The State of Missouri v The St. Louis Zoo Subdistrict of the St. Louis Metropolitan Zoological Park and Museum District
Whereas the The St. Louis Zoo Subdistrict of the St. Louis Metropolitan Zoological Park and Museum District has infringed upon the preemption of the State of Missouri acting by and through the duly elected general assembly in the entire field of legislation touching in any way firearms, et al as codified in RSMo 21.750.1 and 21.750.2 and whereas The St. Louis Zoo Subdistrict of the St. Louis Metropolitan Zoological Park and Museum District having been created under RSMo 184.350 and deriving its authority to pass and implement rules and regulations under RSMo 184.362 is not authorized under such authority to pass any ordinance and therefore cannot claim any exception to preemption under RSMo 21.750.3, and as such the infringement is blatant and egregious upon the authority of the State of Missouri acting by and through the general assembly and therefore the Attorney General of the State of Missouri does hereby ask that this court permanently enjoin and prohibit the The St. Louis Zoo Subdistrict of the St. Louis Metropolitan Zoological Park and Museum District from implementing any rule or scheme which infringes upon said preemption including, but not limited to, removing any signage prohibiting any firearm or other weapon covered under RSMo 21.750 or RSMo 571, from threatening or actually causing removal or exclusion from zoo property of any citizen lawfully carrying such weapons and further to overturn the Temporary Restraining Order issued in St. Louis City Court against Jeff Smith, et al as well as rejecting in its entirety the corresponding Petition for Preliminary Injunction and Permanent Injunction against such person(s) as each and all do or will violate RSMo 21.750 and RSMo 571.
21.750. 1. The general assembly hereby occupies and preempts the entire field of legislation touching in any way firearms, components, ammunition and supplies to the complete exclusion of any order, ordinance or regulation by any political subdivision of this state. Any existing or future orders, ordinances or regulations in this field are hereby and shall be null and void except as provided in subsection 3 of this section.
2. No county, city, town, village, municipality, or other political subdivision of this state shall adopt any order, ordinance or regulation concerning in any way the sale, purchase, purchase delay, transfer, ownership, use, keeping, possession, bearing, transportation, licensing, permit, registration, taxation other than sales and compensating use taxes or other controls on firearms, components, ammunition, and supplies except as provided in subsection 3 of this section.
3. (1) Except as provided in subdivision (2) of this subsection, nothing contained in this section shall prohibit any ordinance of any political subdivision which conforms exactly with any of the provisions of sections 571.010 to 571.070, with appropriate penalty provisions, or which regulates the open carrying of firearms readily capable of lethal use or the discharge of firearms within a jurisdiction, provided such ordinance complies with the provisions of section 252.243. No ordinance shall be construed to preclude the use of a firearm in the defense of person or property, subject to the provisions of chapter 563.
I'm thinking it would go something like the above.
IANAL and the above is
only a conceptualization responding the Grapeshot's question. I make no claim that the manner or style as set out is sufficient, legal or proper under the local rules of any MO court so please do not read anything more into it than that and criticize based on it not meeting some court petitioning something or other.
