Justin Freeman v. Pamela Bondi, et al.

District Court, D. Connecticut·Decided August 5, 2026·No. 3:25-cv-00926·Unknown

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ---------------------------------------------------------------- x JUSTIN FREEMAN : : Plaintiff, : : v. : 3:25-CV-00926 (SFR) : PAMELA BONDI, et al. : : Defendants. : --------------------------------------------------------------- x

MEMORANDUM & ORDER

Plaintiff Justin Freeman brings this action against United States Attorney General Pamela Bondi (“USAG”),1 all thirteen Connecticut State’s Attorneys, and the Commissioner of Connecticut’s Department of Emergency Services and Public Protection (the “State Defendants”) for alleged violations of his right to bear arms under the United States Constitution. For the reasons that follow, I dismiss in part and stay in part Freeman’s Amended Complaint pending resolution of Freeman’s administrative remedies. I. BACKGROUND A. Factual Background Facts are taken from the Amended Complaint, except where noted. Freeman is a citizen of the United States and Connecticut. Am. Compl. ¶ 8, ECF No. 21-2. On November 28, 2018, Freeman pleaded guilty to a one-count information charging him with violating 26 U.S.C. § 7206(1). Id. ¶ 65. The stipulation of offense conduct stated that Freeman signed false income

1 Todd Blanche is the Acting Attorney General of the United States and thus is substituted as Defendant in place of Pamela Bondi pursuant to Federal Rule of Civil Procedure 25(d). tax returns in 2010, 2011, and 2012 that significantly underreported income that Freeman made from his law practice. Id. ¶ 66. Freeman was a practicing attorney before his conviction. Id. ¶ 5. In 2022, following his

release from prison, Freeman was readmitted to the Connecticut bar and in 2025, was reinstated to the bar for the District of Connecticut. Id. ¶¶ 77-78, 81. Other than the tax offense, Freeman has no prior or subsequent criminal record. See id. ¶ 82. Freeman has no history of violence, no mental health or substance abuse issues, and is not subject to any restraining orders. Id. ¶¶ 82-84. Nonetheless, pursuant to federal and state law, Freeman is prohibited from purchasing or possessing firearms. Id. ¶ 5. The Complaint names as a defendant the Attorney General of the United States. Id. ¶

9. The Attorney General is responsible for the criminal enforcement of 18 U.S.C. § 922(g) which, inter alia, bars people previously convicted of felonies from possessing any firearm or ammunition. Id. ¶¶ 9, 24. The other Defendants (“State Defendants”) include: Sharmese Walcott, Michael Gailor, Christian Watson, Matthew Gedansky, Maureen Platt, David Shannon, Margaret Kelley, Joseph Corradino, David Applegate, John Doyle, Jr., Paul Narducci, Paul Ferencek,2 and Anne Mahoney, all of whom are Connecticut State’s Attorneys; and Ronnell Higgins, the

Commissioner of Connecticut’s Department of Emergency Services and Public Protection. Id. ¶¶ 10-22.

2 Defendant Ferencek is listed in the case caption and the prayer for relief as a defendant, but is not described in the claims themselves. I nonetheless construe Freeman as bringing identical claims against Ferencek as against the other Connecticut State’s Attorneys. The State’s Attorneys are responsible for prosecuting individuals who violate Connecticut statutes, including statutes which prohibit individuals convicted of felonies, inter alia, from possessing or selling firearms, ammunition, or electronic defense weapons. Id. ¶¶

10-22; 50-64. Defendant Higgins, in his capacity overseeing the Connecticut State Police, is responsible for, inter alia, enforcing state laws regarding possession, sale, or transfer of firearms by individuals convicted of felonies. Id. ¶ 22. According to the Amended Complaint, Freeman “intends to apply for a Connecticut pistol permit to lawfully purchase, possess, and carry firearms and ammunition.” Id. ¶ 96. Additionally, in September 2025, after the filing of this suit, the Department of Justice invited Freeman to apply for a restoration of his firearms rights pursuant to 18 U.S.C. § 925(c) by

submitting an application to the Office of the Pardon Attorney. Pl.’s USAG Opp’n 11, ECF No. 29; USAG Mem. 9, ECF No. 24-1. B. Procedural History Freeman filed the initial Complaint in this action on June 9, 2025. ECF No. 1. On October 1, 2025, the USAG moved for a stay due to a lapse in funding, which the Court granted on October 2, 2025. ECF Nos. 19-20.3 On January 14, 2026, the Court lifted the stay. ECF No. 25. On December 1, 2025, Freeman filed an Amended Complaint.4 ECF No. 21. On

January 9, 2026, the State Defendants filed their Motion to Dismiss and the USAG filed a

3 This case was initially assigned to the Honorable Omar A. Williams. 4 Freeman filed a Motion to Amend/Correct his Complaint and provided the Amended Complaint as an attachment. See ECF No. 21, 21-2. As the court noted in a subsequent order, “Plaintiff was free to amend the Complaint ‘as a matter of course’ without the court’s leave” but nonetheless granted the motion “for the avoidance of doubt.” ECF No. 25. The USAG and the State Defendants Motion to Dismiss or Stay. ECF Nos. 23-24; see State Defs.’ Mem., ECF No. 23-1; USAG Mem., ECF No. 24-1. Freeman filed his Memoranda in Opposition to the Motions to Dismiss on February 23, 2026. Pl.’s USAG Opp’n, ECF No. 29; Pl.’s State Opp’n, ECF No. 30. USAG

filed a Reply on March 16, 2026, and the State Defendants filed their Reply on March 17, 2026. USAG Reply, ECF No. 34; State Defs.’ Reply, ECF No. 35-1. The case was transferred to me on April 24, 2026. ECF No. 38. II. LEGAL STANDARD The standard governing motions to dismiss under Rule 12(b)(6) is well established. A complaint may not survive unless it contains “sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009); Kim v. Kimm, 884 F.3d 98, 103 (2d Cir. 2018); Lapaglia v. Transamerica Cas. Ins. Co., 155

F. Supp. 3d 153, 155-56 (D. Conn. 2016). Although this “plausibility” requirement is “not akin to a probability requirement,” it “asks for more than a sheer possibility that a defendant has acted unlawfully.” Iqbal, 556 U.S. at 678. The court must “draw all reasonable inferences in [the plaintiff’s] favor, assume all well-pleaded factual allegations to be true, and determine whether they plausibly give rise to an entitlement to relief.” Faber v. Metro. Life Ins. Co., 648 F.3d 98, 104 (2d Cir. 2011) (internal quotation marks omitted). However, the court is not

bound to accept “conclusory allegations or legal conclusions masquerading as factual conclusions.” Rolon v. Henneman, 517 F.3d 140, 149 (2d Cir. 2008).

expressly addressed their motions to dismiss against the Amended Complaint. See State Defs.’ Mem. 2 n.1; USAG Mem. 2 n.1. III. DISCUSSION Freeman’s Amended Complaint alleges five claims against the Defendants in their official capacities: two against the State Defendants and three against the USAG. Freeman seeks declaratory judgments that various state and federal statutes, which prevent him from

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Justin Freeman v. Pamela Bondi, et al., (D. Conn. 2026).

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