The purpose is to seek restitution and to putting an end however we can to this type of action happening to additional people, an action by bureaucracies that should not be permitted to continue if we are to consider this to be a free society.

We say the city ordinances are unconstitutionally vague, ambiguous and over broad not only as written but in the way the city is applying them "arbitrarily and discriminatorily" however they please as harassment against property owners.

People who have a person or persons with a personal vendetta against them, are victims by this person simply call the City with some imagined complaint, (and enlist the city to harass) which supposedly then gives the City bureaucracy free reign to take snooping action to uncover something on their own (that has nothing to do with the imagined "called in" keying complaint,) and follow with any restrictive or "punitive" action they like, completely unrestrained by "reason".

An action that would not have been taken and this unconstitutional harassment even started had not the vengeful neighbor sought city help in stirring up problems for the property owner by making the "keying" phone call. In addition: No action is taken against similar property situations in the neighborhood, since no one "called" about them.

Vague or overbroad laws deter the constitutionally protected activity not only of the litigant, (full and free use of private property) but of third parties not before the court, and for that reason can be challenged facially. (as written) as well as how the officials are applying them.

The Sioux Falls ordinance in question unnecessarily interferes. (as written and as applied) with legitimate rights of Sioux Falls property owners and public to enjoy free and active use of property for which it was intended and licensed.

What is not an infringement upon public safety and is not a nuisance cannot be made one by using police powers to write a ticket.

Negating what the property was purchased for, has been used for, over 18 years amounts to an unconstitutional taking of property without compensation.

We will charge the Sioux Falls City ordinance and as applied are so vague and overbroad that it inhibits totally our use of our property in a normal manner.

The ordinance must be overturned as unconstitutionally overbroad, vague and ambiguous, for totally failing to provide a precise definition of what can be and what can not be conducted and/or defended.

We also charge the ordinance denies us "Due Process Protections".

The Due process part of the constitution requires that laws clearly define their prohibitions.
Vague laws are objectionable because they do not "give the person of ordinary intelligence a reasonable opportunity to know what is prohibited," they do not provide fair warning to those who wish to act lawfully. allowing for "arbitrary and discriminatory application." by agents of the government, which is what is exactly what is happening here.

Not only on the face, (the way it is written ) but also on the way it is used (applied) as harassment. touching here on rights protected by the constitution on owning and use of private property in Sioux Falls.

THE CITY HAS DENIED THE CONSTITUTIONAL RIGHT OF CITIZENS TO APPEAL ORDINANCES OR ACTIONS

The big hitch is the city has "rigged it" so no matter how unreasonable, unconstitutional or out of bounds their ordinance or actions are no citizen can successfully overcome them.

It is this "catch 22" they have worked in so that when you appeal any ordinance, any ticket or Administrative Appeal decision, it is fraudulently all a fake and winds up City 100% Citizens -0.

This happens because of deliberate and knowing action by the city.

This "city system" must be reviewed by a constitutional court, because Sioux Falls citizens have and are being denied review of City actions by a legitimate court.

It would appear that all actions that have happened with this "fake" appeals right system the city has set up should and likely will be overturned en masse.

If a court agrees, those affected in the last year or two will be included automatically.

The city could be held liable for damages to each affected citizen for such knowing and deliberate denial of guaranteed rights.

This is a separate and important issue in addition to the other constitutional issues demonstrated previously.

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