Lawsuit: Pending ToadKing v. Commonwealth of Redmont [2025] SCR 18

Writ of Summons

@Attorney General's Office is required to appear before the Supreme Court in the case of ToadKing v. Commonwealth of Redmont [2025] SCR 18.

Failure to appear within 72 hours of this summons will result in a default judgement based on the known facts of the case.

Both parties should make themselves aware of the Court Rules and Procedures, including the option of an in-game trial should both parties request one.

Answer to Complaint

IN THE SUPREME COURT OF THE COMMONWEALTH OF REDMONT

ToadKing
Plaintiff

v.

Commonwealth of Redmont
Defendant

I. ANSWER TO COMPLAINT
1. AFFIRM that “On or around 23 August 2025, the Conflict of Interest Standards Act was signed into law and enacted immediately upon signature.”
2. AFFIRM facts 2 through 5, which cite law.
6. AFFIRM that “On or around 30 August 2025, President JuniperFig nominated AmityBlamity for the position of Federal Court Judge, occurring seven days after the Conflict of Interest Standards Act took effect.”
7. AFFIRM that “On or around 30 August 2025, AmityBlamity provided an opening statement during their confirmation hearing.”
8. AFFIRM that “AmityBlamity's opening statement contained only information about their qualifications, legal experience, and goals for the position.”
9. AFFIRM that “AmityBlamity's opening statement contained zero information regarding:

• Business ownership interests
• Executive officer positions held in the past 3 months
• Significant financial investments and assets”

10. AFFIRM that “Throughout the entire confirmation hearing, which lasted from 30 August through 4 September 2025, no financial disclosure statement was ever provided by the nominee in any form.”
11. AFFIRM that “No Senator questioned the nominee about potential conflicts of interest or requested financial disclosures during the hearing.”
12. AFFIRM that “On or around 4 September 2025, the Senate voted to confirm AmityBlamity as a Federal Court Judge.”
13. AFFIRM that the confirmation occurred but DO NOT CONTEST that Her Honour’s actions constituted a “complete failure to comply” with the law, NOTING that this is an interpretation of law rather than a fact.
14. AFFIRM the list of cases completed under Her Honour up to October 25th.
15. AFFIRM the list of Her Honour’s active cases up to October 25th.
16. DO NOT CONTEST that “The Commonwealth has taken no action to remedy this violation[...]” NOTING that the Commonwealth was not notified of the alleged error prior to a lawsuit taking place, and NOTING that qualifying the action as a violation is an interpretation of law, and not a fact.

II. DEFENCES
1. AmityBlamity does not, in fact, have any conflicts of interest that would disqualify her from her position as per the Conflict of Interest Standards Act. The only alleged error related to Her Honour’s ascension to office is the failure to include an overt statement of financial disclosure. The error is therefore, as pointed out by this Court in its earlier ruling on the emergency injunction, exclusively technical in nature.
2. While the Conflict of Interest Standards Act prescribes the remedy of removal, the Supreme Court has full discretion over when and how to use its constitutional authority to remove public officials. The Court has shown through its repeated refusal to consider removal, even in similar situations of alleged technical error, that it is apprehensive to use this power unless absolutely necessary. This case does not pose such a necessity.
3. The Plaintiff sought no alternative remedy before taking outright legal action. Alternative actions could have included notifying Congress for consideration of impeachment charges, notifying the Department of Justice regarding a breach of procedure, or any number of other available avenues.
4. The doctrine of de minimis empowers the Court to disregard trifling matters, such as technical errors in administration that do no harm, even when law has been broken from a strictly textual viewpoint. De minimis, explicitly named or not, has been used in past cases within the Commonwealth to dismiss or refuse to award available remedies when law has been broken but no harm done. In line with verdicts such as ToadKing v. Commonwealth [2025] FCR 106 and the Learned Justice Smallfries4’s dissenting opinion in zLost v. Commonwealth [2025] SCR 10, the Court must consider whether applying extreme measures in cases of minor error would, in fact, do more harm than solely recognising the error in abstract.

By making this submission, I agree I understand the penalties of lying in court and the fact that I am subject to perjury should I knowingly make a false statement in court.

DATED: This 24th day of October 2025

Brief

The Plaintiff respectfully requests clarification from this Honourable Court regarding the application of Court Rules and Procedures Rule 4.2 (Submission Required For Use) to the citation of case precedent in closing statements.

I. BACKGROUND​

Rule 4.2 (Submission Required For Use) states:

All material used in legal arguments must have either been included in the case prior to the submission. Material must have been included within the complaint, within the answer, within an amendment to a complaint, within an amendment to an answer, or within a discovery submission. Otherwise the material will be deemed inadmissible and the argument can be voided by the presiding judge.

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Two Federal Court cases of this year have produced seemingly conflicting interpretations of this rule as it applies to the citation of case precedent in closing statements.

II. THE CONFLICT​

1. FlyingBlocks v. Commonwealth of Redmont [2025] FCR 1​

In FlyingBlocks v. Commonwealth of Redmont [2025] FCR 1, the Plaintiff objected to the Defendant's closing statement for citing case precedent:

Breach of Procedure
The plaintiff requests permission to further respond to the new precedent which the defence has used in it's closing statement and not previously mentioned throughout discovery or opening statements.

Otherwise, the plaintiff requests that it be struck.

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The Defendant responded:

Your honor, it is not a breach of procedure to present legal arguments including precedent. It is on the plaintiff for not having researched the case enough to find the precedent themselves and counter it — this is not new evidence, it is public record that we incorporated into our argument.

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The presiding judge overruled the objection, stating:

It is no fault of the Defense that the Plaintiff failed to consider case precedent available to the public.
Their closing statement will not be struck, and this trial is hereby in recess pending verdict.

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This ruling suggests that case precedent, being public record, may be cited in closing statements without prior disclosure.

2. Vanguard & Co v. Naezaratheus [2025] FCR 32​

In Vanguard & Co v. Naezaratheus [2025] FCR 32, the judge addressed a closing statement that "cited 12 unique and previously unmentioned cases to develop novel defences."

The presiding judge ruled:

Defendant's Closing Statement used facts not disclosed in Discovery and cited 12 unique and previously unmentioned cases to develop novel defenses. The facts which weren't brought up in Discovery or prior will be disregarded pursuant to Court Rules and Procedures Rule 4.2. As for the legal arguments raised, I'm granting Plaintiff 72 hours to submit a brief responding to them. If you need more time, please request an extension before the deadline.

Finally, with respect to what was mentioned in the prior paragraph, Defendant's prior counsel is warned to avoid ambushing opposing parties in the future. The arguments you present may not necessarily be faulty, but if they are, they can not be challenged if they're presented in a way that disallows the opposing party a response. The Court recognizes that this was likely a mistake and not intentional, but it will not be tolerated in the future.

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This ruling suggests that citing previously unmentioned case precedent in closing statements violates Rule 4.2 and requires allowing the opposing party additional time to respond.

III. REQUEST FOR CLARIFICATION​

The Plaintiff respectfully requests that this Court clarify whether, under a proper interpretation of Court Rules and Procedures Rule 4.2 (Submission Required For Use):

1. May parties cite case precedent in their closing statements without having introduced those cases during the complaint, answer, or discovery phases?
2. If case precedent may be cited without prior disclosure, are there any limitations on this practice?
3. If case precedent cited in closing statements was not previously disclosed, must the presiding judge grant the opposing party additional time to respond?

Opening Statement

Before addressing the merits, I want to acknowledge and thank this Court for its thoughtful clarification regarding Rule 4.2 and the citation of case precedent. I understand the Court's guidance that while case law exists in the realm of public knowledge and need not be disclosed during discovery, presenting novel legal arguments at the last minute does not serve justice and burdens opposing counsel's ability to respond effectively. I accept this principle wholeheartedly.

With that said, let me turn to the substance of this case.

This case comes before this court with a rare clarity. The facts are not in dispute. The Defence has affirmed nearly every material fact alleged in the complaint - from the enactment of the Conflict of Interest Standards Act on 23 August 2025, to Judge AmityBlamity's nomination seven days later, to the complete absence of any financial disclosure in her opening statement, to the Senate's confirmation despite this omission. The Defence has affirmed that "Throughout the entire confirmation hearing, which lasted from 30 August through 4 September 2025, no financial disclosure statement was ever provided by the nominee in any form." They've updated their Answer to affirm the full scope of cases affected - eight completed and five active proceedings, thirteen cases in total.

What the Defence seems to contest is not what happened, but whether what happened matters. They characterise the Plaintiff's interpretation that this constitutes "complete failure to comply" as merely one possible reading of the law, rather than its plain and obvious meaning. But when every factual element of a statutory violation has been admitted, calling it an "interpretation" doesn't make the violation disappear.

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I. The Law Speaks Candidly​

The Conflict of Interest Standards Act established a mandatory process for, among other roles, judicial confirmations. Section 5 could not be more explicit:

5 - Disclosure Requirements
(1) All nominees for positions covered by this Act must provide a detailed financial disclosure statement, including:
(a) All business ownership interests
(b) All executive officer positions held in the past 3 months
(c) All significant financial investments and assets

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Where must this disclosure be made? Section 5(2) answers:

(2) These disclosures must be made available to the confirming body in the nominee’s opening statement.

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And what happens if a nominee fails to provide this disclosure? Section 5(3) helpfully provides this very answer:

(3) Failure to provide complete and accurate disclosure shall disqualify the nominee from consideration.

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Notice the language chosen. Section 5(1) & 5(2) don't say: "All nominees [...] should provide" or "These disclosures may be made available." It says they "must provide a detailed financial disclosure" and "must be made available to the confirming body." Section 5(3) doesn't say failure "should disqualify" or "may disqualify." It says failure "shall disqualify."

The words "must" and "shall" carry specific legal weight. This Court has previously addressed the distinction between permissive and mandatory language. In xEndeavour v. Commonwealth of Redmont [2024] SCR 11, this Court held that:

"Should" does not create the mandatory requirement of law as the words "shall," "will," "need," "must," and so forth.

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The opinion explained this through a simple example:

I explained this in a simple example to former Justice Dartanman. If I tell you that you should eat an apple, it is your choice to eat the apple. If I tell you that you must eat an apple, you are being commanded to eat an apple.

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Consider also what "disqualify" means when paired with "shall." A plain English definition of "disqualify" is:

To "declare (someone) ineligible for an office, activity, or competition because of an offence or infringement."

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Section 5(3) doesn't say failure "shall provide grounds for disqualification" or "shall authorise disqualification proceedings" - language that would give someone discretion to pursue disqualification or not. It says failure "shall disqualify" - active voice, present tense, automatic operation. The statute itself performs the disqualification. The moment a nominee fails to provide complete and accurate disclosure, Section 5(3) operates to disqualify them. No additional action is required. No one needs to invoke the provision. The disqualification happens by operation of law.

The Defence has affirmed that Judge AmityBlamity provided zero financial disclosure in her opening statement. Under Section 5(2), she must have provided it. She didn't. Under Section 5(3), that failure shall disqualify her from consideration. It did. Once disqualified, she could not be validly confirmed, because you cannot confirm someone who has been rendered ineligible by statute. The Senate's vote doesn't override statutory disqualification any more than a Senate vote could confirm someone who doesn't meet mandatory playtime requirements.

The language in Section 5 is not an accident, not an oversight, and not mere emphasis. Those words were deliberately chosen to create mandatory, non-waivable requirements with clear automatic consequences. "Must" creates a mandatory requirement. "Shall" creates a mandatory consequence. Together, they create a mandatory legal framework that no one - not the nominee, not the Senate, not this Court - has authority to override.

The Defence might argue this is simply one interpretation. But there is no ambiguity here. The statute establishes a requirement. The requirement was not met. The statute specifies a consequence. That consequence - disqualification - necessarily followed.

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II. Addressing the Defence's Arguments​

1. The Irrelevance of Actual Conflicts​

The Defence emphasises that Judge AmityBlamity has no actual conflicts of interest. They will likely offer her testimony to establish this point. The Court should acknowledge this testimony and then set it aside as legally irrelevant to the question before you.

Section 5 establishes two distinct mechanisms. Section 4 lists specific conflicts that prohibit serving in a specified role: Business Ownership Conflicts, Corporate Executive Conflicts, Legal Practice Conflicts, and Financial Conflicts. If someone has these conflicts and serves anyway, they violate Section 4. But Section 5 creates a separate requirement: the mandatory disclosure process. This process exists precisely because the confirming body - the Senate - cannot evaluate whether Section 4 conflicts exist without the information Section 5 requires them to receive.

The Defence's argument will likely amount to: "We broke the law, but it turned out okay, so the violation doesn't matter." But whether Judge AmityBlamity has conflicts is not the question before this Court. The question is whether someone who provided no mandatory disclosure, in violation of the clear mandatory requirement for said disclosure, can validly hold judicial office. The answer must be no. To hold otherwise would mean Section 5 is merely advisory - that compliance is optional so long as you can prove after the fact that you had nothing to hide.

This cannot be the law. The Act established the disclosure requirement for a purpose: to ensure the Senate has the information necessary to evaluate nominees before confirmation, not to create a meaningless formality that can be ignored. The absence of any actual conflicts does not cure the statutory violation that rendered Judge AmityBlamity ineligible for consideration in the first place.

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2. This Court's Precedent on Procedural Violations​

The Defence claims this Court has "repeatedly refused to consider removal, even in similar situations of alleged technical error." That's simply not true. This Court has a clear and consistent record of removing individuals from office when the process by which they obtained that office violated mandatory legal requirements.

Start with Prodigium & Partners at Law v. Commonwealth of Redmont [2021] SCR 1. Congress passed constitutional amendments expanding both the House and Senate, adding new seats to each chamber. Supermajorities in both chambers. Presidential Assent. Every box appeared checked. But the Constitution required a public referendum to be posted within 48 hours, and this simply didn't happen. The amendments were being enforced, and legislators were sitting in the newly created seats, able to submit and vote on bills; able to exercise their power.

This Court could have found the referendum requirement merely procedural. Instead, this Court held that mandatory constitutional procedures must be followed. Two Representatives and two Senators were removed from office as a result. These people had done nothing wrong. They'd been validly elected to seats that existed under enacted amendments. But the amendments themselves were unconstitutional because proper procedure wasn't followed, which meant the seats were invalid, which meant the legislators had to go.

When mandatory procedures for creating an office are violated, the resulting office cannot stand, regardless of whether the occupants themselves bear any fault. The Conflict of Interest Standards Act established mandatory procedures for confirming judges. Those procedures weren't followed. The principle of [2021] SCR 1 applies directly.

Consider the case of The Patriotic Coalition of Redmont v. Commonwealth of Redmont [2025] SCR 1. The House election was conducted according to proper timing and format. But when the Department of State counted the votes, they miscounted. Two candidates who should have won - McBrittle147 and bigpappa140 - lost. Two candidates who should have lost - zLost and RylandW - were declared winners and seated in Congress. They took office and exercised legislative power.

The Commonwealth admitted the error. The Defence could have argued that a recount was sufficient, or that the Representatives should serve out their terms since the error wasn't their fault. This Court removed them anyway. The Representatives who obtained office through a defective process - even one they had no role in creating - were replaced with the rightful winners. When someone obtains office through a process that fails to follow mandatory requirements, the legitimacy of that office is fundamentally compromised. Judge AmityBlamity bears no personal blame for the Senate's failure to ask for disclosure. But to be clear about what Section 5 actually requires. It doesn't say "the Senate must demand disclosure." It says the nominee "must provide" disclosure. Section 5(2) places the obligation squarely on the nominee: "These disclosures must be made available to the confirming body in the nominee's opening statement." The nominee must provide them. Not "the Senate must request them" or "disclosure should be provided if asked." The statute makes the nominee responsible for ensuring disclosure happens.

Finally, in Kycnn1703 v. Department of State [2022] SCR 8, the Oakridge town constitution established clear requirements for mayoral candidates: active in the Oakridge community, on Oakridge's Discord, on the forums, with experience in town government. WackJap and Deadwax didn't meet these requirements. The Department of State, responsible for administering the election, placed them on the ballot anyway. They won and became mayor and deputy mayor.

The Department of State argued that "being an active part of the community is not limited to the Oakridge community" - that federal activity should count. This Court rejected that interpretation. Town constitutional requirements "only apply to the district in which the constitution holds authority." More importantly, "the Department of State is obliged to follow the election laws and requirements set forth by the applicable town Constitution" and "does not have the authority to bypass town election laws and requirements."

WackJap and Deadwax were removed from office. They won a legitimate election by vote count and served as mayor and deputy mayor. But they should never have been on the ballot in the first place. The Department of State's failure to enforce eligibility requirements meant their election was invalid from the start. The Senate had a statutory obligation under Section 5(2) to receive financial disclosure in the opening statement. They failed to require it. Judge AmityBlamity should never have been confirmed - just as WackJap and Deadwax should never have been on the ballot. The Senate's failure to enforce the requirement doesn't validate an invalid confirmation.

Three cases. Three different scenarios. One consistent principle: when mandatory procedures are violated in obtaining office, removal is the appropriate remedy. It doesn't matter whether the violation involves constitutional amendments, election miscounts, or failure to enforce eligibility requirements. In each case, individuals were removed not because they personally did anything wrong, but because the process by which they obtained office violated mandatory legal requirements.

The Defence would try to distinguish these cases on the ground that Judge AmityBlamity's confirmation involved only a "technical error." None of these were malicious acts. All were "technical" in the sense that they involved procedural requirements rather than substantive qualifications. Yet this Court removed individuals in every single case. Why should Judge AmityBlamity be treated differently?

There is no ambiguity whatsoever. Section 5(2) states that disclosures "must be made available to the confirming body in the nominee's opening statement." No interpretation makes zero disclosure comply with this requirement. The Defence has affirmed that "throughout the entire confirmation hearing, which lasted from 30 August through 4 September 2025, no financial disclosure statement was ever provided by the nominee in any form." This is not a matter of following procedures imperfectly, tardily, or under a reasonable misapprehension. It is full non-compliance with a statutory requirement that uses mandatory verbiage: failure to disclose "shall disqualify."

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3. The Question of Alternative Remedies​

The Defence argues the Plaintiff should have pursued other avenues before filing this lawsuit. Let me address each suggested alternative.

First, impeachment. The Defence suggests the Plaintiff could have notified Congress of potential impeachment proceedings. But impeachment is fundamentally a political process. The Impeachment Act makes this explicit in Section 2(1):

2 - Reasons
(1) The impeachment process is a political one internal to the legislature. The Courts should not be intervening in the process.

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Impeachment exists to address officials who have committed "serious constitutional offences". That's not what is alleged here.

The Plaintiff does not argue that Judge AmityBlamity committed a crime. She didn't violate the Constitution through nondisclosure. She failed to provide mandatory disclosure during her confirmation hearing, which rendered her disqualified under Section 5(3). Asking Congress to impeach someone for a defect in their confirmation process would be asking them to rectify their own error through a political trial. The impeachment process requires a supermajority in both the House to bring charges and the Senate to convict - the same Senate that confirmed Judge AmityBlamity despite the disclosure violation. The political nature of impeachment makes it precisely the wrong forum for determining whether a statutory disqualification occurred.

Second, the Department of Justice. The Defence suggests notifying the DOJ about this "breach of procedure." The Conflict of Interest Standards Act did create a criminal offence - "False Financial Disclosure" under the Criminal Code Act. But that offence requires someone to "knowingly provide false, incomplete, or misleading information" or "willfully omit material information." This is a mens rea offence requiring proof of knowledge and intent.

More importantly, even if the DOJ had prosecuted this offence, such a prosecution would come before... this Court. Criminal prosecutions that result in removal from office are heard by the Supreme Court. We would end up right here, except via criminal process rather than civil. The criminal offence focuses on punishing false disclosure, not on remedying defective confirmations. The appropriate penalty listed in the statute is "disqualification from holding a position covered in §3 of the Conflicts of Interest Standards Act, for up to 2 months" - a temporary ban. But the issue before this Court is not punishment; it's whether someone who was disqualified under Section 5(3) can hold office at all.

Third, the Defence vaguely references "any number of other available avenues" without identifying what these might be. The Constitution, under Section 20(1)(a), gives this Court original jurisdiction over "removing and/or banning individuals from public office". This court has explicitly held in Plura72 v. Realimza [2025] SCR 17:

We have made it abundantly clear at this point that we, the Supreme Court of Redmont, may only remove an individual from office using our constitutional powers under limited circumstances. These include if the State is prosecuting a crime, or if there was an alleged defect, mistake, or otherwise illegitimate background to the defendant's obtaining the office that the plaintiff is asking us to remove the defendant from.

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That is precisely the situation before you. A nominee who was statutorily disqualified was nevertheless confirmed - that is a defect in obtaining office. This Court is not merely an appropriate forum for addressing this issue; it is the constitutionally designated forum.

The Plaintiff authored the Conflict of Interest Standards Act. He understands its purpose and intended operation. When he saw the Act he wrote being violated, he brought this case to the Court with proper jurisdiction to address it. The Defence's argument about alternative remedies is not really a defence at all - it's a suggestion that someone else should have fixed this problem. But this is the right case, in the right court, brought by a plaintiff with standing. The Defence's discomfort with that fact doesn't make it wrong.

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4. This Is Not De Minimis​

Finally, the Defence seems to imply this is merely a "trifling matter," a "technical error in administration that [does] no harm." They invoke the doctrine of de minimis and cite two cases: ToadKing v. Commonwealth [2025] FCR 106 and the dissenting opinion in zLost v. Commonwealth [2025] SCR 10. Let me address each.

[2025] FCR 106 involved a dispute over the timing of Executive Orders awarding state honours. The Plaintiff argued the President violated the State Commendations Act by issuing honours after a presidential election concluded, rather than "in the last two weeks before a Presidential Election." The Federal Court dismissed that case on multiple grounds, including that the Plaintiff lacked standing and that the alleged violation was "minor and not worth judicial intervention."

That case is fundamentally different from the matter before you. In [2025] FCR 106, the dispute mostly centred on interpreting when an "election" begins for purposes of calculating a two-week window. The Court found the violation too ambiguous and too inconsequential to justify intervention. The honours had been awarded. Nobody's rights were violated. The proper functioning of government was not impaired.

Here, by contrast, we have a clear statutory requirement. Section 5(2) says disclosure "must be made available to the confirming body in the nominee's opening statement." There is no ambiguity about when an opening statement occurs or what it must contain. The Defence has affirmed that no disclosure was provided. And the consequences are not trivial - the proper functioning of the judiciary depends on judges being confirmed according to law. Thirteen cases have been affected. We're not talking about the timing of ceremonial honours; we're talking about whether someone who was disqualified by statute can exercise judicial power over citizens.

The Defence also cites Justice Smallfries' dissenting opinion in [2025] SCR 10. That case involved the appointment of an individual to the position of Secretary for the Department of Public Affairs, who allegedly did not meet requirements laid out in executive policy. The Plaintiff sought to have the appointment undone.

Let me explain why that case, far from supporting the Defence's position, actually reinforces why removal is appropriate here.

The critical distinction is the nature of the violated requirement. In [2025] SCR 10, the requirements at issue came from executive policy - internal administrative guidelines created by the executive branch itself. Executive policies are not laws passed by Congress. They don't carry the force of statute. When the executive branch creates its own policies and then decides whether to enforce them, courts properly exercise restraint. The political branches have wide latitude in managing their own internal affairs.

This case involves something fundamentally different: a violation of statutory law. The Conflict of Interest Standards Act is not executive policy. It is an Act of Congress, passed by the House and the Senate, and enacted into law. When Congress establishes mandatory requirements using statutory language, such as "disclosures must be made" and "shall disqualify," those requirements carry the full force of law. The executive branch cannot waive them. The Senate cannot ignore them. And courts cannot treat them as merely advisory.

Moreover, [2025] SCR 10 dealt with an appointment to a Cabinet position - a purely political role within the executive branch, where the President has broad discretion over appointments. The Secretary serves at the pleasure of the President and can be removed at will. Federal Court Judges, by contrast, are judicial officers who exercise the sovereign power to interpret law and adjudicate disputes. The judiciary is a co-equal branch of government. Judicial appointments require Senate confirmation precisely because judges don't serve at anyone's pleasure - they serve until removed through constitutional processes or until they resign.

The stakes are also vastly different. If the Secretary in [2025] SCR 10 was improperly appointed, the remedy is simple: the President can appoint someone else at any time. No judicial decisions are tainted. No verdicts need to be questioned. But when a judge is improperly confirmed, every decision they make carries the shadow of illegitimacy. The Defence has affirmed that Judge AmityBlamity has presided over thirteen cases. Every party in those cases can ask: "Did I have my day in court before a properly confirmed judge?"

Even accepting the dissent's framework in [2025] SCR 10 - that courts should exercise restraint and avoid "extreme measures" for "minor errors" - this case falls outside that framework. Justice Smallfries' dissent argued for recognising errors without imposing severe remedies when the error is truly minor and causes no real harm. But what makes an error "minor"? An error is minor when it violates only internal policy rather than statutory law. An error is minor when it affects political appointees who serve at will rather than judicial officers who exercise sovereign power. An error is minor when it can be easily corrected without calling into question official acts already taken.

None of those factors favours the Defence here. This is a statutory violation using mandatory language. It affects a judicial officer whose cases are now tainted. And it cannot be corrected without removing Judge AmityBlamity from office, because the statute doesn't permit "curing" a disqualification after confirmation has occurred. Section 5(3) states that failure to disclose "shall disqualify the nominee from consideration" - not "shall disqualify the nominee unless she's already been confirmed and might be doing a good job."

If anything, [2025] SCR 10 should make the Defence's position harder, not easier. If an executive policy violation regarding a political appointee warranted judicial consideration (even if ultimately dismissed), surely a statutory violation regarding a judicial officer warrants the remedy the statute itself prescribes: disqualification.

III. Conclusion​

The Defence might ask you to exercise restraint, to find that this violation doesn't warrant removal; to treat Section 5(3) as merely advisory despite its mandatory language. But this Court's role is not to determine whether Congress chose the right remedy when it wrote "shall disqualify." This Court's role is to apply the law as written.

The law is clear. Judge AmityBlamity failed to provide the required disclosure. That failure triggered a statutory disqualification under Section 5(3). A disqualified nominee cannot be validly confirmed. The confirmation was therefore defective, and Judge AmityBlamity obtained her office through a process that violated statutory law.

This Court has removed individuals from office for procedural defects before. It did so in [2021] SCR 1 when constitutional amendments failed to follow proper procedure. It did so in [2025] SCR 1 when an election was miscounted. It did so in [2022] SCR 8 when eligibility requirements weren't enforced. The principle is the same here: when mandatory procedures are violated, the resulting office cannot stand.

The Defence has affirmed the facts. The law establishes the consequence. All that remains is for this Court to apply that consequence and reaffirm that in Redmont, even the process of confirming judges must follow the law.

Thank you.

Opening Statement

IN THE SUPREME COURT OF THE COMMONWEALTH OF REDMONT
OPENING STATEMENT

Your honours, opposing counsel, and onlookers. May it please the Court,

Before you today is a public interest case made expressly against the public interest. One of Redmont’s most competent, active, and capable jurists has had her legitimacy questioned, such that the Plaintiff argues that not only should she be removed from her post, likely to be thrown once more into the politically-charged nomination process, but also that all of her already-issued verdicts should be tainted and called into question. Why? Because she forgot to say “I own an inactive press company.”

The matter before us is so menial, so trifling, that it was our first instinct at the Department of Justice to request it be dismissed. Indeed, we weighed very heavily whether or not to file such a motion. Yet, unlike so many of the Plaintiff’s other ‘public interest’ lawsuits against the Commonwealth, this claim seems able to stand – the Plaintiff (or the public as a whole) was affected by an inconsistent application of law with an associated remedy for its breach. Like a blind fisherman, the Plaintiff has cast his line again and again into the open ocean, and now, has seemingly caught something. Yet, it is now the Court’s job to assess whether or not the requested remedy is indeed the most favourable course of action. Our request to this Court is to acknowledge Plaintiff’s catch, pat him on the back, and let us all go on with our lives. An error has been identified. Let us not allow it to cause more harm than necessary.

I. Can this Court Remove the Honourable Judge AmityBlamity from Office?
Yes. This is not an issue in contention.

II. Must it?
No. This Court has complete discretion over when and how to apply its constitutional authority to remove public officials. Indeed, it has been very discerning in the past. The Plaintiff correctly cites a number of cases in which removal was indeed the necessary relief. However, precedent clearly shows that the burden for not only proving an illegitimacy in the official’s ascension to office, but also that removal is the proper and correct remedy for the error, is exceptionally high. This Court has dismissed countless similar public interest cases in the recent past: FCR 81, SCR 12, SCR 14, SCR 15, SCR 17, and SCR 19, to name a few. Many of these were filed by the Plaintiff in this case as well. While Plura72 v. RealImza [2025] SCR 17 sets the clearest precedent for when the Supreme Court is willing to consider removal of public officials, one of that verdict’s cited cases, zLost v. Commonwealth [2025] SCR 14, is perhaps the most interesting. In SCR 14, the Plaintiff alleges a defect in the ascension of the Public Affairs Secretary to office. Nevertheless, this Court dismissed that case sua sponte due to the Plaintiff’s failure to show a meaningful legal effect or injury in relation to the alleged defect. While the Defence respects the Court’s decision not to apply that precedent by dismissing this case in the same manner – perhaps the Plaintiff here succeeds in laying the groundwork for a potential injury – the pattern is more than clear. There must have been an actual defect in the ascension of the official to office, and there must be some harm caused by that defect before the Court will consider removal in a civil case.

Seeing that this Court need not necessarily apply the remedy of removal, even when a defect in ascension is alleged or found, the Defence will argue two-fold in the matter before you today:
- First, there was no harm caused by AmityBlamity’s lack of compliance with the Conflict of Interest Standards Act.
- Second, to apply removal (or invalidation of Her Honour’s prior work) in this matter would be a gross overreaction, and would do significantly more harm than applying no relief at all.

III. On the Lack of Harm
The Plaintiff and the Defence agree: AmityBlamity held no conflicts of interest that would have disqualified her from the position of Federal Judge, and her testimony will corroborate this. Further, whatever information would have been garnered from her financial disclosure was evidently not necessary for the Senate to make their decision – no one bothered to request one or question Amity’s business interests, and she was confirmed without issue. If the Senate did not require the financial disclosure, and its submission would not have affected AmityBlamity’s nomination or confirmation in any way, who was harmed? Certainly not the Plaintiff – he alleges no personal harm. Then, what interest does the public have in this case? Let us explore some possibilities:

• The public has an interest in the law being followed to the letter from this point forward, because future nominees may indeed have disqualifying conflicts.

Indeed. If this is the purpose this case serves, then it has already accomplished it. The Senate has now begun directly asking nominees before them for COISA-compliant financial disclosure. This same effect could have been achieved by simply opening a Congressional ticket or notifying the Senate of the lack of compliance.

• Parties to court cases have a right to have their case heard by a legally confirmed judge.

Perhaps, though it would seem much more likely that the right conferred upon litigants by the COISA is the right to be heard in front of a competent judge with no conflicts of interest that would affect their decision-making ability. AmityBlamity’s sitting on the bench has not infringed that right. Indeed, she has shown a striking ability to deliver unbiased verdicts, despite her lack of overt financial disclosure in her hearing. We once again find that the harm alleged in this case exists purely in the abstract. There is no aberration, aside a minor procedural error, that would be corrected by granting the Plaintiff’s prayer for relief. No one has come forward stating that Her Honour’s failure to comply with the COISA affected them personally in any meaningful way. A potential harm, thoroughly disproven, is certainly not a harm in and of itself.

No one’s rights were infringed, no process of government stopped, no fundamental moral value of society offended by the proceedings of Amity’s confirmation hearing. In Prodigium & Partners at Law v. Commonwealth [2021] SCR 1, the victims of the procedural error were the people of Redmont who were stripped of their right to vote in referenda on Constitutional amendments. In Kycnn1703 v. DOS [2022] SCR 8 and PCR v. Commonwealth [2025] SCR 1, the victims were the participants in the elections who lost to ineligible candidates. Where is the victim in this case?

IV. On the Requested Relief
The Plaintiff requests a number of actions as relief for the alleged violation: removal of AmityBlamity from judicial office, reassignment of all of her active cases, a declaration that her previous verdicts were illegitimate, and the implementation of “procedures to ensure future judicial nominations comply with the Conflict of Interest Standards Act.”

We have already established that removal from office is an action that requires harm to have been done, and requires a heavy burden for the Court to apply. We must ask ourselves, is the remedy of removal consistent with the nature of the error? Established precedent shows, and witness testimony will support, that the answer is an emphatic no. Not only would granting this relief be unfair to AmityBlamity, but it would render an already overworked Court significantly less able to carry out its necessary functions.

A declaration that Amity’s previous verdicts were illegitimate, granting “parties in those cases [...] grounds to seek appropriate remedies” would be potentially even more disastrous. First of all, it is not clear what “appropriate remedies” would look like. There is no procedure established by Congress to grant such remedies, and so the Court would have to fashion such a procedure itself. There is almost no imaginable situation following such a declaration that would not involve retrials for these cases, one of which involved a $17,000,000+ verdict. The relitigation and reopening of wounds relating to these already-settled matters would place a great burden upon the involved parties, the government, and the public.

On the Plaintiff’s remaining prayers, procedures have already been established by the Senate to ensure compliance with the COISA, and reassignment is an implicit aspect of the Plaintiff’s request for removal. These prayers hardly need to be considered.

V. On De Minimis and [2025] SCR 10
The Plaintiff argues that the situation in this case is expressly different from that of [2025] FCR 106, which was dismissed in part on the basis of de minimis. The Plaintiff argues that the issue in that case was the ambiguous nature of the alleged violation, but this is plainly incorrect. The Honourable Judge Ameslap states:

While technically improper, the alleged violation is minor and not worth judicial intervention.

The error was not worth consideration because it was minor – among other issues, the alleged violation simply did not matter. This precedent directly applies, because both deal with technical errors in procedure that harmed no one.

Further, the Plaintiff shows a striking lack of comprehension of the Honourable and Learned Justice Smallfries4’s dissenting opinion in [2025] SCR 10, the logic of which has already been cited by this Court in the prior ruling on the Plaintiff’s emergency injunction. In it, Justice Smallfries argues, in reference to the Public Affairs Secretary’s ascension to office, that:

Dark’s joining the DPA was illegitimate and plainly against department policy. However, I also believe that while technically wrong, this mistake was harmless. [...]

The fact of Dark’s playtime deficiencies did not substantially impact any person’s rights (if at all), and any claim to the contrary ignores that Dark could have just [easily solved the issue after the fact]. Dark has since cured his deficiency, and likely did so soon after this case was filed. We do not wish to encourage individuals fixing mistakes only when a case has been filed as a result of those mistakes. However, here I believe the issue at hand is so minor and so far removed from any real material impact that we can effectively ignore it.

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Nowhere does Justice Smallfries state that the reason that the error was “minor” was because it violated policy rather than statute, or because of the at-will nature of the position – this is simply an invention of the Plaintiff’s imagination. The mistake was minor and unworthy of consideration because it was harmless, and its having not been made would have created essentially no different circumstances for the official in question, despite being “technically wrong.” This precedent is reflective of this Court’s philosophy despite the disagreements between Justices of the details of the violation in question. Additionally, there is no imaginable world in which it does not apply to this case directly. Thus, we can recommend Justice Smallfries’s requested relief here as well:

Were my opinion to rule as majority, I would grant the Plaintiff $5,000 in legal fees, and refuse in their entirety his other two requested reliefs due to the harmlessness of Dark’s error.

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If this dissenting opinion’s logic is indeed binding, or even informative, upon this Court, then the necessary relief is clear. An acknowledgement that a mistake was made, perhaps a granting of legal fees and nominal damages, and, informed by the earlier-cited section, perhaps an injunction requiring a public dissemination of AmityBlamity’s business interests. Nothing more is necessary in this trifling matter.

VI. Conclusion
The Plaintiff’s grievance carries some legitimacy – an error was made. However, it is clear from the lack of harm incurred, the overblown nature of the requested relief, and the well-established precedent regarding similar incidents, that the Plaintiff is misguided. Her Honour’s witness testimony will only serve to further strengthen the case against granting Plaintiff’s requested relief, and by the end of this trial, I firmly believe that the Court will see to it that compliance does not become the enemy of justice.

Thank you.

Writ of Summons

@AmityBlamity is required to appear before the Supreme Court in the case of ToadKing v. Commonwealth of Redmont.

Failure to appear within 72 hours of this summons will result in a default judgement based on the known facts of the case.

Both parties should make themselves aware of the Court Rules and Procedures, including the option of an in-game trial should both parties request one.