IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO DANNY WILLIAMS, et al. Plaintiff, v. PUERTO RICO SUPERIOR COURT, et al. Defendants. CIVIL NO. 12-1218 (FAB) MOTION TO DISMISS PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 12(b)(6) TO THE HONORABLE COURT: COMES NOW, co-defendants POLICE DEPARTMENT, DEPARTMENT OF JUSTICE, the COMMONWEALTH OF PUERTO RICO and the PUERTO RICO SUPERIOR COURT without submitting to the Court's jurisdiction and through the undersigned attorney, who appears for the sole purpose of this motion, very respectfully states and prays as follows: I. INTRODUCTION On March 28, 2012 plaintiffs in above captioned proceeding filed action seeking declaratory and injunctive relief for deprivation of civil rights alleging that Puerto Rico’s Weapons Act of 2000 (25 L.P.R.A § 456a et. Seq.) (herein “Weapons Act”) imposes an undue burden in clear violation of plaintiff’s Second Amendment rights pursuant to the United States Supreme Court’s decision in McDonald v. City of Chicago, 130 S. Ct. 3020 (2010). Dkt. 5, ¶ 23. This action has been brought against the San Juan Superior Court, the Puerto Rico Police Department, the Puerto Rico Department of Justice and the Commonwealth of Puerto Rico. Dkt. 5. Plaintiff Danny Williams (“Williams”) alleges that on October 11, 2011 he requested a permit to carry weapons in the Puerto Rico Superior Court under Article 2.05 of the Weapons Act (25 L.P.R.A § Case 3:12-cv-01218-FAB Document 15 Filed 07/12/12 Page 1 of 24
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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO
DANNY WILLIAMS, et al.
Plaintiff,
v.
PUERTO RICO SUPERIOR COURT, et al.
Defendants.
CIVIL NO. 12-1218 (FAB)
MOTION TO DISMISS PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 12(b)(6)
TO THE HONORABLE COURT:
COMES NOW, co-defendants POLICE DEPARTMENT, DEPARTMENT OF JUSTICE, the
COMMONWEALTH OF PUERTO RICO and the PUERTO RICO SUPERIOR COURT without
submitting to the Court's jurisdiction and through the undersigned attorney, who appears for the sole
purpose of this motion, very respectfully states and prays as follows:
I. INTRODUCTION
On March 28, 2012 plaintiffs in above captioned proceeding filed action seeking declaratory and
injunctive relief for deprivation of civil rights alleging that Puerto Rico’s Weapons Act of 2000 (25 L.P.R.A
§ 456a et. Seq.) (herein “Weapons Act”) imposes an undue burden in clear violation of plaintiff’s Second
Amendment rights pursuant to the United States Supreme Court’s decision in McDonald v. City of Chicago,
130 S. Ct. 3020 (2010). Dkt. 5, ¶ 23. This action has been brought against the San Juan Superior Court,
the Puerto Rico Police Department, the Puerto Rico Department of Justice and the Commonwealth of
Puerto Rico. Dkt. 5.
Plaintiff Danny Williams (“Williams”) alleges that on October 11, 2011 he requested a permit to
carry weapons in the Puerto Rico Superior Court under Article 2.05 of the Weapons Act (25 L.P.R.A §
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456d). Thereon, on October 17, 2011 the court ordered the Justice Department, through the assistant
district attorney to express themselves in 15 days regarding Williams’ petition under the Second
Amendment. Nonetheless, on November 7, 2011 William’s petition was denied because he failed to
present certain documents and the Justice Department never expressed their position regarding the Second
Amendment issue. Dkt. 5, ¶ 19. Williams alleges “that the truth of the matter is” that the court wanted him
to show his income tax returns and to bring 3 reputation witnesses to state that he is someone that could be
trusted with a weapon. Dkt. 5, ¶ 19.
Likewise, on September 8, 2011, plaintiff Rubén González Lora, (“González-Lora”) requested a
permit to carry to the San Juan Superior Court under the Weapons Act and the Second Amendment.
Thereafter, on September 12, 2011 the court allegedly ordered petitioner to file 3 sworn statements from
reputation witnesses and a sworn statement stating that he had filed his state taxes. González-Lora was also
requested to file a certificate from child support stating that he had no debt. Dkt. 5, ¶ 20. González-Lora
filed several motions alleging that these requirements were unconstitutional and unsupported even under
the PR Weapons Act. On November 28, 2011 Hon. Judge Gisela Alfonso Fernández denied González-
Lora’s petition for a permit to carry. Dkt. 5, ¶ 20.
Pursuant to above, plaintiffs claim that the Handgun Permit Laws of Puerto Rico are facially invalid
under the Second and Fourteenth Amendment in violation of 42 U.S.C § 1983. In mounting their case,
plaintiffs assert that the government (1) can not license a constitutional right (1st cause of action); (2) that
the government may not impose a payment for a citizen to exercise their constitutional right (2nd cause of
action); (3) that the weapons act is discriminatory (3rd cause of action).; (4) that articles 2.02 and 2.05 of
the weapons act violate the second and fourteenth amendment because they grant uncontrolled discretion in
the hands of state officials (4th cause of action) and (5) that the requirements of sections 2.02 and 2.05 of the
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weapons act violate the second and fourteenth amendment because the right to bear arms is conditioned on
a range of requirements (5th cause of action).
Nevertheless, it is defendants position that all of plaintiff’s arguments fail as a matter of law. The
Puerto Rico Weapons Act is a weapons licensing and regulating scheme not a total ban law like the cases of
McDonald and Heller. Moreover, the Supreme Court of the United States has stated that the scope of the
Second Amendment is the “right of law-abiding, responsible citizens to use arms in defense of
hearth and home”. Heller v. DC 554 U.S. 570, 635 (2008) (Emphasis ours). In doing so, it has also
clarified that the right is “not unlimited.” Id. at 626, 128 S.Ct. 2783. This interpretation unequivocally
challenges plaintiff’s contention asserting that the Second Amendment bars any licensing system. As will be
thoroughly discussed:
1. Nothing in the US Supreme Court decisions in McDonald or Heller bar weapons licensing schemes like the Puerto Rico Weapons Act
2. Plaintiffs do not have standing to invoke the unconstitutionality of section 456(a) of the Weapons Act because they already possess weapons licenses.
3. Plaintiffs do not have standing to invoke the unconstitutionality of section 456(d) of the Weapons Act because the injury was self-inflicted and not caused by defendants.
4. The Permit to Carry Weapons is a privilege and not a right; the scope of the Second Amendment has been interpreted as the right to possess weapons in one’s home not to carry weapons in public.
5. The requirements in the licensing scheme are constitutional under the intermediate scrutiny standard.
6. The Weapons Act is not Discriminatory: Plaintiffs have failed to assert and Equal Protection Claim.
II. MOTION TO DISMISS STANDARD
To survive a Rule 12(b)(6) motion to dismiss, Plaintiffs' “well-pleaded facts must possess enough heft to
show that they are entitled to relief.” Clark v. Boscher, 514 F.3d 107, 112 (1st Cir.2008). In evaluating
whether Plaintiffs are entitled to relief, the court must accept as true all “well-pleaded facts [and indulge] all
reasonable inferences” in plaintiffs' favor .” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 127 S.Ct. 1955, 167
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possessed by law-abiding citizens for lawful purposes, such as short-barreled shotguns,” id. at 625, 128
S.Ct. 2783, or “the carrying of ‘dangerous and unusual weapons,’ ” id. at 627, 128 S.Ct. 2783, quoting 4
Blackstone 148–149 (1769). The Court declared that a citizen's Second Amendment right did not prohibit
laws regulating who may possess and carry weapons or purchase them, or where such weapons may be
carried. The Court explained: “Although we do not undertake an exhaustive historical analysis
today of the full scope of the Second Amendment, nothing in our opinion should be taken
to cast doubt on longstanding prohibitions on the possession of firearms by felons and the
mentally ill, or laws forbidding the carrying of firearms in sensitive places such as schools
and government buildings, or laws imposing conditions and qualifications on the commercial
sales of arms.” Heller, supra at 626–627, 128 S.Ct. 2783. The Court noted: “We identify these
presumptively lawful regulatory measures only as examples; our list does not purport to be
exhaustive.” Id. at 627 n. 26, 128 S.Ct. 2783.
On June 28, 2010, the Court decided McDonald2. The Court explained that the Second Amendment
right to keep and bear arms is “among those fundamental rights necessary to our system of ordered liberty.”
McDonald, supra at 3042. The Court stated that the right “applies equally to the Federal Government and the
States” and Justice Alito, writing the plurality opinion, concluded that the Second Amendment right is
incorporated to the States through the due process clause of the Fourteenth Amendment. Id. at 3050. Of
significance, the plurality opinion did not disturb the conclusion in Heller that a citizen's rights under the
Second Amendment are limited. The Court explained:
“It is important to keep in mind that Heller, while striking down a law that prohibited the possession of handguns in the home, recognized that the right to keep and bear arms is not ‘a right to keep and carry any weapon whatsoever in any manner whatsoever and for whatever purpose.’ [ Heller, supra at 626, 128 S.Ct. 2783]. We made it clear in Heller that our
2 McDonald v. City of Chicago, 130 S. Ct. 3020 (2010).
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holding did not cast doubt on such longstanding regulatory measures as ‘prohibitions on the possession of firearms by felons and the mentally ill,’ ‘laws forbidding the carrying of firearms in sensitive places such as schools and government buildings, or laws imposing conditions and qualifications on the commercial sale of arms.’ [ Id. at 626–627, 128 S.Ct. 2783.] We repeat those assurances here. Despite municipal respondents' doomsday proclamations, incorporation does not imperil every law regulating firearms. ”McDonald, supra at 3047. (Emphasis Ours).
In the case before this Honorable Court plaintiffs have stated that the government can not license a
constitutional right. Dkt. 5, ¶ 26-31. In other words, plaintiffs assert that the Second Amendment bars any
licensing scheme. Nonetheless, as evident from the decisions in Heller and McDonald this was not the
intention of the Court when it interpreted the scope of the Second Amendment and made it applicable to
the states. To the contrary, McDonald did not disturb the Heller pronouncement and precisely made clear
that the right to keep and bear arms is not ‘a right to keep and carry any weapon whatsoever in any manner
whatsoever and for whatever purpose’. Additionally, the Court made it clear that the decision ‘did not cast
doubt on such longstanding regulatory measures as ‘prohibitions on the possession of firearms by felons and
the mentally ill’ [Heller, supra at 626, 128 S.Ct. 2783]. Consequently, this Honorable Court should
interpret the scope of the McDonald and Heller cases for what they are–a rejection of total ban laws-and not
give in to plaintiff’s flawed interpretation of the current case law as a doomsday proclamation of the states
weapons licensing schemes.
B. The Puerto Rico Weapons Act: The Difference Between Weapons License and Permit to Carry
The government of Puerto Rico through the enactment of the Puerto Rico Weapons Act of 2000,
25 L.P.R.A. § 455 et seq., has used its inherent regulating power with the noble goal of promoting security
and well being for the people of Puerto Rico. The rise in criminal activity in the last decades has been a
product, in part, of the increase in the illegal trafficking of drugs. This, in turn, has caused an alarming rise
in the use of illegal weapons. The illegal firearms have been brought in clandestine ways from other
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jurisdictions and some have been acquired during burglaries to state, private or commercial properties that
have been authorized to legally possess weapons. To effectively deal with this rise in criminal activity, the
Act establishes innovative ways that respond to the inherent state interest of having a legal device whose
implementation permits law enforcement agencies to be more effective in the fight against crime. In this
regard, the Act counsels’ law abiding citizens in the effective and responsible management of firearms while
it advices criminals about the consequences of using firearms in illegal ways. Statement of Motives, Puerto Rico
Arms Act of 2000, 25 L.P.R.A. § 455 et seq.
As part of the regulating scheme manifested in the law, there are two different licenses or permits
that regulate the rights to possess or carry weapons by citizens of Puerto Rico. First, the Weapons Act
provides for the issuance of a weapons license for all those who comply with the requirements of section
456a. 25 L.P.R.A § 456a. This license is defined as “the license issued by the Superintendant that authorizes
the concessionaire to possess, carry and transport arms and ammunition, and, depending on their category,
to carry firearms, target shooting or hunting”. 25 L.P.R.A § 455(o). This weapons license empowers the
licensee to be the owner of a maximum of two (2) firearms except as specifically provided in section 456a
(14)(d). Additionally, the license allows the licensee to bear, carry and transport the weapons in a hidden or
unobtrusive manner but not on his/her person. For a licensee to be able to carry the weapons in his/her
person and in public, a permit to carry is necessary. 25 L.P.R.A. 456a (14)(d)(1)(2). This “permit to
carry” is the second weapons regulation in the licensing scheme and it requires authorization by the Court
of First Instance of Puerto Rico. 25 L.P.R.A. §456d (a). As evident from the text of the Act, to be able to
procure a permit to carry by the competent Court of First Instance, a petitioner must first possess a
weapons license as defined in section 456a. In this regard, section 456d(a) establishes that:
The competent Part of the Court of First Instance shall grant authorization to the Superintendant to include in the petitioner’s identification card a permit to bear, transport and carry, without
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identifying any particular weapon, any legally owned pistol or revolver unless there is just cause to deny said permit with prior notification to the Department of Justice and upon a hearing before the same if so required by the latter, to any person who holds a weapons license and demonstrates that he/she fearsa for his/her safety. (Emphasis added)
Additionally, section 456 d(b) states that “the permit to carry weapons granted herein shall have a
term subject to the effectiveness of the weapons license..”. As evident from the licensing scheme, the
legislative intention behind the Act was to distinguish two different rights and interests; the right to possess
weapons in the home, for protection of the family and self and the privilege to carry a weapon in public.
The weapons license safeguards the first and the permit to carry regulates the second.
The allegations in the complaint make it clear that both plaintiffs already possess the weapons
license given the fact that they were both procuring permits to carry. Dkt. 5, ¶ 19 and 20. Moreover, they
were denied the permit to carry because they intentionally refrained from producing the documents that
were required of them by law, alleging that the requirement to produce said documentation violated their
rights under the Second Amendment.
Nonetheless, and as will be further developed, defendants contend that plaintiffs do not have
standing to allege the unconstutionality of section 456a regarding the requirements for the issuance of the
weapons license because they already possess a weapons license and have nothing at stake regarding this
issue.
Additionally, defendants further contend that the permit to carry is beyond the scope of the Second
Amendment and should not be analyzed as a right but as a privilege. The interpretation of the Second
Amendment has been consistently related to the rights of law-abiding, responsible citizens to use
arms in defense of hearth and home. Heller v. DC 554 U.S. 570, 635 (2008) (Emphasis ours). In this
regard, the weapons license plaintiffs already possess, allows them to enjoy their Second Amendment rights
fully.
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facially invalid because it requires “a citizen to obtain a license for the exercise of a fundamental right”. Dkt.
5, ¶37. Said another way, plaintiffs pretend to assert that the Second Amendment bars any licensing system.
The Court's decisions of McDonald and District of Columbia v. Heller, 554 U.S. 570, 128 S.Ct. 2783, 171
L.Ed.2d 637 (2008) ( Heller ), however, does not support such a conclusion. To the contrary, the Court in
Heller identified an individual right to carry and bear arms that is limited in scope. The Court explained that
a citizen's Second Amendment right did not prohibit laws regulating who may possess and carry weapons or
purchase them, or where such weapons may be carried. The Court stated:
“Although we do not undertake an exhaustive historical analysis today of the full scope of the Second Amendment, nothing in our opinion should be taken to cast doubt on longstanding prohibitions on the possession of firearms by felons and the mentally ill, or laws forbidding the carrying of firearms in sensitive places such as schools and government buildings, or laws imposing conditions and qualifications on the commercial sales of arms.”
The United States Supreme Court noted: “We identify these presumptively lawful regulatory measures
only as examples; our list does not purport to be exhaustive.” District of Columbia v. Heller, 554 U.S. 570,
627 n. 26, 128 S.Ct. 2783, 171 L.Ed.2d 637 (2008).
In McDonald, the Court cited to this specific language in Heller and stated: “We repeat those assurances
here. Despite plaintiff’s doomsday proclamations, incorporation does not imperil every law regulating
firearms.” McDonald, supra at 3047. Thus, the requirement of “a citizen to obtain a license for the exercise of
a fundamental right” or a licensing system, does not by itself render the statute unconstitutional on its face
and given that the underlying licensing regime is lawful the payment provision is also enforceable. Nothing
in the McDonald and Heller decisions has altered or abrogated the state of the law concerning the statutory
presumption set forth in the Puerto Rico Weapons Act. Moreover, if not with a licensing scheme, how else
is the government going to have the assurance that those who possess weapons are law-abiding, responsible
citizens who are not felons or the mentally ill? Without some form of regulation that balances the Second
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2005); Baker v. City of Concord, 916 F.2d 744, 755 (1st Cir. 1990). Rational basis review "is a paradigm of
judicial restraint." FCC v. Beach Commc'ns, Inc., 508 U.S. 307, 314 (1993). "The general rule is that
legislation is presumed to be valid and will be sustained if the classification drawn . . . is rationally related to
a legitimate state interest." City of Cleburne v. Cleburne Living Ctr., Inc., 473 U.S. 432, 440(1985). The
challenger has the devoir of persuasion and must negate any and all conceivable bases upon which the
challenged regulation might appropriately rest. Bd. of Trs. of Univ. of Ala. v. Garrett, 531 U.S. 356, 367
(2001); Heller v. Doe, 509 U.S. 312, 320 (1993). If any such ground exists to support the classification
employed, the regulation must be upheld even if it is drawn from "rational speculation unsupported
by evidence or empirical data." Beach Commc'ns, 508 U.S. at 315. In this case, the interests that section
456c purposes to serve are unarguably legitimate. The Legislature of Puerto Rico, when enacting the law,
understood that the functions and duties of certain government officials were of such risk that an expedited
process for them to obtain a weapons license was appropriate. This value and criteria by the legislature is
presumed to be valid and must be sustained given the fact that it is rationally related to a legitimate state
interest. Accordingly, this Honorable Court should DENY plaintiffs equal protection claim.
iii. Fourth and Fifth Cause of Action: Constitutionality of Statutory Authority of Government Officials to Enforce Regulation of Firearms and Permit to Carry Requirements
In asserting that Articles 2.02 and 2.05 of the Puerto Rico Weapons Act (25 L.P.R.A. § 456a and
456d) violate the Second and Fourteenth Amendment because they vest uncontrolled discretion on the
hands of state officials, plaintiffs rehash the claim challenging the licensing scheme. Dkt. 5,¶ 36-40. On the
other hand, in stating that these articles are unconstitutional because the “exercise of a constitutional right
can not be conditioned on the show of fear, third party opinions, prove of child support payment, prove of
state tax payment and prove of medical abilities certification”, plaintiffs challenge what is a privilege and not
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a right afforded by the Second Amendment. As stated above, plaintiffs don’t have standing to challenge the
constitutionality of section 456a or 456d given the fact that they already possess weapons licenses. In
regards to section 456d, plaintiffs assert that it is facially invalid in that it vests the Superior Court with
uncontrolled discretion to issue or refuse to issue carry permits and that the requirements to do so are
impermissibly burdensome. Dkt. 5, ¶ 36-42. To succeed in a typical facial attack on the constitutionality of
a statute, a party would have to establish that no set of circumstances exists under which the statute would
be valid, or that the statute lacks any plainly legitimate sweep. U.S. v. Stevens, 130 S. Ct. 1577 (2010). This
standard can not be proved by plaintiffs. As previously discussed, the carry permit is beyond the scope of
the Second Amendment and the presumption of constitutionality normally accorded a State's law applies.
Smith v. Doe, 538 U.S. 84, 110, 123 S.Ct. 1140 (2003). Additionally, even if it were to be analyzed within
the scope of the Heller and McDonald decision, the discretion afforded to State Court judges and the
requirements for the permit to carry would still stand because they respond to a legitimate purpose that is
reasonably related to the right at issue. Heller precisely pointed to the fact that the Second Amendment
right applied to “law-abiding, responsible citizens to use arms in defense of hearth and home”.
Heller v. DC 554 U.S. 570, 635 (2008) (Emphasis ours). The discretion to grant a permit to carry to a
weapons licensee holder takes into account factors that go to the heart of the limit of the right. The
requirements of third party opinions, child support payment and prove of state tax payment go to the
question of whether the person is a law abiding, responsible citizen. Accordingly, these requirements are
presumed valid and this Honorable Court should DENY plaintiffs challenge to section 456d.
WHEREFORE, defendants respectfully request that this Honorable Court DENY plaintiff’s
complaint and DISMISS WITH PREJUDICE all the causes of action that have been brought in the instant
civil action.
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I HEREBY CERTIFY that on this same date, I electronically filed the foregoing with the Clerk of
the Court using the CM/ECF system, which will send electronic notification of such filing to all attorneys
of record.
RESPECTFULLY SUBMITTED.
In San Juan, Puerto Rico, this 12th day of July, 2012.
GUILLERMO A. SOMOZA-COLOMBANI Secretary of Justice of the Commonwealth of Puerto Rico GRISEL SANTIAGO-CALDERÓN Deputy Secretary of Justice In Charge of the Office of General Litigation WANDYMAR BURGOS-VARGAS U.S.D.C.-P.R. Bar No. 223502 Acting Director of Legal Affairs Office of General Litigation Federal Litigation Division [email protected] S/ Maraliz Vázquez Marrero MARALIZ VÁZQUEZ-MARRERO U.S.D.C. NO. 225504 Department of Justice Federal Litigation Division P.O. Box 9020192 San Juan, P.R., 00902-0192 Tel. (787) 721-2900 Fax (787) 723-9188 [email protected][email protected]
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