including the plaintiff’s, should be violated before they can seek
redress in a court of law.
67. So while it is true that the plaintiffs have not been fully subject to the reverberations of
S3-10; the harm is certainly imminent and forthcoming.
68. The consequential and instantaneous effect of S3-10 not only poses impending harm to
the plaintiffs, but to all citizens of the State of Ridgeway who possess an automatic
firearm.
69. The State Firearms Act does not adequately consider the Plaintiffs' rights and interests
under both the State and Federal Constitutions, and thus should be eliminated of any
ability to enforce its unconstitutional provisions to the law-abiding citizens of the State of
Ridgeway.
CLAIMS FOR RELIEF
FIRST CAUSE OF ACTION
(1 R. Stat. § 3201 - Deprivation of Rights)
U.S. Const. Amend. II and XIV
70. Plaintiffs' reallege and incorporate by reference all of the allegations contained in all of
the preceding paragraphs.
71. The Second Amendment to the United States Constitution provides: “A well-regulated
Militia being necessary to the security of a free State, the right of the people to keep and
bear Arms shall not be infringed.”
72. The Second Amendment is fully applicable to the States through the Fourteenth
Amendment. McDonald v. City of Chicago, 561 U.S. 742, 750 (2010); id. at 805
(Thomas, J., concurring).
73. The fully regulated automatic firearms at issue, in this case, are the sorts of bearable
firearms in everyday use for lawful purposes that law-abiding residents possess at home
by the hundreds. And as such, they are neither dangerous nor unusual and they cannot be
banned by the State of Ridgeway.
74. 1 R. Stat. § 3201 creates a cause of action against state officials who deprive individuals
of their federal constitutional rights under the color of state law.
75. Plaintiff’s Ridgeway National Rifle Association, through its members Sage03x,
AnthonyPanci, and TomDonovanSmith are law-abiding, upstanding Residents of the
State of Ridgeway who wish to exercise their Second Amendment right to purchase,
possess, and sell firearms that are now prohibited by state law as “automatic firearms.”
76. Defendants have violated Plaintiffs’ right to keep and bear arms by precluding them from
being able to sell, purchase, transfer, or possess such firearms because Defendants
enforce S3-10.
77. Defendants’ enforcement of S3-10, and all related regulations, policies, and/or customs
designed to enforce or implement the same thereto, impedes upon and creates a forbidden
burden on Plaintiffs’ right to keep and bear arms under the Second and Fourteenth
Amendments to the United States Constitution
78. Defendants’ enforcement of S3-10, and all related regulations, policies, and/or customs
designed to enforce or implement the same thereto forces the Plaintiffs to comply with
the forty-eight hour Gun & Weapons amnesty—thereupon being prevented from
exercising their rights under the Second and Fourteenth Amendments to the United States
Constitution—or being subjected to criminal prosecution.
79. As a direct and proximate result of the infringement and forbidden burden on Plaintiffs’
Second and Fourteenth Amendment rights, Plaintiffs have suffered—and continue to
suffer—the unlawful and irreparable deprivation of their—and, in the case of the
Ridgeway National Rifle Association, their member’s fundamental constitutional right to
keep and bear arms.
PRAYER FOR RELIEF
80. WHEREFORE, Plaintiff requests that the court grant relief as follows:
A. Declaratory relief that the bans on commonly possessed automatic firearms and
ammunition magazines consisting of the State Firearms Act, S3-10 and all related laws,
regulations, policies, and procedures, violates the right to keep and bear arms, as
guaranteed under the Second Amendment to the United States Constitution;
B. Preliminary and Permanent injunction against each Defendant, each Defendant’s
respective employees, officers, agents, and representatives, and all those acting in concert
or participation with him or her, from enforcing the Ridgeway ban on automatic firearms
and “high capacity magazines,” consisting of the State Firearms Act, S3-10, and all
related regulations, policies, and/or customs designed to enforce or implement the same;
C. Award the Plaintiff’s attorneys’ fees and costs;
D. Any other and further legal and equitable relief against Defendants as necessary to
effectuate the Court’s judgment, or as the Court otherwise deems just and proper.
Dated: January 22, 2023 Respectfully submitted.
STICKZA
Managing Partner
COHN, CICERO, & GOODRICH, LLC
Suite 3B, Palmer Apartments
Palmer, RW 33328
D: stick#0677
E: [email protected]
ELLOM8HOWAREYOU
Partner
COHN, CICERO, & GOODRICH, LLC
Suite 3B, Palmer Apartments
Palmer, RW 33328
D: ello ! #2023
E: [email protected]
BOBFOGARTY
Senior Associate
COHN, CICERO, & GOODRICH, LLC
Suite 3B, Palmer Apartments
Palmer, RW 33328
D: bob.#4225
E: [email protected]
Counsel of Record
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