IN THE UNTED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

D’ANDRE BRADLEY; DAVID D. MOORE; ) 

TARA D. MOORE; BRETT O. SHELTON; ) 

ILLINOIS STATE RIFLE ASSOCIATION; )

and SECOND AMENDMENT )

FOUNDATION, INC. ) 

)

Plaintiffs, )

) 

v. ) 

)

BRENDAN F. KELLY, in his official )

capacity as Director of the Illinois State )

Police; and JESSICA TRAME, in her official ) 

capacity as Bureau Chief of the Illinois )

State Police Firearms Services Bureau, ) 

) No. 20-cv-4270

Defendants. )

__________________________________________)

)

BRUCE DAVIDSON, and SARAH ) Hon. Ronald A Guzman,

DAVIDSON, )

) presiding

Plaintiff-Intervenors )

)

v. )

)

BRENDAN F. KELLY, in his official )

capacity as Director of the Illinois State )

Police; and JESSICA TRAME, in her official ) 

capacity as Bureau Chief of the Illinois )

State Police Firearms Services Bureau, ) 

) 

Defendants in Intervention. )

COMPLAINT IN INTERVENTION

NOW COME Bruce Davidson, pro se, and Sarah Davidson, by her 

Case: 1:20-cv-04270 Document #: 20-1 Filed: 09/28/20 Page 1 of 4 PageID #:88
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attorney Bruce Davidson, Plaintiff-Intervenors, and make this their 

Complaint against Defendants in Intervention (“Defendants”):

1. Plaintiff-Intervenors Bruce Davidson (“Bruce”) and Sarah (“Sarah”) 

Davidson (the “Davidsons”) are citizens of the United States, domiciled in the 

Village of Hinsdale in DuPage County.

2. On July 20, 2020, the Davidsons each applied for a Firearm Owners 

Identification (“FOID”) card, pursuant to section 4 of the Firearm Owners 

Identification Card Act, 430 ILCS 65/. Each application was complete, and 

provided all requested and/or required information. Payment in the amount 

of twelve dollars was made by electronic means, by both Bruce and Sarah.

3. Defendants, through their employees and/or agents, confirmed 

receipt of Bruce’s application and payment (no. 21063924), and confirmed 

receipt of Sarah’s application and payment (no. 21064050).

4. The applications submitted by the Davidsons, as well as records 

available to Defendants, show the Davidsons are qualified to have their 

applications granted. There are no disqualifying causes, as set forth in 430 

ILCS 65/4(a) for denial of either Bruce’s, or Sarah’s, application. There is no 

statutory provision outside section 4(a) for cause to deny a FOID, and none of 

the statutory provisions within section 4(a) provide reason for delay of 

approving an application, or issuing a FOID card.

5. As of the date the Davidson’s Motion for Leave to Intervene was 

filed (September 28, 2020), Defendants’ have failed to issue, or deny, FOID 

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cards to either of the Davidsons, notwithstanding the express requirements 

of 430 ILCS 65/5(a). 

6. Davidsons have monitored (online at https://ispfsb.com) the status 

of their applications, as suggested in the confirmation notices received from 

Defendants, and – as of the September 28, 2020, filing of the Motion for 

Leave to Intervene herein – those applications were shown as “under review”. 

No information is provided concerning why the applications are delayed, or 

when action will be taken to approve or deny the applications.

7. Attempt was made to check status by telephone, but the call was 

automatically disconnected before status could be checked, and before any 

connection was made to a live human being.

8. Pending action by Defendants to fulfill their Illinois statutory and 

Federal Constitutional rights, the Davidsons suffer continuing injury on a 

daily basis (including, but not limited to, their ability to keep and bear arms, 

and to defend themselves against potential attacks on their property and 

persons) which is irremediable at law, and which merit injunctive relief 

and/or per diem compensation.

9. Fulfilling their clear and unequivocal statutory duties will impose 

no burden on Defendants, other than that imposed by the statute itself.

10. The allegations of the principal “Complaint in Law and Equity”

are well- and truly-pleaded, and the Davidsons join in alleging ¶¶ 1-10, 21-

47, and 53-64 thereof, as if fully set forth herein (except that those allegations 

naming individuals are herein amended, specifically to add the Davidsons)

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WHEREFORE, Plaintiff-Intervenors Bruce Davidson and Sarah 

Davidson pray this Honorable Court will enter judgment in their favor, and 

against Defendants: 

a) Preliminarily and permanently enjoining them from failing to 

fulfill their statutory obligations to Plaintiffs-Intervenors under 

the Firearm Owners Identification Card Act; 

b) Requiring Defendants to issue forthwith, FOID cards to Bruce 

Davidson and Sarah Davidson; 

c) Awarding per diem compensation for injury and damages, 

beginning August 19, 2020 (30 days from date of the Davidsons’

applications); and, 

d) Such other and further relief as the Court may find appropriate 

in the circumstances. 

Respectfully submitted, 

Bruce Davidson 

Sarah Davidson 

By______________________ 

 Bruce Davidson, pro se, 

 and attorney for Sarah 

 Davidson 

Bruce Davidson 

 ARDC Registration no. 0583057 

733 North Oak Street 

Hinsdale IL 60521 

630-947-3117 

Akivida@aol.com

 /s/ 

Case: 1:20-cv-04270 Document #: 20-1 Filed: 09/28/20 Page 4 of 4 PageID #:91