https://storage.courtlistener.com/recap ... 73.1.0.pdf
12. But Nevada’s Ban completely and categorically prohibits individuals not
prohibited from exercising their Second Amendment rights from possessing, acquiring, and
self-manufacturing firearms that are of types, functions, and designs, and are themselves,
commonly owned and possessed firearms—self-made firearms that do not bear a
manufacturer’s serial number—by law-abiding citizens for lawful purposes.
13. Plaintiffs therefore bring this challenge because they unquestionably face “a
realistic danger of sustaining a direct injury as a result of the law’s operation or
enforcement,” Skyline Wesleyan Church v. Cal. Dep't of Managed Health Care, 968 F.3d
Case 3:21-cv-00268 Document 1 Filed 06/10/21 Page 4 of 38
COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF
738, 747 (9th Cir. 2020), seek to vindicate their rights, and to immediately and permanently
enjoin enforcement of Nevada’s Ban as required to conform the law to the Constitution’s
text, our Nation’s history and tradition, and the Supreme Court’s binding Heller, McDonald,
and Caetano decisions.