CrazySanMan
2013'er
https://www.scribd.com/document/379517208/Caldara-et-al-vs-City-of-Boulder
1. On May 15, 2018, the Boulder City Council voted 9 – 0 to approve Ordinance 8245, banning some of the most popular firearms and magazines in use by law-abiding citizens across the United States. In addition, Ordinance 8245 raised the age for legal firearm purchase and possession from eighteen to twenty-one years of age. Upon passage, Ordinance 8245 immediately became law in the City of Boulder, thereby infringing upon the rights of all
of Boulder’s 108,707 residents.
2. Ordinance 8245 and the actions of Defendants violate multiple provisions of the U.S. Constitution, including Article VI, the First Amendment, the Second Amendment, the Fifth Amendment, and the Fourteenth Amendment.
3. Ordinance 8245 and the actions of Defendants violate multiple provisions of the Colorado State Constitution, including Article 2, section 3 and Article 2, section 13.
4. Ordinance 8245 and the actions of Defendants violate multiple Colorado State Statutes, including C.R.S. §§ 29-11.7-102 and 29-11.7-103.
5. Plaintiffs intend and desire to continue to acquire, possess, use, sell, and/or transfer the lawfully-owned, constitutionally-protected firearms and magazines that are banned by Ordinance 8245, but justifiably fear punishment if they do.
JON C. CALDARA; BOULDER RIFLE CLUB, INC., a Colorado nonprofit corporation; GENERAL COMMERCE, LLC, d/b/a Bison Tactical, a Wyoming limited liability company; and TYLER FAYE,
Plaintiffs,
v.
CITY OF BOULDER, a Colorado home rule municipality;
JANE S. BRAUTIGAM, City Manager of the City of Boulder, in her official capacity;
GREGORY TESTA, Chief of Police of the City of Boulder, in his official capacity;
SUZANNE JONES, Mayor of the City of Boulder, in her official capacity;
AARON BROCKETT, Mayor Pro Tem of the City of Boulder, in his official capacity;
CYNTHIA A. CARLISLE, Boulder City Council Member, in her official capacity;
LISA MORZEL, Boulder City Council Member, in her official capacity;
MIRABAI KUK NAGLE, Boulder City Council Member, in her official capacity;
SAMUEL P. WEAVER, Boulder City Council Member, in his official capacity;
ROBERT YATES, Boulder City Council Member, in his official capacity;
MARY D. YOUNG, Boulder City Council Member, in her official capacity;
JILL ADLER GRANO, Boulder City Council Member, in her official capacity;
and
J. DOES 1 – 10,
Defendants
1. On May 15, 2018, the Boulder City Council voted 9 – 0 to approve Ordinance 8245, banning some of the most popular firearms and magazines in use by law-abiding citizens across the United States. In addition, Ordinance 8245 raised the age for legal firearm purchase and possession from eighteen to twenty-one years of age. Upon passage, Ordinance 8245 immediately became law in the City of Boulder, thereby infringing upon the rights of all
of Boulder’s 108,707 residents.
2. Ordinance 8245 and the actions of Defendants violate multiple provisions of the U.S. Constitution, including Article VI, the First Amendment, the Second Amendment, the Fifth Amendment, and the Fourteenth Amendment.
3. Ordinance 8245 and the actions of Defendants violate multiple provisions of the Colorado State Constitution, including Article 2, section 3 and Article 2, section 13.
4. Ordinance 8245 and the actions of Defendants violate multiple Colorado State Statutes, including C.R.S. §§ 29-11.7-102 and 29-11.7-103.
5. Plaintiffs intend and desire to continue to acquire, possess, use, sell, and/or transfer the lawfully-owned, constitutionally-protected firearms and magazines that are banned by Ordinance 8245, but justifiably fear punishment if they do.