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Plaintiffs' Reply to Defendants' Opposition to Plaintiffs' Motion For Case 2:20-cv-02927-CBM-AS Document 37 Filed 05/12/20 Page 1 of 29 Page ID #:661 1 2 Ronda Baldwin-Kennedy, Esq. (SB #302813) Jerome A. Clay, Esq. (SB #327175) 3 LAW OFFICE OF RONDA BALDWIN-KENNEDY 4 5627 Kanan Rd. #614 Agoura Hills, CA 91301 5 Phone: (951) 268-8977 6 Fax: (702) 974-0147 Email: [email protected] 7 8 Raymond M. DiGuiseppe (SB #228457) THE DIGUISEPPE LAW FIRM, P.C. 9 4320 Southport-Supply Road, Suite 300 10 Southport, North Carolina 28461 11 Phone: 910-713-8804 Fax: 910-672-7705 12 Email: [email protected] 13 Attorneys for Plaintiffs 14 15 UNITED STATES DISTRICT COURT 16 FOR THE CENTRAL DISTRICT OF CALIFORNIA 17 DONALD MCDOUGALL, et al., Case No. 2:20-cv-02927-CBM 18 19 Plaintiffs, vs. MEMORANDUM OF POINTS AND 20 AUTHORITIES IN SUPPORT OF COUNTY OF VENTURA, 21 PLAINTIFFS’ REPLY TO CALIFORNIA, et al., DEFENDANTS’ OPPOSITION TO 22 PLAINTIFFS’ MOTION FOR 23 Defendants. PRELIMINARY INJUNCTION 24 25 26 First Amended Complaint Filed Apr. 14, 2020 27 28 – i – MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF PLAINTIFFS’ REPLY TO DEFENDANTS’ OPPOSITION TO PLAINTIFFS’ MOTION FOR PRELIMINARY INJUNCTION CASE NO. 2:20-cv-02927 Case 2:20-cv-02927-CBM-AS Document 37 Filed 05/12/20 Page 2 of 29 Page ID #:662 1 TABLE OF CONTENTS 2 3 INTRODUCTION ................................................................................................... 1 4 ARGUMENT ............................................................................................................ 4 5 A. The Defendants’ Series of Unconstitutional Orders Effectively Banning 6 All Legal Firearm and Ammunition Transfers County-wide ................... 4 7 1. The March 17th Order .......................................................................... 4 8 2. The March 20th Order .......................................................................... 4 3. The March 31st Order ........................................................................... 5 9 4. The April 20th Order ............................................................................ 6 10 5. The May 7th Order ................................................................................ 7 11 12 B. Categorical, or At Least Heightened, Constitutional Scrutiny Applies to Defendants’ Orders and Enforcement Practices ...................................... 10 13 14 C. Plaintiffs Demonstrate a Strong Likelihood of Success ........................... 15 1. Defendants’ Orders Fail the Controlling Heller and Strict Scrutiny 15 ................................................................................................................ 15 16 2. Defendants Fail to Show Any Tailoring of the Means to Their End 17 ................................................................................................................ 19 18 D. The Public Interests and Balance of Equities All Lean in Plaintiff’s Favor 19 ....................................................................................................................... 23 20 21 22 23 24 25 26 27 28 – ii – MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF PLAINTIFFS’ REPLY TO DEFENDANTS’ OPPOSITION TO PLAINTIFFS’ MOTION FOR PRELIMINARY INJUNCTION CASE NO. 2:20-cv-02927 Case 2:20-cv-02927-CBM-AS Document 37 Filed 05/12/20 Page 3 of 29 Page ID #:663 1 TABLE OF AUTHORITIES 2 CASES 3 Adams & Boyle, P.C. v. Slatery, ___ F.3d ___, 2020 WL 1982210 (6th Cir. Apr. 4 24, 2020) ................................................................................................... 11, 14, 23 5 Ashcroft v. ACLU, 542 U.S. 656 (2004) .................................................................. 19 6 Bauer v. Becerra, 858 F.3d 1216 (9th Cir. 2017) .................................................... 19 7 Church of the Lukumi Babalu Aye, Inc. v. City of Hialeh, 508 U.S. 520 (1993) .... 12 8 District of Columbia v. Heller, 554 U.S. 570 (2008) ....................................... passim 9 Duncan v. Becerra, 265 F.Supp.3d 1106, 1136 (S.D. Cal. 2017), aff’d, 742 F. App’x 218 (9th Cir. 2018) .................................................................................... 23 10 Ezell v. City of Chicago, 651 F.3d 684 (7th Cir. 2011) ..................................... 18, 19 11 First Baptist Church v. Kelly, ___ F.3d.Supp ___, 2020 WL 1910021 (D. Kan. 12 Apr. 18, 2020) ...................................................................................................... 13 13 Gish v. Newsom (C.D.Cal. April 23, 2020), case No. 5:20-cv-00755-JGBKK ...... 13 14 In re Abbott, 954 F.3d 772 (5th Cir. 2020) .............................................................. 14 15 In re Salon A La Mode, __ S.W.3d ___, 2020 WL 2125844 (Tex. May 5, 2020) .. 24 16 Jackson v. City and County of San Francisco, 746 F.3d 953, 968 (9th Cir. 2014) 18, 19 17 Jacobson v. Commonwealth of Massachusetts, 197 U.S. 11 (1905) ..................... 1, 2 18 Maryville Baptist Church, Inc. v. Beshear, ___ F.3d ___, 2020 WL 2111310 (6th 19 Cir. May 2, 2020) ................................................................................................. 12 20 McCarthy v. Gov. Baker, D. Mass. No. 1:20-cv-10701-DPW, 2020 WL 2297278 24 21 McDonald v. City of Chicago, 561 U.S. 742 (2010) ................................... 15, 17, 18 22 Rhode v. Becerra, 2020 U.S. Dist. LEXIS 71893 ................................................... 25 23 Robinson v. Attorney General, ___ F.3d ___, 2020 WL 1952370 (11th Cir. 2020) 24 .............................................................................................................................. 11 25 United States v. Chovan, 735 F.3d 1127 (9th Cir. 2013) ............................ 15, 18, 19 Walsh v. City and County of Honolulu, 423 F.Supp.2d 1094 (D. Hawaii 2006) .... 22 26 Ward v. Rock Against Racism, 491 U.S. 781, 800 (1989) ................................. 20, 22 27 Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7 (2008) ................. 24 28 – iii – MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF PLAINTIFFS’ REPLY TO DEFENDANTS’ OPPOSITION TO PLAINTIFFS’ MOTION FOR PRELIMINARY INJUNCTION CASE NO. 2:20-cv-02927 Case 2:20-cv-02927-CBM-AS Document 37 Filed 05/12/20 Page 4 of 29 Page ID #:664 1 OTHER AUTHORITIES 2 Toward a Twenty-First Century Jacobson v. Massachusetts, 121 Harv. L. Rev. 3 1820 (2008); Goston, Jacobson v. Massachusetts at 100 Years: Police Power and Civil Liberties in Tension, 95 Am. J. Pub. Health 576, 580 (2005) .............. 10 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 – iv – MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF PLAINTIFFS’ REPLY TO DEFENDANTS’ OPPOSITION TO PLAINTIFFS’ MOTION FOR PRELIMINARY INJUNCTION CASE NO. 2:20-cv-02927 Case 2:20-cv-02927-CBM-AS Document 37 Filed 05/12/20 Page 5 of 29 Page ID #:665 1 INTRODUCTION 2 Defendants claim their litany of COVID-19 “Stay Well at Home” orders are 3 entitled to “great deference” under the framework of Jacobson v. Commonwealth of 4 5 Massachusetts, 197 U.S. 11 (1905), and epidemiological pragmatism, Opp. to MPI 6 (“Opp.”) at 8, 10, 24. They portray the orders as the product of the “presumptively 7 lawful” “professional judgment” of the County Health Officer (Defendant Robert 8 9 Levin, M.D.), id. at 15, which, according to them, cannot “be reasonably 10 questioned,” id. at 10, n. 6, because they are “temporary, specific and tailored” 11 12 emergency measures “for the collective good,” id. at 1, 10—especially the now- 13 repealed order of April 20th. But the reality is that Defendants have issued and 14 enforced a series of seven unconstitutional directives—its latest one issued just days 15 16 ago on May 7th which repealed the April 20th Order that Defendants relied upon for 17 their anemic opposition—without any legislative process. And, after usurping the 18 19 legislative branch and process, Defendants now seek to preclude the judicial branch 20 from properly scrutinizing their orders and enforcement actions that violate 21 Plaintiffs’ enumerated fundamental rights. 22 23 Defendants characterize Plaintiffs’ motion as a “request for a preliminary 24 injunction to open the firearm stores” Defendants closed. But that purposefully walks 25 past the fact that Defendants did not merely shutter firearm retailers; they did that, 26 27 and more, by broadly and completely prohibiting through criminal sanctions all 28 – 1 – MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF PLAINTIFFS’ REPLY TO DEFENDANTS’ OPPOSITION TO PLAINTIFFS’ MOTION FOR PRELIMINARY INJUNCTION CASE NO. 2:20-cv-02927 Case 2:20-cv-02927-CBM-AS Document 37 Filed 05/12/20 Page 6 of 29 Page ID #:666 1 constitutionally protected conduct necessary to the exercise of enumerated rights. 2 The preliminary injunctive relief Plaintiffs seek in the instant motion is vital to 3 4 protecting and restoring fundamental rights, and to upholding the one fundamental 5 rule of the Jacobson case that has direct bearing here: “[a] local enactment or 6 regulation, even if based on the acknowledged police powers of a state, must always 7 8 yield in case of conflict with the exercise by the general government of any power it 9 possesses under the Constitution, or with any right which that instrument gives or 10 11 secures.” Jacobson, 197 U.S. at 25. 12 Defendants cannot escape two truths about their policies and the realities of 13 their continuing enforcement thereof: First, they completely closed all firearm and 14 15 ammunition retailers, through which plaintiffs and others like them must conduct 16 firearm and ammunition transfers, deeming them non-essential. Defendants have
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