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No.
______, Original
In the Supreme Court of the United States
STATE
OF [INSERT YOUR STATE],
Plaintiff,
v.
UNITED
STATES OF AMERICA, PRESIDENT OF THE UNITED STATES, VICE- PRESIDENT OF THE UNITED
STATES, ATTORNEY GENERAL OF THE UNITED STATES; SPEAKER OF THE UNITED STATES HOUSE
OF REPRESENTATIVES, PRESIDENT PRO TEMPORE OF THE UNITED STATES SENATE, STATE
OF ARIZONA, STATE OF GEORGIA, STATE OF MICHIGAN, COMMONWEALTH OF PENNSYLVANIA, AND
STATE OF WISCONSIN,
Defendants.
BILL OF COMPLAINT
COUNT
I: ELECTORS CLAUSE
COUNT
II: DUE PROCESS
COUNT
III: GUARANTEE CLAUSE
COUNT
IV: TAKE CARE CLAUSE
PRAYER
FOR RELIEF
WHEREFORE, the
Plaintiff State respectfully requests that this Court issue the following
relief:
1. Declare that Defendant States administered the November 2020
election in violation of the Electors Clause and the Fourteenth Amendment of
the U.S. Constitution.
2. Declare that the
United States and Officer Defendants violated the Guarantee Clause and the Take
Care Clause with respect to allowing the foregoing constitutional violations by the Defendant States in
administering the November 2020 election.
3. Declare that the Defendant States’ certification of the
November 2020 election results and of presidential electors on or about
December 14, 2020, violated the Electors Clause and the Fourteenth Amendment of
the U.S. Constitution and vacate those certifications.
4. Declare that the Defendant States’ certification of the
November 2020 election results and of presidential electors on or about
December 14, 2020, violated the Electors Clause and the Fourteenth Amendment of
the U.S. Constitution and vacate those certifications.
5. Declare that the United States violated the Guarantee Clause in
allowing the November 2020 election to proceed on the basis of the
unconstitutional results in Defendant States.
6. Declare that the President, Attorney General, and
Vice-President violated the Take Care Clause by failing to act to remedy the
violations of the Constitution in the November 2020 election.
7. Enjoin the use of
vacated certifications in Defendant States’ use of the 2020 election results
for the Office of President to appoint presidential electors to the Electoral
College.
8. Declare that the
counting of electoral votes in the Joint Session of Congress on January 6-7,
2021, violated the Electors Clause, the Due Process Clause, the Guarantee
Clause, the Take Care Clause, and the Twelfth Amendment, and vacate that count.
9. Enjoin the Officer Defendants to convene special sessions of
the House of Representatives and the Senate to vote for the President and
Vice-President, respectively, pursuant to the Twelfth Amendment.
10. Alternatively, authorize, pursuant to the Court’s remedial
authority, the Defendant States to conduct a special election to appoint
presidential electors.
11. Alternatively, authorize, pursuant to the Court’s remedial
authority, the Defendant States to conduct an audit of their election results,
supervised by a Court-appointed special master, in a manner to be determined
separately.
12. Enjoin Defendant States’ use in future elections of revisions
adopted by non-legislative actors to the election laws enacted by the state
legislatures unless the legislature ratifies any such revisions by enacting
them as state law before the election.
13. Award costs to Plaintiff State.
14. Grant such other
relief as the Court deems just and proper.
REFERENCE:
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By
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2021
