Lawsuit: Adjourned Moyfr v. Crown, Case 4 (Ch. 2025)

[Moyfr]

Closing Statement​

Ms. Chief Justice, Chancellors, and may it please the court,

I would first like to start off with an objection to the entreaty, and dispelling the misinformation that the Crown has seemingly entered into court record: Firstly, I am NOT a citizen, please see the attached screenshot. Second, contrary to the Crown's statement, the tests and law IS actively being enforced given the new amendments to the law. While the amendment does include the provision that "Any player who joins/joined before the relevant exams are set up shall be granted automatic citizenship", there is no provision stating that, while the tests are being set up, the law is not to be enforced.



What I find amusing is that, if the crown was more speedy in its response, the arguments they made today would have some merit, however, as of a few days ago, all non-citizens were given "resident" roles and tests were put at spawn. I ask the crown, if we were all to be given citizenship automatically, why were we instead given resident roles rather than keeping the "citizen" role we had prior? I apologize for bringing evidence to the court in closing arguments, however given the state of the case, as well as the Crown's blatant misinformation, I feel it is necessary to dispel any confusion.

As for my closing statement, your honor, no matter how many times the crown has brought prosecutor after prosecutor, the facts of the case remain the same. The act was passed and enacted as written for nearly a month. During that time, the law did directly impact the way I live my life in Alexandria, moreover the case itself, which I have been battling for an equal amount of time, has deprived me of my opportunity a career in the Ministry of Justice, as I cannot actively apply for a position which I am prosecuting in court. Is it that hard to believe that, under a new law that was written by the parliament, a non-citizen during this time would be afraid of doing pretty much anything in fear of prosecution? Moreover, with elections on the horizon, many non-citizens have been hesitant to start political campaigns in fear of being either prosecuted or prevented of participating in elections.

The Crown has attempted to dismiss my case so many times at this point that I cannot be bothered to count. Yet, the only reason they are so eager for a dismissal is because they know that the only way they could possibly win this case is by stalling the decision until the law was amended. For this act, the Crown has been charged of Contempt of Court not once, but TWICE during the proceedings of this case due to their lack of response.

While the Crown seeks to dismiss this case, or win it by the basis of "we amended the law now, there is no reason to be upset or for this case to be valid", even going as far as saying: "The ICA does not deprive the claimant of citizenship due to its timing and structure. The Kingdom must have laws. It is not the fault of the Crown that the Claimant chose to step into the Kingdom when they did." I find both of these arguments to be useless in nature to the facts of the case. First, it is not my fault that I joined when I did, and to say that the ICA doesn't deprive me citizenship due to timing, while also blaming me for my timing, is absurd. Especially given the murder example used by the Crown, that is an utter misrepresentation of what the facts of the case really are. Second, for nearly a month, the act did infringe on my rights as I was and still am not a citizen. Multiple times in this case has the Crown referred to me as a "Tourist" or "Resident" to which I have no claim to quote:

Within their Claims for Relief, the Plaintiff also directly outlines their premise for the standing of the given complaint. In particular, they cite the General Court Rules & Procedures to claim that "they have a standing application to pursue a case" under the Genuine Interest Clause (GIC). The GIC states the following:

"In order for a plaintiff to pursue a case, they must show ... to the court [that they have] a genuine interest as a citizen and there are no reasonable and effective alternative means to challenge the law."
Note that the applicability of the GIC is specifically predicated first on "genuine interest as a citizen," which the Plaintiff admits to not being at the top of their complaint. Moreover, in RealImza v. Crown (2025), this Court held the following two points with respect to The Immigration & Citizenship Act, which was under Parliamentary debate at the time:

1. "It seems untrue that there is no reasonable and effective means to challenge the law." (Parliament vetted and passed the law just as it can reconsider and repeal it.)
2. "The fact that a proposal within Parliament has been brought that clarifies this question soundly fails the test of having a reasonable and effective means to challenge the law." (This reaffirms the first point and establishes the precedent for the Parliament's ability to clarify uncodified constitutional questions via legislation, incidentally rebutting the Plaintiff's second Claim for Relief.)

Taken together, these precedents soundly disprove the GIC's second condition, meaning the Plaintiff does not have sufficient standing in order to pursue the case

How can the crown then validly argue that the law was never in effect or enforced when the defense themselves used the law against me in previous arguments in this very case?

Let us also not forget the main argument of my case. It does not matter how many times the government seeks to change this one law, but the constitutionality of the law will always be in question. The Constitution does not grant Parliament the explicit authority to define or regulate citizenship. By unilaterally establishing criteria for citizenship and delineating rights based on this status, Parliament has overstepped its constitutional bounds. The ICA's provisions, therefore, represent an overreach of legislative power, infringing upon rights that the Constitution guarantees to all individuals, not just those designated as citizens by parliamentary decree.

While the ICA has recently been amended, these changes do not address the core constitutional issues at hand. The amendments fail to rectify the lack of constitutional authority for defining citizenship and continue to impose unjust barriers to fundamental rights. Therefore, the Act, even as amended, remains unconstitutional.

In retrospect, while the case has evolved numerous times through the course of it's now near month lifespan, I would not take back any of it. I am a firm believer that, without this case, the original act would still be in effect and none of the rights that we have been able to advocate for would be in place today. I remind the court that I am not just fighting for my own rights, but for the rights of hundreds, if not thousands, of future players who should not be arbitrarily excluded from society simply due to the timing in which they joined. We were all new players once, and players who previously did not have to take these tests still function greatly in our society today. With all that said, I still humbly ask the court to review these prayers of relief:

I. That the Immigration and Citizenship Act is unconstitutional and violates the my rights under the Constitution, specifically the right to equality, political participation, and due process.

II. That the Court issue an injunction preventing the enforcement of the Act as applied to individuals who were residents of Alexandria before the Act’s enactment, until a more equitable and constitutionally sound process is established.

III. That I be granted citizenship or provided an alternative means to gain citizenship under conditions that do not violate constitutional rights.

I thank the court for its kindness, tenderness, and service to the kingdom and justice as a whole.

Submitted,

Moyfr
Plaintiff

 

[Smallfries]

The Crown shall have seventy-two hours to make their closing statement.

 

[ameslap]

​

In the Chancery of Alexandria
Closing Statement​

---

May it please the Chancery and the Claimant,

I'm glad to hear that the Claimant finds the Crown humorous, but I must admit I do not understand the joke. In regards to the question posed by the Claimant:

I ask the crown, if we were all to be given citizenship automatically, why were we instead given resident roles rather than keeping the "citizen" role we had prior?

The answer is simple: The plugin had issues. I submit a conversation with staff below for proof. Even if the Claimant does not have the active role right now, they are a citizen. Maybe they should have asked why something occurred instead of jumping to a conclusion that the Crown is out to get them.

Spoiler: Staff Ticket Conversation

To the Esteemed members of this Chancery, I pose a simple question: Has the Claimant provided any proof for their claims? I could tell you that the Sun is blue and the sky is red, but without evidence there is no reason to believe me. The Claimant has provided a single shred of evidence this entire case, of which was shoehorned in last second during Closing Statements and has been explained above. If there has been such a huge threat or harm, where is the proof?

To the constitutionality of of the ICA. I shall only point to the Constitution itself. See PART I - The Parliament, Section 3. Powers of Parliament.
"1. Legislative Power: Parliament has the authority to create, amend, and repeal laws....
8. Power to Control Immigration: Parliament can regulate immigration policies and laws."

And now, PART V - Rights and Freedoms:
"The following rights and freedoms are guaranteed as stated, subject only to such reasonable limits prescribed by law that are justified in a free and democratic society."

The constitution is explicit and clear in two instances. The first being that Parliament has the power to create laws and regulate immigration. The second that rights are subject to reasonable limits by law, which is a Power of Parliament. This makes the Immigration and Citizenship Act constitutional. Furthermore, while not explicit it is implied that if Parliament is able to regulate immigration, they are also able to regulate Citizenship, which is directly related to and a part of immigration.

The Crown thanks the Chancery and the Claimant for their time.

 

[Smallfries]

This case is in recess pending a response to submitted Entreaties, and surviving those, a verdict.

 

[Smallfries]

IN THE CHANCERY OF
THE KINGDOM OF ALEXANDRIA
VERDICT

Chancellor Smallfries4 writes this majority opinion, joined by Chancellor Kaiserin_. High Chancellor Juniperfig abstains.​

First, we attend to the outstanding request for a Writ of Dismissal in this case. We refuse to grant this writ. The Crown, as a matter of fact, is incorrect; not all of the Claimant's reliefs have been granted. Specifically, the Immigration and Citizenship Act is still on the books as law, and relief could be granted there. Because this is the Crown's load-bearing argument, that argument fails.

-=-​

Next, we look to the case itself. The issue in this case relies primarily upon the concept of citizenship, which is not elaborated upon in any great detail within our current constitution. See K. A. Const. § V Art. 22(1)–(3). The Constitution clearly references citizens, and makes a distinction between individuals who are citizens, and who are not citizens, referred to generally as "players". See Id. at (1)–(13). Without any reference to what determines a citizen, or how the qualifications of a citizen are made, or how an individual that is not a citizen becomes one, it is clear that the Constitution leaves up to the Parliament assembled the task of determining citizenship. Without action from Parliament, there was no way to know who was a citizen and who was not.

The contention from Claimant that "The Constitution does not grant Parliament the explicit authority to define or regulate citizenship" is clearly incorrect. Out of all trappings of Government, the question of "Who is a Citizen?" is perhaps one of the most important—so much so that many highly prominent empires and nations, both current and historical, have been nearly torn to shreds because they were not able to properly answer it. Thus, out of all constitutional questions, the question of citizenship is perhaps the one the Constitution most direly begs Parliament to answer. No other body—including this court—can answer that question on its own; it is clear that citizenship must be resolved by Parliament, and they have appropriately done so.

In the present case, Parliament took the task of defining citizenship upon itself though the promulgation of the Immigration and Citizenship Act. A.P. 004 § 3–6. It is here that issues began to arise. At the passing of this bill, any player who had joined before the bill became law would be made a citizen, and any player joining after would have to become a citizen through the citizenship exams, implemented by this bill. Id. at § 10. Claimant joined after the bill had passed into law, and the exams had not been set up yet. As a consequence, Claimant could not become a citizen, and began this effort for relief. Claimant alleges they lost many constitutional rights and protections due to this lack of ability to become a citizen.

They further allege the act itself is unconstitutional, as at the time, the Constitution stated players could run for office, without any specific mention of needing to be a citizen. The claimant further alleges the bill is too burdensome for the tempest-tost wretched refuse of the wider world, and further are "akin to that of a poll tax or literacy test," and for these reasons the bill must be struck down. It is important to note that this action was submitted on the twenty-first of April. Our Constitution was amended to its current state passing final plebiscite on the fifth of May. That amendment changed several portions of the Constitution, but the most important for our purposes is article 22. Now, the Constitution clearly states that every citizen has the right to run for office. This is a clear determination.

It is also important to recognize that the opening crawl of article 22 holds that the laundry list of rights are "subject only to such reasonable limits prescribed by law that are justified in a free and democratic society." This means, inter alia, that any right enumerated in that laundry list can be narrowed in scope so long as that abridgement is justified in the context of a "free and democratic society." Though no longer relevant, we believe that limiting who can run for office to only citizens of our nation is clearly a limitation that is reasonable in any democratic society. The Constitution being amended to reflect this belief clearly shows the Government and the public agree with the Court on this matter.

-=-​

With this in mind we turn to the complaint itself. Claimant begs for the following relief: (1) That the bill be struck down due to its violation of the constitutional rights of equality, political participation, and due process, (2) that this Court issue an injunction preventing the bill from being applied to those who "were residents of Alexandria before the Act's enactment," and (3) that Claimant be granted citizenship or provided an alternative means to gain citizenship.

First we look at the final relief, where the Court can confidently say the following: Claimant is indeed a citizen, and has been for nearly a month. As the Crown has correctly pointed out, the bill in question was amended on the sixth of May, and section 10 was altered to say that any player who joined before the "relevant exams" were set up would be automatically granted citizenship.

Because the Claimant complained of not being able to become a citizen at all in their initial filing, the amendment in question admitted at the time that the relevant exams were not set up, and the amendment was made after the Claimant's original complaint, as a matter of law the Claimant is a citizen. Thanks to a screenshot provided by the Claimant showing the tests not working, we can further say that any individual who joined before the eighth of May is a citizen of Alexandria. We dismiss the third prayer of relief.

Next, we agree with the general spirit of the Crown's rebuttal to the second claim. Though personally unfortunate for Claimant, it is not an issue for the government that Claimant joined after a deadline had elapsed. Though this no longer matters (as determined above, Claimant is and has been a citizen), even at the time of filing the Claimant was not unjustly deprived of any right, privilege, or ability. Though this Court does not necessarily approve of the Crown's specific argument, the general understanding exists and is undeniably true that some times in life one event happens before another, and if the chronological order had been switched someone would have benefited. The mere fact of this beneficial alternative time-swap does not necessitate legal remedy. For this reason, we dismiss the second prayer of relief.

Finally, as to the first prayer of relief, we believe that though possible that the act could be used in an unconstitutional manner, to strike it down at this moment would be premature and unnecessary. When reviewing an act or action of Parliament or Government, the test that must be conducted is one of hindsight. This "hindsight test" is simple: Has the act or action violated a constitutional principle, or is its very existence an obvious manifestation of future unconstitutionality? In the case of an act passing mandating that the Prime Minister eat a slice of cheese every day, theoretically the Prime Minister could leverage this act to say that as he is a citizen and all citizens should be treated equally under the law, all citizens must eat a slice of cheese and any who do not must be executed. This action by the Prime Minister would clearly be unconstitutional. However, this potential, unconstitutional act that does not naturally flow from the act of Parliament passed does not necessarily make the law unconstitutional.

We should only disprove those acts and actions which naturally produce unconstitutionality, or themselves are surely unconstitutional. Here, it is possible that the Government could use the act in question to an unconstitutional end. However, the act itself does not naturally produce unconstitutional results by a well-meaning Government intent on being good stewards of the Kingdom. Though individual acts by the Government justified by the law could be ruled unconstitutional, those acts occurring (or having the potential to occur) does not mean the law itself must be removed. With this in mind, we dismiss the first prayer of relief.

It seems necessarily true that at the time the act was originally brought into law, it withdrew potential citizenship from future players without providing any clear remedy for a path to citizenship, as the exams had not been set up at that time. However, at this time we hesitate to answer the question of what happens when a law is promulgated that is inherently unenforceable. The immediate impotency of the law in question meant that in effect, Parliament had temporarily withdrawn the ability for new players to become citizens. This action is not in and of itself unconstitutional, so we refuse to rule on it at this time.

We see the possibility that such a ruling at this time could have unintended consequences. Stating that any legislation that is at any point unenforceable is immediately unconstitutional and shall be struck could lead to nefarious legislating tricks where a malicious member could attach an unenforceable provision to a bill in an attempt to cause confusion and chaos, and ultimately doom that piece of legislation. For now, we are satisfied that the unenforceability changed very little (as it merely did not grant individuals an opportunity, as opposed to depriving them of something they already had) and the immediate result was one that Parliament could have already legislated if it wanted to. The eventual amendment to grant citizenship to all who joined remedies any further malady inflicted by the unenforceability.

-=-​

Ultimately, both parties are correct: It is neither party's fault that Claimant joined when they did. It is a simple fact which unfortunately resulted in the Claimant not becoming a citizen until the law was amended. However, Claimant was not constitutionally entitled to citizenship. There is, truly, no ill to be remedied, though if there were it already has been. Claimant is now undeniably a citizen, a fact which my sister and I in the majority are confused regarding the Claimant’s insistence to deny.

The Claimant's rights would have been violated only if they were a citizen upon joining (they were not), they had some inviolable right vested by the constitution that was ripped from them (they had not, or if they did it has not been shown in any convincing manner beyond "I wish I could do this"), or some other thing was promised to them that the Government refused to grant. None of these have been shown, and thus we deny the Claimant's contentions. This case is awarded to the Crown-Defendant, and we rest. As we close court, we thank both parties and all involved for their diligence, efforts, and patience.