Knight v. DSHS, Administrative Procedure, Appeal to King County Superior Court, No. 03-2-27325-2 SEA, Appeal to Court of Appeals, No. 54129-3-I, Petition to Supreme Court of Washington, No. 77063-8 Web Page
We WON Court of Appeals No. 58250-0!! Reported at 142 Wash. App. 291, 174 P. 3d 1198. Further details at the bottom of Writ of Prohibition Against Contempt Prosecution web page!
Some Practical Advice for Support Contemnors in the State of Washington.
A Way to Walk a Mile in a Noncustodial Parent's Moccasins.
Please check out the litigation listed toward the bottom of the web page Knight v. State Writ of Prohibition Against Contempt Prosecution where I was forced to file a Motion to Modify Commissioner's Decision citing Antipeonage Act because the State of Washington imposed a court order that is a direct violation of the Antipeonage Act, requiring me to maintain at least 30 hours of work per week or make 3 job contacts. Therefore, I display my Brief of Appellant because this is an issue of extreme public importance for which the public should be aware.
My latest Reply Brief of Appellant provides the answers to California's Moss v. Superior Court, the Ninth Circuit's Ballek, and Hawaii's new Child Support Enforcement Agency v. Doe, No. 24457, (Hawaii, December 27, 2005) 109 Hawaii 240, 125 P. 3d. 461, each an obscenity against the Rule of Law.
Petition for Writ of Certiorari to the United States Supreme Court is considered filed as of the date I mailed it, August 8, 2007, within 90 days of June 6, 2007. It is docketed as No. 07-184.
One analogy to illustrate the absurdity of the proposition that choice of employer avoids finding of involuntary servitude is with Washington's Death Penalty statute, RCW 10.95.180(1) grants the condemned a choice: lethal injection or hanging. No one seriously argues that merely because the condemned has a choice in his demise, there is no death penalty. However, California's Moss v. Superior Court, the Ninth Circuit's Ballek, and Hawaii's Doe uses this precise logic: if the peon has a choice of employer, there is no involuntary servitude!
Patently absurd, of course!
C Level Enterprises is to be commended for their courage, unlike Borders, in distributing father Kevin Thompson's book, "Exposing the Corruption in the Massachusetts Family Courts" in the face of Judge Mary McCauley Manzi's court order prohibiting its distribution. More on this at the Massachusetts Enemies of Freedom webpage. FathersUnite.org has a link to this page.
Restraining order overturned on appeal. Book is now available at Lulu.
We now have the Antipeonage Act Website Forum, please click the "Enter my Forum" banner!
Here are some free places where you can find published opinions:
Ninth Circuit Opinions in pdf since 1995
Municipal Research and Services Center Search Page for Supreme Court of Washington and Court of Appeals of Washington published opinions.
Adobe website.
for those who need a reader for pdf files.
Lianne Malloy, Assistant Attorney General, to her credit, sent me copies of the Petition for Review and the State's Answer to Petition for Review in Amunrud v. DSHS, Supreme Court of Washington No. 76590-1 at my request as a courtesy. I scanned them in and they are now available here as pdf files:
Petition of Greg Amunrud for Review pdf 152 kb
State's Answer to Petition for Review pdf 295 kb
Robert Stevenson, Greg Amunrud's attorney, filed the Petition for Review on or about January 10, 2005. It is a request for review of Amunrud v. Dep't of Social & Health Services, (2004) 124 Wash. App. 884, 103 P. 3d. 257. The review was granted on September 7, 2005. Oral argument was heard on November 9, 2005. TVW Docket and its video of this oral argument.
That two months! No one told me about these developments. More on this case below. My pleadings in my challenge to the WorkFirst Act through the administrative hearing process are listed herein below:
This is the Web Page upon which I list the internal links to the briefs in the administrative procedure commenced on March 11, 2003 when the King County Sheriff's Department served me with paperwork that should have been properly served before the illegal license suspension performed in September 2001. They got me! Now will they wish they hadn't? After all, maybe the Salem Court would not want a REAL witch on their hands!
Request for Adjudicative Hearing
We had the adjudicative hearing on April 16, 2003, the decision is the Final Order in No. 03-2003-C-1839. Adobe Acrobat pdf file.
So it's off to King County Superior Court in Knight v. State of Washington, Department of Social and Health Services, No. 03-2-27325-2 SEA. After getting the case assigned to Judge Richard Jones, I filed the Amended Petition for Judicial Review of Agency Decision, Chapter 34.05 RCW.
Motion for Leave to File Overlong Brief
Exhibit A to Knight Declaration
DSHS's Memo in Opposition to Motion to Restore His License and to File Overlong Brief pdf file 288 kb
Reply to DSHS's Memo in Opposition to Motion to Restore License and to File Overlong Brief
Declaration of Roger W. Knight in Support of Petitioner's Reply Brief on Motions
Judge Richard Jones' Order Denying Restoration of License and Overlong Brief Adobe Acrobat pdf file.
State's Trial Brief Adobe Acrobat pdf file 378 kb. Excerpt from its Exhibit A pdf file
On March 19, 2004 Judge Richard A. Jones heard our oral argument. Much of what I said is summed up in my letter to Mayor Greg Nickels of Seattle. Judge Jones, a younger brother of the musician Quincy Jones, yes THAT Quincy Jones, found that 1) he was barred by res judicata and collateral estoppel by the findings in the two federal cases, Knight v. Mercer Island and Knight v. Serpas. Never mind that these federal courts also found that they had to abstain under Younger abstention doctrine and lacked jurisdiction under Rooker-Feldman. Like the federal courts, Judge Jones decided to have it both ways, after finding that he lacked jurisdiction (collateral estoppel and res judicata are jurisdictional arguments as well as equitable principles) he then found that none of my constitutional and other arguments were valid.
Judge Richard Jones' Order Affirming Administrative Decision Adobe Acrobat pdf file.
I have appealed, Washington Court of Appeals No. 54129-3-I. In the meantime, I suggest a boycott of Quincy Jones music. Perhaps we can ask Quincy Jones if he helped pay for his brother's law school education so he can be a shill for a tyrannical power structure.
And now, my Brief of Appellant citing the new City of Redmond v Moore (June 3, 2004) 151 Wash. 2d. 664, 91 P. 3d. 875 decision!!!!
The Clerk of the Court of Appeals wrote a letter and hearing notice as to the nature of the appeal.
My Appellant's Response to Hearing Notice of Court Concerning Review as a Matter of Right
The State agrees with me as to the nature of the appeal, pdf,
and the Court of Appeals so found, jpeg, It is an appeal as of right.
State Repondents' Brief. Adobe Acrobat pdf file 523 kb The original is 8.5 by 11 inches, I used the cropping tool to chop 1.5 inches off the left, 1.0 inch off the right, and 1.0 inch off the top to conserve bandwidth and to have mercy on the 56k modem users.
Redmond v. Moore inspired me to file a Motion on the Merits to Reverse instead of a reply brief.
There was another case then pending before the Court of Appeals brought by a noncustodial parent whose license was suspended for child support where Redmond v. Moore was brought up, at least at oral argument. Amunrud v. DSHS, Court of Appeals No. 52910-2 before Division One. Mr. Amunrud's attorney is Robert Harold Stevenson, WSBA No. 519. Admitted to practice in 1951. We could affectionately call him the "Ancient Solicitor". Thank you, Robert, for doing this for us!
The Court of Appeals entered an order in my case staying decision pending outcome of Amunrud v DSHS.
Comment on the OBSCENE UN-AMERICAN Amunrud v. Dep't of Social & Health Services, (2004) 124 Wash. App. 884, 103 P. 3d. 257 decision by the Court of Appeals on December 27, 2004 by Judges William Wayne Baker, Faye Collier Kennedy, and Mary Kay Becker.
Based on this Amunrud decision, the State's Motion on the Merits. pdf
And my Response to State's Motion on the Merits
And on March 21, 2005 the Court of Appeals entered its decision against me.
Next stop, the Supreme Court of Washington. My Petition for Review.
The State filed their Answer to my Petition for Review. pdf 210 kb
And now my Reply to State's Answer to Petition for Review
On January 10, 2006, Department One of the Supreme Court of Washington, composed of Justices Alexander, Charles Johnson, Sanders, Chambers, and Fairhurst, unanimously ordered my Petition for Review deferred pending decision in Amunrud v. DSHS No. 76590-1. Two months after oral argument in the Amunrud case.
On September 21, 2006, the Supreme Court of Washington violated their oaths of office with their unAmerican decision in the Amunrud case. Reported at 158 Wash. 2d. 208, 143 P. 3d. 571 However, Justices Richard Sanders wrote the excellent dissent, joined by Justices James Johnson and Tom Chambers. Dissent reported at 158 Wash. 2d. 231-246
A hooray and thank you to Justices Richard Sanders, James Johnson and Tom Chambers!
A Seattle Times editorial that disagrees with a decision against us. Please take a deep breath. No need to laugh, it is true, this is not a hoax!
Here is the "Sound Off" commentary by those who read the Seattle Post-Intelligencer editorial which draws the opposite conclusion of the Seattle Times editorial.
My petition was set for hearing on December 5, 2006, and they denied it.
Petition for Writ of Certiorari to the United States Supreme Court is considered filed as of the date I mailed it, February 21, 2007, within 90 days of December 5, 2006. It is docketed as No. 06-1162.
I will try a little experiment here. Here is the Petition in Microsoft Word 97-2003 format. If it works out, I might post some more of my other pleadings this way. The reason I have not is that I did not want to discriminate against Apple users, WordPerfect users, and old Word users. I am also posting the htm versions with the citations linked as has been my practice. Feedback has been positive on that format, as it allows the Internet surfer to look up the cases cited and the statutes without taking a trip to the law library. With such preliminary research on line, the trip to the library or to the Westlaw account for those with access can be so much more productive.
Petition for Writ of Certiorari Title Page.
Petition for Writ of Certiorari Questions Presented and Tables Equivalent to: Questions Presented in htm
Petition for Writ of Certiorari Argument Equivalent to Second Part of Petition for Writ of Certiorari
Petition for Writ of Certiorari Appendix. This presents the previous decisions in the state courts.
Turns out Greg Amunrud through Robert H. Stevenson did file their Petition for Writ of Certiorari, Supreme Court of the United States No. 06-1092.
Enjoy these war posters, they are appropriate to this license suspension business:
<--- Terrible Record!
My Taxes Are Another Deadbeat ----> Exhibit A
Car Pooling Sorry Kid If I Walk You're Fingered!
If the back button does not take you there, click Home to go to the Index page of this Antipeonage Act Website, click Enemies for the main Enemies page, click Letters for the Letters page, and click Allies for the Allies page. Or you can use the Antipeonage Act Site Map.
