Sevier V Davis

Case: 0:16-cv-00080-HRW Doc #: 1 Filed: 07/01/16 Page: 1 of 44 - Page ID#: 1
UNITED ST ATES DISTRICT COURT FOR THE EASTERN DISTRICT Ol\'r LEX!N.
ROB.
GTON
KENTUCKY
CLfRK vs ERr R. CAflR
CHRIS SEVIER
., . DISTR!c1 COURT
v.
KIM DAVIS, in her official capacity as
Clerk Of Rowan County; MATT BEVIN,
in his official capacity as Governor Of
Kentucky; and ANDY BESHEAR, in his
official capacity as Clerk of Attorney
General For Kentucky
Case No:
COMPLAINT FOR INJUNCTIVE
RELIEF
JURY DEMAND
COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF

"At what point shall we expect the approach of danger? By what means shall wefortifa against it?-- Shall
lVe expect son1e transatlantic milita1J' giant, to step the Ocean, and crush us at a b/0111? Never!--All the arn1(es of
Europe, Asia and Aji-ica combined, with all the treasure of the earth (our own excepted) in their militmy chest; with
a Buonaparte for a commander, could not by force, take a drink from the Ohio, or make a track on the Blue Ridge,
in a trial of a thousand years. At what point then is the approach of danger to be expected? I answer, if it ever reach
us, it 1nust spring up an1ongsl us. It cannot come fio1n abroad If destruction be our lot, rile 1nust ourselves be its
author andfinisher. As a nation offreen1en, lve niust live through all tilne, or die by suicide. "President Lincoln;
Lyceum Address
I.
PART ONE INTRODUCTION
A. LAYING THE FOUNDATION OF A CASE OF CASE INVOLYING OUT OF
CONTROL JUDICIAL DISHONESTY. THE DISREGARD OF THE FIRST
AMENDMENT ESTABLISHMENT CLAUSE. AND THE INTENTIONAL
MISUSE OF THE 14TH AMENDMENT AT THE EXPENSE OF THE
INTEGRITY OF THE CIVIL RIGHTS MOVEMENT
"Where is the wise man? Where is the scribe? Where is the philosopher of this age? Has not God made foolish the
wisdom of the world? - I Corinthians 1:20
The Plaintiff, a former Judge Advocate General, former prosecutor, combat Veteran of
Operation Iraqi Freedom rnle oflaw mission with the U.S. Attorney's office, a seasoned
whistle blower, commercial model, and international EDM artist brings this action to challenge
the Constitutionality of the current definition of marriage in its amended form after the Supreme
Court's decision in Oberg~fell v. Hodge, 192 L. Ed. 2d 609 (2015). 1 As it stands now, "love" did
Since the Federal Court has elected to reduce itself to a makeshift legislature in redefining the defmition of
marriage to fit a new definition that patently violates the first amendment establishment clause and either
discritninates against man-\votnan couples or the arbitrarily excluded non-obvious classes of sexual orientation, it is
the Comt itself, and its integrity, that is as equally on trial as the State Defendants who are merely charged with
enforcing the new definition of marriage. Because the Comt's integrity is in question, the Plaintiff seeks leeway
not "win" as a result of Obergefell v. Hodge, 192 L. Ed. 2d 609 (2015) fraud did. "Fraud won."
The Plaintiff unapologetically is accusing the Federal Judiciary of constitutional malpractice and
intellectual dishonesty. Accordingly, it is the Court who is equally on trial for having created the
new legal definition of marriage; the Defendants are merely liable for enforcing the injurious
definition. By filing this action that challenges the cunent legal definition of marriage, the
Plaintiff has reopened an unsettled controversy in which justice Kennedy called all Christians
"bigots" for not thinking about marriage like he does in United States v. Windsor, 133 S. Ct.
2675, 186 L. Ed. 2d 808 (2013) and in which the Honorable Justice Scalia called moral relativist
in office "a threat to democracy" in Obergefell v. Hodge, 192 L. Ed. 2d 609 (2015). Both men
cannot be right at the same time. 2 The new definition of marriage is either "too narrow" or "too
broad"because it codify religious identity narratives based on unproven faith based assumptions
in violation of the 1st amendment establishment clause under Pleasant Grove City v. Summum,
555 U.S.460 (2009) or because the definition arbitrarily leaves behind the non-obvious classes of
sexual orientation, violating the 14th amendment establishment clause under McDonald v. Santa
Fe Trail Transp. Co., 427 U.S. 273, 27879, 96 S. Ct. 2574, 2578, 49 L. Ed. 2d 493 (1976). That
ftom the Defendants and the Court to provide a rather long introduction that the general public can understand in
order to frame these matters correctly and to provide for watchdog oversight from the media. The Press is, after all,
mentioned in the Constitution for a good reason.
2
Justice Kennedy and Justice Scalia - like the rest of America - are literally live in under two irreconcilable realities.
Both men cannot be right and either the Christians or the moral relativist must be removed from office in order for
the United States to progress into the deeper richer freedom of human flourishing. Despite the fact that the marriage
bans in their original forms are Constitutional, the Kentucky Court must stop listening to Hollywood and decide if
the United States is a "Savage Nation," as Justice Kennedy found in Planned Parenthoodv. Casey, 505 U.S. 833
( 1992) or a "Christian Nation" as the United States Supreme Court found in Holy Trinity v. United States, 143 U.S.
457 (1892). The evidence shows that at the ve1y minimum the United States is "Constitutional Nation" where the I st
amendment establishment clause is being ignored in the marriage matters and the 14th amendment is being misused
to shoehorn a sexually exploitative and reckless worldview into legal plausibility at the expense of the integrity of
the civil rights movement of the 1960s. If individuals are entitled to civil rights for their sexual orientation, then all
of the individuals in the non-obvious classes of this suspect class are entitled to these same civil rights, not just those
who self-identify as (straight) and (gay). To suggest othenvise is intellectually dishonest and completely shallow.
is, the new definition of man-iage is either overly inclusive because it attempts to equate other
forms of manfage to "actual marriage" between a man and a woman on a faith basis, not factual
one, which inherently ( 1) violates the 1st Amendment Establishment' by codifying unproven
naked assertions that are semi-religious assumptions that stem from postmodern western
individualism which comes out of the Enlightemnent tradition, (2) serves to discriminate against
men and women on the basis of gender in what is communicated, and (3) violates the obscenity
codes and community standards see KRS Chapter 531 and 18 US Code 1460 et. seq.
Alternatively, the current legal definition of marriage is underinclusive because it arbitrarily
excludes the other non-obvious classes of sexual orientation (to includes the Plaintiffs) in
violation of the due process and equal protection clause of the 14th amendment - individuals who
want man-object, man-animal, and man-multiperson remain relegated to third class citizens. The
same exact legal bases that supports man-man and woman-woman marriage supports
man-machine, man-animal, and man-multiperson manfage equally. To critique the legal bases of
man-object marriage is to critique the legal bases for man-man and woman-woman marriage. To
suggest otherwise is intellectually dishonest, since the Courts saw fit to define marriage as
"individual right," "fundamental right," and "existing right" bound in a "personal choice." 4 There
Laws that codify man-woman marriage are not establishing the plausibility of a religious idea; instead such laws
codify the facts that about the way humans are designed and the way things are. However, all other forms of
marriage stem from unproven faith based assumptions that are implicitly religious, and therefore, these religious
notions based on naked asse11ions cannot be lega11y recognized. However, if 1nan-man and \Voman-\von1an 1narriage
is to remain legally cognizable under the 14th amendment, then the Court must force the state to allow for
n1an-n1achine 1na1Tiages, an1ongst all other fonns. This is not a ga1ne of semantics. The Plaintiff has sustained an
equal injury as the misguided and phony tolerant same-sex litigants. The Plaintiff is convinced by insurmountable
evidence that moral relativist on the bench have hijacked the Constitution, which should lead to their impeachment
and prospective prosecution, following the change in administration.
4
Zablocki v. Redhail, 434 U.S. 374, 384 (1978)(fundamental right); Cleveland Bd. of Educ. v. LaF/eur, 414 U.S.
632, 639-40 (1974) (personal choice); Loving1>. Virginia, 388 U.S. 1, 12 (1967) (existing right/individual right);
Lawrence v. Texas, 539 U.S. 558 (2003) (intimate choice)
is no way around it other than it other than additional judicial cover up, which by this point is
making the Courts look downright unethical, laughable, and untrustworthy for good cause. 5 The
Court cannot say that man-man marriage is legally plausible but man-object marriage is not. The
Federal Courts are not merely a playground of semantics where the ends justify the means,
especially if it is cultivating in sexual exploitation of minors and religious persecution. Yet, the
Plaintiff - as a machinist - is entitled to the same civil rights as those who self-identify as
homosexual under the holding in Obergefell v. Hodge, 192 L. Ed. 2d 609 (2015). and United
States v. Windsor, 133 S. Ct. 2675, 186 L. Ed. 2d 808 (2013) or the greatest judicial fraud since
the inception of American Jurisprudence has been perpetrated on the American people by moral
relativist on the bench. Because the current legal definition of maniage is unconstitutional under
the !st and 14th amendment, Sevier v. Davis will be to Obergefell v. Hodge,192 L. Ed. 2d 609
(2015) what Brown v. Board a/Education a/Topeka, 347 U.S. 483 (1954) was to to Plessy v.
Ferguson, 163 U.S. 537 (1896). When the Federal Courts turn their backs on transcultural truth
and universal law recognized at the Nuremberg trials and foolishly elect to mirror the law off the
cultural sentiment as it did in Dred Scott v. Sandford, 60 U.S. 393 (1857) the court ends up
looking like a laughing stock for being shallow, inept, backwards, and out of touch with reality.
I.
What has taken place here is that moral relativist on the bench, aided and abetted by a
feckless PresidentJKing with Daddy issues, have used their offices to shoehorn gay dogma into
Justice Oliver Wendte Holmes famously stated: "The world has produced the rattlesnake as well as me; but I kill it
if I get a chance, as also mosquitoes, cockroaches, murderers, and flies. My only judgment is that they are
incongruous with the world I want, the kind of world we all try to make according to our power .... .! see no reason
for attributing to a 111an a significance different in kind fro1n that \Vhich belongs to a baboon or to a grain of sand.''
Well then, if man is not more significant than a grain of sand, then a man's request to marry an object is not less
"significant" than a n1an's request to inany a n1an. Fo1tunately, Justice Holn1e's positions atnount to religious asserts
which offend self-evident facts, which means that his jaded views should not be the basis of law. But ifthe Court is
going to continue to attempt to co111e up \Vith ne\V excuses to legitimize gay inarriage based on additional
dishonesty, then it should most definitely allow for man-machine marriage so it can better pass itself off as credible.
legal legitimacy through a series of intellectually dishonest power powers. Their goal was to
replace traditional morality for their own private moral code in order to self-justify their own
misguided religious identity narrative and view of the cosmos through the use of government
codification, which absolutely violates the I st amendment establishment clause to the point that
Judges responsible should not merely be impeached by the Judicimy committee, but put on trial
for treason under 18 U.S. Code 2381. The United States JAG Corps could have jurisdiction to
oversee the proceeding. The evidence insurmountably shows that in order to get around the
impossible problem of"bi-sexuality," the moral realtivists on the bench were forced to define
marriage as an (1) "individual right," (2) "fundamental right," and (3) "existing right" centered
on a "personal choice." Zablocki v. Redhail, 434 U.S. 374, 384 (1978) (fundamental right);
Cleveland Bd. ofEduc. v. LaF!eur, 414 U.S. 632, 639-40 (1974) (personal choice); Loving v.
Virginia, 388 U.S. 1, 12 (1967) (existing right/individual right); Lm11rence v. Texas, 539 U.S. 558
(2003) (intimate choice).

2.
Now that the Plaintiff has filed this cause of action seeking to exercise those rights for
himself based on his identity narrative, the Court cannot turn around and imperialistically
pronounce that "the prior Courts really didn't mean it."6 It is not difficult to understand that the
Plaintiff is an "individual" who seeks to exercise his "fundamental," "individual," and "existing
right" to "personally choose" to make an animate object his spouse in step with his civil rights in
order to force the public to whomp up some dignity interest to bestow upon himself at the
The Court can, however, have a moment of humility and admit that the moral relativist in office who used words to
shoehorn gay rights into legal plausibility did so in a manner that amounts to the greatest fraud ever perpetrated in
the hist01y of American Jurisprudence. TI1e Judges who are pushing to cultivate what amounts to a caliphate of
moral relativism lack the ability to define right and wrong on an objective standard and are by definition unfit to
hold office. Their irrational value system and refusal to think amounts to a danger to the public's health, safety, and
welfare.
expense of their conscience and standards of decency. The fact that the Plaintiff is a combat
veteran and Army Officer who risked his life to defend the very fundamental freedoms that the
Court's in the same-sex marriage crusade have openly molested is even more reason for the
Comt to stop acting like children and at the very least give him one of the two forms ofreliefhe
seeks in the restoration of Constitutional integrity and judicial honesty. 7 As it stands, the Courts
are in a persistent state of dishonor by the exclusive ratification of the shallow gay narratives that
are inherently sexually exploitative and implicitly religious - not to mention irrational,
dehumanizing, and the catalyst for a growing public health crisis. The Government - to include
the Judiciary - is barred from codifying religion - especially one as phony and impeached as
moral relativism, which is all about attempts to justify acts that are "objectively immoral"" and
subversive to human flourishing by twisting truth. The religion of moral relativism is as equally
phony, dangerous, and void of a living hope as the preposterous religion of Islam. Neither can
serve as a basis for the laws in the United States.
Anger is not the opposite oflove. Hate is. And the final fonn of hate is indifference, and the Plaintiff is not
indifferent to the LGBT gestapo using the holding in Obergefell v. Hodge, 192 L. Ed. 2d 609 (2015) as a
proselytizing tool to seduce minors into converting to their ideological selfish beliefs that are predicated on
self-fulfilhnent and self-actualization.
' If an Army Lieutenant, like the Plaintiff Sevier, has the right to disregard immoral orders from his superiors, like
Democratic Congressman Windle in Operation Iraqi Freedom, then for reason's sake it must be the obligation and
duty of the Attorney General, Governor, and the Court to disregard laws that violate transcultural law and
morality.Tite Unifonn Code ofMilitmy Justice (UCMJ) 809.ART.90 (20), makes it clear that military personnel
need to obey the "lawful command of his superior officer," 891.ART.91 (2), the "lawful order of a warrant officer",
892.ART.92 (I) the "lawful general order", 892.ART.92 (2) "lawfol order." In each case, military personnel have an
obligation and a duty to only obey lawfol orders and indeed have an obligation to disobey unlawfol orders, including
orders by the president that do not comply with the UCMJ. Armbruster v. Cavanaugh, 140 Fed. Appx. 564 (3rd Cir.
2011). TI1e moral and legal obligation is to the U.S. Constitution and not to those who would issue unlawfol orders,
especially if those orders are in direct violation of the Constitution and the UCMJ. The paramount question is "upon
what set of morality can a junior officer classify a law as immoral in order to validly disobey an order?" And if
umorality" is the valid basis decision for a junior officer to disobey an order, clearly this satne "tnorality" n1ust itself
serve as a compelling mid proper basis for the legislature, executive, and courts to fashion law and policy in the area
of sex and marriage policy. (The New Transgender policy in the Military should be disregarded by unit
commanders under (UCMJ) 809.ART.90 (20) for being objectively immoral).
3.
Because of the culturally driven opinions of five jaded Judges in Obergefell v.
Hodge,192 L. Ed. 2d 609 (2015), the Defendants denied the Plaintiffs marriage request at an in
person meeting in view of a current definition that is narrow, shallow, and exclusive, while
clearly being predicated on the unexamined assumption of the superiority of our cultural moment
pursuant to per se judicial narcissism and self-justifying entitlement syndrome that is worthy of
(1) non-political psychiatric evaluation and (2) extreme contempt to the point military
responsiveness would be authorized under the standing rules of engagement held by the states, if
Federal Congressional oversight does not engage responsively to this internalized threat that
Justice Scalia pointed out expressly without stuttering. 9 The results of this treasonous activity are
that (1) Christians are being set up to be systematically persecuted within the United States for
not bowing down to the religion of relativism wrongfully established by our government due to
an unprecedented "truth phobia;" (2) the Federal Goverrnnent is trying to blackmail the states
under its "convert or else" proselytization plan that is cultivating into a full blown public health
crisis, 10 (3) community standards and decency laws are under assault as gay and transgender
rights promote obscenity in action, and (4) millions of young people are confused about healthy
forms of sex and sexual identity, as the LGBT gestapo uses the government's ratification of their
religious ideology to seduce minors into opening the door to give the gay lifestyle a try. 11 Some
From the perspective of the former Anny Prosecutor Plaintiff, moral relativist in office have imperialistically
impose their irrational religious worldview on the citizens of the United States in a manner that amounts to an act of
actionable treason under 18 U.S. Code 2381 by codifying unproven religious asserts that are as fake as Sharia law.
What have taken place is that the moral relativist in office have simply replaced traditional morality as a basis of law
and replaced it with their own private moral code in a manner that is dehumanizing and depersonalizing 18 U.S.
Code 238t Whoever, owing allegiance to the United States, levies war against them or adheres to their enemies,
giving them aid and comfort within the United States or elsewhere, is guilty of treason and shall suffer death, or
shall be imprisoned not less than five years and fined under this title but not less than $10,000;; and shall be
incapable of holding any office under the United States.
1
()
https;//ca, news. yahoo. com/su rvey-finds-excess-hea lth-prob!e ms-lesbians-gays-bisexuals-224 741845. html
11
Public Health Crisis: TI1e Plaintiff is involved in the music industry and is immensely concemed about how the
Court's unsound decision in Obergefell v. Hodge, 192 L. Ed. 2d 609 (2015) has proliferated immense amounts of
doors are better left unopened, and it is the government's fundamental duty to make the objective
"right choice" the "easy choice" in accordance with common sense a the Constitutional oath of
office. Sex is not predicated on "immutable traits" but it is connected to the science of classical
conditioning. The fact that Federal Courts have been infiltrated by justices who seem to lack the
capacity to tell the difference between "right and wrong" and "real and fake" cannot be tolerated.
12
Such Justices meet the legal definition of insanity and are a threat to reason and the public's
health. The maniage bans passed by the Kentucky Legislature in their original fo1m were not
designed to target homosexuals, as they pretended. The marriage bans were created to block
moral relativist from using government to codify their self-justifying and wacky religious beliefs
confusion in the public sector regarding the youth as it ( 1) erodes consent; (2) destroys the community standards;
and (3) proliferates false permission giving beliefs. The Plaintiff, a court officer, who has experienced Judicial
cormption that makes Mrs. Davis's experience look like candy land is concerned about the integrity of the Com1s
and the just system itself. Most imp011antly, the Plaintiff is concerned with the welfare of children. Hypothetically
speaking, if"little Billy" is to grow up believing that marrying "little Timmy" or "little Sally" someday are equally
viable options under the law, he should also be allowed to believe that someday marrying an animal, a blow up doll,
or multiple people is an equal viable option under the law. The Com1 and State cannot have it both ways, either all
individuals must be allowed to marry on the basis of their sexual orientation or no one should be allowed to marry
other than one man and one woman, causing the DOMA amendments to be revjved.McDonald v. Santa Fe Trail
Transp. Co., 427 U.S. 273, 27879, 96 S. Ct. 2574, 2578, 49 L. Ed. 2d 493 (1976). This is not a matter of the
"slippery slope." This is a matter of the uniform application of the equal protection and due process clause. All of
the non-obvious classes of sexual orientation are immediately entitled to marry on the basis of their self-identified
sexual orientation or the greatest fraud in the hist01y of American Jurisprndence has been perpetrated on the
American people under the false flag of"progress," 11 civil rights," "love," "equality," and 11 tolerance.'' The evidence
insurmountably demonstrates "love" did not "win" as a result of Obergefell v. Hodge,192 L. Ed. 2d 609 (2015),
"fraud" did. "Fraud won." The Plaintiff has charged the Com1 with the duty to correct this manifest injustice or the
people will legally be authorized to use lawful means to ove11hrow the government in step with the standing rules of
Engagement. We do not live in Iran, and judicial tyranny must not and cannot be tolerated. The Plaintiff is in fact
ang1y. But Anger is not the opposite of love. Hate is. And the final form of hate is indifference. And this Plaintiff
will not be indifferent to the judicial dishonesty that is taking place through our federal courts in the area of sex that
is exposing our youth to incredible risk and danger.
12
"Silence in the face of evil is itself evil: God will not hold us guiltless. Not to speak is to speak. Not to act is to
act." - Dietrich Bonhoeffer. Ex-gay activist, like Greg Quinlan and Pastor Charlene Cothran will provide sworn
statements in this case that - alone - demonstrate the the Supreme Court in Lmvrence v. Texas, 539 U.S. 558, 575
(2003) and Obergefell v. Hodge,192 L. Ed. 2d 609 (2015) were intellectually dishonest in pretending that sexual
orientation is based on "im1nutable traits/' and thereby, serve as a basis for civil rights under the 14th amend1nent.
Sex is predicated on a the science of dopamine, oxytocin, beta fosb, and other neuro-tranmitters. Whatever a person
has sex with, they bond with, especially upon orgasim. But the trnth has been snuffed out because gay adults want to
use government to ratify their self-justifying identity narratives so that they feel less inadequate and shameful for
having centered their entire life on the gay life and the irrational idea that there is no such thing as absolute truth.
on marriage that are predicated exclusively on identity narratives that objectively offend the
obscenity standards, amounting to unprotected harmful speech. Therefore, the marriage bans at
issue were not passed into law for "religious purposes" but "irreligious purposes." Traditional
marriage legal definition law was not based exclusively on the radically transformative grace
based personalized truth of Christianity stemming from the New Testament but on the same
self-evident truth that supports the bill of rights - which only happens to parallel Christianity like
the science of classical conditioning does. If all laws in the United States that paralleled
Christianity or traditional morality were thrown out because they rubbed with the religious
ideology of moral relativism or parallel Christian doctrine, then the United States would be in a
complete state of nature. While it is not illegal to self-identify as a homosexual, machinist, or
polygamist, whether the Government can include any form of marriage in the legal definition is a
different stmy. There is no doubt that the Plaintiff has the same procreative potential with an
object that a man has with a man. From a legal standard point, the Plaintiff request to marry an
object is equal to a man's request to many a man. No amount of intellectual squinting or judicial
cover up is going to change this. It is perhaps time for the District Court to demonstrate actual
honor, character, and humility, while stop being a cultural sell out.
B. THE QUESTION PRESENTED: THE THREE WAYS TO DEFINE MARRIAGE=

ONLY TWO ARE POSSIBLY CONSTITUTIONAL
The supreme quality for leadership is unquestionabl)' integrity. JVithout it, no real success is possible, no ntatter
whether it is on a section gang, a football field, in an army, or in an office. -Dwight Eisenhower
4.
The paramount question presented in this case is what forms of marriage can the state
legally recognize. The one thing that the Supreme Court in Obergefell v. Hodge, 192 L. Ed. 2d
609 (2015) got completely right is this: all 50 states must have one definition of marriage.
Leaving the matter to the individual states to decide is Constitutionally unsound. Mat1'iage is too
important to our National identity and the fundamental right to travel is interfered with due to
ideological differences. The reason why the cunent definition of marriage is unconstitutional in
Kentucky is the same reason why it is unconstitutional in so called liberal states like California
and New York. By t1ying to impose their private self-justifying religion on the states that
banned gay marriage, the same-sex marriage religious zealots have provided the basis for why all
states must immediately nullify other fonns of maniage or completely expand the definition to
include eve1y possible form of marriage to protect individuals in the non-obvious classes of
sexual orientation.
5.
There are three possible ways to define marriage. The first option, legally defining
man'iage between a man and a woman, is completely Constitutionally sound because it codifies
fact and not a religious self-identity narratives that have to be taken on faith. The second way
(the cmTent definition of marriage handed down by the Obergefell Court which includes gay
marriage) is completely unconstitutional because it violate the first amendment establishment
clause under Pleasant Grove City v. Summum, 555 U.S.460 (2009) for establishing the religion
of moral relativism and because it arbitrarily excludes all of the non-obvious classes of sexual
orientation (to include the Plaintiffs) under McDonald v. Santa Fe Trail Transp. Co., 427 U.S.
273, 27879, 96 S. Ct. 2574, 2578, 49 L. Ed. 2d 493 (1976). The third possible definition of
maniage, (total maniage equality) also violates the first amendment establishment clause under
Pleasant Grove City v. Summum, 555 U.S.460 (2009) but it manages to actually accord with the
14th amendment because it does not arbitrarily leave behind the true minorities of sexual
orientation. In this action, the Plaintiff asks the Court to adopt the third option, but would
tmderstand if the Court accepted the first option. But the current status quo legal definition of
marriage cannot remain if the Court wants to keep its power and not face over throw.
6.
Option One (The Traditional Definition): The idea of defining marriage between "one
man and one woman" is Constitutionally sound because it is self evident that this dictionary
definition codifies "the way things are" and "the way we are," without overly tangling
Christianity with the Government excessively - no more than the Bill of Rights does. If the
government were to mandate that all man-woman marriages had to be carried out in the name of
Christ that policy would absolutely violate the 1st amendment establishment clause. But that is
not the case. No reasonable person is offended by man-woman marriage and no one denies that
man-woman marriage should not be in the legal definition because that is what marriage is. All
other forms of marriage amount to a critique on both marriage and religion are themselves hyper
religious. In theory, it could be argued that the traditional definition of marriage stems from the
superior tmth claims of the radically transfonnative New Testament Gospel, which is what the
same-sex marriage litigants argued in Obergefell v. Hodge, 192 L. Ed. 2d 609 (2015) in hopes of
replacing traditional morality that the Nation was founded on with their private moral code. But
that assertion would be too whimsical and simplistic to accord with the truth. The marriage bans
in place were actually designed for an irreligious reasons. They were crafted by the legislatures
to prevent moral relativist from using our government to codify their wacky self-justifying and
sexually exploitative religious ideals that only lead to more suffering, confusion, frustration, and
oppression. Moral relativism, like Islam, is a disastrous basis for law and policy, as history has
demonstrated over and over again. Unlike with gay marriage, the traditional definition of
marriage does not codify an unproven religious assumption but it does codify facts that are
neutral and that accord with transcultural objective truth. And government can codify neutral
fact without violating the first amendment. It is self evident that men and women are born with
corresponding sexual patts that when coalesced have the ability to create human life itself.
Children who are born out of that marriage union have the input of two individuals of opposite
gender that are different but equal. Furthermore, these children have the genes of their two
individuals of the opposite sex with a readily identifiable ancestral chain that is unbroken impacting their own identity narrative and psychological health. The Plaintiff stipulates that no
other marriage union is like that one but asserts that man-man marriage is legally equal to
man-object manfage. For better or worse, man-object maniage and man-man marriage must
meet the same fate or the Comts are not functioning as they are required and severe
Congressional oversight is warranted. Furthennore, man-man marriage and woman-woman
manfage violates the obscenity statutes and erodes the community standards - proliferating false
permission giving beliefs and undermining consent. 13 The Courts have always been harsh on
laws that are enshrine religion and press themselves on the youth; the gay rights legal policies are
doing that exactly and strict scrutiny is warranted.
14
13
Laws that codify gay marriage and transgender rights amount to promoting obscenity in action which conflicts
with the state and federal obscenity laws. 18 U.S. Code 1460-1470; Kentucky Code 531.010- 531.370.
14
THE IMPACT ON YOUTH CULTURE IS PARAMOUNT: These matters are implicitly domestic and in keeping
with the spirit of the domestic laws, the best interest of children should be considered of the utmost importance. The
Plaintiffis greatly concerned about how the new defmition of marriage is impacting the youth culture. If the first
amendment does not apply and only the 14th amendment does, then hypothetically if'little Billy" is to grow up
knowing that someday marrying "little Sally" or "little Tilmny" are equally legally viable options, little Billy must
also know that marrying a blow up doll, dog, or both little Sally and little Tilnmy are equally viable options as well.
Yet, ifthe first amendment establishment clause does matter that changes things. Where a message communicated by
the goverrunent is deemed priniarily religious, generally the Establislunent Clause is violated. Much of the precedent
clearly supp011ing this broad general principle, however, is skewed by its source in the school context, where the
Court is generally more careful due to the susceptibility of young students. See Lee v. Weisman, 505 U.S. 577
(1992) ("As we have observed before, there are heightened concerns with protecting freedom of conscience from
subtle coercive pressure in the elementary and seconda1y public schools."). And here is the bottomline: the
legalization of same-sex marriage is confusing young people about appropriate forms of sexual conduct. Just like
pornography does the grooming for human trafficking, laws that allow for other forms of marriage are used by the
7.
Furthermore, it is self-evident that man-man marriage discriminates against and
dehumanizes women, by telling them that they are not worthy to be a spouse of a member of the
opposite sex, when the design of the design of their body suggests that they were meant for not
only sex with members of the opposite sex but the possibility of being mothers and wives.
Government sanctioned gay man'iage effectively lies to women and is an extreme act of violent
hate towards them in what it insinuates and suggests about their value. Likewise, it is
self-evident that woman-woman marriage discriminates against men by signaling to them that
they are not good enough to be the spouse of woman, when clearly the self-evident design of a
man shows that he was made for sexual relations with a member of the opposite sex. More than
that, woman-woman manfage communicates to men that they are not good enough to be
husbands and fathers, which depersonalizes and dehumanizes them by state action. Equating
marriages that are not equal as if they were dehumanizes the children of all man'iages.
15
LGBT gestapo to recrnit the youth to join their world view on sexuality which is rife with exploitative false
permission giving beliefs. Cases are not tried in a vacuum. TI1e Plaintiff is an international EDM artist and interfaces
with the youth culture, until Federal Justices who live in their marble castles. Tite Plaintiff sees first hand how the
youth is being crnshed and confused by the fake gay rights movement. False permission giving beliefs in the area of
sex are being nonnalized, \Vhich is eroding consent and leading to sexual horrors.
15
The fact that there are moral relativist Judges in office who are allergic to the truth and unable to come to tenns
with reality makes them a threat to logic, reason, liberty, and Democracy itself. Moral relativist in office are
dangerous because they cannot tell the difference between right and wrong or real and fake, and they seem incapable
of understanding or fulfilling their oath to uphold the Constitution. They are motivated by the ends justifying the
1neans doctrine \Vhich does not accord \Vi.th our values. The evidence is over\vhehning that freedo1n co1nes frotn the
truth. And freedom is not the absence of restriction nor the presence of restriction, freedom is the presence of
restrictions that fit the givenness of our nature and the truth about the way things are and what we were designed
for.More relativist believe that the absence of restriction is the way to be free. The think that having to comply with
a set of directives erodes freedom. But their worldview is far too simplistic to have anything to do with reality and
merely futther shows that the default mode of the human heart is "me first." Take a fish on the grass. A fish on the
grass is not free at all. It is only when the fish is restricted to the water that it can swim lightenh1g fast and flourish.
So it goes with man. The Federal Courts musth channel humanity to have the right kind of sexual relations. But at
the ve1y least, the Court has no choice but maintain the integrity of the equal protection clause by allowing all
individuals to many what they want if gay marriage is to remain valid.
8.
Option Two (The current definition of marriage): the idea of the government defining
man-iage between "one man and one woman, one man and one man; and one woman and one
woman" is predicated on unproven faith based assumptions that are implicitly religious, and
thereby, violate the first amendment establishment clause. Pleasant Grove City v. Summum, 555
U.S.460 (2009); lvfcCrea1y County v. ACLU, 545 U.S. 844 (2005); Engel v. Vitale, 370 U.S. 421
(1962); Abington School District v. Schempp, 374 U.S. 203 (1963); Stone v. Graham, 449 U.S.
39 (1980). Critiques on religion are always religions themselves. 16 Same-sex marriage is a
critique on traditional marriage. Gay marriage is assault on absolute trnth and those with the
wisdom and humility to see it as self-evident. However, "gay maniage," "gay rights," and
transgender rights" are all predicated on unproven faith based assumptions that are implicitly
religious, which means government cannot codify them because it interferes with an individual's
ability to formulate their own beliefs. There is no real proof that a "gay gene" exists 17 or that
people are "born gay." 18 For the Government to suggest through legal codification that people
are born gay or that there are gay genes amounts to naked assertions that have to be taken on
16
Hypothetically speaking, if Bill is allowed to marry Ted, and make everyone in society recognize Ted as his
man-wife, then it is no less removed from reality for the Plaintiff to many an animate object and make the rest of
society recognize his spouse as his machine-wife. The moral relativist in office have taken the position that doctrine
does not matter when it comes to defining marriage which is of course a form of doctrine itself. At some point we as
a Nation are going to have to come to terms with the fact that without faith there is no basis for morality, and
without morality there is no basis for law. And not all sets of truth claims are equal. Moral relativism as a basis for
law amounts to a set of truth claims that are vying for superiority amongst the rest. Judge Sedwick in a Federal
Action out of Arizona found that "although the Plaintiff could not intervene in the same-sex marriage action, he did
have standing to file his own separate lawsuit." (See Exhibit.)
17
http: I/\\~YW. theallanti c. conllscience/archive/20 l 5/ 10/no-sdentists-have-not found-the-gay-gene/410059/
https:/A\'\\'\Y. gcneti cl iteracyprokct. orgt20 I511 0/ 12/<lesni tc-what-yot1-1nay-havc-rc ad-thcres-no-uay-e.cnc/

18
https://\\'\VW.truthwinsoutorg/histon'-of-thc-ex-gay-ministrics/
https://m ic. com/arlicl es/ I "/ 0029/meet-thc-m an-who-he! pc<l-c rcntc-thc-cx-gny-movc1ncnt-and-now-\\'Orks-to-savc-its-vic tims#. Vig Otu5 oR
http://w\\'\\'.\\'11d.co1nf2 0 1211 O/,vhy-you-cant-be-born-f!ay/
faith and not all Americans check their brain at the door of culture and get their source of truth
from the philosophers at MTV and MSNBC - who are only out to justify their own worldview
that they have based their entire life on. 19 The Govermnent is banned from codifying these
religious assertions, as a way to make everyone come under the oppressive thumb of the
dogmatic religion of moral relativism. There is no question that moral relativist in office are
doing everything within their power to produce a caliphate of moral relativism in the same way
that members ofISIS are doing everything within their power to bring about a caliphate under
the immensely inational religion oflslam.2 Both moral relativism and Islam are a threat to
freedom because they are based on pride and are removed from the the truth. 21 The religion of
moral relativism and Islam are abstract and predicated on idiosyncratic value judgments that lead
to a sense of moral superiority and the marginalization and ultimately violent persecution of
those who refuse to convert to these irrational dogmas.
9.
Option Three: The idea of allowing every individual to many anyone or anything in
accordance with the sexual orientation they identify with (at least at the moment they apply for a
19
We have to ask ourselves "what is religion really." And the answer is that "religion is a set of answers to the big
questions." A set of unproven faith based assumptions on why we are made, what should we be doing, and what
were we made for are implicitly religious in nature and the government is barred from codifying religious notions.
20
Both the religion of moral relativism and Islam are predicated on immense egoism and pride. Those world views
are abstract and exploitative. It is those world views that lead to violence and oppression because they are
fundamentally removed from the trnth and removed from reality. Both relativism and Islam proliferate a sense of
moral superiority that leads to the marginalization and ultimately the violent oppression of Christians.
21
It is quite clear that moral relativist in office are abusing their government authority in codifying gay mmTiage as a
way of malicious proselytization in a pathetic attempt to shoehorn their sexually exploitative self-justifying
narratives into normalcy and plausibility. "Gay 111arriage'i and Hgay civil rights,, has proven to be a total disaster that
has lead to the systematic persecution of Christians and platforms for blackmailing non-converts to include the
state's themselves. Even Defendant Davis knows something about that first hand. As a Judge Advocate General, the
Plaintiff advises Governor Bevin that he could mobilize the Army National Guard under Title 32 and surround the
Federal Court house for having threatened the civil rights movement and hijacked the Constitution. The Federal
Government is attempt to blackmail the states, and the state's have the right to respond in opposition to the hostile
blackmail manifest by the Federal Government in order to preserve our Democracy and liberty interests.
maniage license) does equally violate the first amendment establishment clause as same-sex
marriage, but at the very least, this more inclusive definition of manfage would actually accord
with the equal protection and due process clause of the 14th amendment, which should give more
credibility to gay and transgender rights if the Courts are being honest with the public. This
would be like just prohibiting the government from discriminating against blacks and whites on
the basis of their skin tone, but not allowing the government to discriminate against people of
other colors. Standing alone, gay and transgender rights seem completely Constitutionally
invalid. Equal protection and due process civil rights cannot merely be assigned to the largest
minority (the gays) and the majority (the straights) of a suspect class, at the expense of the real
minority of sexual orientation classification. And just because man-object marriage might seem
peculiar or morally repugnant the Court should tty to remember that "a bare ... desire to harm a
politically unpopular group cannot justify disparate treatment of that group." Romer v. Evans,
517 U.S. 620, 635 (1996). There is no doubt that the integrity of the civil rights movement is on
the line and that President Obama and AG like Lynch have done more to jeopardize that
movement that to protect it, The Federal Comi in Kentucky and the State defendants should be
as equally concerned about the integrity of the racial civil rights movement as the Plaintiff.
22
22
The liberal media, loves to call the Plaintiff a "bigot." But it is hard to call the Plaintiff a bigot when he has
appeared in a posture that defends the integrity of the 1960 civil rights movement. In blatant violation of the 13th
amendment and civil rights act, the moral relativist on the bench and the gay gestapo have hijacked the slavery and
civil rights movement in a desperate attempt to exploit the sympathies of the public, when they know that these two
plights are not even remotely equal. To use the civil rights movement as a footstop to accomplish otherwise
unobtainable ends is an act of actual bigotiy and animus that warrants that LGBT groups be classified as fraudulent
hate groups - because that is what they are. Perhaps it is individuals like Justice Kennedy who are not merely
bigoted but shallow, irrational, dishonest, and engulfed in self-deception. And just because Justice Ke1medy lacks
the wisdom to see that he is making absolute trnth claims and setting up religious binaries in a pathetic attempt to
justify his irrational worldview does not make his judicial misconduct any less dangerous and actionable. TI1ere is
no such thing as "gay people." There are only people. And President Lincoln was right. All people are born equal.
We are all born equally broken and in need of a redeemer. The problem with the world is the human heart and the
second problem is our collective refusal to recognize that. We are not all subjected to the sa1ne influences, and we do
not all plug into the same narratives. If a person gets angry and acts on that emotion and commits murder two, once
at trial, the defendant cannot use the Lady Gaga defense and asse1t 11You 're honor, I \Vas born \Vith feelings of anger
10.
One thing that is clear is that the United States Supreme Court in Lawrence v. Texas, 539
U.S. 558, 57677 (2003) was intellectually dishonest when it pretended to find that sexu<il
orientation was an inunutable trait. The Plaintiff will provide testimonials in this action from the
leaders of the ex-gay movement, like Greg Quinlan and Pastor Charlene Cothran, to destroy the
lies floated by the Supreme Court in Lawrence v. Texas, 539 U.S. 558, 575 (2003). 23 The
evidence is overwhelming that a person can go from gay to straight, to bi-sexual, to perfen-ing
animals, to polygamy, and back to straight again. But there is no evidence that a person can go
from black to white, to brown, to yellow, to red, and back to black again. 24 The fact that a person
can self-identify as gay on moment and straight at another shows that the gay gestapo warrants
hate group status just like the KKK because they are falsely using skin color to advance their
own political agendas in a manner that is both racially and sexually exploitative. 25 For the
relativist to use race matters in a dishonest fashion to shoehorn their crnsade into plausibility is
and acted on them, therefore, I should be released." No we put people who acted on those emotions in jail. We do
not release those who commit murder two from prison because we are concerned that their children might be
embarrassed and ashamed about the decisions that their parents made.
23
https:llwww.tmthwinsout.or1
24
Throughout the Civil Rights movement, Dr. King was never pushing the United States to move away from
Christianity like the relativist are. Instead, he was pushing for the United States to move into a deeper and truer
Christianity. If truth really was relative, like the moral relativist in office have put forth regarding gay civil rights,
the whites in the south who were in power would have never given up power. But they did because it was the
objectively right thing to do based on principles that flow from the New Testament. And let's face it, the master
narrative of the United States Constitution is the radically transformative grace based New Testament Gospel.
25
The Plaintiff moved twice at the District Court level, four times at the 6th Circuit Court appeals level, and twice at
the Supreme Court level to intervene in Obergefell v. Hodge, 192 L. Ed. 2d 609 (2015) as a member of the hue
minority of sexual orientation whose interest was being left behind. Under the local rules, the Plaintiff asked the so
called "tolerant" gays for permission to intervene. Evel)' single time, the satne-sex marriage litigants strongly
opposed the Plaintiffs request to intervene and in doing so they managed to explain away the entire explanation for
their case in chief - which by the way is the same legal basis that President Obama and AG Lynch are using to
Blackmail the state of Kentucky for not confonning to their transgender batluoom holocaust that is literally
cultivating a public health crisis. The Plaintiff always presented the same-sex marriage litigants refusal to allow him
to intervene as an exhibit into the public record. In response the Court decided to try and sweep the matters under
the rug because it was too busy getting off on power tripping about changing the definition of marriage - with total
disregard with the impact would have on impressionable youth and the integrity of the law.
an act of actual animus and racial bigotty that is exploitative and fraudulent.
26
If the Courts
really believed that sexual orientation involved immutable traits and was on par with racial civil
rights, they would have granted the Plaintiffs intervention request as he moved to intervene in
over 10 same-sex marriage actions to include Obergefell v. Hodge, 192 L. Ed. 2d 609 (2015).
The fact that the Courts did not allow the Plaintiff to intervene without any justification
conclusively proves that the Courts are intentionally engaging in fraud, quasi-criminal sexual
exploitation of minors, and the criminalized targeting of those who do not conform to their
irrational religious ideology.
C. NATURE OF THE CASE
"Injustice anyivhere is a threat to justice everylvhere. 11 - Dr. King
11.
The Plaintiff seek one of two forms of relief: (1) that the state be enjoined from enforcing
any laws and policies that prevents him from legally manying an inanimate object in light of the
decision in Obergefell v. Hodge,192 L. Ed. 2d 609 (2015) and United States v. Windsor, 133 S. Ct.
2675, 186 L. Ed. 2d 808 (2013), or alternatively, (2) that all forms of marriage outside the
traditional definition of marriage be nullified in reviving the original marriage laws and bans,
since laws that tty to establish the plausibility of gay rights violates the establishment clause of
the first amendment. All of the existing controlling law support total matTiage equality. 27 Yet,
26
The evidence shows this - being "gay" or sympathetic to gay rights amounts to over conformity to society's
messages but then again rape is over conformity to society's messages as well. There is no doubt that human
traffickers, child exploiters, cartels, strip clubs, and the LGBT are all pati of the seamless interconnected continuum.
The government is hardly engaging in an act of "love" by codifying "gay rights" at the expense of the rights of
others, but it is managing to plunge relativist into deeper darkness and confusion, which is only increasing feelings
of inadequacy, insecurity, discord, and unrest. Christianity did not produce the Orlando terrorist attack, but the
phony narratives of Islam and moral relativism did, which continue to feed one another. Both of these worldviews
as a basis for law are out of step with Constitutional directives for cause because they invariably lead to a sense of
unchecked moral superiority, which cultivates into the marginalization and violent oppression of people who
disagree with the ideology. The government of the United States is prevented from codifying these doctrines
because they are not neutral and characterized by unproven faith based assumptions that are implicitly religious.
27
The Supreme Court has reaffirmed at least fourteen times that the right to marry is one of the most fundamental
rights-if not the most fimdamental right- of an individual. Loving, 388 U.S. at 12. (TI1e Court was referring to
if the Plaintiff is to be denied the right to many because his marriage would amount to the
establishment of religious ideology, then on the same basis all laws that attempt to codify gay
rights, same-sex marriage, and transgender rights must be nullified by both the state and federal
government. If the plaintiffs request to many a machine is frivolous and "removed from
reality," then certainly a man's request to many a man in order to call him his lawfully wedded
wife in hopes that the society will whomp up more dignity for such marriages is equally
"removed from reality" and culturally imperialistically arrogant. It is this kind of moral relativist
that causes Middle Eastern Nations to hate the United States so much - because the adaptation of
these values are a tlneat to the integrity of families - and they recognize that.
12.
The Plaintiff bring this action to challenge the constitutionality of Kentucky's laws
voiding or otherwise refusing to recognize the marriages of man-object individuals entered in

other countries. In United States v. Winclsor, 133 S. Ct. 2675 (2013), the United States Supreme
Court held that withholding federal recognition and benefits from legally married individuals
who married something besides a member of the opposite-sex, as required by Section 3 of the
Defense of Marriage Act (DOMA), violates the federal constitutional guarantees of equal
protection and due process. The Plaintiff seeks to apply this holding, and/or the reasoning
traditional mmTiage in each case bnt who cares). The Court has defined marriage as a right of liberty (Zablocki v.
Redhail, 434 U.S. 374 (1978), privacy (Griswold v. Collllecticut, 381 U.S. 479 (1965), intimate choice (Lawrence v.
Texas, 539 U.S. 558 (2003), and association (1\;LL.B. v. S.L.J, 519 U.S. 102 (1996). Marriage is "a coming together,
for better or for worse, hopefully enduring, and intimate to the degree of being sacred." Griswold, 381 U.S. at 486. It
is "the most important relation in life" and "is of fundamental importance for all individuals." Zablocki, 434 U.S. at
384 (internal quotation marks omitted); see also Cleveland Bd. ofEd11c. v. LaFleur, 414 U.S. 632 (1974).The
Supreme Court has also repeatedly reaffirmed that"[c]hoices about marriage" are "sheltered by the Fourteenth
Amendment against the State's unwarranted usurpation, disregard, or disrespect." ML.B., 519 U.S. at 116; see also
Planned Parenthood ofS.E. Pa. v. Casey, 505 U.S. 833, 848 (1992) (marriage is "an aspect of liberty protected
against state interference by the substantive component of the Due Process Clause"). In light of this histmy, the
district court recognized that "[t]here can be no serious doubt that in America[,] the right to many is a rigorously
protected fundamental right." JA 365. These arguments all equally apply to the Petitioners, as they do to other
branches of sexual orientation, including mine. But the Petitioners are not presenting the arguments that protect all
fo1n1s of sexual orientation.
underlying it, to invalidate and enjoin the enforcement of Kentucky's state constitutional
provision prohibiting recognition of legally married different-sex individuals, as well as
Kentucky statutes, Section 2 of DOMA, and any other relevant provision which would allow
Kentucky's continued refusal to respect such legal marriages. Otherwise, the Comt must reverse
and overturn the holdings in cases like Obergefell v. Hodge,'192 L. Ed. 2d 609 (2015), United
States v. Windsor, 133 S. Ct. 2675, 186 L. Ed. 2d 808 (2013), Lawrence v. Texas, 539 U. S. 558,
575 (2003), Romer v. Evans, 517 US. 620, 633 (1996), ect. As it stands now, the Courts are
demonstrating patterns that appear very similar to white collar criminals accused of fraud in
racketeering actions under 18 U.S. Code 1961-1968 et. seq.
PART II THE COMPLAINT
Dr. Postdoc Tuck Ngun, "there is no gay gene."
http://www.theatlantic.com/science/arch ive/2015/l O/no-scientists-have-not-found-the-gay-gene/41 0059/
A. THE PARTIES
"JfeverJ1body is thinking alike, someone isn't thinking." -George S. Patton
13. At the time of the injury, the Chris Sevier was residing in Kentucky. The injmy took place at
County Clerk's office under Mrs. Davis' charge, while following the guidance and instruction
passed along to her by the Governor and Attorney General. Melissa Thomas and Nathan Davis
rejected the Plaintiffs man'iage request following the guidance of the Defendant's named here.
The Plaintiff appeared in person at the clerk's office with a valid license, the man'iage license
fees, and his spouse to be. Yet, he was denied this dignity interest and turned away because his
marriage request was outside considered morally repugnant and less valid than a woman's
request to many a woman.
14. Defendant Mike Bevin is the Governor of the Commonwealth of Kentucky. In his official
capacity, Mr. Bevin is the chief executive officer of the Commonwealth and is responsible for
the faithful execution of the laws of the Commonwealth of Kentucky, including the laws that
exclude individuals who want to marry an inanimate object or something other than a members
of the same-sex or opposite sex a marriage license and including the laws that do not recognize a
marriage ceremony that has taken place between a man and a machine.
28
15. Defendant Andy Beshear is the Attorney General of the Commonwealth of Kentucky. In his
official capacity, Mr. Beshear is the chief legal officer of the Commonwealth, and is charged
with advising state and local officials on questions of Kentucky and federal law. The former
Judge Advocate expects Defendant Beshear to make a stand for the truth in supporting or
defending either the original legal definition of marriage or the definition that allows for total
marnage.
16. Defendant Kim Davis is the County Clerk of Rowan County Kentucky. In her official
capacity, she refused to issue a marriage license to the Plaintiff. Clerk Davis has been
systematically harangued and persecuted by the proponent of the gay rights religious dogma.
Unless total marriage equality is permitted as demanded by the Plaintiff, Mrs. Davis will have a
valid cause of action under racketeering statutes against those who conspired to persecute and
prosecute her maliciously as an an attempt to force her to convert to their sexually exploitative
self-justifying world view. 18 U.S. Code 1961-1968. Allowing the Plaintiff to marry an
28
Governor Bevin has to be proactive. The Governor should use his authority to call a special assembly. TI1e
Plaintiff would like to see the Governor present two bills surrounding marriage - one bill can revive these laws in
dispute which were only partially rendered unconstitutional. The second bill would call for total marriage equality.
The status quo definition of maniage is unconstitutional. TI1is special session would help the State conclude whether
transgender rights were plausible or not. Moreover, the Plaintiff would like the Governor to have a legislature
present the Child Online Filter Act - which the Plaintiff authored.
http://\V\V\V. eood4 utah. c0111/n e\vs/ Io ca 1-ne\vs/I egi s Iati ve-proposal-ca 11 s- on-tech-coin panics-Ii kc-a pp Ic-goo e Ie-to-fi Ite
r-porn-011-dcvices. The Courts are so dishonest and out of control that the Plaintiff NEVER files a lawsuit anymore
without interfacing directly with Federal and state legislatures. Too many Judges have proven to be characterless
egomaniacs who are irrational and opposed to the truth and that is putting it with tact. Although the Plaintiff is for
total marriage equality, he is not for having children have their sexual orientation altered due to exposure to
pornography on products that distribute the internet. Governor Bevin and Attorney General Beshear, respectfully,
should try to care about the public health and do their job to enforce the existing obscenity codes against
manufacturers and wholesalers in the state of Kentucky that sell filterless products that distribute the internet.
inanimate object will give those who put her in jail more credibility, since it will show that the
Courts really believe that sexual orientation is based on civil rights matter and not an ideological
religious one stemming from an attempt to legislate away feelings of shame and inadequacy.
B. JURISDICTION AND VENUE
"Nothing in the world is 1nore dangerous than sincere ignorance and conscientious stupidity. 11 - Dr. King
17. The Plaintiff brings this action under 42 U.S.C. 1983 and 1988 to redress the deprivation,
under color of state law, of rights secured by the United States Constitution.
18. This Courthasjurisdictionpursuantto 28 U.S.C. 1331and1343.
19. This Court has the authority to enter a declaratory judgment and to provide preliminary and
permanent injunctive relief pursuant to Rules 57 and 65 of the Federal Rules of Civil Procedure,
and 28 U.S.C. 2201 and 2202. 21. Venue is proper in this district pursuant to 28 U.S.C.
139l(b) because the Defendants have offices within the district, because Plaintiff reside in this
district, and because the events giving rise to Plaintiffs claims occmTed, continue to occur, and
will occur, in this district.
C. CONSTITUTIONAL AND STATUTORY PROVISIONS CHALLENGED
Our Constitution lt'GS made only for a moral and religious people. It is
other. - John Adams
lt 1holly
inadequate to the government ofany
20. Kentucky Constitution, Section 233A, ratified November 2, 2004, provides: "Only a
marriage between one man and one woman shall be valid or recognized as a man'iage in
Kentucky. A legal status identical or substantially similar to that of marriage for unmatTied
individuals shall not be valid or recognized." To suggest that this law singled out individuals
who self-identify as "homosexual" is intellectually dishonest. The law singles out all individuals
who want to many someone or something other than one member of the opposite sex. 29 30
29
It is completely shallow and narrow to suggest that people can only cultivate a sexual thirst for members of the
same-sex. There are literally thousands of pomographic websites that feed the appetites for sex with animals,
Sen. Vernie McGaha declared on the Senate floor that he was sponsoring the bill that led to the
above amendment because "marriage is a divine institution" and that heterosexual marriage
"joins together a man and a woman for the stability of society and for the greater glory of God."
This belief, he told the Senate, is based upon a story in the Old Testament Book of Genesis
which led him to believe that the first marriage was between Adam and Eve, a maniage of
heterosexual individuals. The amendment was proposed, according to Sen. McGaha "to protect
our communities from the desecration of these traditional values .... we must protect our
neighbors and our families and our children."
21. The State naturally has a compelling interest to protect the community standards and
decency, given the realities of the human heart and how it can slipped into dehumanizing
depravity that is self-evidently subversive to human flourishing, against our natural design, and
self-evidently evil. The same-sex marriage litigants that attacked Sen. Vernie McGaha basically
argued that "nobody's version of morality mattered when legally defining marriage except
multiple people, machines, and all kinds of things. TI1ese websites do not exist by accident and that there are
countless testimonials of people who have purchased a sex doll who have become classically conditioned to prefer
sex with an that as opposed to real person. To afford these kinds of individuals equal dignity status as those who
self-identify as homosexual, equal rights for them are understandably demanded on the basis of countless controlling
cases. There are two types of people in the world. People who make absolute truth claims and set up binaries and
people who do but don't know that they are. Basically groups like the ACLU and Michael Weinstein's Military
Religious Freedom Foundation who enable the same-sex marriage litigants effectively took traditional morality and
replaced it with their narrow, out of date, shallow, and exclusive private moral code, which failed to include the true
minority of sexual orientation. It takes even more religious faith to not to believe in God than it takes to believe in
the God of the Bible. Christianity is a set oftmth claims that humbles those subscribe to it, but moral relativism fills
its followers with sense of moral superiority that entitles them to marginalize, caricature, and violently oppress those
who do not convert to that world view. Just consider Defendant Davis's experience. If the Court would like to see
what real animus looks like consider:
http://www. thedaily beast.com/arti c1es/20 16/04/21 Im eet-the-anti-lgbt-bigo t-marrying-his-computer .httnl
30
The Plaintiff understands and acknowledges nearly all laws must be predicated on a moral as a basis. Just as the
la\vs of gravity exist \Vhereanyone believes in it or not, it is an axiom of the universe that 'iwithout faith there is no
basis for morality, and without morality, there is no basis for law." To suggest that doctrine does not matter when
defining marriage is itself a doctrine that is vying for moral superiority. Those who say that there is no such thing as
absolute tmth have to assume the ve1y thing that they are trying to deny in order to deny it, which brings us back to
square one. Christian morality does not offend the Constitution because the evidence shows that it is the superior set
of truth claims that accords with transcultural universal law.
theirs." In making such arguments, the gay advocates proved that they are self-absorbed,
irrational, trnth allergic, and egotistical. Such an argument was merely a jaded power play and
way of getting their moral code to come out on top in order to self-justify their religious ideology
that is void of peace, accountability, and a living hope, but manages to promote savage sexual
conduct that obscene by definition that sexually exploits minors and erodes the community
standards by state action. The Plaintiff acknowledges that the Bible accords with the truth about
who we are and the way things are and is not merely predicated on unprovable faith based
assumptions but self-evident reasoning identifiable by teleological and cosmological deduction. 31
22. Sen. Gary Tapp declared on the Senate floor that he was sponsoring the bill that led to the
above amendment so that no one "will be able to question [the citizens of Kentucky's] beliefs in
the traditions of stable marriages and strong families." Sen. Gmy Tapp worldview stems from the
Bible because he is not arrogant enough to think that he can monkey with divine law and higher
law from God that was the basis for the civil rights movement, the Nuremburg trials, and the
Constitution itself.
32 33
31
Gay marriage is merely a critique on actual marriage and the trnth. But ifthe private morality imposed by
relativist Judges in the Com1 is going to be allowed to stand, it must be declared that the current private moral code
in place remains too nairnw, out of date, shallow, and exclusive, not going far enough because it arbitrarily excludes
machinists, beastialists, polygamists, and other non-obvious classes of sexual orientation for reasons that are invalid
under Obergefel/ v. Hodge, 192 L. Ed. 2d 609 (2015) and United States v. Windsor, 133 S. Ct. 2675, 186 L. Ed. 2d
808 (2013). If this Court attempts to come up with a way to sneak around that by trying to sweep these matters under
the rug, the Plaintiff will ensure that the Judge is hauled before the Senate Judiciary committee and purged. Quid pro
quo cuts both ways. The Plaintiff as a Judge Advocate has a personal dislike of dishonest judges for good reason.
32
The Plaintiff moved to intervene in the gay marriage litigation that came from his home state ofKentueky only to
have the dishonest and intolerant gay crusaders tun1 around and say "no one \Vill be able to question beliefs in our
morality and gay mmTiage." TI1e Court ratified this line of reasoning to its total discredit, demonstrating
insurmountably that moral relativist on the bench are shallow and enemies of the trnth and logic reasoning.
33
In his letter from Birmingham jail, Reverend Martin Luther King Jr. said that "the only way that he can know that
a human law is unjust is if there is a divine law/higher law from God. If there was no God and no divine higher law,
there would be no way of knowing if a particular human law was unjust or not." If there was no God or higher law, a
state official or Court could say "the Plaintiffs request to marry an inanimate object is unjust" but that is according
to their standards. Why should a government employee's standards be privileged over the Plaintiffs, who actually
23. Sen. Ed Worley argued that the bill was not discriminato1y against homosexuals. He said the
purpose was to "Reaffirm [the citizens of Kentucky's] belief, their very basic and core belief,
that the definition of marriage is between a man and a woman." Sen. Worley argued that the
amendment was necessary because "liberal judges" have prevented his children from saying the
Lord's Prayer in school, he will soon be prohibited from saying "the Pledge to the Legiance [sic]
in public places because it has the words 'in God we tmst. "' 34 Justice Scalia took Sen. Ed
Worley' s concern a step farther and called "liberal judges" a tlueat to Democracy in Obergefell
v. Hodge,192 L. Ed. 2d 609 (2015). Scalia did not stutter. 35
served Honorably overseas to defend the very freedom that is now under attack from the inside out by moral
relativist who are enemies of the truth. Let's just take that a step further under the "let's abandon belief in God"
approach to the Justice systen1 and defining marriage, if there is uno belief in God" and "no higher divine la\v," then
ho\v can \Ve say that any historical event is "unjust?" There is no basis to conde1nn the Nazis holocaust, slavery, or
the terror attacks of September 11th without a higher law. lfthere is nothing but "nature" and if nature is all that
there is, there is nothing more natural than violence. Natural Selection explains that it is how we got here the strong
eating the weak right? If there is no God and all we have is nature, what is wrong with violence and what is wrong
with manmachine marriage, especially since ALL of the law that pretends to legitimize same-sex marriage
insurmountably supports mamnachine marriage? These things are perfectly natural to the same extent that man-man
and woman-woman sexual relations are. A person can have sex with a blow up doll just like that can with a member
of the samesex. Whether these forms of sex and maniage should be illegal is one thing; whether the state should
pass laws that establish the credibility of these implicitly religious narratives is another. The "private moral code"
that defined marriage between one man and one woman accords with the universal law that was employed at the
Nuremberg Trials which the United States must always recognise. Kiobel v. Royal Dutch Petroleum Co., 621 F.3d
111, 154 (2d Cir. 2010).
34
Sen. Ed Worley was correct. In not allowing prayer in school, moral relativist Judges in office are effectively
making students and teachers pray to them. It is a power trip erodes freedom of expression and freedom of thought.
All humans are homo religioso but not all religions are the equal. Secularism is a religion, and like the phony
religion oflslam secularism is having a crisis because it is based on a set of fatally llawed unproven faith based
assumptions. Secularis1n erodes freedom and dehumanizes our citizens. Secularis1n has not created more peace and
understanding but far less.
35
What these Senators in Kentucky failed to include in the legislative histmy is what the Plaintiff asserts here and
now that disbelief in God requires just as much faith and religious conviction as belief in God if not more so. They
also forgot to add that lllall-\VOtllatl tnarriage codifies the "\Vay things are" and "the way we are/' and codifying facts
that happens to parallel the very faith basis that the Country was founded on does not violate the establishment
clause. In te1ms of fact, it is a fact that the Plaintiff has the same procreative potential with a machine that a man has
with another man. What the Senators forgot to add was that if the definition of marriage was opened to codifying
marriages based on personal beliefs and unproven faith based assumptions that it would need to be open to all
individuals, not just the largest minority of a suspect class.
24. Ky. Rev. Stat. (KRS) 402.040(1) provides that if a resident of this state manies in another
state, the marriage will be valid in Kentucky if it was valid in the state where solemnized.
25. However, KRS 402.040(2) provides: "A marriage between [individuals who want to many
something other than a member of the opposite sex] is against Kentucky public policy and shall
be subject to the prohibitions established in KRS 402.045." This is because the state of Kentucky
has an obscenity code and a compelling interest to maintain the community standard. It can be
inferred that the statute also excluded the marriages between one man and one machine with the
same vitriol that it once excluded man-man and woman-woman marriage.
26. KRS 402.045(1) provides in part that, "A marriage between [individuals who married
something or someone other than a member of the opposite sex] which occurs in another
jurisdiction shall be void in Kentucky."
27. KRS 402.045(2) provides that "Any rights granted by virtue of the [man-machine] marriage,
or its tennination, shall be unenforceable in Kentucky courts."
28. The above-described provisions of Kentucky law are in violation of the United States
Constitution, insofar as they deny man-machine individuals the rights, privileges, responsibilities
and immunities extended to similarly situated opposite-sex individuals and same-sex individuals
who have obtain maniage status.
29. To the extent that the Defense of Marriage Act (DOMA), 28 U.S.C. 1738C 2 (2000)
purports to authorize discriminatory treatment of married different-sex individuals or individuals
who want to be marriage to something or someone other than a spouse of the same-sex or
opposite-sex, but are not allowed for arbitrary reasons, it is unconstitutional. 36
36
The idea that the Plaintiff has to wait aronnd to wait until one state , like California, allows for man-machine
marriage before he can make all of the other states allow for man-machine marriage is downright silly and further
proof that the legal cognizability of gay rights has been stitched together through a series of invalid powerplays.
30. Kentucky is issuing licenses to individuals who prefer to many a member of the same-sex
now, the state has no legitimate state interest in denying an individual from manying a gender
neutral spouse, simply because he is in a non-obvious class of sexual orientation. The State lacks
a compelling interest in treating individuals, like the Plaintiff, who had a marriage ceremony in a
different state and counhy differently from legally manied same-sex individuals and
opposite-sex individuals. Kentucky should be required to recognize the Plaintiffs out of state
man'iage or allow him to get a license from the state itself.
31. Especially since man-man and woman-woman marriages are legally valid due to actions of a
handful of priest of moral relativism who masquerade as valid federal Judges, Kentucky has no
legitimate state interest in enforcing the statutes or Kentucky constitutional amendment
challenged by Plaintiff in this case, against individuals who want to many something other than
one member of the same-sex or opposite-sex.
32. Any identifiable state interest is not served in an adequately tailored manner by Ky. Const
233A or the statutes challenged in this litigation, if and only if man-man and woman-woman
marriage is factually and legally valid under first amendment establislnnent clause strict scrutiny.
In fact, the State has a either a compelling interest to (1) completely open the door to total
maniage equality to give more respect to the legal validity of man-man and woman-woman
marriage or to (2) completely bar all other forms of marriage beyond man-woman marriage fully reviving the laws in question to their original form prior to the charade that took place in
Because a inan can ina1ry a 111an and make everyone recognize hlln as his \Vife only to receive all of the sa1ne
benefits as traditionally married individuals means that that the Plaintiff is already entitled to marry in step with his
sexual orientation and feelings of love. There is no legal vantage point for the Court or the Defendant to suggest that
man-machine marriage is invalid. All that could be done is the Court and State could try to use the Federal rnles of
civil procedure to cheat. But any Judge who has unwisely taken that action has come to severely regret it given the
Plaintiff's intimate relations with judicial oversight.
Obergefell v. Hodge,192 L. Ed. 2d 609 (2015). The fact that the Federal Government is
threatening the blackmail the state by withholding billions of dollars if it does not do away with
opposite-sex bathrooms demonstrates that gay rights have not lead to peace but to a public health
crisis that is traumatizing. Laws that establish the legal validity of gay rights need either more
validation or they need to be completely done away with because they violate the 1st
Amendment Establishment clause under Pleasant Grove City v. Summwn, 555 U.S.460 (2009).
37
D.FACTS
"The n1oven1ent ofpost-1nodernism is against binaries. 1'1any in the acade1ny say 'ifyou say you have the truth you
are selling up a binmy. 'All of my post-modemji-iends say "I am one of the good people who do not set up binaries
and you are one ofthe bad people who do. ' There are two kinds ofpeople in the world, people who set up binaries
and 1nake e.tclusive truth clain1s and people lt ho do but clon 't kt1011v they are doing it. The real question is, 'not hoH'
do u e get more lt orld peace by slopping people from niaking exclusive truth clain1s' - no you cannot no make stop
making exclusive truth c!ailns. You cannot stop selling up biranies. What you really need to kno111 is this "11'hose
truth claims make them more loving and respecting ofpeople who differ with them. That's what you need. Do not
live in the illusion that you can stop making truth claims"- Tim Keller quoting Teny Eagleton "The Illusions of
Post-kfodernis1n" in a discourse on Public Faith in The Rise Series Redeen1er
1
hllps:!!tt~vw.youtube.comlwatch?v~dzkspSXg2tM
33. The Plaintiff graduated from Vanderbilt with a degree in Politics. He graduated from
Vanderbilt Law school and passed the Tennessee Bar (The Tennessee Judiciary is easily the most
corrupt in the Nation because of a good ole boy network has been allowed to run wild). He is an
officer of the 6th Circuit Court of Appeals, pending application with the United States Supreme
Comt. He attended Combat Basic Training at Pott Sill, Officer Candidate School at Fort
McClellan and Fort Benning, and Officer Basis at Pott Lee and TJAGLCS. He deployed to
Operation Iraqi Freedom as an 02 under Title 10 and served in an 06 slot in the rule of law
37
Just as states like Utah are declaring pornography made available by manufacturers and wholesalers of products
that distribute the internet has created a public health crisis (See SCR 9 which passed into law on April 19, 2016),
the whole fake gay rights crusade is cultivating in to both a public health crisis and a platform of blackmail and
persecution. Society is not more free because of gay civil rights but less. As Defendant Davis has proven, Christians
are not going to abandon their beliefs in Jesus, checking their brains at the door of culture, because it is politically
expedient to do so.
mission with the US Attorney's office and 3rd ID, in hopes of making middle eastern courts
more like the Courts in the United States.
34. The Plaintiff has been subjected to countless reprisal campaigns to punish him for being a
whistleblower and for defending the rnle of law. This includes fake criminal proceedings that
were designed to control and stifle his speech and fake ethical assaults - like the one that the
Honorable Judge Roy Moore is currently being subjected to. (Sevier v. Jones, 3110435 (M.D.
Tenn. Feb 15, 2012) and Sevier v. Windle, 3:1 l-cv-00246 (M.D. TN 2011).
35. The Plaintiff was exposed to pornography on devices that distribute the internet because the
State and Federal Executive absolutely refuse to enforce the obscenity code against the Tech
Enterprise. 38
36. The Plaintiff became classically conditioned to prefer sex with inanimate objects. He feels
love for an inanimate object in the same way that members of the same-sex can cultivate and act
upon a sexual attraction to member of the same-sex.
37. On May 31, 2016, the Plaintiff went to the clerk's office in Rowan County. The Plaintiff had
a valid driver's license, his preferred spouse, and the fee for a manfage application. The Plaintiff
interfaced with Melissa Thomas, and her supervisor Nathan Davis. Both were polite but
confirmed that the under the direction of the Governor, Attorney General and County clerk, they
could not issue a marriage license to the Plaintiff because he was not one man trying to marry
one man or one woman, but instead one gender neutral object.
38. The Plaintiff was denied a great dignity interest afforded to other Americans.
38
This is because we have a Democracy for hire. We do not have a government of the people, by the people, and
for the people. We have a government of the Apples, by the Microsofts, and for the Verizons.
39. The State cannot deny the Plaintiff's matTiage request because of the moral code of relativist
in office who invented the new definition of marriage in Obergefell v. Hodge,192 L. Ed. 2d 609
(2015) in a 5 to 4 split.
40. The State cannot deny the Plaintiff's manfage request simply because the drafter of the new
marriage definition find gay marriage morally acceptable but man-machine marriage morally
repugnant.
41. The Plaintiff and his children aie denied dignity interest and benefits otherwise afforded to
same-sex individuals and opposite-sex individuals who are married.
42. There are over a 1000 federal and state benefits that married individuals are entitled to.
43. The Governor and Attorney General over see these benefits and oversea that Clerk's
implementation of laws and policies issued by the state and federal government.
39
44. Since the Plaintiff is not allowed to the spouse of his choosing, he cannot claim the spousal
exception under the rules of evidence at criminal trial.4
39
The Plaintiff was wounded in combat and injured as the result of Democratic State Congressman John Mark
Windle's use of the combat stress clinic in Mosul Iraq to stop the Plaintiff from reporting him for(!) violations of
the UCMJ (having sex with lower enlisted Soldiers), for (2) violating Army regulations, and (3) violations of
standing General Order I. Tfthe Plaintiff was married to a man or woman, the Plaintiff would be entitled to
additional benefits, but because he merely prefers to many an inanimate object, the Plaintiff is denied benefits that
the Federal Government and State Government are otherwise required to provide.
40
The Plaintiff has been subjected to countless fake criminal proceedings, as moral relativist in office use their
positions of authority to seek revenge for the Plaintiffs legal initiatives in Federal Court that they felt like have
embarrassed them. The Plaintiff sued multiple Assistant District Attorneys in Nashville for fraud, waste, and
conuption. The District Attorney's office then invented fake stalking charges regarding Donald Trnmp celebrity
apprentice victor John Rich, who planned to rnn for governor of the state of Tetmessee and who is known as a
unconscionable bully. When it became clear that the fake case would completely collapse ADA Tammy Meade,
threatened to have the Plaintiff investigated for child porn because he admitted in Federal Court he had become a
porn addict after being exposed to pornography on a filterless device. There the Plaintiff was fighting human
trafficking, and ADA Tammy Meade thought it would be a good career move think of a new way to tty and jail the
Plaintiff in order to discredit his well founded allegation of fraud, waste, mismanagement, and abuses under
Constitution. TI1e Plaintiff has every intention of suing the state of Tennessee under racketeering for their
intentionally fake malicious prosecution initiative. This could produce additional reprisal attacks through the misuse
of the criminal courts. Because the state of Kentucky refuses to allow the Plaintiff to many an inanimate object he is
precluded from claiming the spousal exception under Federal and State mies of evidence. Kentucky Rules of
Evidence 504. Two men who spontaneously self-identify as gay can in the same day go get married and rob a bank.
45. Like so many, the Plaintiff had a nunTiage ceremony with an inanimate object in the state of
New Mexico through a company that provides such services that was not illegal. The Plaintiffs
marriage, however, is not legally recognized by the State of Kentucky.
46. If gay marriage is not legally cognizable, people who self-identify as gay can have a marriage
ceremony too, but this does not mean that the state is required to ratify those maniages. If only
man-woman maniage were authorized, the Plaintiff would understand and not put up a fight. But
because man-man and woman-woman marriage is valid, the Courts and State have no basis to
deny the Plaintiff the marriage relief he seeks here and will continue to seek until the Courts
decide to knock it off, get serious about the rule of law, and stop perpetrating fraud on the
American people.
47. The plaintiff had an overseas marriage with an inanimate object spouse - through skype, but
the state of Kentucky refuses to recognize that marriage due to what Justice Kennedy calls
"bigotry" in step with his moral superiority complex that is comparable to Abu Bakr
al-Baghdadi's in some respects.
48. But despite those other marriages, the Plaintiff wants to have Kentucky issue him a new
marriage license in step with his self-proclaimed sexual orientation in accordance with the same
rights issued to those who self-identify as homosexual, transgender, bi-sexual, and other labels
that the Plaintiff is not familiar with but the LGBT gestapo is.
PART III CAUSES OF ACTION
11
/n case of doubt, attack." - General Patton
Upon their capture, the husband and wife can invoke the spousal exemption and prelude the other from testifying
against them at trial. If individuals who self-identify as gay are entitled to that right, then so are individuals who
self-identify as 1nachinist are as well. If a inan tnarries an AR 15 and co1n111its inurder 'vith it, the inurder \Veapon
should be preluded from introduction into evidence under the spousal exception in the name of love. To quote the
gay litigants - "love is love" and "love \Vins."
A. CLAIMS FOR RELIEF DEPRIVATION OF DUE PROCESS
49. The Fourteenth Amendment to the United States Constitution, enforceable pursuant to 42
U.S.C. 1983, provides that no state shall "deprive any person oflife, liberty, or property,
without due process of law." U.S. Const. amend. XIV, 1.
50. The right to many is a fundamental right under the U.S. Constitution, and is protected by the
Due Process Clause.
51. The State lacks a compelling interest to allow for man-man and woman-woman marriage but
not man-machine marriage.
52. The Due Process Clause also protects choices central to personal dignity and autonomy,
including each individual's rights to family integrity and association.
53. Kentucky Constitution 233A, KRS 402.040(2), KRS 402.045 and DOMA 2 violate the
due process guarantees of the Fifth and Fourteenth Amendments facially and/or as applied to the
Plaintiff by infringing upon his right to many and to have his maniage recognized in the
Commonwealth of Kentucky.
54. In addition, Section 233A conflicts with other portions of the Kentucky Constitution,
thereby depriving man-machine individuals of rights otherwise granted to all of Kentucky
citizens who self-identify as gay and straight thus depriving them of Due Process rights under
both the state and federal constitutions.
B. EQUAL PROTECTION
55. The Fourteenth Amendment to the United States Constitution, enforceable pursuant to 42
U.S.C. 1983, provides that no state shall "deny to any person within its jurisdiction the equal
protection of the laws." U.S. Const. amend. XIV, 1.
56. The Commonwealth of Kentucky has no legitimate interest in discriminating against citizens
on the basis of sexual orientation. This does just include individuals who self-identify as gay or
straight, but individuals who are other-orientated.
57. The Commonwealth of Kentucky has no legitimate interest in discriminating against citizens
on the basis of sex, especially since gay rights have been ensln'ined.
58. There is no rational basis for the Commonwealth of Kentucky to treat different-sex
individuals who want to be married to their spouse of choice differently from opposite-sex
individuals and same-sex individuals who are married or who desire to marry on the basis of
their identity nanative in the name of progress.
59. There is no rational basis for the Commonwealth of Kentucky to treat Kentucky citizens
differently based solely on their sexual orientation. This does not narrowly include only people
who self-identify as shaight or gay.
60. Sexual orientation bears no relation to a person's ability to perform in or contribute to
society. This position applies to man-object individuals just as it does to man-man individuals,
who merely have a different kind of peculiar sexual appetite that most Americans believe to be
self-evidently subversive to human nature, iimnoral, and obscene.
61. By restricting the definition of marriage to "one man and one woman; one man and one man;
and one woman and one woman" the Commonwealth of Kentucky engages in sex-based
discrimination without rational basis or a legitimate interest in doing so. Of colll'se the state does
have a compelling basis to uphold the community standards that me the basis for obscenity
codes, and the state has a compelling interest not to codify definitions of marriage that are
cultivated on ideological semi-religious unproven faith based assumptions in light of the
establishment clause. But the Commonwealth of Kentucky engages in sex-based discrimination

without a rational basis in allowing man-man marriage but not man-machine marriage
(man-animal manfage or man-multi-person marriage).
62. Gay and lesbian people have not experienced a histmy of discrimination in the United States
and in the Commonwealth of Kentucky, like Christians and man-machine individuals have. If
gays feel like second class citizens, machinists and Christians feel like third class citizens.
63. To the same extent that sexual orientation for homosexuality is an immutable trait it is an
immutable trait for machinists too.
64. Gay and lesbian people represent the largest minority of sexual orientation. Machinists
represent a small minority of the population, and thus lack the political power to assert their
rights to equal treatment under the law. The phony tolerant same-sex maniage litigants went to
great effmt to exclude the Plaintiff from sharing in the fmits of their litigation and from even
intervening.
65. The purpose of Kentucky Constitution 233A, KRS 402.040(2), KRS 402.045 and DOMA
2 is to impose restrictions and disabilities on the sexual orientation of individuals who
self-identify as lovers of animals, machines, and multiple people. It is false to say that these laws
merely bar man-man and woman-woman maniages.
66. Kentucky Constitution 233A, KRS 402.040(2), KRS 402.045 and/or DOMA 2 are
motivated by a desire to harm a politically unpopular group who want to force the United States
to recognize the plausibility of their religious worldview and self-justifying narratives.
Machinists are more of a politically unpopular group than transgender and homosexual
individuals.
67. Ky. Const. 233A and the statutory provisions challenged in this lawsuit also serve the
impermissible purpose of enforcing and perpetuating sex stereotypes by excluding the Plaintiff
from being recognized as validly married because the Plaintiff has failed to confo1m to sex-based
stereotypes that men should many men (whose body parts are not conesponding) or that men
should many women (whose body parts are corresponding).
equal protection guarantees of the Fourteenth Amendment facially and/or as applied to the
Plaintiff by infringing on his right to have a new marriage license issued and to have his out of
state maniage recognized in the Commonwealth of Kentucky.
C. FREEDOM OF ASSOCIATION
69. The First Amendment to the United States Constitution, enforceable pursuant to 42 U.S.C.
1983, ensures the right to freedom of association.
freedom of association guarantees of the First Amendment facially and/or as applied to the
Plaintiff by discriminating against him and penalizing him based solely upon his own sex and/or
sexual orientation and because he wants to many a gender neutral object and not a man or a
woman.
D. SUPREMACY CLAUSE
71. Article VI, Section II of the United States Constitution provides: "This Constitution, and the
Laws of the United States which shall be made in Pursuance thereof; and all Treaties made, or
which shall be made, under the Authority of the United States, shall be the supreme Law of the
Land; and the Judges in every State shall be bound thereby, any Thing in the Constitution or
Laws of any State to the Contrary notwithstanding."
72. By virtue of the Supremacy Clause, state statutes, constitutions and amendments thereto are
subject to applicable prohibitions and limitations of the Federal Constitution.
73. Kentucky Constitution 233A, KRS 402.040(2) and KRS 402.045 violate the Supremacy
Clause by contravening the United States Supreme Cami's holding in United States v. Windsor,
133 S. Ct. 2675, 186 L. Ed. 2d 808 (2013) as applied to all forms of sexual orientation- not just
the self-absorbed gays, who only believe that their class is entitled to the civil rights in step with
a pattem of refusing to understand the law and sound logic reasoning. 41
E. RIGHT TO TRAVEL
74. The Fomieenth Amendment protects the libetiy of individuals to travel throughout the
nation, uninhibited by statutes, rules, or regulations that unreasonably burden or restrict their
movement.
75. The right to travel prohibits both laws that affirmatively interfere with or prevent a citizen's
travel, and also laws that penalize those who choose to migrate to another state
76. The right extends not only to temporaty visits to other states, but also to becoming a
permanent resident of another state.
41
Ifman-machine mall'iage is invalid legally and factually, then so is same-sex marriage, and so where the holdings
in cases like United States v. Windsor, 133 S. Ct. 2675, 186 L. Ed. 2d 808 (2013) and Obergefell v. Hodge, 192 L.
Ed. 2d 609 (2015). The Court does not get to just mince words and play around with semantics because it is trying
to self-justify its worldview and force all Americans to buy into the self-justifying dogma of Judges who subscribe
to post modern individual relativism. It takes a whole lot of religious faith to believe that there is no divine law
which tells us how to shape our federal and state statutes. It takes a tremendous amount of al1'ogance and faith to
believe that this life is all that there is. That we are all merely accidental particles, a bundle of chemicals, and
animated pieces of meat.
77. Kentucky C:onstitution 233A, KRS 402.040(2), KRS 402.045 and DOMA 2 violate the
right to travel as guaranteed by the Fourteenth Amendment facially and/or as applied to the
Plaintiff by imposing a penalty on the Plaintiff for choosing to move to and/or reside in the
Commonwealth of Kentucky, in that their residence in Kentucky requires them to relinquish all
rights, privileges, benefits and responsibilities of marriage that the Plaintiff could be afforded if
he lived in India.
F. ESTABLISHMENT CLAUSE
78. It is clearly the case that laws that define marriage between one man and one woman does
not violate the establishment clause because they codify facts and not unproven faith basis
assumptions like being gay involves "immutable traits." The cmTent definition of man'iage after
Obergefell v. Hodge,192 L. Ed. 2d 609 (2015) violates the 1st amendment for being based on
79. The First Amendment to the United States Constitution states, "Congress shall make no law
respecting an establishment of religion ... "
80. This prohibition is extended to the states through the Fourteenth Amendment.
81. Kentucky Constitution 233A, KRS 402.040(2), KRS 402.045 and DOMA 2 were
enacted for the purpose of preventing relativist from establishing a definition of marriage based
upon religious beliefs of those who make truth claims and set up binaries while not knowing that
they are doing so. The laws were designed to prevent those who are living in a persistent state of
darkness from redefining marriage to fit a worldview that offends the truth of our nature and the
givenness of our design.
82. Secularism is a religion that is based on semi-religious unproven faith based assumptions.
These laws were originally designed to prevent individuals who embraced an objectively inferior
and implausible moral code like Islam and moral relativism from redefining the law to meet their
worldview that is self-evidently removed from reality and the way things are.
83. The primmy effect of the above legislation is to codify the truth of things which only happens
to accord with Clnistianity.
84. The current definition of matTiage absolutely result in an excessive government entanglement
with the religion of moral relativism. Moral relativism put man at the center of the universe
instead of the Creator who is reflected in the Bill of rights, and endorsed by leaders like Adams,
Dr. King, and Reagan.
85. To suggest that sexual orientation is a basis for changing the law is a naked assertion that is
implicitly religious in so far it cannot be proven and must be taken on faith. Although it is true
that laws that attempted to establish the legal plausibility of man-man, woman-woman, and
man-object marriage all equally violate the first amendment establishment clause, expanding the
definition of marriage to include all forms of sexual orientation and not just the largest minority
(the gays) and the majority (the straights) at the ve1y least accords with the equal protection and
due process clause. Just as the gays have tried to legislate away their feelings of shame and
inadequacy for a lifestyle remains criminalized by other Nations, the Plaintiff has the same right
to make the government attempt to legislate away feelings of guilt and inadequacy as a result of
self-identifying as a machinist.
G. HARM TO THE PLAINTIFF AND NEED FOR INJUNCTIVE RELIEF

86. This case presents an actual controversy because Defendants' present and ongoing denial of
equal treatment to the Plaintiff subjects him to serious and immediate harms, wmrnnting the
issuance of a declmato1y judgment.
87. By refusing to issue a maniage license to the Plaintiff or to recognize his marriage to
something other than an members of the same or opposite sex, the Commonwealth's law
deprives the Plaintiff of numerous legal protections that are available to married opposite-sex
individuals and same-sex individuals who reside in Kentucky but were married in other
jurisdictions.
88. The fact that the Clerk is issuing maniage license to same-sex married individuals but not
individuals who qualify as straight or gay reduces the combat veteran to third class citizen status.
89. The tangible and int.angible harm to the Plaintiff created by Kentucky's failure to recognize
his marriage request or his maniages affect virtually every aspect of the Plaintiffs life, including
but not limited to the following:
90. Wounded warriors, like the Plaintiff, who are injured in battle and who married are entitled
to higher state and federal benefits than wounded warriors who are not. A male Soldier who
manied a man or woman would be entitled to these additional benefits.
91. Communications between opposite-sex and same-sex individuals who are married enjoy
evidentiary privileges in both civil and criminal proceedings, and an opposite-sex and same-sex
spouse may not be compelled to testify against his or her spouse over that spouse's objection
except in limited circumstances, but confidential communications between man-machine
individual and his spouse are not afforded the same privilege or immunity.
92. Certain federal protections for married individuals are available to individuals only if their
marriages are legally recognized in the state in which they live, which Plaintiffs cannot access as
long as Kentucky refuses to recognize their existing man'iage. See, e.g., 42 U.S.C.
416(h)(l)(A)(i) (marriage for eligibility for social security benefits based on law of state where
couple resides at time of application); 29 C.F.R. 825.122(b) (same for Family Medical Leave
Act).
93. The exclusion from the esteemed institution of marriage humiliates children being raised by
man-object individuals, making it more difficult for the children to understand the integrity and
closeness of their own family and its concord with other families in their community and in their
daily lives.
94. The fact that their parents' mat1'iages are not recognized in Kentucky harms the Plaintiffs
minor children materially by reducing family resources and by denying their families social and
legal recognition and respect. After all, this campaign is all about stelling dignity away from
traditional marriage couples and people who have traditional values and giving it to people who
are enemies of absolute truth and traditional wisdom. It is a huge power trip.
95. When the Plaintiff goes to apply for a marriage license, he cannot have it written on his
license that he is married. But a man who believes that he is actually matTied to a man-wife can.
96. Under the laws of the Commonwealth of Kentucky, the Plaintiff is treated differently from
legally married opposite-sex and same-sex individuals solely because he is in gender neutral
relationship that if anything has female like qualities.
97. If Plaintiff was an individual who was legally manied in an opposite-sex or same-sex
marriage, he would not suffer any of the harms or potential harms enumerated above.
98. Defendants' deprivation of the Plaintiffs' constitutional rights under color of state law
violates 42 U.S.C. 1983. Man-machine, man-animal, man-multiperson, man-man, and
woman-woman marriage all deserve to meet the exact same fate on the same legal bases. The
Plaintiff hopes that all marriage request are valid of course, but at the very least, if the Court and
State are going to bar his relationship, then they must be enjoined from recognizing any laws or
policies that deal with the myth of gay rights, transgender rights, and gay man"iage. This includes
the transgender bathroom policy.
99. The Plaintiff has no adequate remedy at law to redress the wrongs alleged herein, which are
of a continuing nature and will cause him hTeparable harm.
100. The Commonwealth will incur little to no burden in allowing man-machine couples to
marry in the same way that it has not incurred burdens in allowing man-man individuals and
woman-woman individuals to marry, and in recognizing the valid marriages of man-machine
marriages from other jurisdictions on the same terms as same-sex and opposite-sex maniages,
whereas the hardship for the Plaintiff of being denied equal treatment is severe, subjecting him to
an hTeparable denial of the ve1y constitutional rights he fought for in Operation Iraqi Freedom.
PRAYER FOR RELIEF

WHEREFORE, Plaintiffs respectfully request that this Court:
A. Enter a declaratory judgment that Section 233A of the Kentucky Constitution violates the Due
Process, Equal Protection, Freedom of Association, Full Faith and Credit, Supremacy, and/or
other clauses of the United States Constitution as it relates to barring man-object marriage
request or recognizing man-object marriage requests to the same extent that it once barred and
man-man and woman-woman marriage requests and man"iage recognition;
B. or alternatively, declaring that Section 233A of the Kentucky Constitution does not violate the
Due Process, Equal Protection, Freedom of Association, Full Faith and Credit, Supremacy,
and/or other clauses of the United ,States Constitution; thereby enjoining all marriages outside the
definition of"one man and one woman" for violating the First Amendment Establishment clause
equally other provisions of the United States Constitution.
C. Enter a declaratory judgment that KRS 402.045(2) and KRS 402.045 violate the Due Process,
Equal Protection, Freedom of Association, Full Faith and Credit, Supremacy, and/or other
clauses of the United States Constitution as applied to man-object marriage requests or
recognition to the same extent that they barred same-sex marriage requests and recognition;
D. Otherwise, the Plaintiff asks that the Court enter a Declaratory Judgment that KRS 402.045(2)
and KRS 402.045 do not violate the Due Process, Equal Protection, Freedom of Association, Full
Faith and Credit, Supremacy, and/or other clauses of the United States Constitution but that all
laws that codify man"iage outside the scope of man-woman marriage violate the first amendment
establishment clause and other provisions of the United States Constitution.
E. Enter preliminary and permanent injunctions enjoining Defendants from denying the Plaintiff
and all other individuals in the non-obvious class of sexual orientation the rights and benefits
associated with lawful marriage;
F. Or alternatively, the Plaintiff demands that the Court enter a preliminaiy and pernmnent
injunction enjoining the Defendant from enforcing any law or policy that that seeks to establish
the legal cognizability of gay marriage, gay rights, sexual orientation rights, and other forms of
unproven religious mythology that is designed to convert the Nation into subscribing to the
religion of moral relativism.
G. Enter an order directing Defendants to recognize marriage request and marriages beyond
man-man, woman-woman, and man-woman entered into by the Plaintiff and other other-sex
outside of the Commonwealth ofKentucky;
H. Or alternatively, to enter an order directing Defendants to not recognize marriage request and
marriages beyond man-woman entered into by the Plaintiff and all of the other forms of sexual
orientation outside of the Commonwealth of Kentucky for being equally removed from reality establishing that the Court is a creature of the law and not of pop culture;
I. Enter a declaratory judgment that Section 2 ofDOMA as applied to the Plaintiff and all other
similarly situated other-sex individuals violates the Due Process, Equal Protection, Freedom of
Association, and/or Full Faith and Credit clauses of the United States Constitution;
J. Enter a declaratory judgment that Section 2 ofDOMA as applied to the Plaintiff and all other
non-opposite-sex individuals does not violates the Due Process, Equal Protection, Freedom of
Association, and/or Full Faith and Credit clauses of the United States Constitution;
K. Enter a declaration whether sexual orientation is or is not predicated on "immutable traits"

and the basis for civil rights; enter a declaration whether the gay civil rights movement and
other-sex civil rights movement - together or separately - parallel the racial civil rights
movement of the 1950s and 1960s;
L. Enter a declaration and issue an injunction concerning whether gay marriage and man-object
matTiage violates the 13th amendment;
M. Enter a declaration and issue an injunction whether man-man marriage and man-object
marriage discriminates against women on the basis of gender - dehumanizing and
depersonalizing them and whether woman-woman and man-machine marriage discriminates
against men on the basis of gender;
0. Enter a declaration and issue an injunction on whether all forms of marriage outside the
traditional definition violate the state and federal obscenity statutes;
P. Award costs of suit, including reasonable attorneys' fees under 42 U.S.C. 1988; just because
the Tennessee Supreme Court pretends that the Plaintiff cannot practice law to punish him for his
demand for honest and integrity does not mean that he cannot as is self-evidently on display; and
Q. Enter all further relief to whicn Plaintiff may be justly entitled.
e12JJ..;.,
ls/Chris Sevier Esq./

BPR#026577
9 Music Square South #243
Nashville, TN 37203
(615) 500-4411
!LT 27A th SPF
Kentucky Address Redacted
ghostwarsmusic@gmai I.com
Ghost Op Oscar Charlie

Sevier V Davis

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COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF

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(2003) (intimate choice).

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Because of the culturally driven opinions of five jaded Judges in Obergefell v.

https;//ca, news. yahoo. com/su rvey-finds-excess-hea lth-prob!e ms-lesbians-gays-bisexuals-224 741845. html

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B. THE QUESTION PRESENTED: THE THREE WAYS TO DEFINE MARRIAGE=

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Furthermore, it is self-evident that man-man marriage discriminates against and

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http: I/\\~YW. theallanti c. conllscience/archive/20 l 5/ 10/no-sdentists-have-not found-the-gay-gene/410059/

https:/A\'\\'\Y. gcneti cl iteracyprokct. orgt20 I511 0/ 12/<lesni tc-what-yot1-1nay-havc-rc ad-thcres-no-uay-e.cnc/

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voiding or otherwise refusing to recognize the marriages of man-object individuals entered in

fo1n1s of sexual orientation.

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inadequate to the government ofany

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/n case of doubt, attack." - General Patton

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A. CLAIMS FOR RELIEF DEPRIVATION OF DUE PROCESS

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establishment clause. But the Commonwealth of Kentucky engages in sex-based discrimination

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G. HARM TO THE PLAINTIFF AND NEED FOR INJUNCTIVE RELIEF

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PRAYER FOR RELIEF

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K. Enter a declaration whether sexual orientation is or is not predicated on "immutable traits"

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ls/Chris Sevier Esq./

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