Justice Torie, I have attempted to draft a brief per your request without going too deep into the substantive arguments, so that that step may be saved for if the Court grants certiorari. If you would like a more detailed description of my arguments, I would be happy to provide them in an amended brief.
Brief for Petition of Writ of Certiorari
Statement of Facts
Art. I, §7, cl. 1 of the Third Constitution states:
[1]On February 4, 2014, the Senate of Atlasia passed the Pacific Deconstruction Resolution, which states:
[2]At no point have either the Pacific Region or the Midwest Region drafted any Treaty, Alliance, Confederation, Agreement, Compact, or accord to combine their governing bodies. At no point in time did the Senate note that its consent had been given for the purpose of handling any "Specific Issues" that affected the Pacific and Midwest, but not the nation as a whole. In fact, no Specific Issue was noted by the Senate in its resolution.
Issue Presented
Is the Pacific Deconstruction Resolution unconstitutional as a violation of Art. I, §7, cl. 1 of the Third Constitution, where the Senate gave consent to the Pacific and Midwest Regions to combine their governing bodies without noting a Specific Issue for which the accord will be entered into to resolve?
Brief Answer
Because the Senate granted blanket consent to the Pacific and Midwest Regions to enter an accord to combine their governments, without noting or discussing a Specific Issue for which the accord will our would be formed, the resolution at issue is unconstitutional. Furthermore, even if the Senate had noted an issue, as will be discussed below, the only plausible issue for which the accord could have been formed is not an issue that does not affect the nation as a whole, further making the resolution unconstiutional.
For these reasons, there has been an error in the Senate's application of the law. A merger of two regions' governments will have a major impact not only on the regions part of the accord themselves, but the other regions of Atlasia and the nation as a whole. Because the Senate gave blanket consent for a governmental merger between the two regions, without noting any Specific Issue that the merger would address, the Senate has not only violated the Constitution but sets a dangerous precedent for the future. The Constitution set limits on when regions can enter agreements with other regions, and by ignoring the boundaries of these limits, the Senate has encouraged future violations of this provision; such violations, including the present violation, strip the federal government of its duly held power.
Because there has been a flagrant disregard for the Constitution, which has a major impact on the regions and nation as a whole, Plaintiff petitions this Court to grant a Writ of Certiorari.
--Inks.LWC
