NARSOL’s ex post facto case clears hurdle, proceeds to discovery

By Robin . . . On January 23, 2017, the National Association for Rational Sexual Offense Laws (NARSOL) and its affiliate in North Carolina (NCRSOL), along with two John Doe plaintiffs, filed an 88-page complaint in the U.S. Federal Court for the Middle District of North Carolina. The complaint alleged various constitutional claims concerning Article 27A (sex offender registry scheme) of the N.C. General Statutes. The case (NARSOL v. Stein) was assigned to Judge Loretta Copeland Biggs, who presided at a hearing on April 16, 2018, to consider the state’s motion to dismiss the complaint.

On May 30, 2018, Judge Biggs ordered the plaintiffs to submit a more definite statement clearly identifying the factual allegations that support each claim for relief, the specific statutory provision(s) of which plaintiffs complain, and the specific claim(s) alleged against each defendant named in the complaint.

In response, on July 6, 2018, plaintiffs’ attorney removed certain allegations of constitutional harm contained in the original complaint and filed them as a new case in the Federal District Court for the Middle District of North Carolina. That case (styled NCRSOL v. Stein) is currently before Judge William Lindsay Osteen, Jr.

On the same day, plaintiffs’ attorney filed an amended complaint that left in place all the underlying facts and legal arguments presented as Ex Post Facto claims in the original complaint.

Then we heard birds chirping by day and crickets chirping by night for more than a year. From time to time, someone would send an email or post a comment inquiring about the status of the North Carolina cases. The state got so bored it replaced its attorney. There was much wringing of hands and chattering of teeth.

Finally, on July 30, 2019, we got some long awaited and positively good news. The state’s motion to dismiss was denied. So now the hard work begins. The case moves into the discovery phase in preparation for trial.

The state’s motion to dismiss relied, as expected, primarily upon some important procedural rules included in the Federal Rules of Civil Procedure (FRCP), specifically Rule 12(b)(1), Rule 12(b)(2), and Rule 12(b)(6). So what are these rules?

Yes, this is going to sound a lot like legal mumbo jumbo. If this frustrates you, then stop reading right here! You’ve been fairly warned.

Rule 12(b)(1) states that a defendant may move a federal court to dismiss a plaintiff’s claim on the basis that the court lacks subject matter jurisdiction. In other words, the court can’t really “hear” the claim because it doesn’t have any authority over the matter being presented for consideration. This is where you may have heard it said that a plaintiff lacks standing to sue.

It is under Rule 12(b)(1) where attorneys representing the state usually include an Eleventh Amendment defense, as well. It normally comes in several forms ranging from, “The federal courts should defer to the state’s understanding of its own regulatory laws,” to, “The federal courts should not intervene in a legal dispute where there has been no fair adjudication of the matter by state-level courts,” to “The state’s statute of limitations precludes a federal court from considering a legal challenge that exceeds the time bar imposed by state law.” In most of these cases, the federal courts will often agree. But, when it comes to claims against state laws that are alleged to be unconstitutional, federal courts are duty bound to consider a challenge which alleges an ongoing violation of federal law.

Rule 12(b)(2) states that a defendant may move a federal court to dismiss a plaintiff’s claim on the basis that the court lacks personal jurisdiction. In other words, no matter what the claim is and no matter whether the court could actually “hear” the claim, the court doesn’t have any authority to enforce a judgment against the people who are named as defendants in the lawsuit. Sometimes you will hear this spoken about as immunity.

Rule 12(b)(6) states that a defendant may move a federal court to dismiss a plaintiff’s claim on the basis that the plaintiff has not presented a claim upon which relief can be granted. This rule is the kitchen sink of federal procedural rules. There are really two practical parts to it. When using Rule 12(b)(6), a defendant is trying to say one of two things, and sometimes both. The defendant is either saying that the plaintiff has not made what’s called a “cognizable claim” or that the plaintiff has not articulated any facts that support the “cognizable claim.” But, most of the time, the defendant is saying both. It’s laws and facts. And both are necessary to withstand a motion to dismiss under this procedural rule.

So what is a “cognizable claim”? A cognizable claim is one that meets the basic criteria of viability for being tried or adjudicated before a federal court and is also within the power or jurisdiction of the court to adjudicate. Simply put, your complaint has to present a claim that the court has the constitutional authority to “hear.”

What are articulated facts? These are really the most important things to demonstrate, and they are also what are most lacking, many times, in efforts to bring serious constitutional claims on behalf of the registered population. Put simply, it is not enough to say, “This is unfair,” or, “I feel bad,” or, “I don’t understand how they could do this,” because these are not articulated facts of anything. They are merely conjectural statements about feelings.

An articulated (well stated) fact looks something like this:

Plaintiff, a registered sex offender, states that he had a well-paying job with full medical benefits while working for his former employer. The state then passed a law restricting anyone on the sex offender registry from working within 300 feet of any facility where children are schooled, instructed, or cared for. As a consequence, plaintiff lost his job and his medical insurance. He is now unemployed and recently discovered he suffers from hypertension. But for the effects caused by the state’s new law, plaintiff would still have lucrative employment and the necessary insurance to seek the medical care he needs.

There’s nothing there about feelings or fairness or conjectural harm. The harm is real, the causation is obvious, and the facts are “articulated.”

You probably expected that I might spend more time explaining the state’s motion to dismiss in the NARSOL v. Stein case and walk you through the reasons why the Court saw fit to deny it. But instead, I’ve decided to write something a bit more instructional as a guide to assist you in reading through the Court’s decision to deny the state’s motion. You will understand the process—and the Court’s reasoning—a lot better if you take the time to read Judge Biggs’ Memorandum Opinion and Order.

Otherwise, the good news is that the NARSOL v. Stein case will now move forward into the most critical phase of its development, discovery. This is where we will have an opportunity to further develop the facts, provide additional statistical support, interview possible witnesses (including expert witnesses), and frustrate the state’s efforts at preparing for battle. It should be great fun!

And thank you for your patience! “The night may seem long, but it is the part of fidelity to watch and wait for the morning” (Jeff Davis, 1866).

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Robin Vander Wall

As vice chair of NARSOL, Robin is the managing editor of the Digest, director of development, and provides assistance to the webmaster in keeping our websites running smoothly. He also serves as founder and president of Vivante Espero, NARSOL's 501(c)(3) foundation and legal fund.

This topic contains 23 replies, has 2 voices, and was last updated by Avatar Warrior 1 month, 1 week ago.

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  • #58773 Reply
    Robin Vander Wall
    Robin Vander Wall
    Admin

    By Robin . . . On January 23, 2017, the National Association for Rational Sexual Offense Laws (NARSOL) and its affiliate in North Carolina (NCRSOL), a
    [See the full post at: NARSOL’s ex post facto case clears hurdle, proceeds to discovery]

  • #58777 Reply
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    John

    Incredible work by your lawyers Robin. I’m assuming Paul Dubbeling is behind this case, and I have to thank both of you extensively for pursuing and publishing litigation like this, both past and present. It’s helping further arm me with support in my own preparations to file in federal court here in D.C. People can get drowned so easily by the hurdles and numerous traps of the system, and despite actual injustice…not been able to proceed because the judge’s hands get tied! It’s time the country accepts the 10 years of challenges the district courts have ruled on. That BJS report the other month clearly shows when looked at more critically that Smith v Doe 2003’s justifications in regards to public safety interests are so not merited at the cost they come at.

    I am so grateful for discovering Narsol last month. As I work with organizations who are considering the merits of my civil claims, please keep me in your thoughts and prayers.

  • #58779 Reply
    Avatar
    TS

    @Robin

    Well Done! I learned something here which is always a plus. Though, it is an interesting the quote you used from the person who was quoted and where from all things considered of then and now. Onward and upward with both of these!

  • #58780 Reply
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    Tim

    I’d be interested in the history of rule 12b,1-6.
    It seems to me once Congress embraced the words, “a person who was in prison for a crime” in writing an Act\ bill a ” cognizant claim ” always exists once the Act is implemented and promulgated upon those already convicted.

    IMO, many of the constitutional infringements have been redefined by Congress as exception to the rule because it is former prosecutors who’ve been elected to congressional office. Simply put, the rules of engagement have been altered in the favor of the prosecution. This helps explain wrongful convictions and DNA exoneration numbers that exist in the U.S.
    This notion also helps to explain why folks plead guilty to \for crimes, or admit guilt for crimes they know darn well they didn’t commit.

    At any rate I’d also be interested in the discovery sought by plaintiffs to help make the case. Good luck.

  • #58782 Reply
    Avatar
    Tim

    NARSOL,
    I’ve long thought the very minute sexual oriented offenders were sold out to big data, for political security, the rest of the nation soon followed. Let’s call it equal unprotection, from the databases, public and private. Many registrants complain about ban from FB, while I believe a kindness was done by it.

    I’m thinking a deep dive in discovery here in Stein V should be all out effort to bring the in heart of the issue to light. The Electronic Frontier Foundation (eff.org) has a nice position piece describing CPB agents use of social media surveillance poses risks…to free speech and privacy rights data for collection and retention. The PIA ( Privacy Impact Assesment). DHS is also part of this picture. A focus on this issue runs complementary to the case here. Kentucky V Padilla. I would hope Robin has time to review the article at eff, and discuss it with attorneys.

    That the sex offender and the gov database are inextricably linked is not my doing, that culpability rests squarely in OMNIBUS et. al. and leadership’s choices.

  • #58796 Reply
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    Connie

    Thank you to all those who are fighting against this harmful and unjust punishment called a registry.
    The public is brainwashed into thinking it is a protection against dangerous sex offenders and they have no idea what it really does and who is actually punished by it.
    You who are able to legally fight give me hope that someday the laws will be changed in a good way.
    I wish we had money to fight my husband’s case. We would win and he would be removed if states had to apply only the law at time of offense or time of guilty plea, instead of purposely withholding his sentencing till the law changed to a stricter, twice as long, registry time. Also, if I read the National SOR law correctly, someone who wore shorts without underwear and visually offended 2 adult women, would not even be required to be on the registry; especially not for 20 years of his life! We have 5 more years of punishment to suffer.

    • #58815 Reply
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      d

      They would arrest a man if he was offended by a woman in shorts with no underwear. Let me get this right sir you were looking up her shorts? This would be followed by Miranda rights reading.

    • #58837 Reply
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      Dustin

      Connie,

      It’s not in the statutes, but I did run across a Georgia Supreme Court case that held that the applicable law is what was in effect at the time of offense, not sentencing. Of course, it’s always overlooked. And we all know that most courts will overlook anything in a registrant’s favor, anyway.

      Not certain about other states, but willing to bet some of them have similar precedents.

      • #58845 Reply
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        d

        This is well-known law a good lawyer could appeal and win easily if the law at the time of the alleged offense did not cover the conduct then you did not break the law. If you took a plea deal however you will not get to appeal and will have to seek post-conviction relief because of ineffective assistance of counsel. If your lawyer did not try this argument they were corrupt or stupid.

    • #58900 Reply
      Avatar
      Sex Offender Truth

      You are correct – the public is “brainwashed” and that is deliberate and coordinated with lies told by politicians and law enforcement. There are a number of reasons why American leaders wanted/needed/created this second class citizen AKA “registered sex offender” and they are numerous and all despicable evil by design.

      I will not go into them at length here – I have created an entire website for that – SexOffenderTruth *(type that into google for address) which is a site that explains exactly what the registry is and what its true function is (not to protect children)! Check out my informational site for details and answers to the question of why the sex offender registry exists and continues to grow despite having been proven useless and even counterproductive in stopping child abuse!

      I am mad as hell and I am NOT going to take it anymore!

  • #58798 Reply
    Avatar
    tom

    There are 2 things that perplex me about registry laws, or more specifically, the Smith v. Doe ruling. The ruling was based on fraudulent reasoning, using information, (not even data), that was an outright lie. There was, and still is no data to support “a higher risk of recidivism’. Every member of the current court MUST be aware of this. Knowing that a ruling was based on fraud, on the part of Justice Dept. attorneys, why has it not been examined. Any conviction in this country, if it was found to be based on fraud, lies, or misconduct WOULD be overturned.
    Secondly, why has the issue of Bill of Attainder never been used ? Clearly, registry laws are an act of a legislature declaring a person or group of persons guilty of some crime and punishing them, often without a trial. As with attainder resulting from the normal judicial process, the effect of such a bill is to nullify the targeted person’s civil rights, most notably the right to own property, etc. Unless ALL criminal convictions were given a ‘registry’, I fail to see how a registry IN ANY FORM would not be a Bill of Attainder for sex offenders.

    • #58828 Reply
      Avatar
      Tim

      @Tom,
      Precisely because it was really (collateralized) about gov USE of a registry (database) or data use ( unfettered & unconstitutional). SOR was sold as strictly a ” states domain ” when I fact the feds had much to gain as well. One must consider the source of Byrne Grants. The other uses play out just under the surface. Still a greater risk may lay elsewhere. Once speech was proven abridg-ed too far in NC V PACKINGHAM: effect implicated initial intent behind ” was in prison for… ” in weighing congressional language choice review.

      The big lie, but the die caste. Sexual assault can not be remedied by data nor database. Never could, but it made a benevolent attempt, some say. Plain indenture man to machine database that works anti-social liberty. Such an unnatural imbalance in human disposition would necessarily need tending in a republic of free men women and children. The sexual oriented offender was the first to have their sovereignty sold out to big data. The kids came later.

      What’s nuts is some nations whoop our average kid in math and science starting theirs out with a mastery of the simple abacus. We give them Ipads, yuck!
      Thx to Mrs. Arens for insisting on those fifty spiral notebooks for Alg1-4.

  • #58799 Reply
    Timothy D.
    Tim Davich

    Great job to all that have taken part. Time to piss on their party. It will be nice to see the results, this is a well written article and case hats off to the legal team.

  • #58800 Reply
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    Mike Hall

    Great work and dedication to the fight, Robin and Paul….As I read Judge Biggs’ Ruling, I had a nice BIG smile each time I saw the word DENIED in print! Thanks for all you and others do to further our cause and goals.

  • #58809 Reply
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    CP@TX

    Absolutely great work done here 👍. If this case makes it to SCOTUS, it may be the one to finally break the SOR’s back. However, as a TX registrant, I believe that there should be the same attack on this state’s SOR as well. I have attempted to contact the ACLU of TX to request this be done but to no avail. This organization is not up to the task. If I had a copy of the suit filed by NARSOL in this case, I would make the necessary modifications to outfit it for TX and file it in federal court. In my opinion, TX is the “Megaladon” of SOR states and if you can kill this state’s SOR you are looking at a domino affect.

    • #58813 Reply
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      Mr.P

      Alabama is worse than Texas!!

  • #58812 Reply
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    Mr.P

    Great work..Thank you NARSOL and everyone who works there, donates their time and resources! Thank you to everyone who donates their money!!
    When is someone going to research/investigate the RSO laws for Alabama. I know this could present a challenge due do the (alleged) corruption that permeates the judicial system. The chance you (out of their system lawyers) take (Being set-up and caught with drugs packaged for distribution and subsequently sent to prison) when you become a plaintiff against the state/county/local judicial systems. This tactic (allegedly) is used to have any GOOD out of town/system Plaintiff lawyers to drop the case or turn it over to a local lawyer who are (allegedly) conspiring with the authorities. When this happens you cannot expect any lawyer to continue to pursue justice. There are many people who have been forced into coerced confessions when the state/county (allegedly)use this tactic!! Your future becomes either you take the deal they offer or do 30 years!! They tell you they will tell everyone in the prison you are a quote “kiddie raper” unquote.. what would you do??
    When a person accused of being a sex offender is arrested the authorities use every piece/type/mode of communication, news paper, television, penny shopper, radio stations, anything, possible to spread your name and picture to make sure everyone that could possibly be chosen for a jury knows you have been arrested! They give intimate details of your alleged crime, and use the term “many other allegations” to poison the jury pool. We have no channel for justice, we suffer job loss, insurance loss, public humiliation, restrictions, inspections with numerous law enforcement vehicles, public notices, etc. to do as much damage to every individual, spouse, and child. No one will stand up to this type of corruption for fear of long term jail sentences! A meth, crack, cocaine, or heroin dealer gets long jail terms when you go against them..lawyers know this and run away, we are left to the whims of corruption!!

    WHAT CAN DO WE DO??!!

    • #58820 Reply
      Avatar
      Tim

      Mr. P,
      Well for sure we can see the limits of federal judicial power in the State of Michigan’s disposition. First the ruling, then Mandamus and while I’ve view MI legislature page on bills, none have yet been made law. Still some time left though. The question better asked is whether it is unpopularity – or something ( group) else? I suspect it is the latter.

      SOR is viewed as an entitlement. ‘We have the right to know.’ Yet I’ll be damned if I’ve ever read that clause in the constitution. Similar the the re-deprivation hearing fanaticism in Conn. DPS: 538US1, such inclinations are pure fantasy. A few of us were not at all similarly situated to that bonehead.
      Clearly that baseless test case was selected purposefully to fit an Agenda.

      Can citizens tell their home state bureaucrats ‘No’ when it involves personal sovereignty conflicts? Yes! May they, NO!
      in Masterpiece Bake shop 584US__ it took the Supreme court ruling to determine if a man could tell a regulatory agency supporting a couple of flakes to go elsewhere for their darn {wedding} cake! The couple could have purchased 10,000 wedding cakes for the same cash spent on a federal review. How far freedom has fallen when it takes a highest court to hold that basic right-to say ” no” to gov agents. All registrants and citizens can relate to that dilemma.

  • #58824 Reply
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    Teresa Waters

    I just submitted my appellate brief to the 5th Circuit Court of Appeals, New Orleans, LA.
    Case No. 19-20414 Waters vs. Tx Atty General, et al
    It is on appeal from the US District Court- Southern District of Texas- Houston Division

    The case and my brief is worth reading and noting that the issues brought up have never been addressed or adjudicated.
    This is a unique challenge to the way Texas applies the Adam Walsh Act. Your attorneys should seriously look into these issues.

    The district court ruled that the state defendants had no immunity under Ex parte Young and requested I amend to specify what constitutional rights were affected. I stated 5th, 6th and 14th.

    Texas response was that “sex offenders are not a protected class under the 14th amendment” and it was dismissed for failure to state a claim. But on appeal I questioned whether Texas can apply state law that provides my crime was violent and it was placed in Tier III when the AWA states it is non violent Tier I.

    Texas groups the act of touching with penetration and does not differentiate between them and declares touching is Aggravated Sexual Assault and places it in the category of a violent crime. The fact that there was no penetration does not come into play at all under this statute. It goes by age only. It is the Texas version of Statutory Rape.

    Therefore, Texas falsely applies Texas law instead of federal law and places everyone in Tier III. The Texas aggravated sexual assault is not equivelant to the AWA federal definition and statutes for aggravated assault.

    Under 42 U.S.C. 16911 et seq. (Adam Walsh Act) and the Sex Offender Registration and Notification Act (SORNA) states are directed to compare state elements to AWA federal elements to be “substantially similar” not in name or title only, but that the state elements be comparable or more severe than the federal elements.

    They are unconstitutionally applying state law in violation of federal consitutional law when the two are not similar and the elements just don’t match at all, and they aren’t even remotely similar.

    Defendants erroneously relied upon their definition of aggravated sexual assault and sexual violence according to the Texas statutes (ROA.133) but are bound by the definitions and elements set forth in the AWA. Richard v. Missouri Dept. of Corrections, 162 S.W.3d 35, 37 (Mo. Ct. App. W.D. 2005) (―The interpretation of a statute is a question of law.)
    This could be a class action suit for everyone convicted under this statute…You should file an amicus brief.

    • #58969 Reply
      Avatar
      Tim

      @Theresa,
      WI makes the same non-distinction and I like your cases use of the supremacy clause to challenge TX interpretation of ” volence.” Human touch is a basic human right and outlawing touch is very dangerous ground. The low standard was brought about in the 1968 OMNIBUS. The evangelical conservatives of the day insisted on defusing notions of rape. Rape being absolutely provable given the female child’s virginity was intact. So while those convicted of 1-4th ° aggrevated sexual assault of a child under X age have not traditionally ” raped by penetration ” ( the verifiable) but rather the unproven and indefensible ” mindful sexual intent in the touch for arousal or gratification.”

    • #59163 Reply
      Avatar
      James

      Texas here, having similar issues where there is no contact and no real person, AWA says tier 2 and Texass say tier 3. There is an attorney in Austin who recently filed suit against DPS for purposely not complying with the statute in making the state vs federal comparisons correctly and refusing to correct in order that DPS can keep as many people on the registry as possible. I am holding off filling suit until I see the results of this case against DPS.

  • #58825 Reply
    Avatar
    Saddles

    Are we are all guilty in absentia or does one thing lead to another One wonder do we all reap what we sow or who actually pulls the trigger. Going to court is not a piece of cake. At times I wish I had a sixth grade education but we all know our actions. I wonder why my dad had two or three volumes of Abrham Linclom in his bookcase when I was growing up. Yes he was a lawyer before becoming President.

    Whill the old saying is forgiveness is bless, in todays courtroom its a challenge of the minds and the true rhyme and reason seems to be cluttered up in some government scandle or conspircy encounter for public safety. I guess its time to round up everyone that had a dirty thought or looked at a woman incorrectly and do a background check on all. One wonders where Principal comes into play or if it does in this nation today.

    You come to our country your gonna act and do by our rules. I’m sure law enforcement and governents are proud of themselves. Even this judge thats hearing the plainiff review makes more sence than some. Sure discovery is the process for many to understand but how does one discovery themself or is humanity and character suppose to be the same for all or should we all hope this game changes for the better in this discrimintory game. I guess an apology is not acceptable when government does a racist act on another or discriminates or do we all still have open minds today to staple or label the value of human beings.

    We can all learn something if we listen and open our eyes. I have learned a lot on here from Robin and others and that is good. This sex offender issue harms more than it prevents. Sure touching a little girl can be an issue for some, even rape, also the enticement or who trespasses against another. Labeling is a steriotype and can be a game changer that bars others from activitries even seperation from families.I believe the statement speech is proper to say ” I am mad as hell and I’m not gonna take it” I believe the movie was Newtwork.

  • #58826 Reply
    Avatar
    Jim

    The USA court system loves to make laws that are against our rights. They enjoy the billions of dollars and mundane court appearances the people and their attorneys spend trying to restore their rights that are so easily taken. The legal system in the USA is a multibillion dollar system that dwarfs any other legal system on the planet. There are more people in the “legal system and prison” in the USA than all other countries in the world combined. This is the true reality of the fight everyone in the USA faces everyday. FREEDOM????? Really?? So sad

  • #58884 Reply
    Avatar
    Saddles

    Robin you said’ now comes the discovery part and yes the discovery part can be an opportunity to prove, to also find out the mysteries of why, such as a gambler using loaded dice or why someone plays on the mind via an internet encounter. Even the discovery of intent to comit or inflict mental harm.

    Personally the discovery stage is fascinating. Sure they will tell you that they are doing this for internet safety percaution but the why is the reason for these internet things. Truth be known these are all Satan based. Even discovering their method of operation can be a game changer such as inducing these ordeals on adult sites instead of kids sites.

    Conning is a big factor when one ask why they would want you to come down their and meet. “To have some fun”, “hang out” or get naughty”. Who is playing the happy hooker in this death sentence. Discovery could mean the guide or person that lead’s the one in this folly. Right is right and wrong is wrong or should we all error and stumble today by another man’s tresspass. Yes it takes discernment to understand this. Do we all have wisdom to know the difference.

    And yes discovery could also mean how many people caught up in this action have died, More people are killed in car wreaks do they pose a threat to publc safety which is debatable. One wonders who discovers wisdom today in these callous internet provokings. One wonders who is respectring who with this vigilantism of a callous nature.

  • #58913 Reply
    Avatar
    Warrior

    Good job NARSOL
    We must unite to stop this insane police and government take over of our rights ,
    especially the false label attached for life that we are a danger to society.
    We did our legal time for punishment, yet they continue to punish us forever, giving us NO future and destroying families, which is their plan to fill up the jails/prisons and employ more police etc, we know there is lots of money made on Sex Offenders, mostly on the poor and minority who cannot fight back.
    ‘The battle must continue with NARSOL help to give us our rights back”

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