IN THE UNTED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

 

JAMES D. ROBINSON; JOHN M. MARSZALEK; )

NATALIA E. LaVALLIE; )

MATTHEW D. SORENSON; )

ILLINOIS STATE RIFLE ASSOCIATION; and )

SECOND AMENDMENT FOUNDATION, INC. )

)

Plaintiffs, )

) No. 1:20 CV 4270

v. )

)

BRENDAN F. KELLY, in his official capacity as )

Director of the Illinois State Police; and )

JAROD INGEBRIGTSEN, in his official capacity as )

Bureau Chief of the Illinois State Police Firearms )

Services Bureau, )

)

Defendants. )

 AMENDED COMPLAINT IN LAW AND EQUITY 

 

COME NOW the Plaintiffs, JAMES D. ROBINSON, JOHN M. MARSZALEK, 

NATALIA E. LaVALLIE, MATTHEW D. SORENSON, ILLINOIS STATE RIFLE 

ASSOCIATION, and SECOND AMENDMENT FOUNDATION, INC., by and

through undersigned counsel, and complain of the Defendants, BRENDAN F. 

KELLY, in his official capacity as Director of the Illinois State Police, and JAROD 

INGEBRIGTSEN, in his official capacity as Bureau Chief of the Illinois State Police 

Firearms Services Bureau, as follows:

1. In Illinois, the ability to exercise one’s Second Amendment right to 

keep and bear arms is conditioned on first obtaining a Firearm Owners 

Identification (“FOID”) card. 430 ILCS 65/2(a)(1). Without a FOID card, a person 

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may not even possess a firearm, much less purchase one; violation constitutes a 

Class A misdemeanor; a repeated offense is a Class 4 felony. 430 ILCS 65/14. So 

exacting and sever as this law is applied, the spouse of a FOID-card-bearing gun 

owner can be criminally prosecuted if the spouse lacks his her own FOID card 

because the State may deem the spouse who lacks the card to be in “constructive 

possession” when the FOID-card-bearing spouse is absent from the home. See, e.g.,

People v. Elders, 63 Ill. App. 3d 554 (5th Dist. 1978); See also Hicks v. Poppish, 

2011 U.S. Dist. LEXIS 95222, *15 (N.D. Ill. 2011).

2. The Illinois Legislature imposed this extraordinary1 statutory scheme 

that requires a person to submit a form, pay a fee, and not suffer a specified

disqualification in order to possess or purchase a firearm or ammunition. Unless 

and until the applicant actually obtains and holds in his or her hand the piece of 

plastic that is the FOID card, the person cannot exercise the most basic Second 

Amendment right to possess a firearm in one’s home for self-defense. 

3. Undoubtedly recognizing the constitutional imposition the FOID 

scheme presents, the Illinois legislature required the Illinois State Police (“ISP”) to 

either approve or deny an application for a FOID card within 30 days. 430 ILCS 

65/5(a). But despite this statutory command, the ISP commonly does not approve 

qualified residents’ applications within 30 days. 

1 Illinois is just one of two states to impose this Second Amendment restriction for 

possession of a rifle, the other being Massachusetts. Mass. Gen. Laws ch. 140, § 

129C.

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4. Instead, the ISP leaves applicants in limbo for months, with residents 

commonly waiting as long as 60 to 90 days to receive a FOID card. That has been 

true for years, and it has only become worse as applications for FOID cards have 

surged in response to recent looting and violence. 

5. And the consequences for delay are neither abstract nor a mere 

inconvenience; they are a matter of life and death. Sadly, in similar situations,

where the government bureaucracy legislatively empowered to act as a Second 

Amendment gatekeeper has dithered in processing applications, there have been 

fatal results.

2 

6. The Illinois residents who are Plaintiffs in this lawsuit have all been 

waiting longer than 30 days to receive the FOID cards for which they have applied. 

Many members of the organizational Plaintiffs in this case, the Illinois State Rifle 

Association (“ISRA”) and the Second Amendment Foundation (“SAF”), have also 

been waiting longer than 30 days to receive the FOID cards for which they have 

applied. 

7. Illinois cannot justify completely and indefinitely denying its residents 

their fundamental Second Amendment right to possess a firearm to defend their 

lives, families, and homes while they wait for the ISP to approve their FOID card 

2 For example, Carol Bowne was stabbed to death outside her Berlin, New Jersey 

home by an ex-boyfriend while the Berlin Township Chief of Police, the bureaucrat 

charged with deciding whether Ms. Bowne really needed a pistol for self-defense, 

processed her application. Ms. Bowne’s application specifically stated her fear of 

death or great bodily harm from the man who ultimately killed her. 

https://www.fox5dc.com/news/no-one-helped-her-nj-woman-murdered-by-ex-whileawaiting-gun-permit.

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applications. Simply put, if the State of Illinois is going to condition the exercise of a 

fundamental right on the receipt of a license, then the process for issuing that 

license cannot be defective to the point of near-inoperable.

8. Plaintiffs have therefore brought this lawsuit to protect their Second 

Amendment rights, and, in the case of Plaintiffs ISRA and SAF, their members’

Second Amendment rights. They ask this Court to (1) declare that the ISP’s failure 

to issue FOID cards to qualified applicants within 30 days violates the Second and

Fourteenth Amendments, and (2) order the state to immediately issue FOID cards 

to the individual Plaintiffs and to members of ISRA and SAF who applied for FOID 

cards more than 30 days ago, who have not had their applications approved or 

denied. 

JURISDICTION AND VENUE

9. This Court has subject matter jurisdiction over this action pursuant to 

28 U.S.C. §§ 1331, 1343, 2201 and 2202, and 42 U.S.C. § 1983 because this action 

seeks to redress the Defendants’ deprivation, under color of state law, of rights 

protected by the U.S. Constitution. 

10. Venue lies in this Court pursuant to 28 U.S.C. § 1391 because the 

events and omissions giving rise to this action are harming Plaintiffs in this 

District.

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PARTIES 

 

Plaintiffs

11. Plaintiff James D. Robinson is an individual over 21 years of age who 

resides in the City of Blue Island in Cook County, Illinois. Mr. Robinson has a B.A. 

in Philosophy from North Central College in Naperville, Illinois. He has two 

daughters and is currently employed as a retail manager in Munster, Indiana.

12. Plaintiff John M. Marszalek is an individual over 21 years of age who 

resides in the Village of Carol Stream in DuPage County, Illinois. He has a B.F.A. 

in theater from Columbia College in Chicago, Illinois. He is currently employed as 

an Operations Director for a property management company in Lincolnwood, 

Illinois. He is married with four children.

13. Plaintiff Natalia D. LaVallie is an individual over 21 years of age who 

resides in the Village of Geneva in Kane County, Illinois. Dr. LaVallie has a 

Bachelor’s degree from George Washington University in Washington, D.C., 

graduated cum laude as a Doctor of Chiropractic from Life University in Marietta, 

Georgia, and received advanced training in animal chiropractic from Parker 

University in Dallas, Texas. In addition to her regular chiropractic practice in St. 

Charles, Illinois, she is certified in animal chiropractic by the Animal Chiropractic 

Certification Commission of the American Veterinary Chiropractic Association. She 

founded Barnyard Chiropractic as a mobile chiropractic practice to support animals 

and their humans in the comfort of their own home. 

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14. Plaintiff Matthew D. Sorenson is an individual over 21 years of age 

who resides in the City of Chicago in Cook County, Illinois. Mr. Sorenson has a 

Bachelor of Business Administration in accounting from the University of Iowa, and 

a Master of Accounting Science from Northern Illinois University. He is a Certified 

Public Accountant and a Certified Financial Planner. He is the owner of a tax and 

financial planning practice in Chicago.

15. Plaintiff ISRA is a non-profit membership organization incorporated 

under the laws of Illinois with its principal place of business in Chatsworth, Illinois. 

ISRA has more than 26,000 members and supporters in Illinois, and many members 

outside the State of Illinois. The organizational purposes of ISRA include securing 

the constitutional right to privately own and possess firearms within Illinois, 

through education, outreach, and litigation. ISRA brings this action on behalf of 

itself and its members.

16. In addition, ISRA operates a firing range in Bonfield, Illinois, for use 

by members of its range. Range membership is separate from general ISRA 

membership.

17. ISRA has members who are Illinois residents and have applied for 

Illinois FOID cards but have not received their cards, or had their applications 

denied for cause, within 30 days as state law requires. 

18. These ISRA members would possess one or more firearms in Illinois 

but refrain from doing so because they do not wish to be prosecuted for possessing a 

firearm without a FOID card.

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19. Plaintiff SAF is a non-profit membership organization incorporated

under the laws of Washington with its principal place of business in Bellevue, 

Washington. SAF’s membership includes residents of Illinois. SAF has over 650,000 

members and supporters nationwide. The organizational purposes of SAF include 

education, research, publishing, and legal action focusing on the constitutional right 

privately to own and possess firearms. SAF brings this action on behalf of itself and 

its members.

20. SAF has members who are Illinois residents and have applied for 

Illinois FOID cards but have not received their cards, or had their applications 

denied for cause, within 30 days as state law requires. 

21. The individual plaintiffs are members of both ISRA and SAF.

Defendants 

 

22. Defendant Brendan F. Kelly is the Director of the Illinois State Police 

(“ISP”).

23. The ISP is a department of the executive branch of the State of Illinois 

created by statute, 20 ILCS 2605/2605-1, et seq. Under the Illinois Firearm Owners 

Identification Card Act, 430 ILCS 65/1, et seq. (“FOID Card Act”), the ISP is 

charged with administering the system for consideration applications for, granting, 

denying, and/or revoking individual licenses to possess firearms under the FOID 

Card Act. 

24. Defendant Kelly is the ISP employee directly responsible for the 

administration of the FOID Card Act. As such, Defendant Kelly is responsible for 

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the ISP’s failure to issue FOID cards to Plaintiffs within 30 days of receiving their 

applications. He is sued in his official capacity pursuant to the principles set forth 

in Ex Parte Young, 209 U.S. 123 (1908). 

25. Jarod Ingebrigtsen is the Bureau Chief of the Firearm Services Bureau 

(“FSB”), a division of the ISP established to administer programs relating to 

firearms delegated to the ISP, including under the FOID Card Act. Having the 

power to make decisions in these programs, the FSB is an administrative agency of 

the State of Illinois as defined by 735 ILCS 5/3-101.

26. As Bureau Chief of the FSB, Defendant Ingebrigtsen is directly 

responsible for the ISP’s failure to issue FOID cards to Plaintiffs and others within 

30 days of receiving their applications. He is sued in his official capacity pursuant to 

the principles set forth in Ex Parte Young, 209 U.S. 123 (1908).

FACTS

Illinois’s FOID Card Requirement

27. Under Illinois law, an individual must obtain a FOID card to be 

allowed to possess any firearm. 

28. 430 ILCS 65/2 states, in relevant part:

Sec. 2. Firearm Owner’s Identification Card required; 

exceptions. 

(a) (1) No person may acquire or possess any firearm, 

stun gun, or taser within this State without having 

in his or her possession a Firearm Owner's 

Identification Card previously issued in his or her 

name by the Department of State Police under the 

provisions of this Act. 

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(2) No person may acquire or possess firearm 

ammunition within this State without having in his 

or her possession a Firearm Owner's Identification 

Card previously issued in his or her name by the 

Department of State Police under the provisions of 

this Act.

...

29. Illinois also provides that the ISP must “either approve or deny all 

[FOID card] applications within 30 days from the date they are received,” except for 

renewal applications, which are to be approved or denied within 60 days. 430 ILCS 

65/5.

30. The ISP must approve a FOID card application unless a disqualifying 

factor listed in the FOID Card Act (such as a felony conviction or certain mental 

health problems) applies. See 430 ILCS 65/8.

Illinois’s Failure to Timely Issue FOID Cards

31. Despite the statutory requirement, the ISP often does not approve or 

deny new FOID card applications within 30 days. 

32. For years, the ISP has commonly taken much longer than 30 days to 

approve qualified applicants’ FOID card applications. 

33. For example, in March 2013, the ISP publicly admitted that applicants 

were waiting 64 days to receive a FOID card. See Illinois Gun Buyers Now Waiting 

More than 60 Days for FOID Card, CBS Chicago, Mar. 27, 2013.3

3 https://chicago.cbslocal.com/2013/03/27/illinois-gun-buyers-now-waiting-morethan-60-days-for-foid-card/.

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34. Others at that time were reporting waits of 10 to 15 weeks to receive a 

FOID card. See id.

35. In 2020, violence and looting have led to a surge in applications for 

FOID cards, and the ISP is still failing to issue FOID cards within 30 days as state 

law requires. 

36. The ISP recently purported that its average time to issue a FOID card 

is 51 days, but many individuals have experienced much longer delays. See Megan 

Hickey, Surge in FOID Card Applications After Recent Violence Leads to Backlog, 

CBS Chicago, June 10, 2020.4

37. For a significant amount of time, ISRA has received reports from its 

members and supporters of FOID application delays by the Defendants and the ISP. 

38. For a significant amount of time, SAF has received reports from its 

members and supporters of FOID application delays by the Defendants and the ISP. 

39. ISRA members who have been waiting longer than 30 days to have 

their FOID card applications granted or denied include, among others, a 76-year-old 

male residing in DuPage County, Illinois, who applied for a FOID card in June, 

2020.

40. Plaintiff James D. Robinson applied for a FOID card on February 8, 

2020. The ISP still has not approved or denied his application.

41. Plaintiff John M. Marszalek applied for a FOID card on May 4, 2020.

The ISP still has not approved or denied his application.

4 https://chicago.cbslocal.com/2020/06/10/foid-card-application-backlog-illinoisviolence-looting/.

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42. Plaintiff Natalia E. LaVallie applied for a FOID card on or about April 

15, 2020. The ISP still has not approved or denied her application.

43. Plaintiff Matthew D. Sorenson applied for a FOID card on June 2,

2020. The ISP still has not approved or denied his application.

44. None of the individual Plaintiffs is prohibited from obtaining a FOID 

card under the disqualifying factors listed in 430 ILCS 65/8.

45. For a significant amount of time, the ISRA has received reports from 

its members and supporters of FOID application delays by the Defendants and the 

ISP. See Declaration of Richard Pearson.

46. For a significant amount of time, SAF has received reports from its

Illinois members and supporters of FOID application delays by the Defendants and 

the ISP.

47. One cause of Defendants’ failure to timely process FOID applications is 

the State of Illinois’s persistent refusal to provide the resources necessary to do so.

48. On September 10, 2019, the State of Illinois Commission on 

Government Forecasting and Accountability reported that, in the preceding five 

years, the ISP had more than $29.5 million swept or transferred away from the 

State Police Firearms Services Fund, the State Police Operations Assistance Fund, 

and the State Police Services Fund and into other accounts. 

49. That money was to be used for three purposes: background checks for 

firearm-related services, concealed carry licensing, and administration of the FOID 

Card Act. 

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50. Instead, the more than $29.5 million has been subject to interfund 

transfers, which are ostensibly to be repaid, but which have not been, or has been 

swept into other accounts with no obligation to reimburse the funds at all. 

51. The effect of this has been a systematic slowdown and sometimes halt 

of the processing of applications under the FOID Card Act. Even before the state 

lockdown in response to COVID-19, applicants commonly made many attempts to 

reach someone at the ISP by phone with no success. In the unlikely event that a 

person would answer, the applicant is usually told only that his or her case is under 

review. 

Injury to Plaintiffs

52. The individual Plaintiffs are each injured by the Defendants’ failure to 

issue them FOID cards within 30 days of receiving their respective applications 

because this failure has completely deprived them of their right to keep and bear 

arms and to use a firearm to defend their lives, families, and homes. But for the 

Defendants’ failure to issue them FOID cards, the Plaintiffs would immediately 

obtain and possess firearms in Illinois. 

53. Members of Plaintiffs ISRA and SAF who have applied for, but not 

timely received, FOID cards are injured by the Defendants’ failure to issue FOID 

cards within 30 days of receiving them because this failure has completely deprived 

them of their right to keep and bear arms and to use a firearm to defend their lives, 

families, and homes. But for the Defendants’ failure to issue them FOID cards, 

these individuals would immediately obtain and possess firearms in Illinois. 

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54. If not permanently enjoined by this Court, Defendants and their 

agents, representatives, and employees will continue to fail to timely approve FOID 

card applications, which deprive the individual Plaintiffs and the members of 

Plaintiffs ISRA and SAF of their constitutionally protected right to keep and bear 

arms. Thus, Defendants’ challenged practices are now causing and will continue to 

cause Plaintiffs to suffer irreparable injury, including but not limited to deprivation 

of their right to keep and bear arms. Plaintiffs have no plain, speedy, and adequate 

remedy at law for their injuries. 

55. ISRA is also directly injured by the state’s failure to timely approve 

FOID cards. To use the ISRA’s Bonfield shooting range, ISRA members must pay 

an additional $600.00 annual range membership fee. But, as a prerequisite to 

range membership, the member must have a valid FOID card and submit a written 

application that includes his or her FOID card number and expiration date.

Defendants’ failure to timely process FOID card applications harms ISRA because it 

deprives ISRA of revenue it would otherwise receive while would-be members wait 

to receive their FOID cards. See Craig v. Boren, 429 U.S. 190, 194 (1976) (vendor 

had standing to challenge statute under which she “was obliged either to ... incur[] 

a direct economic injury through the constriction of her buyers’ market, or to 

disobey [a] statutory commend and suffer ... ‘sanctions and perhaps loss of 

license’”).

56. An actual and substantial controversy exists between Plaintiffs and 

Defendants as to their respective legal rights and duties. Plaintiffs contend, 

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pursuant to 42 U.S.C. § 1983, that Defendants’ challenged practices violate the 

Second and Fourteenth Amendments. Plaintiffs are informed and believe, and 

allege on that basis, the Defendants contend otherwise all counts.

 

COUNT I: VIOLATION OF RIGHT TO KEEP AND BEAR ARMS 

U.S. CONST. AMENDS. II AND XIV, 42 U.S.C. § 1983 

57. Plaintiffs incorporate and reallege all of the foregoing Paragraphs as if 

fully restated herein.

58. The Second Amendment 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.

59. The Second Amendment is “fully applicable against the States.” 

McDonald v. City of Chicago, 561 U.S. 742 (2010). 

60. The right to keep and bear arms protected by the Second Amendment 

is a fundamental individual right and includes both the right to possess a firearm 

for “defense of hearth and home,” District of Columbia v. Heller, 554 U.S. 570, 635 

(2008) as well as the right to carry a firearm for self-defense outside the home, 

Moore v. Madigan, 702 F.3d 933, 942 (7th Cir. 2012). 

61. Defendants’ failure to comply with their statutory obligation and issue 

FOID cards in accordance with the 30-day legislative command to Plaintiffs 

Robinson, Marszalek, LaVallie, and Sorenson, and to the affected members of 

Plaintiffs ISRA and SAF has completely denied those individuals their 

constitutionally guaranteed rights to keep and bear arms for self-defense.

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62. The Defendants, under color of state law, have deprived and are 

depriving Plaintiffs Robinson, Marszalek, LaVallie, and Sorenson, and the affected 

members of Plaintiffs ISRA and SAF, of their right to keep and bear arms, in 

violation of the Second and Fourteenth Amendments to the United States 

Constitution. These individuals were and are thus injured in violation of 42 U.S.C. § 

1983. Plaintiffs are therefore entitled to declaratory and preliminary and 

permanent injunctive relief against the continued deprivation of their rights.

63. The Defendants’ failure to timely issue FOID cards and violations of 

applicants’ Second Amendment rights injure Plaintiff ISRA because they deprive

ISRA of revenue from individuals who otherwise would be able to become members 

of its firing range. Plaintiff ISRA is therefore entitled to declaratory and 

preliminary and permanent injunctive relief against the continued deprivation of its 

would-be range members’ rights. 

COUNT II: VIOLATION OF RIGHT TO PROCEDURAL DUE PROCESS 

U.S. CONST. AMEND. XIV, 42 U.S.C. §1983 

 

64. Plaintiffs incorporate and reallege all of the foregoing Paragraphs as if 

fully restated herein.

65. By failing or refusing to timely process their FOID applications, the 

Defendants have denied Plaintiffs Robinson, Marszalek, LaVallie, and Sorenson, 

and the affected members of Plaintiffs ISRA and SAF, their constitutionally 

guaranteed rights to an objective, prompt, and appealable procedure.

66. Whenever the government requires individuals to obtain a license or 

permit to exercise a right—especially a fundamental constitutional right—due 

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process demands that: (a) the burden of proof be allocated to the state, not the 

individual; (b) the applicant be informed of a specific and brief period within which 

the government will either grant or deny the license or permit; and (c) the licensing 

or permitting requirement provide a mechanism for prompt judicial review in the 

event of the erroneous denial of a license. See Freedman v. Maryland, 380 U.S. 51, 

58 (1965); Staub v. City of Baxley, 355 U.S. 313, 322 (1958). 

67. Defendants’ persistent failure to comply with their statutory obligation 

and issue FOID cards in accordance with the 30 day legislative command has 

violated and, unless enjoined by this Court, will continue to violate, the due process 

rights of Plaintiffs Robinson, Marszalek, LaVallie, and Sorenson, and the affected 

members of Plaintiffs ISRA and SAF.

68. Plaintiffs Robinson, Marszalek, LaVallie, and Sorenson, and the 

affected members of Plaintiffs ISRA and SAF therefore have been and are being 

damaged in violation of 42 U.S.C. § 1983. 

69. Plaintiffs Robinson, Marszalek, LaVallie, and Sorenson, and the 

affected members of Plaintiffs ISRA and SAF therefore are entitled to declaratory 

and preliminary and permanent injunctive relief against the continued deprivation 

of their rights. 

70. The Defendants’ failure to timely issue FOID cards and violations of 

applicants’ Fourteenth Amendment due process rights injure Plaintiff ISRA because 

they deprive ISRA of revenue from individuals who otherwise would be able to 

become members of its firing range. Plaintiff ISRA is therefore entitled to 

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declaratory and preliminary and permanent injunctive relief against the continued 

deprivation of its would-be range members’ rights. 

REQUEST FOR RELIEF 

WHEREFORE, Plaintiffs respectfully request that this Court enter judgment 

in their favor and:

A. Declare that Defendants’ failure to approve or deny for cause

applicants’ FOID card applications within 30 days violates the Second Amendment;

B. Declare that Defendants have unjustifiably denied Plaintiffs Robinson, 

Marszalek, LaVallie, and Sorenson, and the organizational Plaintiffs’ affected 

members, their Second Amendment right to keep and bear arms for self-defense;

C. Declare the Defendants’ failure to approve or deny for cause qualified 

applicants’ FOID card applications within 30 days violates the Due Process Clause 

of the Fourteenth Amendment;

D. Declare that Defendants have unjustifiably denied Plaintiffs Robinson, 

Marszalek, LaVallie, and Sorenson, and the organizational Plaintiffs’ affected 

members, their Fourteenth Amendment right to due process;

E. Enter an injunction ordering Defendants to immediately issue FOID 

cards to Plaintiffs Robinson, Marszalek, LaVallie, and Sorenson, and the 

organizational Plaintiffs’ affected members;

F. In the alternative, if Defendants cannot issue applicants’ FOID cards 

within 30 days as the FOID Card Act requires, enter an injunction against 

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enforcement of the FOID Card Act until at least such time as Defendants are able to 

so comply;

G. Award Plaintiffs their attorney’s fees and costs, pursuant to 42 U.S.C. 

§ 1988; and

H. Award Plaintiffs such other and further relief as it deems just.

Dated: November 9, 2020 Respectfully submitted,

JAMES D. ROBINSON, JOHN M. MARSZALEK, 

NATALIA E. LaVALLIE, MATTHEW D. SORENSON, 

ILLINOIS STATE RIFLE ASSOCIATION, and SECOND 

AMENDMENT FOUNDATION, INC. 

By: /s/ David G. Sigale

One of the Attorneys for Plaintiffs

By: /s/ Gregory A, Bedell

One of the Attorneys for Plaintiffs

By: /s/ Jacob Huebert

One of the Attorneys for Plaintiffs

David G. Sigale (Atty. ID# 6238103) 

LAW FIRM OF DAVID G. SIGALE, P.C. 

430 West Roosevelt Road 

Wheaton, IL 60187 

630.452.4547 

dsigale@sigalelaw.com

Gregory A. Bedell (Atty. ID# 6189762) 

KNABE & BEDELL

33 North Dearborn Street 

10th Floor 

Chicago, Illinois 60602 

312.977.9119 

gbedell@kkbchicago.com

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Jacob Huebert (Atty. ID# 6305339)

Martha Astor (pro hac vice motion pending)

Scharf-Norton Center for Constitutional Litigation at the

GOLDWATER INSTITUTE

500 E. Coronado Rd.

Phoenix, AZ 85004

Telephone: (602) 462-5000

litigation@goldwaterinstitute.org

Attorneys for Plaintiffs

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