ToadKing
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Case Filing
IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
CIVIL ACTION
ToadKing
Plaintiff
v.
Commonwealth of Redmont
Defendant
COMPLAINT
The Plaintiff complains against the Defendant as follows:
WRITTEN STATEMENT FROM THE PLAINTIFF
I. PARTIES
1. ToadKing2. Commonwealth of Redmont
II. FACTS
1. On or around 24 August 2025 at 21:54 UTC+1, then-President Kaiserin resigned from the office of President. (P-001)2. On or around 28 August 2025 at 04:51 UTC+1, Vice President Juniperfig assumed the office of President pursuant to Section 26(1) of the Constitution. (P-002)
3. On 2 October 2025 at 01:03 UTC+1, the Department of State officially announced the 15th Presidential Elections for October 2025. (P-003)
4. The 15th Presidential Election concluded on 11 October 2025 at 01:17 UTC+1, when the Department of State officially announced the election results. (P-004)
5. On 11 October 2025 at 22:44 UTC+1, President Juniperfig issued Executive Order 34/25, awarding Order of Service honours to ten individuals. (P-005)
6. On 12 October 2025 at 23:27 UTC+1, President Juniperfig issued Executive Order 35/25, awarding Order of Redmont honours to ten individuals. (P-006)
7. On 13 October 2025 at 22:48 UTC+1, President Juniperfig issued Executive Order 36/25, awarding three Presidential Commendations. (P-007)
8. Section 6(1) of the State Commendations Act explicitly states: "Executive Honors are to be awarded in the last two weeks before a Presidential Election."
9. All three Executive Orders were issued after the Presidential Election had concluded.
III. CLAIMS FOR RELIEF
1. Violation of the State Commendations Act
The Defendant's Executive Orders violate Section 6(1) of the State Commendations Act, which establishes clear timing requirements for when the President may award honours. Section 6(1) states:The Defendant issued three Executive Orders awarding various honours and commendations:
- Executive Order 34/25 awarded Order of Service honours to ten individuals (P-005)
- Executive Order 35/25 awarded Order of Redmont honours to ten individuals (P-006)
- Executive Order 36/25 awarded Presidential Commendations to three individuals (P-007)
Orders of Merit Are Executive Honours
Executive Order 34/25 awarded Orders of Service, and Executive Order 35/25 awarded Orders of Redmont. Both types of honours are defined in Section 5 of the State Commendations Act as "Orders of Merit." Section 5 establishes that these orders are to be sponsored by the President, in Section 5(3)(i)(c) and Section 5(3)(ii)(b).These Orders of Merit constitute "Executive Honours" for several reasons:
- First, when the President - the head of the Executive branch - awards honours, those awards are by definition "Executive Honours." The President exercises executive power when awarding state commendations. Any honour awarded by the President pursuant to statutory authority is an exercise of executive power and therefore an "Executive Honour."
- Second, the State Commendations Act divides honours by which branch of government awards them. Section 6 addresses "Executive Honours" awarded by the President and Cabinet secretaries. Section 7 addresses "Congressional Honours" awarded by Congress. Section 7(1) (should be "Section 8(1)") of the Act expressly states that "Judicial Honors are to be awarded in the last two weeks before a Presidential Election," creating a parallel structure. The Act distinguishes honours based on which branch awards them, not based on which section defines them. Section 5 establishes what Orders of Merit are and designates the President as their sponsor. Section 6(1) establishes when Executive Honours - including those defined elsewhere in the Act - may be awarded. To interpret Section 6(1) as applying only to honours explicitly enumerated in Section 6(2) onwards would create an absurd loophole: the President could circumvent timing restrictions simply by awarding Orders of Merit instead of Presidential Commendations.
- Third, Congress established timing requirements in Section 6(1) to regulate when the President may award honours and prevent abuse of commendation power during election periods. If Orders of Merit sponsored by the President were exempt from Section 6(1), the timing restriction would become meaningless. Presidents could evade the deadline by choosing which type of honour to award. This interpretation would defeat the clear legislative intent.
- Fourth, the Defendant's own acknowledgement - in Executive Orders 34/25 and 35/25, the President stated these awards were made "in accordance with §5 of the State Commendations Act." The Defendant recognised that these orders were being issued pursuant to the State Commendations Act and are therefore subject to all provisions of that Act, including Section 6(1).
Presidential Commendations Are Unambiguously Executive Honours
Executive Order 36/25 awarded Presidential Commendations. These are explicitly defined in Section 6(2)(i) of the State Commendations Act as Executive Honours with the President as sponsor. There can be no dispute that Presidential Commendations fall squarely within the category of "Executive Honours" subject to Section 6(1)'s timing requirements.Notably, in Executive Order 36/25, the Defendant incorrectly stated:
This citation is erroneous - Presidential Commendations are governed by Section 6(2)(i), not Section 5. This error demonstrates confusion about the statutory framework, but does not change the legal reality. Presidential Commendations are unambiguously "Executive Honours" that must be awarded "in the last two weeks before a Presidential Election."
The Timing Violation
The statute requires "Executive Honours" to be awarded "in the last two weeks before a Presidential Election." The Electoral Act clearly defines when a Presidential Election occurs and provides the framework for understanding this timing requirement.Section 4(5) of the Electoral Act establishes that "General Presidential and Congressional Elections will operate on a ten-day cycle during an election month," consisting of three distinct periods:
The Electoral Act makes clear that the election begins on the first day of the electoral month, with the Declaration Period. This is when the election commences as a formal process - not when results are announced ten days later.
The phrase "in the last two weeks before a Presidential Election" must mean the two-week period immediately preceding the commencement of the election on the first day of the electoral month. The word "before" means prior to an event - the election begins on the 1st day of the electoral month, therefore "before a Presidential Election" means before the first day of that month.
This interpretation would align with a clear policy purpose - preventing executive honours from being awarded during election periods when such awards could be perceived as political favouritism or attempts to influence electoral outcomes. If Presidents could award honours during the Declaration Period, Voting Period, or after results are announced, the timing restriction would be meaningless.
For the October 2025 Presidential Election, the election began on 1 October 2025 - the first day of the electoral month and the start of the Declaration Period. The "last two weeks before" this election ran from approximately 17 September 2025 through 1 October 2025. The Defendant had this entire window to award "Executive Honours" lawfully.
Instead, the Defendant issued all three Executive Orders well after the statutory deadline - indeed, after the entire ten-day election cycle had concluded:
- Executive Order 34/25 on 11 October 2025 - approximately 10 days after the deadline and one day after the election cycle ended (P-005)
- Executive Order 35/25 on 12 October 2025 - approximately 11 days after the deadline (P-006)
- Executive Order 36/25 on 13 October 2025 - approximately 12 days after the deadline (P-007)
2. Ultra Vires Executive Action
Section 42 of the Constitution defines an Executive Order as:The President's authority to award state commendations derives entirely from the State Commendations Act. Congress established the framework for these honours, including specific timing requirements. The President has no inherent constitutional authority to award state honours outside the statutory framework Congress created.
By issuing Executive Orders outside the timeframe prescribed by statute, the Defendant acted beyond the authority granted by law. When Congress establishes conditions and limitations on executive authority, the President must comply with those conditions, or the executive action is unlawful. An Executive Order that violates statutory requirements is not a "lawful directive" as defined in Section 42 of the Constitution. The Defendant's purported exercise of authority to award honours after the statutory deadline represents an unlawful exercise of power.
The Constitution vests legislative power in Congress, not the Executive. Congress makes the laws, and the Executive must faithfully execute those laws as written. The President cannot override congressional statutes through Executive Orders. To permit the Defendant's actions to stand would undermine the separation of powers doctrine and establish a dangerous precedent that the President may disregard statutory limitations.
3. Remedy
The appropriate remedy for unlawful Executive Orders is judicial nullification. When the Executive exceeds statutory authority, the courts have both the power and duty to strike down such actions. The honours and awards granted pursuant to Executive Orders 34/25, 35/25, and 36/25 were issued without lawful authority and therefore must be declared void ab initio.
IV. PRAYER FOR RELIEF
The Plaintiff respectfully requests that this Honourable Court:- Strike down all commendations, honours, and awards granted pursuant to Executive Orders 34/25, 35/25, and 36/25;
- Issue a declaratory judgment that "Executive Honours" under the State Commendations Act must be awarded within the last two weeks before a Presidential Election, and that any awards issued outside this statutory timeframe are unlawful and without effect;
- Award the Plaintiff legal fees in the amount of $1;
EVIDENCE:
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DATED: This 14th day of October 2025
