# Petition for Writ of Certiorari — Lasting Beauty, LLC v. City of Chesapeake, Virginia (No. 06-1374)

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## Record

- **Collection:** Supreme Court brief
- **Document type:** Petition for Writ of Certiorari
- **Published:** January 1, 2006

## Text

Gn ojphe ~°FiCe OF THE CLERK
Supreme Court of the Chited States

LASTING BEAUTY, L.L.C.
and DENISE HUMPHRIES,

Petitioners,

Vv.

CITY OF CHESAPEAKE
and JAMES T. DAVIS, CZA,
Zoning Administrator,

Respondents.

+

ON PETITION FOR WRIT OF CERTIORARI
TO THE SUPREME COURT OF VIRGINIA

®

PETITION FOR WRIT OF CERTIORARI

+

Kevin E. Martingayle

Counsel of Record

STALLINGS & BISCHOFF, P.C.
2101 Parks Avenue, Suite 801
Post Office Box 1687

Virginia Beach, Virginia 23451
(757) 422-4700

Counsel for Petitioners

THE LEX GROUP®® @ 1750 K Street N.W. @ Suite 475 @ Washington, DC 20006
(202) 955-0001 @ ($00) $15-3791 @ Fax: (202) 955-0022 @ www.thelexgroupdc.com

QUESTIONS PRESENTED

1. Did the courts below err in failing to determine
that the subject City zoning scheme governing
tattooing unconstitutionally burdens free speech
and expression rights guaranteed by the United
States Constitution?

2. Did the Courts~below err in failing to determine
that the subject City zoning scheme, facially and
as applied, denies equal protection and due
process rights guaranteed by the United States
Constitution?

ii

LIST OF PARTIES

The petitioners are Lasting Beauty, LLC and
Denise Humphries, and the Respondents are City of
Chesapeake, a municipal corporation, and James T.
Davis, CZA, Zoning Administrator.

CORPORATE DISCLOSURE STATEMENT

Petitioner, Lasting Beauty, LLC is a Virginia
company that has no parent corporation. No
publicly-held company holds 10% or more of
Petitioner’s stock.

ill

TABLE OF CONTENTS

Page
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CORPORATE DISCLOSURE STATEMENT ............ ll
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TABLE OF AUTHORITIES .......ccccccccccscocsssevevsevsensess iv
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PARI EIEN sehiivseciictinicteicegiatinieeainnie 1
CONSTITUTIONAL PROVISIONS AND
CITY ZONING ORDINANCE INVOLVED ............... 1
STATEMENT OF THE CASE .......ccssssssssssssesssssseeesseees 8
Fh, GN cccckcivesictnnivtinnctadammenisniand 3
B. Prior tattoo litigation and the City’s
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CFR Bei OE CRI CI aise sctictcitvcctesntemnneccens 4
REASONS WHY THE WRIT SHOULD BE
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A. Summary of ATMuMeht.......ccccccccsvecceesvevecseesseeesth
B. Free Speech/Expression Issues.................::0086+ 7
C. Equal Protection and Due Process ................ 10
CEPR A IAIN cividercetassssciinirbiaioansinibemeriacatmuiagiainae 12

APPENDIX

TABLE OF AUTHORITIES

CASES

Bery v. City of New York,
97 F.3d 689 (2d Cir. 1996)

Board of Airport Comm’rs v. Jews for Jesus, Inc.,
482 U.S. 569 (1987)

Board of Supervisors v. Carper,
200 Va. 653, 107 S.E.2d 390 (1959)

Broadrick v. Oklahoma,
413 U.S. 601 (1973)

Brown v. Louisiana,
383 U.S. 131, 86S. Ct. 719,
15 L.Ed.2d 637 (1966)

City of Chesapeake v. Ancient Art Tattoo Studio,
02 Va. S. Ct. UNP 012082 (2002)

Commonwealth v. Meuse,
1999 Mass. Super. Lexis 470,
10 Mass. L. Rep. 661 (Mass. Super. Ct. 1999)

Erie v. Pap’s A.M..,
529 U.S. 277 (2000)

Lanphear v. Commonwealth of Massachusetts,
Mass. Superior Court Slip Opinion
99-1896-B (October 20, 2000), affd,
Commonwealth v. Lanphear,

50 Mass. App. Ct. 1107,
737 N.E.2d 1281 (2000)

MacNeil v. Board of Appeal of Boston,
2004 Mass. Super. LEXIS 282,

18 Mass. L. Rep. 153 (Mass. Super. Ct. 2004)

Nike, Inc. v. Kaskv,

i Ie CE oss sisidickphnnsidstbinisievedsossiessices

People v. O’Sullivan,

96 Misc. 2d 52 (N.Y. Misc. 1978).........0....00...

Schad v. Mount Ephraim,

Re Aes EE AIRED siete shicisnianisncncaninxaueavcsnisacacss

Smith v, Goguen,
415 U.S. 566, 94S. Ct. 1242,

Fe Mis ME CATS) cs ceticrssccencdecisasenrsenssscierers

Spence v. Washington,
418 U.S. 405, 94 S. Ct. 2727,

BE Rie OO IO isco v essoticeepesionsnisveconvsxivinn

State ex. rel. Medical Licensing Bd. v. Brady,

492 N.E.2d 34 (Ind. Ct. App. 1986)................0..

State v. White,

348 S.C. 532, 560 S.B.2d 420 (2002)..............

Stephenson v. Davenport,

110 F.3d 1508 (6 Cir. 1907) 00. :cccccssisecsscdsccooes

Stromberg v. California,
283 U.S. 359, 51S. Ct. 532,

Se A EEF CRO ED isc crnksvtbinsscatetblinnndindesmnins

Texas v. Johnson,
491 U.S. 397, 109 S. Ct. 2533,

BO Bie RE CL occ scscvensizesei cctesercdneineninnae

ereneee

eeeeee

vl

Tinker v. Des Moines School District,
393 U.S. 503, 89S. Ct. 733,

oe RAE FH GM inthis srdacvercdcehinnsudderouistenseceu 9
Tory v. Cochran,

Re ee: WOE MIU cicssetvnccoceccissernctscerescbeccebmsneasenss 5
United States v.
Playboy Entertainment Group. Inc.,

RE PRR DOR AER on ee eee oe tod 5
Village of Willowbrook v. Olech,

ee Ene SUE GUID Sica cenndnvinnsisawievctuvcseestes 11
Virginia v. Black,

RMR IEEE CIENT... sa csv sedsenerevcubcouacnbtesedaeedecmaeucks 5
Virginia v. Hicks,

ee ee ao. aia dliiduenvtcmeapcanseiaoouaeniaa 5
Yurkew v. Sinclair,

495 F. Supp. 1248 (D. Mirn. 1980) ..................008. 9
CONSTITUTIONAL PROVISIONS
Ra IT MI Bhi occ sicispwesneucenuosececaukswseens passim
ee I, I FG isi iscuctcenesieud ccvetucadcnnietsbeewiacenen 2
STATUTES
IRIE TE MD ie ind cchcin cee dneaptnaanennioneeiia 1
Pe ee Be TI ik a oceratcnicenetusines aaeuanuveneciictersndvwninedaas 3

_ ORDINANCES

Chesapeake City Ordinance § 8-601......................... 4
Chesapeake City Ordinance § 8-601(C)(27)............... 2

Vill

OTHER AUTHORITIES

Anthony Jude Picchione,
Tat-too Bad for Municipalities:
Unconstitutional Zoning of Body-Art
Establishments, 84 B.U.L. Rev. 829 (June,

Bobby G. Frederick,
Tattoos and the First Amendment - Art
Should Be Protected As Art: The South
Carolina Supreme Court Upholds _ the
State’s Ban on Tattooing, 55 S.C. L. Rev.
Fe Cs SN bite ieciehinttcere datieeniumlota veseiass

Virginia Board of Health Professions Report
SA Te, Se iscsctssssciioces eicsisciianenaauannnsawaiadeases

PETITION FOR WRIT OF CERTIORARI

Lasting Beauty, LLC and Denise Humphries
(hereinafter referred to collectively as “Humphries”)
respectfully petition this Court for a writ of certiorari
to review the judgment of the Circuit Court of the
City of Chesapeake (the “trial court”), and the
decision of the Virginia Supreme Court denying
review. The trial court held that tattooing is not
sufficiently “communicative in nature to warrant
protection under the First Amendment” and rejected
Humphries’ free speech, equal protection and due
process arguments.

OPINIONS BELOW

The trial court issued a memorandum opinion on

March 23, 2006 (reprinted in the appendix herein at
App. 2-15), followed by a Judgment and Final Order
entered May 3, 2006 (App. 17-19). The Virginia
Supreme Court initially denied review by Order
dated October 25, 2006 (App. 1), and then denied a
Petition for Rehearing by Order dated January 19,
2007 (App. 16).

JURISDICTION

The Order of the Virginia Supreme Court refusing
Humphries’ Petition for Rehearing was entered on
January 19, 2007 (App. 16). This Court has
jurisdiction pursuant to 28 U.S.C. § 1257.

CONSTITUTIONAL PROVISIONS AND CITY
ZONING ORDINANCE INVOLVED

The First Amendment to the Constitution of the
United States states as follows:

Congress shall make no law respecting an
establishment of religion, or prohibiting the
free exercise thereof; or abridging the freedom
of speech; or of the press; or the right of the
people peaceably to assemble, and to petition
the Government for a redress of grievances.

The Section One of the Fourteenth Amendment to

the Constitution of the United States states as

follows:

§ 1. All persons born or naturalized in the
United States, and subject to the jurisdiction
thereof, are citizens of the United States and
of the state wherein they reside. No state shall
make or enforce any law which shall abridge
the privileges or immunities of citizens of the
United States; nor shall any state deprive any
person of life, liberty, or property, without due
process of law; nor deny to any person within
its jurisdiction the equal protection of the
laws.

Chesapeake City Ordinance § 8-601(C)(27) states
as follows:

The following conditions shall apply to specific
uses, as indicated in the “condition” column in
the uses schedule:

KOK KOK

27. Tattoo parlors shall be established and
operated in accordance with applicable
provisions in chapter 38 of the City Code.
Additionally, in order to protect and preserve
the character of residential neighborhoods,

residential property values, the vitality of
commercial districts and the overall quality of
life in Chesapeake, and further to prevent
detrimental effects on educational facilities
and public recreation areas, no tattoo parlor
shall be located within 1,000 feet of any other
tattoo parlor, private and public schools, day
care facilities, public parks, religious
institutions or any property zoned or used for
residential purposes.

STATEMENT OF THE CASE
A. Overview

Humphries is a performer of “intradermal
micropigmentation”. Legally, this service is defined
and treated exactly the same as _ traditional
tattooing. Code of Virginia § 54.1-700°. This appeal
involves the City of Chesapeake’s zoning scheme
relating to tattooing and restrictions imposed on the
activity.

The subject zoning allows tattooing only in the
City’s “industrial” districts (“M-l” and “M-2”), and
only as a “conditional use”. Further, it bans any
tattoo establishment “within 1000 feet of any other

‘ Section 54.1-700 provides these relevant definitions: “Tattoo
parlor’ means any place in which tattooing is offered or
practiced. “‘Tattooer’ means any person who for renumeration
practices tattooing. ‘Tattooing’ means the placing of designs,
letters, scrolls, figures, symbols or any other marks upon or
under the skin of any person with ink or any other substance,
resulting in the permanent coloration of the skin, including
permanent make-up or permanent jewelry, by the aid of
needles or any other instrument designed to touch or puncture
the skin.”

tattoo parlor, private and public schools, day care
facilities, public parks, religious institutions or any
property zoned or used for residential purposes.” See
ordinance § 8-601. See also the color-coded map in
the record as Plaintiffs Exhibit 5, depicting the
limited allowable areas.

B. Prior tattoo litigation and the City’s
former ban

Legal battles over tattooing are nothing new to
the City of Chesapeake, and one was the subject of a
previous appeal to the Virginia Supreme Court.
Specifically, in a June 5, 2001 ruling (memorialized
in an order dated June 21), a judge of the Chesapeake
Circuit Court struck down the City’s then-existing
blanket ban on tattooing. Days later, the City
repealed the ban and enacted new ordinances
regulating tattooing and severely limiting where it
would be allowed. In the meantime, the City also
appealed the trial court ruling invalidating the ban,
but because of the repeal of the provision struck
down by the trial court, the Virginia Supreme Court
found that the appeal was rendered moot. City of
Chesapeake v. Ancient Art Tattoo Studio, 02 Va. S.
Ct. UNP 012082 (2002). Although the parties in that
appeal briefed and argued many of the same issues
presented here -- including free speech -- the
dismissal ended that appeal without any opinion
being issued.

C. The history of this case

This case proceeded before the trial court as a
declaratory judgment action and a trial was held

September 1, 2005. Thereafter, a March 23, 2006
memorandum opinion was issued by the trial court

ruling against Humphries. Humphries responded by
appealing to the Virginia Supreme Court and
followed all of the necessary appellate rules and
procedures.” The writ of appeal was denied on
October 25, 2006. Because of the critical issues in
this particular appeal, and also because of ongoing
tattoo law conflicts in Chesapeake and other
neighboring cities, a Petition for Rehearing was
presented for consideration by the Virginia Supreme
Court. It was denied by Order dated January 19,
2007.

REASONS WHY THE WRIT
SHOULD BE GRANTED

A. Summary of Argument

This appeal presents to an opportunity for this
Court to address and resolve an important conflict in
constitutional jurisprudence. The specific issue is
whether tattooists and their customers are protected
by free speech, due process and equal protection
principles, or whether localities are at liberty to
engage in unrestrained regulation of and

“In the Virginia Supreme Court, the Thomas Jefferson Center
for the Protection of Free Expression, a free speech advocacy
organization based in Charlottesville, Virginia, filed an “Amicus
Curiae Memorandum of Support for Petitioners’/Appellants’
Petition for Appeal” in which it agreed with Humphries that the
trial court engaged in a flawed analysis and reached a clearly
erroneous conclusion. This Court has accepted and reviewed
several amicus briefs from this organization in recent years in
cases involving important free speech issues. See _e.g., Tory v.
Cochran, 544 U.S. 734 (2005); Virginia v. Hicks, 539 U.S. 113
(2003); Nike, Inc. v. Kaskv, 539 U.S. 654 (2003); Virginia v.
Black, 538 U.S. 343 (2003); Erie v. Pap’s A.M., 529 U.S. 277
(2000); United States v. Playboy Entertainment Group. Inc.,
529 U.S. 803 (2000).

discrimination against the art form. This Court has
never addressed this particular issue, and the trial
court concluded the latter. The result of the trial
court’s opinion is continuing har n to fundamental
constitutional rights. This outcome burdens and
damages not only Humphries and countless other
tattooists and customers in Virginia and elsewhere,
but also other citizens wishing to engage in forms of
self-expression that local politicians may not favor.
The trial court’s opinion and the authority upon
which it relied constitute dangerous precedent for
localities to follow. Because there is a well-developed
and thoroughly briefed lower court record, this case
provides a good vehicle for issuing a defining and
culturally significant opinion. To be sure, this is a
legal battle that will rage on until this Court settles
the debate.

As Humphries argued in the Virginia courts,
tattooing is an ancient art form that has seen a
resurgence in popularity in the United States in the
past couple of decades. Like any other art form, it is
entitled to First Amendment protection. Instead, .
however, its practitioners and those who wish to have
the art form practiced upon their bodies have been
subjected to a burdensome zoning scheme in the City
of Chesapeake that cannot be justified. Not one
witness who testified in the trial court could explain
any need for the highly restrictive zoning involved in
this case.

Facially, the subject zoning scheme discriminates
against tattooing by imposing’ unjustifiably
burdensome zoning requirements, while similar
personal services are allowed as a matter of right in
almost all areas of the City, and without the need for

a “conditional use permit”. As applied, Humphries
presented evidence of selective enforcement, to
which the City had no answer or explanation.

B. Free Speech/Expression Issues

For purposes of this appeal and the City’s zoning
ordinance, intradermal micropigmentation and
tattooing are indistinguishable; therefore, the
Constitutional analysis is identical and Humphries
has proper standing to challenge the subject
ordinances on free speech and expression grounds.
Broadrick v. Oklahoma, 413 U.S. 601, 611-12 (1973).
See also Board of Airport Comm’rs v. Jews for Jesus,
Inc., 482 U.S. 569, 574 (1987).

There is currently a significant and long-standing
split of authority in American jurisprudence regarding
whether tattooing is an activity sufficiently imbued
with communicative aspects to justify free speech and
expression protection under the First Amendment to
the Constitution. Logically, it is difficult to conceive
of any reason why tattooing should be considered any
differently from any other type of “art”. Tattooing is
an “art form” recognized both nationally and
internationally. Lanphear_v. Commonwealth of
Massachusetts, Mass. Superior Court Slip Opinion
99-1896-B (October 20, 2000), aff'd by Commonwealth

1281 (2000); Virginia Board of Health Professions
Report (January 3, 1994).° “Persons obtain tattoos to
demonstrate commitment to other persons, to
institutions, to religious beliefs, and to political and
personal beliefs.” Lanphear, p. 3. Many people -- men

° A copy of this report to the Virginia General Assembly is in
the record as Exhibit B to Humphries’ Bill of Particulars.

and women, middle-class professionals and otherwise
-- seek tattoos “as an expression of individuality.”

Report, p. 12.

In Lanphear, the Superior Court of
Massachusetts. declared that a Massachusetts
statute prohibiting tattooing by anyone other than a
licensed physician was an_ unconstitutional
infringement on the right to freedom of expression.
See also Commonwealth v. Meuse, 1999 Mass. Super.
Lexis 470, 10 Mass. L. Rep. 661 (Mass. Super. Ct.
1999) (dismissing criminal indictment of violation of
tattoo statute because statute requiring tattooing by
a qualified physician was unconstitutional).

In MacNeil v. Board of Appeal of Boston, 2004
Mass. Super. LEXIS 282, 18 Mass. L. Rep. 153 (Mass.
Super. Ct. 2004), the court analyzed amendments to
the Boston zoning code authorizing tattoo parlors
pursuant to a conditional use permit scheme. In that
case, the court rejected the notion that “merely
speculative factual grounds” can justify regulations
restricting free speech and expression rights, and
refused to accept unsupported’ conclusions
supposedly justifying the enactment. Id., 18 Mass.
L. Rep. at 155 (internal citations omitted). The court
went on to find that there was “insufficient evidence
that the City and Zoning Commission’s conditional
use designation was designed to serve any
substantial governmental interest and for that
reason, the body art establishment ordinance...is
unconstitutional.” Id.

The trial court in this case rejected the free
speech and expression arguments advanced by
Humphries, and in comparing competing authority

submitted by the parties, appeared to rely primarily
on State v. White, 348 S.C. 532, 560 S.E.2d 420
(2002).* The trial court also found support for its
decision in Stephenson v. Davenport, 110 F.3d 1303,
1307, n. 4 (8" Cir. 1997), State ex. rel. Medical
Licensing Bd. v. Brady, 492 N.E.2d 34 (Ind. Ct. App.
1986), Yurkew v. Sinclair, 495 F. Supp. 1248, 1254
(D. Minn. 1980), and People v. O’Sullivan, 96 Misc.
2d 52, 53 (N.Y. Misc. 1978). The analysis of the trial
court and other courts which have denied free speech
and expression protection for tattooing have made
rulings that simply cannot be reconciled with this
Court’s jurisprudence, which has made it clear that
many non-verbal, communicative and/or expressive
activities are entitled to protection. See, e.g., Texas
v. Johnson, 491 U.S. 397, 109 S. Ct. 2533, 105 L.E.2d
342 (1989) (the burning of an American flag is
“speech” entitled to First Amendment protection);
Spence v. Washington, 418 U.S. 405, 94 S. Ct. 2727,
41 L.Ed.2d 842 (1974) (the display of an American
flag to which a peace symbol had been sewn is
afforded First Amendment protection); Smith vy,
Goguen, 415 U.S. 566, 94 S. Ct. 1242, 39 L.Ed.2d 605
(1974) (wearing a small American flag sewn to the
seat of one’s pants is protected expressive conduct);
Tinker v. Des Moines School District, 393 U.S. 503,
89 S. Ct. 733, 21 L.Ed.2d 731 (1969) (wearing a black
armband by students to protest American

* This opinion from a sharply divided South Carolina Supreme
Court has been the object of a great deal of criticism. See, e.g.,
Anthony Jude Picchione, Tat-too Bad for Municipalities:
Unconstitutional Zoning of Body-Art Establishments, 84 B.U.L.
Rev. 829 (June, 2004); Bobby G. Frederick, Tattoos and the
First Amendment - Art Should Be Protected As Art: The South
Carolina Supreme Court Upholds the State’s Ban on Tattooing,
55 S.C. L. Rev. 231 (Fall, 2003).

10

involvement in Vietnam is “speech”); Brown_v.
Louisiana, 383 U.S. 131, 86 S. Ct. 719, 15 L.Ed.2d
637 (1966) (the act of conducting a sit-in by African
American students at a segregated “whites only”
library is protected “speech”); and Stromberg v.
California, 283 U.S. 359, 51 S. Ct. 532, 75 L.Ed. 1117
(1931) (display of a red flag in support of communism
is speech). See also, Bery v. City of New York, 97
F.3d 689 (2d Cir. 1996) (invalidating, on free speech
and equal protection grounds, a licensing
requirement imposed on artists desiring to sell
artwork in public spaces). There is no principled
distinction to be made between the above-described
expressive activities and the art of tattooing, and, in
fact, the permanent nature of tattoos makes the
chosen statement or expression potentially much
more significant than, for example, the temporary
wearing of an arm band or the quick destruction of a
flag via a burning.

C. Equal Protection and Due Process

Facially, the zoning denies equal protection and
due process rights because it singles out a particular
form of expressive activity and subjects it to a
burdensome zoning scheme, without any justification
whatsoever. This is a continuing effort by the City to
discriminate against a particular activity and
clientele, and Gene Waters, a former member of the
Chesapeake City Council, testified without objection
or rebuttal to the blatant admissions of intentional
discrimination he heard from fellow Council
members as the zoning was created. (TR 48-57).°

° The September 1, 2005 trial transcript is in the record.

11

As applied specifically to Humphries, the subject
zoning has not only ensnared her in the City’s effort
to hinder the opening of “tattoo parlors”, but she has
also suffered selective prosecution. (TR 30-41).

As this Court made crystal clear in a per curiam
opinion, the equal protection clause of the United
States Constitution recognizes a so-called “class of
one” claim where a plaintiff alleges that “she has
been intentionally treated differently from others
similarly situated and that there is no rational basis
for the difference in treatment.” Village _ of
Willowbrook v. Olech, 528 U.S. 562, 564 (2000)
(internal citations omitted). This is exactly what the
trial court record in this case reveals, and it is exactly
what Humphries argued to the trial court at the
conclusion of the evidence. (TR 170-71).

“The purpose of the equal protection clause of the
Fourteenth Amendment is to secure every person
within the State’s jurisdiction against intentional
and arbitrary discrimination, whether occasioned by
express terms of a statute or by its improper
execution through duly constituted agents.” Village
of Willowbrook, 528 U.S. at 564 (internal citations
omitted).

Although there is some precedent in Virginia law
for invalidating zoning classifications and decisions
on equal protection and due process grounds (see, e.g.,
Board of Supervisors v. Carper, 200 Va. 653, 107
S.E.2d 390 (1959)), there has been little guidance
from this Court regarding the extent to which such
constitutional principles apply to such and how lower
courts ought to judge them. In fact, Justice Breyer’s
concurrence in Village of Willowbrook, Id. at 565, was

12

careful to “minimize any concern about transferring
run-of-the-mill zoning cases into cases of
constitutional right.” See also Schad _v. Mount
Ephraim, 452 U.S. 61, n. 4 (1981) (declining to
address similar due process and equal protection
arguments and, instead, sustaining appellant’s First
Amendment challenge to a zoning’ scheme).
Humphries urges this Court to take this opportunity
to clarify the due process and equal protection
analysis to be employed in zoning disputes, and
respectfully submits that the City’s irrational
campaign against the art of tattooing makes this
zoning battle anything but “run-of-the-mill.” Simply
Stated, there must be a constitutional solution to the
type of governmental oppression and admitted
discrimination involved here.

CONCLUSION

For the reasons stated above, the petition for a
writ of certiorari should be granted.

Respectfully submitted
LASTING BEAUTY, LLC
and DENISE HUMPHRIES

By: /s/ Kevin E. Martingayle
Of Counsel

Kevin E. Martingayle (VSB No. 33865)
STALLINGS & BISCHOFF, P.C.

2101 Parks Avenue, Suite 801

Post Office Box 1687

Virginia Beach, Virginia 23451

(757) 422-4700 (Telephone)

(757) 428-6982 (Facsimile)

April 19, 2007

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386016_2435%3A1. Public record. Not legal advice.