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Case Filing
IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
CIVIL ACTION
Matthew100x
Plaintiff
v.
The Commonwealth of Redmont (Department of State)
Defendant
COMPLAINT
The Plaintiff complains against the Defendant as follows:
I. PARTIES
1. Plaintiff Matthew100x is a citizen of the Commonwealth of Redmont who submitted a passport application to the Department of State on July 22, 2026.
2. Defendant Commonwealth of Redmont is the sovereign governmental entity responsible for the actions and omissions of its executive departments, including the Department of State. The Department of State is an executive department of the Commonwealth charged with administering elections and issuing, updating, and replacing passports in accordance with Redmont law.
II. FACTS
1. A valid passport issued by the Department of State is required for a citizen to vote in an election held within Redmont. (See Passport Act, Passport Administration, § 3(2)(c), Passport Act))
2. The Department of State must issue a passport to an applicant who has reached the applicable active-player threshold. (See Passport Act, Passport Administration, § 3(2)(d).. Passport Act)
3. The Department of State may delay an individual passport request for no more than seven days where the delay is used to investigate possible electoral fraud. (See Passport Act, Passport Administration, § 3(2)(d)(i), Passport Act))
1. The Department of State is expressly charged with issuing, updating, and replacing passports in accordance with the Passport Act. (See Passport Act, Amendments, § 4(1). Passport Act))
2. On or about July 17, 2026, President Multiman155 issued Executive Order EO-23-26, directing members of the Executive Branch to cease performing governmental work. (See [Executive Order EO-23-26]([Executive Order - Executive Order 23/26 - Work Stoppages])).
3. Beginning on or about July 17, 2026, the Department of State ceased processing passport applications (see P-001)
4. Passport applications remained unprocessed between July 17 and July 22, 2026 (see P-001-P006).
5. The Department of State’s payment records reflect that no payments were issued to Department personnel for processing passport applications during that period.
6. On July 22, 2026, the Plaintiff submitted a passport application containing the information required by the Department of State.
7. The Plaintiff has accrued at least six active hours of playtime during the thirty days preceding the election and is otherwise eligible to vote.
8. The current election is scheduled to start voting today.
9. Because of the Department’s continuing work stoppage, the Plaintiff’s application is unlikely to be reviewed and processed before the polls close.
10. Without a valid passport, the Plaintiff cannot vote in the current election.
11. The Plaintiff’s inability to obtain timely consideration of his passport application therefore creates an imminent and particularized risk that he will be deprived of his constitutional right to vote.
12. Upon information and belief, the applications of other eligible citizens have also remained unprocessed because of the same blanket work stoppage. The Plaintiff does not purport to represent those citizens and alleges this fact only as evidence of the Department’s general cessation of its statutory functions.
III. CLAIMS FOR RELIEF
COUNT I
FAILURE TO PERFORM STATUTORY DUTY
A government officer or governmental body commits the civil violation of Failure to Perform Statutory Duty when it fails to perform a duty required by law and that failure causes harm to the plaintiff, unless the failure resulted from circumstances beyond the defendant’s control. (See Redmont Civil Code Act, Part XI, § 7(a)–(c), Redmont Civil Code Act)
The Passport Act requires the Department of State to administer passport applications and requires passports to be issued to applicants who satisfy the active-player threshold. (See Passport Act, Passport Administration, § 3(2)(d); Amendments, § 4(1), Passport Act)
The Department’s authority to delay a request for up to seven days is limited to delays undertaken to investigate possible electoral fraud. (See Passport Act, Passport Administration, § 3(2)(d)(i).)
A blanket refusal to process passport applications pursuant to a general work stoppage is not an individualized electoral-fraud investigation and is not authorized by the Passport Act. By ceasing passport processing, the Department failed to perform a duty required by law. That failure has harmed the Plaintiff by placing him at imminent risk of losing his ability to vote before the current election concludes.
A Writ of Mandamus is the prescribed remedy for a governmental body’s failure to perform a statutory duty. (See Judicial Standards Act, Part V, § 2, Judicial Standards Act).
COUNT II
VIOLATION OF CONSTITUTIONAL RIGHTS
The Constitution guarantees eligible citizens the right to vote in elections and referendums. (See Constitution of the Commonwealth of Redmont, Part V, § 35(2).)
A valid passport is a legal prerequisite to voting. (See Passport Act, Passport Administration, § 3(2)(c); Electoral Act, Registration, § 13(1), Electoral Act).
The Commonwealth therefore has an obligation to administer the passport system in a manner that does not arbitrarily prevent otherwise-qualified citizens from exercising their constitutional right to vote. The Department acted under colour of law because it possessed and exercised governmental authority over passport issuance and voter eligibility. By knowingly ceasing the processing of passport applications despite an ongoing election, the Department has created an imminent risk that the Plaintiff will be deprived of a right secured by the Constitution.
A person acting under colour of law commits a civil violation where that person intentionally or negligently deprives another person of rights secured by the Constitution. (See Redmont Civil Code Act, Part XI, § 1(a)). The Department’s failure to administer passport applications during an election constitutes, at minimum, negligent conduct because the Department knew or reasonably should have known that its inaction would prevent eligible applicants from voting.
The Plaintiff is entitled to declaratory, nominal, and equitable relief for this threatened or completed constitutional deprivation.
IV. PRAYER FOR RELIEF
The Plaintiff seeks the following relief from the Defendant:
1. A declaratory judgment that the Department of State’s blanket cessation of passport processing violates the Passport Act and the Redmont Civil Code Act.
2. A declaratory judgment that the Department of State may not administer the passport system in a manner that arbitrarily deprives otherwise-qualified citizens of their constitutional right to vote.
3. A Writ of Mandamus compelling the Commonwealth and the Department of State to immediately resume reviewing and processing passport applications in accordance with the Passport Act (Guide - Court Orders).
4. A Writ of Mandamus compelling the Department of State to review the Plaintiff’s passport application before the polls close, subject only to a lawful and individualized electoral-fraud investigation authorized by the Passport Act.
5. In the alternative, an order directing the Department of State to exercise the remedies provided for an electoral emergency—including extending, pausing, or restarting the voting period—to ensure that the Plaintiff is afforded a meaningful opportunity to vote. (See Electoral Act, Electoral Emergencies, § 12(1)–(3).)
6. Nominal damages of $7,500 to recognize the violation or deprivation of the Plaintiff’s statutory and constitutional rights. (See Redmont Civil Code Act, Part III, § 4(1)–(2).)
Any other relief that the Court considers just and proper.
By making this submission, I agree that I understand the penalties for lying in court and that I am subject to perjury should I knowingly make a false statement in court.
DATED: This 22nd day of July 2026.
Motion
IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
MOTION FOR EMERGENCY INJUNCTION
Matthew100x
Plaintiff
v.
The Commonwealth of Redmont (Department of State)
Defendant
The Plaintiff respectfully moves for an emergency injunction and expedited Writ of Mandamus directing the Commonwealth of Redmont, acting through the Department of State, to immediately resume processing passport applications and to review the Plaintiff’s application before the current election concludes. In support of this Motion, the Plaintiff states as follows:
I. BACKGROUND
1. The Plaintiff filed the accompanying Complaint challenging the Department of State’s cessation of passport processing during an active election period.
2. Redmont law requires a voter to hold a valid passport issued by the Department of State. (See Passport Act, Passport Administration, § 3(2)(c); Electoral Act, Registration, § 13(1).)
3. The Constitution guarantees the Plaintiff the right to vote, provided that he has accrued the required active playtime. (See Constitution of the Commonwealth of Redmont, Part V, § 35(2).)
4. The Plaintiff submitted a passport application on July 22, 2026.
5. Beginning on or about July 17, 2026, the Department of State ceased processing passport applications pursuant to Executive Order EO-23-26.
6. Unless emergency relief is granted, the Plaintiff’s application is unlikely to be processed before the polls close, and the Plaintiff will be unable to vote.
II. BASIS FOR EMERGENCY RELIEF
1. The purpose of an emergency injunction is to prevent imminent harm, and the Court considers whether the harm prevented by the injunction exceeds any harm that would result from granting it. (See Commonwealth v. Bardiya_King, [2023] SCR 23, Lawsuit: Adjourned - Commonwealth v. Bardiya_King [2023] SCR 23)
2. The Plaintiff faces imminent harm because the constitutional right to vote cannot be meaningfully exercised after the election has concluded.
3. Monetary relief issued after the election would not provide the Plaintiff with the opportunity to cast a ballot in that election.
4. The threatened injury is therefore irreparable for purposes of emergency relief.
5. The requested injunction would impose minimal hardship on the Defendant because it would require the Department only to resume performing duties already imposed upon it by statute.
6. The Passport Act requires passports to be issued to applicants who have reached the active-player threshold. (See Passport Act, Passport Administration, § 3(2)(d).)
7. Although the Department may delay an individual application for up to seven days to investigate possible electoral fraud, a generalized refusal to perform work is not an individualized electoral-fraud investigation. (See Passport Act, Passport Administration, § 3(2)(d)(i).)
8. The public interest favors enforcement of the Constitution and election laws, preservation of eligible citizens’ voting rights, and orderly administration of the passport system.
9. The balance of harms strongly favors the Plaintiff. Without relief, the Plaintiff may permanently lose the opportunity to vote in the current election. With relief, the Defendant is required only to lawfully review pending applications.
III. WRIT OF MANDAMUS
1. The Redmont Civil Code Act establishes a cause of action where a governmental body fails to perform a statutory duty and that failure causes harm to a plaintiff. (See Redmont Civil Code Act, Part XI, § 7(a)–(c)).
2. A person acting under colour of law commits a civil violation where that person intentionally or negligently deprives another person of rights secured by the Constitution. (See Redmont Civil Code Act, Part XI, § 1(a)).
3. A Writ of Mandamus is the established remedy for compelling a government body to perform a duty required by law. (See Guide - Court Orders).
4. The Department has a nondiscretionary duty to administer passport applications in accordance with the Passport Act.
5. The Department’s discretion concerning how to investigate possible fraud does not authorize it to entirely abandon passport processing.
6. Expedited mandamus relief is necessary because an order entered after the polls close would not restore the Plaintiff’s lost opportunity to vote.
IV. RELIEF REQUESTED
The Plaintiff respectfully requests that the Court:
1. Immediately enjoin the Commonwealth and the Department of State from continuing any blanket cessation or suspension of passport processing during the current election.
2. Issue an expedited Writ of Mandamus directing the Department of State to immediately resume reviewing and processing all pending passport applications in accordance with the Passport Act.
3. Direct the Department of State to review the Plaintiff’s July 22, 2026 passport application before the polls close.
4. Prohibit the Department from denying or delaying the Plaintiff’s application solely because of Executive Order EO-23-26 or a generalized work stoppage.
5. Alternatively, direct the Department of State to declare an electoral emergency and extend, pause, or restart the voting period so that the Plaintiff and other affected eligible applicants receive a meaningful opportunity to vote. (See Electoral Act, Electoral Emergencies, § 12(1)–(3).)
Grant any other emergency relief that the Court considers just and proper.
DATED: This 22nd day of July 2026.
