______________________________________________

CASE NO. 1120465

______________________________________________

HUGH McINNISH, et al.,

Appellants,

v.

BETH CHAPMAN, in her capacity as Secretary of State,

Appellee.
_____________________________________________

ON APPEAL FROM THE CIRCUIT COURT OF

MONTGOMERY COUNTY, ALABAMA

CV 2012-1053
______________________________________________

BRIEF OF AMICUS CURIAE

In support of the Plaintiffs/Appellants, the Constitution of Alabama, the

Constitution of the United States of America, the Rule of Law, the Citizens and
Residents of the State of Alabama, the American People, and Priceless LIBERTY.

By Scott Rille, Amicus curiae

Natural-born American Citizen
August 4, 2013
______________________________________________________________

COVER SHEET
 ______________________________________________

CASE NO. 1120465

______________________________________________

HUGH McINNISH, et al.,

Appellants,

v.

BETH CHAPMAN, in her capacity as Secretary of State,

Appellee.
_____________________________________________

ON APPEAL FROM THE CIRCUIT COURT OF

MONTGOMERY COUNTY, ALABAMA

CV 2012-1053
______________________________________________

BRIEF OF AMICUS CURIAE

In support of the Plaintiffs/Appellants, the Constitution of Alabama, the

Constitution of the United States of America, the Rule of Law, the Citizens and
Residents of the State of Alabama, the American People, and Priceless LIBERTY.

By Scott Rille, Amicus curiae

Natural-born American Citizen
August 4, 2013
______________________________________________________________

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 TABLE OF CONTENTS

I. TABLE OF AUTHORITIES......2
II. CONCISE STATEMENT OF THE IDENTITY OF THE AMICUS
CURIAE AND ITS INTEREST IN THE CASE5
III. CONSTITUTIONAL QUESTION OF LAW PRESENTED.........................5
III. TWO POSSIBLE ANSWERS TO THE QUESTION....6
IV. WHY AMICUS CURIAES QUESTION SHOULD BE ANSWERED...6
VI. CONCLUSION.....................12
VII. CERTIFICATE OF SERVICE ................................................13
VIII. EXHIBITS 1 - 9 ATTACHED HERETO

TABLE OF AUTHORITIES

I. United States Constitution, Article I, Section 8, Clause Offenses against the

Law of Nations: The Congress shall have Power . . . To define and punish
Piracies and Felonies committed on the high Seas, and Offenses against the
Law of Nations.

II. 1775 Edition. Le Droit Des Gens, Livre I, Chapitre XIX, Page 115; . 212.
Des citoyens & naturels: Les citoyens sont les members de la socit civile:
lis cette socit par certains devoirs, & soumis son autorit, ils participant
avec galit ses avantages. Les naturels, ou indigenes, sont ceux qui sont
ns dans le pays, de parens citoyens.

III. United States Constitution, Article II, Section1, Clause 5: No Person except
a natural born Citizen, or a Citizen of the United States, at the time of the
Adoption of this Constitution, shall be eligible to the Office of President:
neither shall any Person be eligible to that Office who shall not have attained to
the Age of thirty five years, and been fourteen years a Resident within the
United States.

IV. Alabama Rules of Appellate Procedure

NOTE: Amicus curiae believes a Constitutional Amendment, pursuant to United

States Constitution, Article V, would be required to redefine, amend or repeal the

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original wording or meaning of Clause 5 above, that no such Amendment has been

lawfully added to the Constitution, and that Clause 5 continues to be controlling

law in the United States of America, including the State of Alabama.

[NOTE: The 1775 Edition of Le Droit Des Gens portrayed in Exhibit 2 is the very

volume Dr. Benjamin Franklin deposited in 1775 at The Library Company of

Philadelphia, which he and some other businessmen founded in 1731, and the

edition used extensively by the Founders and Framers. (Please see Exhibit 2

attached hereto.)] [Eng. Tr. of above French clause: Translated as Founding Father

John Jay may have translated it before writing his famous letter, dated July 25,

1787, to George Washington, Presiding President of the Constitutional Convention

at Philadelphia [1787] (Please see Exhibit 1 attached hereto.): The citizens are the

members of the civil society: bound to this society by certain duties, & subject to

its authority, they equally participate in its advantages. The natural born citizens

(naturels, natural, naturally, born, inborn, begotten), or natives (indigenes,

indigenous, naturally, inborn), are those born in the country, of parents who are

citizens. (Please see Exhibit 4 attached hereto.) Please take note of the fact that the

marginal entry, . 212. Des citoyens & naturels and the text Des citoyens and

de parens citoyens clearly indicate the subject of this section is CITIZENS.

John Jay was fluent in the French language and thoroughly qualified to interpret

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and translate French and English. (Please see Exhibit 3 attached hereto.) Would it

be unreasonable to conclude that anyone fluent in French reading . 212 could

easily and logically combine the three terms Les naturels [natural, natural-born],

ns [born], and citoyens [citizens] into the phrase natural born citizens?

Amicus curiae believes it would be illogical to believe John Jay could read Les

naturels in Le Droit Des Gens and not contextually translate these words into

anything but natural born Citizens, as he wrote in his letter to His Excellency

General Washington on 25 July 1787 (Please see Exhibit 1attached hereto).

John Jay was a delegate to the First & Second Continental Congresses and was

elected President of the 6th Continental Congress. Benjamin Franklin wrote:

Monsignor Charles F. W. Dumas

Chez E. van Harrevelt
Amsterdam

Dear Sir,
Philadelphia, 9 December, 1775.

I am much obliged by the kind present you have made us of your edition of
Vattel. It came to us in good season, when circumstances of a rising state make
it necessary frequently to consult the law of nations. Accordingly, that copy,
which I kept (after depositing one in our own public library here, and sending the
other to the College of Massachusetts Bay, as you directed), has been continually
in the hands of the members of our Congress, now sitting, who are much
pleased with your notes and preface, and have entertained a high and just esteem
for their author.
Kindest
regards,
Benjamin Franklin
(Please see Exhibit 2 attached hereto.)
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Amicus curiae believes that it would be unreasonable to assume during all the

years John Jay participated and served in the Continental Congresses and being

fluent in French, that he did not thoroughly familiarize himself with Vattels Le

Droit Des Gens continually in the hands of the members of our Congress, and

discuss Vattels PRINCIPES DE LA LOI NATURELLE [Principles of the

Natural Law] with his fellow delegates in intimate detail (Please see Exhibit 5). In

addition, John Jay owned his own personal copy of The Law of Nations.

CONCISE STATEMENT OF THE IDENTITY OF THE AMICUS CURIAE

AND ITS INTEREST IN THE CASE

Amicus curiaes name is Scott Rille, he lives in Tulare, CA, is a 73-year-old

Vietnam-era Veteran, Narural-born American Citizen and AMERICAN

PATRIOT. Amicus curiaes interest in the case is his intense love of the priceless

LIBERTY he inherited at birth, and love of his Constitution of the United States of

America and his Constitutional Republic. Amicus curiae sincerely believes that

lack of a Constitutionally defensible and authoritative definition of natural born

Citizen is a clear and present danger to his LIBERTY and the LIBERTY of every

Alabamian and American, and is foundational to this Court arriving at a just

decision in this matter.

CONSTITUTIONAL QUESTION OF LAW PRESENTED

Amicus curiae respectfully requests this Honorable Court courageously and with
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Constitutional authority, clearly and unambiguously answer the following

Constitutional question of law:

Where does the Constitution of the United States specifically require the
President of the United States must be born in the United States of America?

TWO POSSIBLE ANSWERS TO THE QUESTION

Answer No. 1: The Constitution of the United States does not specifically require

the President of the United States must be born in the United States of America.

NOTE: Amicus curiae believes that most intelligent, knowledgeable, logical and

rational citizens would reject Answer No. 1 as legally unacceptable, illogical,

irrational and ludicrous.

Answer No. 2: The Constitution of the United States, by Constitutional extension

and authority, does specifically require the President of the United States must be

born in the United States of America. Amicus curiae sincerely believes the

Constitution does so through a unique, 2-step Constitutional process.

WHY AMICUS CURIAES QUESTION SHOULD BE ANSWERED

The Constitution of the United States and the Constitution of Alabama are the Rule

of Law for Alabama citizens, residents, businesses, governments, courts, and other

lawful entities. Preamble to the Constitution of the State of Alabama:

We the people of the State of Alabama, in order to establish justice, insure

domestic tranquility, and secure the blessings of liberty to ourselves and our
posterity, invoking the favor and guidance of Almighty God, do ordain and
establish the following Constitution and form of government for the State of
Alabama.
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By requiring that the President of the United States must be a natural born

Citizen [United States Constitution, Article II, Section 1, Clause 5], Amicus

curiae believes our Founding Fathers and Constitutional Framers created a new

and unique class of Person and Citizen, and that only Persons and Citizens

belonging to this unique class (which includes most Americans born on U.S. soil)

are eligible to hold the Office of President of the United States and Commander-in-

Chief of the Armed Forces of the United States.

It is a well-established fact that our Founding Fathers and Constitutional Framers

relied heavily on Emmerich de Vattels Le Droit Des Gens [The Law of Nations],

First French Edition 1758, Second French Edition 1775, while involved in the

weighty matter of creating our Constitution and Constitutional Republic (Please

see Exhibits 1and 2 attached hereto). Founding Father and future first Chief Justice

of the United States, John Jay, on July 25, 1787, sent a letter to George

Washington, Presiding President of the Constitutional Convention at Philadelphia

[1787]. Jay wrote:

Permit me to hint, whether it would be wise and seasonable to provide a strong

check to the admission of Foreigners into the administration of our national
Government; and to declare expressly that the Commander in Chief of the
American army shall not be given to, nor devolve on, any but a natural born
Citizen.

Amicus curiae believes that John Jay may have been fully aware of the root

meanings of Les naturels, ou indigenes (Please see Exhibit 4 attached hereto),

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that strong feelings and intent to create a new and unique Constitutional Republic,

free of the beliefs, actions, and laws that governed the nations of Europe, and

governed by new, distinctly American laws were prevalent among the Founders

and Framers, and that John Jay may have chosen to knowledgably interpret

Vattels Les naturels as natural born citizens. Amicus curiae believes that John

Jay was intellectually capable and possessed his inalienable right to do so. Many of

the Framers were fluent in French, including Jay, the delegates unanimously

accepted the clause natural born Citizen written in the letter Jay sent to

Washington as valid without debate or opposition, and wisely included this

extremely important to the safety of our Nation clause at United States

Constitution, Article II, Section 1, Clause 5.

Amicus curiae believes that many people in the United States falsely believe and

claim that the Constitution of the United States fails to define the natural born

Citizen clause found at United States Constitution, Article II, Section 1, Clause 5.

Amicus curiae believes, and respectfully submits, that said belief and claim are

patently false, that the Framers of the Constitution of the United States did not fail

to Constitutionally define natural born Citizen, and that the Framers wisely

and purposely did so through a unique, 2-step Constitutional process:

STEP 1: United States Constitution, Article I, Section 8, Clause Offenses against

the Law of Nations: The Congress shall have Power . . . To define and punish
 8
Piracies and Felonies committed on the high Seas, and Offenses against the Law

of Nations.

STEP 2: The Law of Nations, Book 1, Chapter XIX, 212, The citizens are the

members of the civil society: bound to this society by certain duties, & subject to

its authority, they equally participate in its advantages. The natural born citizens

(naturels), or natives (indigenes), are those born in the country, of parents who are

citizens. (Parenthesis supplied.)

By granting the Congress Power . . . To define and punish Piracies and Felonies

committed on the high Seas, and Offenses against the Law of Nations, Amicus

curiae sincerely believes our Founding Fathers and Constitutional Framers

extended Constitutional authority to The Law of Nations.

The Law of Nations, First French Edition 1758, Second French Edition 1775,

clearly and unambiguously defines natural born citizens. Natural born

citizenship contains two (2), not one (1), eligibility requirements. To qualify as

natural born citizens persons must be 1. born in the country, and 2. of parents

who are citizens. No exceptions.

Amicus curiae believes that to be eligible to hold the Office of President of the

United States, that Person must be a natural born Citizen, meaning he or she

must be born in the United States of America [including United States Territories]
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and both parents of said Person must have been citizens of the United States at

the time of said Persons birth, and also meet the other eligibility requirements

found at United States Constitution, Article II, Section 1, Clause 5.

Amicus curiae sincerely believes that electing and inaugurating an ineligible

person as president in violation of the Constitution would be tantamount to

rendering the Constitution null and void, and to tossing it, the Constitutional

Republic it undergirds, and the priceless LIBERTY it guarantees onto the

garbage heap of history!

On 4 June and 18 June, 1940, Sir Winston Churchill spoke these immortal words

of wisdom and courage to the Parliament and beleaguered people of Great Britain:

We shall go on to the end. We shall fight in France, we shall fight on the

seas and oceans, we shall fight with growing confidence and growing
strength in the air, we shall defend our island, whatever the cost may be.
We shall fight on the beaches, we shall fight on the landing grounds, we
shall fight in the fields and in the streets, we shall fight in the hills; we
shall never surrender, . . . But if we fail, then the whole world,
including the United States, including all that we have known and cared
for, will sink into the abyss of a new dark age made more sinister, and
perhaps more protracted, by the lights of perverted science. Let us
therefore brace ourselves to our duties, and so bear ourselves, that if the
British Empire and its Commonwealth last for a thousand years, men will
still say, This was their finest hour!

Amicus curiae sincerely believes that Your Honors courage to review and to

Justly rule on this weighty matter herein presented could be your finest hour!

May God bless the citizens and residents of the great State of Alabama and the

United States of America.

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Amicus curiae believes that this matter of justly answering his Constitutional

question of law, and thereby establishing the authoritative, Constitutional

definition of the natural born Citizen clause, is the most important matter,

relevant to the survival of our priceless LIBERTY, State of Alabama and

Constitutional Republic of the United States of America, and the Rule of Law

adjudicated in the history of this Court. Honorable Justices, you are hereby

afforded the weighty opportunity to responsibly and courageously honor your

solemn Oaths:

"I, , solemnly swear (or affirm, as the case may be) that I will support the
Constitution of the United States, and the Constitution of the State of Alabama, so
long as I continue a citizen thereof; and that I will faithfully and honestly discharge
the duties of the office upon which I am about to enter, to the best of my ability. So
help me God." SECTION 279 [Alabama Constitution],

and to become Alabamas and Americas

CHAMPIONS for LIBERTY!

Since 1775, millions of Patriots have sacrificed their lives and sustained horrific

injuries in defense of our Constitutions, Constitutional Republic, and priceless

LIBERTY. As a genuine American Patriot, Amicus curiae proudly and

courageously stands shoulder-to-shoulder with our Founding Fathers, who

mutually pledged to each other their Lives, their Fortunes, and their sacred Honor,

and with our courageous men and women in uniform in defense of LIBERTY, and
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with their families.

Amicus curiae respectfully invites this Honorable Court to review and take Judicial

notice of the Exhibits attached hereto.

Quotation from Abraham Lincolns address, The Perpetuation of Our Political

Institutions, before the Young Men's Lyceum of Springfield, Illinois, January 27,
1838:

Let reverence for the laws be breathed by every American mother. Let it be taught
in schools, in seminaries, and in colleges. Let it be written in primers, [in] spelling
books and in almanacs. Let it be preached from the pulpit, proclaimed in legislative
halls, and enforced in the courts of justice. In short, let reverence for the law
become the political religion of the nation. . . Shall we expect some transatlantic
military giant, to step over the ocean, and crush us at a blow? Never! All the
armies of Europe, Asia and Africa combined, with all the treasure of the earth (our
own excepted) in their military chest; with a Bonaparte for a commander, could not
by force, take a drink from the Ohio, or make a track on the Blue Ridge, in a trial
of a Thousand years. At what point, then, is the approach of danger to be
expected? I answer, if it ever reach us, it must spring up amongst us. It cannot
come from abroad. If destruction be our lot, we must ourselves be its author and
finisher. As a nation of freemen, we must live through all time, or die by suicide.

CONCLUSION

Amicus curiae sincerely believes and respectfully submits that confusion

concerning the definition of natural born Citizen threatens the LIBERTY,

safety and well-being of every Alabama citizen, resident, and American, threatens

the survival of the Rule of Law, threatens the survival of the State of Alabama and

Constitutional Republic of the United States of America, that this Honorable Court

should have a compelling interest in settling this weighty matter for all time, that a

clear, unambiguous and Constitutionally defensible and authoritative definition of

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natural born Citizen urgently needs to be identified, and respectfully requests

this Honorable Court, with Constitutional authority, in the interest of preserving

the personal LIBERTY, safety and well-being of all Alabamians and Americans, in

the interest of preserving the Rule of Law, and in the interest of Justice answer the

above Constitutional question of law and issue its findings and ruling.

Respectfully submitted this 4th day of August, 2013.

_________________________
Scott Rille, Amicus curiae 139 East Tulare Avenue, 325
Natural-born American Citizen Tulare, CA 93274
AMERICAN PATRIOT 559-688-0357
Vietnam-era Veteran American.Patriots@sbcglobal.net

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true copy of the following document, BRIEF OF

AMICUS CURIAE has been furnished by U.S. Mail this 8th day of August, 2013 to
the following parties:

HUGH McINNISH, et al. through their attorney:

Larry Klayman, Esq.

Klayman Law Firm
2020 Pennsylvania Avenue, NW
Suite 800
Washington, D.C. 20006
Counsel for Appellants

BETH CHAPMAN, Alabama Secretary of State through her attorneys:

Honorable Attorney General of Alabama Luther Strange and the

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Honorable Assistant Attorney General Margaret L. Fleming
Office of the Attorney General of Alabama
501 Washington Street
Montgomery, Alabama 36130
Counsel for Appellee

Dated: August 8, 2013

/s/ Scott Rille

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