COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF
Plaintiffs New York State Rifle & Pistol Association, Inc., Robert Nash, and Brandon Koch (collectively “Plaintiffs”), by and through the undersigned attorneys, file this Complaint against the above-captioned Defendants, in their official capacities as state and local officials responsible under New York law for administering and enforcing the State’s laws and regulations governing the carrying of firearms outside the home. Plaintiffs seek a declaration that New York’s limitations of and burdens on the right to carry firearms as enacted in Senate Bill 51001 (“SB51001”) and as otherwise detailed below are unconstitutional under the First, Second, Fourth, and Fourteenth Amendments to the United States Constitution. Plaintiffs also seek an injunction compelling Defendants to refrain from enforcing those invalid limitations