Yesterday, an amended complaint was filed in Doe v. Swearingen, the case pending in the Northern District of Florida which (for convenience and not to be confused with Does v. Swearingen in the 11th Circuit) we refer to as Ex Post Facto Plus II.
Recently that case survived a Motion to Dismiss filed by the State, so the Amended Complaint removes some of the claims that did not survive and enhanced the claims that did. Included in the enhancement is something that I’m sure we all find offensive, branded driver’s licenses!
You can read the amended complaint by clicking the link below. As usual, the attorneys representing the plaintiff have done an amazing job.
Ex Post Facto II – Amended Complaint
Come on judge I know you can say it…. “pun”…… come on…. “puni… Punitive.” See that wasn’t so hard was it?
That seems to be well written with ample backup for the points being made. I wish them well.
My question is, should this lawsuit prevail, what would it mean for the rest of us?
The amended complaint is good reading. Easily understandable, direct, and to the point.
The only provisions challenged here are travel + driver lic, correct?
As always, strongly argued, for what it is, and appreciate the heroism of the plaintiff.
The boldness of punitive laws against RC happens bc we registrants bark without much of a bite. Dare I say “we have no teeth”. I aim to help RC’s have teeth to bite not just Bark. How? I go into salons and barber shops and harness those relations to get reasonable people elected. It works!
Robert Curtis you are correct, it is imperative for us to help elect those that will be reasonable and read the facts. Not the less then truth fear mongers in our local community’s.
This looks impressive. Thanks to all who are involved in making it go forward.
Praying for an outcome that she and everyone deserves.
WOW!! The only thing I can say after reading the entire complaint, is that last fall while deciding on whether to move my elderly mom from Florida to Pennsylvania or for me to move down there, the right decision was made. There is absolutely no way ANYBODY can follow all those rules without messing up somewhere. I wish there was some way to help, but, I wouldn’t know where to start. I will say that here, you are notified by PSP (PA State Police) by mail a couple weeks before your reporting date. You have the 11 days leading up to your date to report, no appointment needed, just show up. I could go on and on, but won’t. My heart goes out to those of you who reside in FL. I can’t begin to imagine living under such draconian and most likely unconstitutional rules.
I only receive about 80% of my snail mail. So, I’m very glad that, years ago, Florida stopped sending out its annual verification mailer that needed to be returned to avoid a felony charge. Sadly, FDLE can still send such a mailer anytime they want (it’s still in the statute), so I’ll just have to hope that I receive it.
Well no thanks to one recent court ruling, I only have 10 months to file litigation against FloriDUH for kidnapping me and trafficking me across state lines, holding me for ransom, then forcing me upon their registry. Time is getting short.