Case: 12-17808, 11/21/2018, ID: 11096529, DktEntry: 193, Page 1 of 110 No. 12-17808 In the United States Court of Appeals for the Ninth Circuit George K. Young, Jr. Plaintiff-Appellant, v. State of Hawaii, et al. Defendants-Appellees. Appeal from a Judgment of United States District Court For the District of Hawaii Civ. No. 12-00336-HG-BMK United States District Court Judge Helen Gillmor Sur-Reply in Opposition of Defendants Petition for Rehearing En Banc ALAN BECK Attorney at Law 2692 Harcourt Drive San Diego, California 92123 Telephone: (619) 905-9105 alan.alexander.beck@gmail.com STEPHEN D. STAMBOULIEH STAMBOULIEH LAW, PLLC P.O. Box 4008 Madison, MS 39130 Telephone: (601) 852-3440 stephen@sdslaw.us Attorneys for Appellant, George K. Young, Jr.
Case: 12-17808, 11/21/2018, ID: 11096529, DktEntry: 193, Page 2 of 110 TABLE OF CONTENTS Introduction...1 Argument...1 I. The Monthly Reports Are Judicially Noticeable and Evidence of Past Practice....3 II. Gloucester is Inapplicable to the Current Situation....7 Conclusion.....8 Certificate of Compliance Certificate of Service ii
Case: 12-17808, 11/21/2018, ID: 11096529, DktEntry: 193, Page 3 of 110 TABLE OF AUTHORITIES Cases Gloucester Cty. Sch. Bd. v. G.G. exrel. Grimm, 137 S. Ct. 1239 (2017)...7, 8 Hart v. Massanari, 266 F.3d 1155 (9th Cir. 2001)... 7 Heller v. District of Columbia (Heller II), 670 F.3d 1244 399 U.S. App. D.C. 314 (D.C. Cir. 2011)... 6 Jackson v. City & County of San Francisco, 746 F.3d 953, 961, 2014 U.S. App. LEXIS 5498, *14, 2014 WL 1193434... 6 United States v. Chovan, 735 F.3d 1127 (9th Cir. 2013)... 6 Statutes H.R.S. section 134-9... 1, 2, 3, 4, 8 Rules Hawaii Revised Statutes, Police Dep t of Cty. Of Haw., Rules and Regulations Governing the Issuance of Licenses 10 (Oct. 22, 1997)...1, 2 Other Sources http://hifico.org/ag-reports/?fbclid=iwar1uuvuu4zp41azxm- QZZAfKVayWDLYGBvtPeV-udXiYFRPj2xr9xCjqPqk... 5 El Larson, "Police Commission reviewing HPD's policies on letting the public carry guns", September 20 th, 2018, http://www.kitv.com/story/39131297/honolulu-police-commission-reviewinghpds-policies-on-letting-the-public-carry-guns... 4 "Firearm Registrations in Hawaii, 2017", https://ag.hawaii.gov/cpja/files/2018/05/firearm-registrations-in-hawaii- 2017.pdf... 5 iii
Case: 12-17808, 11/21/2018, ID: 11096529, DktEntry: 193, Page 4 of 110 T. Langford, "Police Commission: Why Is It So Hard To Get A Permit To Carry A Gun In This City?"Honolulu Civil Beat, November 2, 2018, https://www.civilbeat.org/2018/11/police-commission-why-is-it-so-hard-to-geta-permit-to-carry-a-gun-in-this-city/... 4 iv
Case: 12-17808, 11/21/2018, ID: 11096529, DktEntry: 193, Page 5 of 110 Introduction Mr. Young files this sur-reply to address several material misrepresentations made in Defendants Reply brief 1. The relief sought in Mr. Young s complaint is to be issued a permit to carry a firearm. See ER 5. The only entity able to issue him a permit is the County of Hawaii via its Chief of Police. The County s written implementation of H.R.S. section 134-9 is to limit open carry permits to security guards. The extra record evidence Defendants rely on should be ignored because as shown below it is neither properly before this court nor credible. Defendants Petition should be denied. Argument The County s ordinance is not an independent regulation. The rules and regulations are promulgated by the Chief of Police for the granting of authorization for the carrying of weapons as provided by section 134-9, Hawaii Revised Statutes. Police Dep t of Cty. Of Haw., Rules and Regulations Governing the Issuance of Licenses 10 (Oct. 22, 1997) at *1. It limits open carry permits to Licensed Employees which it defines as any person employed by a private detective or 1 Mr. Young s sur-reply focuses on the argument made in Section 1 of Defendants Reply. Most of the argument made in Section II and IV rehash argument that was addressed in the response and thus do not need to be addressed. As to Section III, Mr. Young directs this Court to San Diego County Gun Owners excellent amicus brief which thoroughly demonstrates that Defendants and their amici have seriously misconstrued the history at issue. 1
Case: 12-17808, 11/21/2018, ID: 11096529, DktEntry: 193, Page 6 of 110 guard agency. Police Dep t of Cty. Of Haw., Rules and Regulations Governing the Issuance of Licenses 10 (Oct. 22, 1997) at *4, *11. Thus, Hawaii County s implementation of state law bans open carry for anyone other than private detectives or those employed at a guard agency. Even if this Court were to take the Hawaii Attorney General s opinion and the Counties amicus brief at face value, they have no probative value because the actual implementation of state law against Mr. Young by the County of Hawaii bans open carry for private citizens. However, this Court should not accept Defendants new position because it is inconsistent with their previous briefing. Defendants contend the State position is not at odds with its previous briefing. However, a faithful review of the record demonstrates otherwise. Rather than correct the County about the correct interpretation of state law, the State repeatedly endorsed the County s implementation of section 134-9 as correct. In addition to the argument made in its first amicus brief, the State argued in its supplemental amicus: Hawai i does allow concealed carry for applicants in the "exceptional case" who "show[] reason to fear injury to the applicant's person or property." Plaintiff is thus clearly wrong to claim Hawai i "completely ban[s] the carry of firearms, open or concealed." Instead, Hawai i allows public carry (via concealed carry)for those establishing a concrete self-defense need See Defendants Supplemental Amicus Brief at 7 Docket No. [91]. And later: Mor[e]over, Hawai i's regulation of public carry also does not severely burden, see id., any purported right to publicly carry firearms for self- 2
Case: 12-17808, 11/21/2018, ID: 11096529, DktEntry: 193, Page 7 of 110 defense, because those with a special need to carry for self-defense -- i.e., those who can show "reason to fear injury;" see HRS 134-9 -- have access to concealed carry licenses. Id at 8 fn. 6. Based on Defendants own representations, the Panel reasonably interpreted Hawaii law as a ban on open carry for private citizens. I. The Monthly Reports Are Judicially Noticeable and Evidence of Past Practice. Defendants argue that this Court should not consider the monthly reports Mr. Young submitted with his response because it is non-record evidence. That is ironic because Defendants heavily rely on three declarations that were attached to an amicus brief. Those declarations are not properly before this Court. Unlike those declarations, the monthly reports can be properly considered because they are judicially noticeable. Rule 201 of the Federal Rules of Evidence allows this Court to take judicial notice of facts that can be accurately and readily determined from sources whose accuracy cannot reasonably be questioned. See Rule 201 of the Federal Rules of Evidence. The monthly reports are judicially noticeable because they are official government reports whose accuracy cannot be reasonably questioned. Defendants do not and could not dispute the veracity of these reports. Equity requires these reports be considered, especially at this stage, because the Defendants opened the door to them by introducing extra record evidence. The attached 3
Case: 12-17808, 11/21/2018, ID: 11096529, DktEntry: 193, Page 8 of 110 reports have been submitted to impeach the credibility of Defendants extra record evidence. 2 These reports demonstrate that Hawaii s past practice supports the Panel s interpretation of H.R.S. section 134-9. The monthly reports by each County list the permits as security and citizen. At the end of the year, the authors of the annual report tally up all the security applications in order to produce a number for open carry permits issued and denied and then they tally up all the citizen applications denied producing a concealed carry number. For example, in 2017 the monthly reports submitted by the Counties to the State show 14 citizen applications were 2 Honolulu s position is especially suspect. The Honolulu Police Commission has recently expressed concern that the Honolulu Police Department s ( HPD ) licensing scheme violates the Constitution. In September it requested HPD disclose how it evaluates permits and HPD refuses to do so. Commissioner Sheehan recently said: If we don t have adequate regulations in place, then people s constitutional rights could be violated. T. Langford, Police Commission: Why Is It So Hard To Get A Permit To Carry A Gun In This City? Honolulu Civil Beat, November 2, 2018, https://www.civilbeat.org/2018/11/police-commission-why-is-it-so-hard-toget-a-permit-to-carry-a-gun-in-this-city/ (accessed 11/16/2018). See also El Larson, Police Commission reviewing HPD's policies on letting the public carry guns, September 20th 2018, http://www.kitv.com/story/39131297/honolulu-policecommission-reviewing-hpds-policies-on-letting-the-public-carry-guns (accessed 11/16/2018) ( Commissioner Steven Levinson says Honolulu needs to be ready because he expects more cases to come forward. This is our Hurricane Florence. It is a monster storm. It is out there, and its coming. And it s coming at us and if we do not have a defensible mechanism for passing upon applications for permission to exercise what the United States Supreme Court has now held is a fundamental individual constitutional right we're going to be in big trouble ). 4
Case: 12-17808, 11/21/2018, ID: 11096529, DktEntry: 193, Page 9 of 110 received 3,4. See YoungAdd-127 to 221. The State took this figure to create their annual report which states: Hawaii s county police departments also process license applications for the open and/or concealed carry of firearms in public. Statewide in 2017, 225 employees of private security firms applied for and were issued carry licenses, and there were no denials. A total of 14 private citizens applied for a concealed carry license in 2017, including seven in the City and County of Honolulu, three in Maui County, two in Hawaii County, and two in Kauai County; all applicants were denied by the respective county s police chief. 5 The State s past practice of treating citizen applications as interchangeable with concealed carry applications demonstrates open carry permits have always been reserved for security guards. Defendants falsely claim that the Young Panel established a constitutional rule that will impose strict scrutiny on any public-carry. As a preliminary matter, 3 These reports were obtained via a Uniform Information Practices Act request which is Hawaii s version of the Freedom of Information Act. 4 The Hawaii Firearms Coalition has uploaded all 18 years of monthly reports from the Counties onto their website. A review of those monthly reports along with the publicly available annual reports demonstrates that the past practice of the State of Hawaii has always been to treat citizen carry applications as interchangeable with concealed carry permits. See http://hifico.org/agreports/?fbclid=iwar1uuvuu4zp41azxm-qzzafkvaywdlygbvtpevudxiyfrpj2xr9xcjqpqk (accessed 11/21/2018). 5 See Firearm Registrations in Hawaii, 2017, https://ag.hawaii.gov/cpja/files/2018/05/firearm-registrations-in-hawaii- 2017.pdf at *9. 5
Case: 12-17808, 11/21/2018, ID: 11096529, DktEntry: 193, Page 10 of 110 the Panel did not even apply strict scrutiny. The Young Panel simply applied Circuit precedent which holds that: [a] law that imposes such a severe restriction on the core right of selfdefense that it amounts to a destruction of the [Second Amendment] right, is unconstitutional under any level of scrutiny. Heller, 554 U.S. at 629 (internal quotations omitted). By contrast, if a challenged law does not implicate a core Second Amendment right, or does not place a substantial burden on the Second Amendment right, we may apply intermediate scrutiny. See, e.g., [United States v. ]Chovan, 735 F.3d at 1138-39; cf. Heller v. District of Columbia (Heller II), 670 F.3d 1244, 1257, 399 U.S. App. D.C. 314 (D.C. Cir. 2011) ( [A] regulation that imposes a substantial burden upon the core right of self-defense protected by the Second Amendment must have a strong justification, whereas a regulation that imposes a less substantial burden should be proportionately easier to justify. ). See Jackson v. City & County of San Francisco, 746 F.3d 953, 961, 2014 U.S. App. LEXIS 5498, *14, 2014 WL 1193434. Abiding by Circuit precedent, the Young Panel applied a categorical approach because both State law and the County of Hawaii s implementation of State law result in a destruction of the Second Amendment right. Further, the hyperbolic statement that somehow the Ninth Circuit just established a constitutional rule that will impose strict scrutiny on any public carry law that Hawaii or California or Oregon or any other State enacts in the future[] is absurd and farcical. See Reply, p. 8. As stated previously, no such pronouncement was made. Secondly, the suggestion that states in other Circuits could somehow be bound by the Panel s Opinion is a complete fabrication. It is well-settled law that: 6
Case: 12-17808, 11/21/2018, ID: 11096529, DktEntry: 193, Page 11 of 110 an opinion of [this] court is binding within [the Ninth] circuit, not elsewhere in the country. The courts of appeals, and even the lower courts of other circuits, may decline to follow the rule we announce-- and often do. This ability to develop different interpretations of the law among the circuits is considered a strength of our system. It allows experimentation with different approaches to the same legal problem, so that when the Supreme Court eventually reviews the issue it has the benefit of percolation within the lower courts. Hart v. Massanari, 266 F.3d 1155, 1172-73 (9th Cir. 2001). Despite Defendants categorically false misreading of the Panel s Opinion, this Court is still free to apply intermediate scrutiny to carry restrictions which do not impose a substantial burden on the right to self-defense. II. Gloucester is Inapplicable to the Current Situation. Defendants claim that Courts often vacate and remand opinions in light of formal interpretations rendered by executive agencies. However, the only case Defendants cite to support that proposition is completely inapposite to Mr. Young s case. In Gloucester Cty. Sch. Bd. v. G.G. exrel. Grimm, 137 S. Ct. 1239 (2017), the Fourth Circuit was acting on a guidance document to resolve an ambiguity in the law. The Fourth Circuit stated: [W]e conclude that the Department's interpretation of its own regulation, 106.33, as it relates to restroom access by transgender individuals, is entitled to Auer deference and is to be accorded controlling weight in this case. We reverse the district court's contrary conclusion and its resultant dismissal of G.G.'s Title IX claim. See G. G. v. Gloucester Cnty. Sch. Bd., 822 F.3d 709, 722-723, 2016 U.S. App. LEXIS 7026, *27-28. 7
Case: 12-17808, 11/21/2018, ID: 11096529, DktEntry: 193, Page 12 of 110 Subsequently, the guidance document was withdrawn and the basis for the Fourth Circuit s decision was nullified. For that reason, the Supreme Court remanded the case to the Fourth Circuit for panel reconsideration. But in Mr. Young s case, there was no ambiguity, nor did Mr. Young s Panel rely on any guidance document. The law is clear on who is entitled to an open carry license in Hawaii: security guards, i.e. persons protecting life and property. The Attorney General s belated opinion is just a new and convenient litigation position. Defendants attempt to interpret state law in a manner inconsistent with the express wording of the statute and their prior representations to this Court and the County s implementation of the statute should be ignored. Even if section 134-9 were vague, G.G. v. Gloucester does not support remand to the trial court. In G.G. v. Gloucester, the Supreme Court remanded the case back to the Fourth Circuit to give the panel an opportunity to reconsider the case in light of the new guidelines. At best, G.G. v. Gloucester supports panel rehearing which Defendants conspicuously have not requested. Conclusion Defendants Petition is a concession that Hawaii law cannot be justified. Rather than ask for rehearing en banc based upon Hawaii s actual implementation of its laws, Defendants have gone to great lengths to create a fantasy where all three judges on Mr. Young s Panel misread Hawaii law. There is absolutely no reason for 8
Case: 12-17808, 11/21/2018, ID: 11096529, DktEntry: 193, Page 13 of 110 this Court rehear Mr. Young s appeal based on a post-hoc fiction. Defendants Petition should be denied. Respectfully submitted, this the 21st day of November, 2018. s/ Alan Beck ALAN BECK (HI Bar No. 9145) Attorney at Law 2692 Harcourt Drive San Diego, California 92123 Telephone: (619) 905-9105 Email: alan.alexander.beck@gmail.com s/ Stephen D. Stamboulieh STEPHEN D. STAMBOULIEH Stamboulieh Law, PLLC P.O. Box 4008 Madison, MS 39130 Telephone: (601) 852-3440 Email: stephen@sdslaw.us 9
Case: 12-17808, 11/21/2018, ID: 11096529, DktEntry: 193, Page 14 of 110 CERTIFICATE OF COMPLIANCE 1. This brief complies with the type-volume limitations of Fed. R. App. P. 5(c)(1) and 32(c)(2) because, excluding the parts of the document exempted by Fed. R. App. P. 5(c) and 32(f), it contains 2,104 words. 2. This brief complies with the typeface requirements of Fed. R. App. P.32(a)(5) and the type-style requirements of Fed. R. App. P. 32(a)(6) because it has been prepared in a proportionally spaced typeface using Microsoft Word 365 in 14-point Times New Roman. /s/ Alan Alexander Beck Alan Alexander Beck 10
Case: 12-17808, 11/21/2018, ID: 11096529, DktEntry: 193, Page 15 of 110 CERTIFICATE OF SERVICE I hereby certify that on November 21st, 2018, I filed the foregoing Sur-Reply in Opposition of Petition for Rehearing En Banc with the Clerk of the Court for the United States Court of Appeals for the Ninth Circuit by using the appellate CM/ECF system. I certify that all participants in the case are registered CM/ECF users and that service will be accomplished by the appellate CM/ECF system. /s/ Alan Alexander Beck Alan Alexander Beck 11
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