WESTERN DISTRICT OF
WASHINGTON AT SEATTLE
ROGER W. KNIGHT, )
)
plaintiff, ) No. C00-151Z
v. )
) MOTION FOR
NORM MALENG. King County ) SUMMARY JUDGMENT
Prosecuting Attorney, and
CALVIN G. )
RAPADA, Deputy Prosecuting
Attorney, )
)
defendants. ) Noted for hearing: April 28, 2000
____________________________________)
Comes
now ROGER W. KNIGHT, the plaintiff, to move for a summary judgment declaring
that use of contempt proceedings in state court to coerce labor to enforce
compliance with a child support order or to punish unemployment, willful or
nonwillful, by a noncustodial parent ordered to pay child support, is null and
void as violation of the Antipeonage Act of 1867,
42 U.S.C. §1994, and for
permanent injunction prohibiting the defendants from any use or further use of
the threat or fact of contempt proceedings, arrest, or imprisonment under
RCW
26.18.050 or any other statute or absent any statute, to enforce any support
order whether it arises in the courts and administrative agencies of the state
of Washington, or of any other state, territory, commonwealth, or possession of
the United States, or of any foreign state.
This
motion is based on the pleadings herein and upon the
Memorandum in Support of
this Motion for Summary Judgment.
RESPECTFULLY SUBMITTED, April 6, 2000.
____________________________________
Roger
W. Knight, plaintiff