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HvO Complaint Aug 2012

HvO Complaint Aug 2012

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Published by Jack Ryan

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Published by: Jack Ryan on Aug 10, 2012
Copyright:Attribution Non-commercial

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09/17/2012

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IN THE COMMONWEALTH OF KENTUCKY
 
FRANKLIN CIRCUIT COURT48TH JUDICIAL CIRCUIT
CIVIL ACTION NO. __________________ 
L. Todd House,
Plaintiff,
 
vs.
Barack Hussein Obama,Democratic National Committee,Kentucky Secretary of State,
and
 Kentucky State Board of Elections,
Defendants.
COMPLAINTSummary of Complaint
Plaintiff is challenging the eligibility of Barack Obama to be listed on Kentuckyballots as a candidate for President of the United States. This challenge is basedupon two alternative theories related to his not being a
natural born 
citizen, asrequired by Article II, Section I, Clause 5 of the U.S. Constitution, namely:
 
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 1.
He is not a
natural born 
citizen, because he was born of foreign paternity;and,
2.
He is foreign born.Plaintiff brings this complaint as three causes of action:
1.
Violation of one of the plaintiffs’ rights derived from the United States
Constitution;
2.
Negligence for violation of Article II, Section I, Clause 5 of thatConstitution; and
3.
 A challenge of the candidate’s bona fides
under KRS 118.176.
Parties, Jurisdiction, Standing, and Venue
Plaintiff alleges as follows:
1.
Plaintiff L. Todd House (“House”) is an individual, and candidate for 
president, and brings suit in each of his respective capacities.
2.
Defendant Barack Obama (“Obama”) is an individual, and is sued in that
capacity.
3.
Defendant Democratic National Committee (“DNC”) is the governing body
of the National Democratic Party, and is sued in that capacity.
 
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 4.
Under the KRS 118.325, defendant DNC plays a key role in determiningwho is listed as a Democratic Party candidate for President of the UnitedStates on Kentucky Ballots and, accordingly, is an indispensable party tothe remedies sought, even if the court should find that it has no liabilitywith respect to causes of action alleged below.
5.
Under KRS 118.215, defendant Kentucky
Secretary of State (“SOS”)
certifies the names of candidates for President of the United States onKentucky Ballots and, accordingly, is an indispensable party to thenoncompensatory remedies sought, even though plaintiff is not allegingthat defendant SOS has any liability with respect to causes of actionalleged below.
6.
Under KRS 118.176, defendant Kentucky State Board of Elections
(“BOE”) will receive the applicable certification from the court if de
fendantObama is found not to be a bona fide candidate and, accordingly, is anindispensable party to the noncompensatory remedies sought, eventhough plaintiff is not alleging that defendant BOE has any liability withrespect to causes of action alleged below.
7.
Plaintiff seeks relief and this court has jurisdiction under KRS 118.176 andKRS 418.040.
8.
Plaintiff has standing under Ky. Const. § 14.
9.
Causes of action alleged in this complaint arose in, among other places,Franklin County, and defendants SOS and BOE have offices in Franklin

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