COMPLAINT FOR DEPRIVATION OF CIVIL RIGHTS
COMES NOW the Plaintiff, Christopher Baker (“Mr. Baker”), by andthrough the undersigned counsel, and complains of the Defendants as follows:
Plaintiff Mr. Baker is a natural person and a citizen of the UnitedStates, State of Hawai’i and a resident of Honolulu County. Mr. Baker has beendeprived of liberty and property in violation of the Second, Fifth and FourteenthAmendments of the United States Constitution.
This action arises from Hawai‘i’s ban on transporting and bearingfirearms as a license to carry is the only means by which Mr. Baker could bear afirearm and/or ammunition, whether openly or concealed, even within his ownhome, for the purpose of self-defense, proficiency training, or other protectedpurposes. Mr. Baker is a law-abiding citizen who is fit and qualified to bear arms.Mr. Baker applied for a license to carry a firearm, pursuant to Section 134-9 of theHawai‘i Revised Statutes (“HRS”). However, the application was denied by theDefendant, Chief of Police Louis Kealoha (“Defendant Kealoha”), withoutproviding Mr. Baker with a meaningful opportunity to be heard, a reason orexplanation for the denial, or any opportunity for further review.3.
The right to bear operational firearms and ammunition, and otherweapons in common use for lawful purposes is a fundamental constitutional right