---
title: "No-Fault Tyranny: An Indictment of Title IV-D and the Assault Upon Family and Freedom"
description: "Exposing the Lies Once and For All"
taxonomies:
   tags:
      - law
      - justice
      - balance
author: "Tim D"
authorGithub: "nrdxp"
authorImage: "https://avatars.githubusercontent.com/u/34083928?v=4"
authorTwitter: "nrdexp"
date: "2025-08-19"
category: "legal"
extra:
  read_time: true
  repo_view: true
---

> ⚠️ You probably want to wait for the legalese-english translation of this in an upcoming post.

# Preamble

What follows is the current draft of my formal civil rights complaint against the State of Colorado, its judicial and prosecutorial entities, and the U.S. Department of Health and Human Services (including the Office of Child Support Enforcement and its Secretary, Robert F. Kennedy Jr.). Due to a relentless pattern of obstructions—the latest being a federal judge in Colorado ordering me to refile, demanding dry procedural compliance to non-existent rules in willful ignorance of the escalating emergency nature of the circumstances and the substantive nature of the constitional claims which cannot be ignored (Haines v. Kerner, 404 U.S. 519 [1972])—I have not yet submitted this updated version to the courts. For this very reason, I intend to pursue a change of venue based on the systemic bias and conflicts detailed herein, which will require navigating the existing case, updating it, and transferring jurisdiction to a more neutral locale, such as the District of Tennessee.

In the meantime, I am publishing this document publicly on my website because I no longer trust any arm of the government to handle it fairly or transparently. These arguments must enter the public domain immediately to begin exposing—and ultimately dismantling—this abomination of justice that has shattered countless homes, lives, and futures. Even if my case falters in court, the legal and evidentiary foundation laid here is unassailable and must become common knowledge if we are to course-correct and safeguard our children's future—for if we still believe our children are our future, we cannot ignore this threat. I plan to condense these arguments into a more digestible, less legally exhaustive format, but in the interest of urgency, and for the sake of elucidating the truly (quite literally) criminal nature of this system in its totality, I've decided the full legal filing was worth sharing now.

After pondering most of my life at the roots of modern societal woes, I can now pinpoint no issue more pivotal than this one. It underpins so much decay: from widespread debauchery and moral apathy to fiendish sexual deviancy and the largest-scale global child-trafficking networks in history. Consider, for example, the modern "battle of the sexes"; that perplexing tension between men and women fueling endless cultural wars, from #MeToo backlash to incel movements and declining birth rates. Nobody can seem to agree what lay at the root cause of all this chaos, but I'm now forced to conclude that this isn't organic; it's engineered by the corrupt state apparatus for profit and dominion. If you don't believe it, I challenge you to make it to the end of this document while retaining that skepticism.

By pitting genders against each other through biased and (as shown) illegal laws that largely demonize men, reward manipulation, and extract wealth from broken families, the system ensures perpetual conflict. No sane, informed modern man would risk marriage or fatherhood in this horrific meat grinder, contributing to plummeting birth rates as families crumble and society weakens, all while the racketeers count their billions and power consolidates further and further away from the people.

Meanwhile, we blame everything from "feminism" to "incel culture" for the high crime of treason (yes, I said it) committed by our own governments against their most vulnerable citizens; after all, it is the very children they claim to defend which will pay the worst price for profiteering. It is time to point the finger squarely where it deserves to be pointed. While my suit targets specific Colorado statutes and the federal Title IV-D program for legally pragmatic reasons, analogous laws plague virtually every Western nation. I can no longer escape the conclusion that this represents a deliberate, coordinated assault on the family structure—the bedrock of freedom itself.

John Locke, whose philosophy profoundly shaped the American Revolution and our Constitution, asserted that the family is the first unit of society; I would add that, without the protection of family, there can be nothing but slavery. In our time, this truth is self-evident. Skyrocketing debt and living costs force us into isolated "independence," while we harbor grudges against fathers cast into an incomprehensible meat grinder of a system they could neither comprehend nor defend against. It's time to grow up, wake up, and forgive our fathers as I have forgiven mine. We must reject the delusion that endless debt slavery through artificial "independence" equates to a free society. We must restore the family, and the buttress against tyranny it affords us, or I fear we deserve the dystopia that awaits us.

It took me—an intelligent if perpetually misunderstood individual actively suffering under these legal perversions for most of my adult life—years to piece this all together and fully comprehend just what it is that I am truly facing. Still further, it took my children [going missing](../letter-to-my-children) for months while every single state actor remained complicit-refusing to lift a finger-before I worked up the courage to offer this formal legal challenge.

I can, therefore, forgive skepticism and misunderstanding, as it was and is still difficult to believe that our institutions would corrode to this level of injustice. However, I would invite you to review my developing [moral philosophy](../code-of-rebellion) which demonstrates that such distortion is inevitable when society loses vigilance and carelessly disregards its duty to stave off entropy in the State—it's the lens that helped me see this crisis clearly, and it may, perhaps, do the same for you.

Now, every indifference to law, and every injustice meant to ensnare men seeking only to raise their children in peace has become just the opposite: my fuel. I've done the grueling work that no one else—not even the highest-paid legal "professionals"—would dare seem to undertake. What follows constitutes over a decade of thinking, researching, and pondering this specific topic, which I have unhappily been subjected to time and again throughout my life, experiencing virtually every aspect of the decay outlined, and slowly coming to realize the scope and scale of its deliberate corruptions. The legal arguments are dense, but they're your roadmap to understanding.

As I've mentioned elsewhere, I shall not trim my hair nor cut my beard until justice has finally been served, as a (insufficient) symbol of the long fight for justice for my children and their future, which I continue to willingly endure on their behalf.

Now I shall conclude this introduction with a question to the reader. How free is a man who has no say in how best to raise his children? How hollow is the lip service paid to the Constitution by our rulers—mere words to pacify the masses—while such a profoundly illegal institution endures, eroding liberty at its core? Again, as you'll come to see in this document, the grunt work of discovery is largely finished. All I need now is your backup: copy, share, repost, [donate](https://www.givesendgo.com/fathersfightforkids), mirror the document, fork the source code—do whatever it takes to flood the public domain with this message and these arguments. Prove, once and for all, that the emperor, once again, has no clothes. By all means, decide for yourselves, but first, please consider the argument: read it, absorb it, put it into your own words and join the fight before it's too late—Perhaps you will come to realize, as I have, that our families, our freedom, and our future depend on it.

---


# IN THE UNITED STATES DISTRICT COURT  
# FOR THE EASTERN DISTRICT OF TENNESSEE  
# GREENEVILLE DIVISION  

TIMOTHY WILLIAMS,  

Plaintiff,  

v.  

THE STATE OF COLORADO;  
PHIL WEISER, in his official capacity as Attorney General of Colorado;  
COLORADO JUDICIAL DEPARTMENT;  
COLORADO DISTRICT ATTORNEYS' COUNCIL;  
ROBERT F. KENNEDY JR., in his official capacity as Secretary of Health and Human Services;  
U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES;  
OFFICE OF CHILD SUPPORT ENFORCEMENT;  
DOES 1-20  

Defendants.  

Case No. \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_  

**CIVIL RIGHTS COMPLAINT UNDER 42 U.S.C. § 1983**  
**FACIAL CONSTITUTIONAL CHALLENGE TO TITLE IV-D RACKETEERING ENTERPRISE**  
**WITH REQUEST FOR EMERGENCY NATIONWIDE RELIEF**  

Timothy Williams, Pro Se  
[Address]  
[Phone Number]  
[Email Address]  

## Table of Contents  

- [Nature of the Action](#nature-of-the-action)  
- [Jurisdiction and Venue](#jurisdiction-and-venue)  
- [Parties](#parties)  
- [Standing, Ripeness, and Justiciability](#standing-ripeness-and-justiciability)  
- [Discovery of Title IV-D Racketeering Enterprise](#discovery-of-title-iv-d-racketeering-enterprise)  
- [The Systemic Funnel of Constitutional Violations](#the-systemic-funnel-of-constitutional-violations)  
- [Substantive Due Process Violations](#substantive-due-process-violations)  
- [Procedural Due Process Violations](#procedural-due-process-violations)  
- [Other Constitutional Violations](#other-constitutional-violations)  
- [Colorado's Systematic Bias Necessitating Forum Change](#forum-change)  
- [Title IV-D as a Criminal Racketeering Organization Masquerading Under Color of Law](#title-iv-d-as-a-criminal-racketeering-organization-masquerading-under-color-of-law)  
- [Summary of Constitutional Claims Facial Challenge to Title IV-D Racketeering Scheme](#summary-of-constitutional-claims-facial-challenge-to-title-iv-d-racketeering-scheme)  
- [Prayer for Relief](#prayer-for-relief)  

## Table of Authorities  

### Cases  

- Aetna Life Ins. Co. v. Lavoie, 475 U.S. 813 (1986)  
- Allied Structural Steel Co. v. Spannaus, 438 U.S. 234 (1978)  
- Bailey v. Alabama, 219 U.S. 219 (1911)  
- Board of Directors of Rotary International v. Rotary Club, 481 U.S. 537 (1987)  
- Boy Scouts of America v. Dale, 530 U.S. 640 (2000)  
- Caperton v. A.T. Massey Coal Co., 556 U.S. 868 (2009)  
- Cedric Kushner Promotions, Ltd. v. King, 533 U.S. 158 (2001)  
- Church of the Lukumi Babalu Aye v. Hialeah, 508 U.S. 520 (1993)  
- Clyatt v. United States, 197 U.S. 207 (1905)  
- Coffin v. United States, 156 U.S. 432 (1895)  
- County of Sacramento v. Lewis, 523 U.S. 833 (1998)  
- Cox v. Louisiana, 379 U.S. 559 (1965)  
- Dartmouth College v. Woodward, 17 U.S. 518 (1819)  
- DeShaney v. Winnebago County, 489 U.S. 189 (1989)  
- Employment Div. v. Smith, 494 U.S. 872 (1990)  
- Energy Reserves Group v. Kansas Power & Light, 459 U.S. 400 (1983)  
- Ex parte Young, 209 U.S. 123 (1908)  
- Fletcher v. Peck, 10 U.S. 87 (1810)  
- Gibson v. Berryhill, 411 U.S. 564 (1973)  
- Goldberg v. Kelly, 397 U.S. 254 (1970)  
- Gonzales v. Raich, 545 U.S. 1 (2005)  
- Griffin v. Illinois, 351 U.S. 12 (1956)  
- Gulf Oil Corp. v. Gilbert, 330 U.S. 501 (1947)  
- Haines v. Kerner, 404 U.S. 519 (1972)
- H.J. Inc. v. Northwestern Bell Telephone Co., 492 U.S. 229 (1989)  
- Holmes v. Securities Investor Protection Corp., 503 U.S. 258 (1992)  
- Home Building & Loan Ass'n v. Blaisdell, 290 U.S. 398 (1934)  
- In re Murchison, 349 U.S. 133 (1955)  
- In re National Presto Industries, Inc., 347 F.3d 662 (7th Cir. 2003)  
- In re Winship, 397 U.S. 358 (1970)  
- Little v. Streater, 452 U.S. 1 (1981)  
- Lochner v. New York, 198 U.S. 45 (1905)  
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992)  
- Mathews v. Eldridge, 424 U.S. 319 (1976)  
- Maynard v. Hill, 125 U.S. 190 (1888)  
- Meyer v. Nebraska, 262 U.S. 390 (1923)  
- Murphy v. National Collegiate Athletic Ass'n, 138 S. Ct. 1461 (2018)  
- New York v. United States, 505 U.S. 144 (1992)  
- Northern Pipeline Construction Co. v. Marathon Pipe Line Co., 458 U.S. 50, 58 (1982)
- Parham v. J.R., 442 U.S. 584 (1979)  
- Parratt v. Taylor, 451 U.S. 527 (1981)  
- Pierce v. Society of Sisters, 268 U.S. 510 (1925)  
- Pollock v. Williams, 322 U.S. 4 (1944)  
- Printz v. United States, 521 U.S. 898 (1997)  
- Reed v. Reed, 404 U.S. 71 (1971)  
- Reno v. Flores, 507 U.S. 292 (1993)  
- Research Automation, Inc. v. Schrader-Bridgeport Int'l, Inc., 626 F.3d 973 (7th Cir. 2010)  
- Reves v. Ernst & Young, 507 U.S. 170 (1993)  
- Roberts v. United States Jaycees, 468 U.S. 609 (1984)  
- Rochin v. California, 342 U.S. 165 (1952)  
- Rotella v. Wood, 528 U.S. 549 (2000)  
- Santosky v. Kramer, 455 U.S. 745 (1982)  
- Sedima, S.P.R.L. v. Imrex Co., 473 U.S. 479 (1985)  
- Sherbert v. Verner, 374 U.S. 398 (1963)  
- Stanley v. Illinois, 405 U.S. 645 (1972)  
- Steffel v. Thompson, 415 U.S. 452 (1974)  
- Stern v. Marshall, 564 U.S. 462, 484 (2011)
- Sturges v. Crowninshield, 17 U.S. 122 (1819)  
- Susan B. Anthony List v. Driehaus, 573 U.S. 149 (2014)  
- Troxel v. Granville, 530 U.S. 57 (2000)  
- Tumey v. Ohio, 273 U.S. 510 (1927)  
- Turner v. Rogers, 564 U.S. 431, 435 (2011)
- United States v. Angelilli, 660 F.2d 23 (2d Cir. 1981)  
- United States v. Maloney, 71 F.3d 645 (7th Cir. 1995)  
- United States v. Robertson, 514 U.S. 669 (1995)  
- United States v. Shenberg, 89 F.3d 1461 (11th Cir. 1996)  
- United States v. Thompson, 685 F.2d 993 (6th Cir. 1982)  
- United States v. Jackson, 196 F.3d 383, 387 (2d Cir. 1999)
- United States Trust Co. v. New Jersey, 431 U.S. 1 (1977)  
- Ward v. Village of Monroeville, 409 U.S. 57 (1972)  
- Washington v. Glucksberg, 521 U.S. 702 (1997)  
- Washington v. Harper, 494 U.S. 210 (1990)  
- Wilkie v. Robbins, 551 U.S. 537 (2007)
- Wisconsin v. Yoder, 406 U.S. 205 (1972)  
- Younger v. Harris, 401 U.S. 37 (1971)  

## Nature of the Action  

This facial constitutional challenge exposes Colorado's family law system as a federally-incentivized racketeering enterprise that systematically violates fundamental parental rights for financial profit. State and federal actors, operating under color of law, have created a criminal organization masquerading as legitimate government function, generating hundreds of millions in federal Title IV-D revenue through constitutional deprivations affecting Plaintiff and similarly situated individuals nationwide. This § 1983 action seeks to dismantle this illegal enterprise and restore constitutional governance while establishing binding precedent that states cannot claim federal mandate immunity when enforcing facially unconstitutional federal programs that commandeer state judicial systems into systematic constitutional violations. By holding states liable for enforcing such mandates, this action aims to re-establish the originally intended federalist balance in America, preventing federal overreach that coerces states into violating citizens' rights.  

Plaintiff's claims are not barred by Younger abstention, as this is a facial constitutional challenge to state and federal statutes of national importance, and Plaintiff intends to withdraw any ongoing state proceedings to avoid interference. See Steffel v. Thompson, 415 U.S. 452 (1974) (federal courts should not abstain from hearing constitutional challenges to state statutes merely because related state proceedings exist, particularly in facial challenges). Moreover, the ongoing harms are capable of repetition yet evading review, warranting federal intervention regardless of state proceedings.  

## Jurisdiction and Venue  

1. This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 (federal question), 1343 (civil rights), and the Declaratory Judgment Act, 28 U.S.C. § 2201. This action arises under 42 U.S.C. § 1983, 18 U.S.C. § 1961 et seq. (RICO), and the First, Fourth, Fifth, Sixth, Eighth, Ninth, Tenth, Thirteenth, and Fourteenth Amendments to the United States Constitution, Article I, Section 10 (Contracts Clause), and Article III (judicial power limitations).  

2. Venue is proper under 28 U.S.C. § 1391(e) as this action challenges federal programs with nationwide application administered by federal defendants, and under § 1391(b) as constitutional violations have interstate effects. Plaintiff has established Tennessee residency and resides within the Eastern District of Tennessee, Greeneville Division, seeking constitutional refuge from systematic bias in Colorado's judicial system that renders fair adjudication impossible due to institutional financial dependency on the challenged Title IV-D revenue streams. Additional defendants may be joined under the Federal Rules of Civil Procedure without affecting venue, as the action involves federal agencies and officials. See 28 U.S.C. § 1391(e)(1)(C) (venue proper where plaintiff resides in actions against federal officials where no real property is involved).  

3. Constitutional Necessity of Forum Change: Plaintiff originally filed constitutional claims in the District of Colorado (Case No. [redacted]) but discovered systematic judicial bias that makes impartial adjudication structurally impossible. Colorado's financial dependency on Title IV-D revenue creates institutional conflicts of interest that violate due process requirements for neutral tribunals, as evidenced by eight weeks of systematic obstruction regarding missing children and arbitrary denial followed by acceptance of identical emergency motions. Plaintiff intends to voluntarily dismiss the Colorado federal action upon filing here to consolidate proceedings and avoid duplication.  

## Parties  

### Plaintiff:  

4. Timothy Williams, a United States citizen who has established Tennessee residency to escape systematic constitutional violations spanning his entire adult life in Colorado. Plaintiff seeks constitutional refuge in this Court due to Colorado's demonstrated inability to provide impartial adjudication of challenges to the federal funding programs supporting their judicial operations. Plaintiff has standing based on ongoing harms, including deprivation of parental rights, threats of economic coercion, and systematic bias in enforcement, which are redressable through the requested relief.  

### State Defendants:  

5. The State of Colorado, sued under Ex parte Young, 209 U.S. 123 (1908), for systematic enforcement of facially unconstitutional statutes in violation of federal civil rights, including C.R.S. § 14-10-124 (best interest determinations), C.R.S. § 14-14-107.5 (parental responsibility allocations), C.R.S. § 19-1-103 (state intervention standards), C.R.S. § 18-6-801 (domestic violence), C.R.S. § 14-10-106 (no-fault divorce provisions), C.R.S. § 13-14-102 (protection orders), C.R.S. § 14-10-115 (child support), C.R.S. § 14-10-114 (maintenance), C.R.S. § 14-14-107 (income withholding), C.R.S. § 14-14-111 (contempt enforcement), and C.R.S. § 18-3-304 (parental kidnapping).  

6. Phil Weiser, in his official capacity as Attorney General of Colorado, sued for enforcement of unconstitutional statutes and failure to protect constitutional rights while enabling systematic Title IV-D revenue generation through constitutional violations.  

7. Colorado Judicial Department, sued for systematic constitutional violations and institutional bias created by Title IV-D financial conflicts, including physical denial of court access and arbitrary enforcement of procedural requirements designed to obstruct constitutional challenges.  

8. Colorado District Attorneys' Council, sued for systematic prosecutorial policies that violate constitutional rights to generate federal revenue, including selective enforcement based on Title IV-D funding incentives.  

### Federal Defendants:  

9. Robert F. Kennedy Jr., in his official capacity as Secretary of Health and Human Services, sued for administering the unconstitutional Title IV-D program under 42 U.S.C. § 658a that commandeers states into constitutional violations through financial incentives.  

10. U.S. Department of Health and Human Services, sued for creating and maintaining federal programs that systematically violate constitutional rights by conditioning funding on enforcement of facially unconstitutional procedures.  

11. Office of Child Support Enforcement, sued for direct administration of Title IV-D programs that incentivize constitutional violations through performance-based funding formulas that reward family destruction and parental rights violations.  

12. Does 1-20, unknown federal and state actors who participated in the systematic deprivation of constitutional rights under this racketeering enterprise.  

## Standing, Ripeness, and Justiciability  

13. Plaintiff has standing under Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992), as he suffers concrete injuries from the challenged statutes, including ongoing deprivation of parental rights, economic coercion, and threats of selective enforcement, directly caused by the Title IV-D enterprise and redressable through declaratory and injunctive relief.  

14. The claims are ripe as the harms are ongoing and imminent, with Plaintiff facing active threats from the system. See Susan B. Anthony List v. Driehaus, 573 U.S. 149 (2014) (pre-enforcement challenges ripe where credible threat of enforcement exists).  

15. The action is justiciable as it presents facial challenges to statutes with nationwide implications, not abstract disputes.  

## Discovery of Title IV-D Racketeering Enterprise  

16. Post-Filing Discovery of Federal Conspiracy: Subsequent to filing constitutional claims in Colorado, Plaintiff discovered the underlying financial mechanism driving systematic constitutional violations: the Title IV-D federal funding program under 42 U.S.C. § 658a that creates direct financial incentives for state actors to violate constitutional rights.  

17. Title IV-D Revenue Structure: Federal defendants provide billions in incentive payments to states based on:  

    - Family dissolution rates (more divorces = more federal funding)  
    - Custody enforcement actions (more parental conflicts = higher federal payments)  
    - Support collection volumes (more financial extractions = increased federal revenue sharing)  
    - Parental rights restrictions (more state control = enhanced federal grant eligibility)  

18. Colorado's Financial Dependency: Colorado receives approximately $200+ million annually in Title IV-D federal funding, creating institutional dependency that makes constitutional compliance economically impossible and explains systematic constitutional violations.  

19. Racketeering Enterprise Structure: The Title IV-D program operates as a criminal enterprise under 18 U.S.C. § 1961 wherein:  

    - Federal defendants provide financial incentives for constitutional violations  
    - State defendants systematically violate constitutional rights to generate federal revenue  
    - Both levels coordinate to maximize profit through family destruction while minimizing constitutional compliance  

    This enterprise involves a pattern of racketeering activity, including mail and wire fraud in support collections, extortion through coerced payments, and obstruction of justice in family courts, causing injury to Plaintiff's property and business interests.  

## The Systemic Funnel of Constitutional Violations  

20. The Title IV-D enterprise creates an interconnected statutory funnel that traps individuals in a cycle of escalating constitutional deprivations, where each violation feeds into the next, generating revenue at every stage while making escape constitutionally and practically impossible. This funnel operates through ostensibly separate but deliberately integrated civil and criminal schemes, including:

    - C.R.S. § 18-6-801 (domestic violence proceedings that presume guilt and enable weaponization of unsubstantiated allegations);  
    - C.R.S. § 13-14-102 (protection orders issued ex parte without meaningful evidentiary standards);  
    - C.R.S. § 14-10-106 (no-fault divorce eliminating fault-based grounds and remedies);  
    - C.R.S. § 14-10-124 (best interest determinations substituting state judgment for parental authority);  
    - C.R.S. § 14-14-107.5 (parental responsibility allocations imposing indefinite state supervision);  
    - C.R.S. § 14-10-115 (child support obligations creating perpetual financial extractions);  
    - C.R.S. § 14-10-114 (maintenance awards enforcing spousal support without regard to fault);  
    - C.R.S. § 14-14-107 (income withholding for automatic enforcement);  
    - C.R.S. § 14-14-111 (contempt enforcement through incarceration for non-compliance); and  
    - C.R.S. § 18-3-304 (parental kidnapping statute requiring pre-existing custody orders for enforcement, thereby conditioning protection on prior financial expenditure).  

    These statutes function as components of a single revenue-generating conspiracy, incentivized by Title IV-D funding formulas under 42 U.S.C. § 658a that reward family conflict, parental alienation, and prolonged judicial involvement. This creates perverse incentives for bad faith actors (e.g., abusive spouses or partners) to collaborate with the state in exploiting good faith parties for mutual financial gain—the state profits from federal reimbursements tied to collection volumes and enforcement actions, while the bad faith actor secures economic advantages without accountability for misconduct. The funnel ensnares both married and unmarried individuals: unmarried parents are channeled directly into custody proceedings under C.R.S. § 14-10-124 and § 14-14-107.5, while Colorado's low threshold for common law marriage (e.g., cohabitation and mutual agreement implying marital intent) can retroactively impose marital status to trigger dissolution requirements, ensuring no relationship structure evades the system's grasp.

    The interconnected nature of these statutes, combined with the deliberate design of Title IV-D funding incentives that reward escalating family conflict and financial extraction at every stage, renders any claim of incidental or uncoordinated operation untenable; the system's virtual impossibility of escape—through catch-22 mechanisms like wealth-based enforcement barriers, retaliatory prosecutions, and perpetual economic bondage—establishes a deliberately orchestrated scheme of entrapment, where state and federal actors profit from systematic constitutional violations under the pretext of child welfare.

21. **Entry Point: No-Fault Divorce and Contract Impairment (Contracts Clause Violation):** The funnel begins with C.R.S. § 14-10-106, which declares marriages "irretrievably broken" without requiring proof of fault, thereby impairing marriage contracts by eliminating enforceable terms and remedies for material breaches such as abuse, adultery, or child endangerment, in direct violation of Article I, Section 10. This impairment manifests as follows:

    a. Retroactively undermining contractual obligations without compelling justification, per Fletcher v. Peck, 10 U.S. 87, 137-138 (1810) (Contracts Clause prevents states from undermining contractual obligations) and United States Trust Co. v. New Jersey, 431 U.S. 1, 17-18 (1977) (states bound by contracts they recognize);

    b. Eliminating mutual remedies essential to binding contracts, violating Dartmouth College v. Woodward, 17 U.S. 518, 629 (1819) (contracts must provide remedies for breach) and Sturges v. Crowninshield, 17 U.S. 122 (1819) (mutual obligations fundamental);

    c. Failing to serve an important public purpose through reasonable means, contrary to Allied Structural Steel Co. v. Spannaus, 438 U.S. 234, 244 (1978) (impairment must be reasonable and necessary) and Energy Reserves Group v. Kansas Power & Light, 459 U.S. 400, 411 (1983) (no retroactive impairment of existing contracts);

    d. Lacking emergency justification for impairment, violating Home Building & Loan Ass'n v. Blaisdell, 290 U.S. 398, 428 (1934) (impairment requires compelling crisis).

    This creates the only "contract" in Anglo-American jurisprudence with no enforceable terms, as recognized in Maynard v. Hill, 125 U.S. 190, 211 (1888) (marriage as foundational societal contract), incentivizing bad faith actors to escalate misconduct without consequence while denying innocent parties legal recourse, funneling families into dissolution proceedings that generate custody disputes and trigger Title IV-D revenue through increased enforcement metrics. For unmarried couples, the funnel bypasses formal divorce but inflames conflicts through parallel custody mechanisms, often leading to retroactive common law marriage findings to impose the same impairments.

22. **Escalation Through Domestic Violence and Protection Orders (Due Process and Equal Protection Violations):** From no-fault dissolution (or equivalent custody entry for unmarried parents), the system channels conflicts into C.R.S. § 18-6-801 (defining domestic violence broadly to include non-physical acts without requiring corroboration) and § 13-14-102 (authorizing temporary protection orders based solely on affidavits, with permanent orders following minimal hearings), where accusations—often unsubstantiated—lead to presumptive guilt and immediate restraints. This escalation violates constitutional protections as follows:

    a. Denying procedural due process by reversing the burden of proof and eliminating meaningful investigation or pre-deprivation hearings, per Mathews v. Eldridge, 424 U.S. 319, 335 (1976) (adequate safeguards required before liberty deprivation); In re Winship, 397 U.S. 358, 363 (1970) (presumption of innocence essential); and Goldberg v. Kelly, 397 U.S. 254, 267-268 (1970) (meaningful hearing mandated);

    b. Depriving liberty interests through ex parte seizures without procedural safeguards, violating Washington v. Harper, 494 U.S. 210, 221-222 (1990) (protections needed for liberty deprivations);

    c. Enforcing systemic gender bias through selective enforcement—e.g., ignoring evidence of female-perpetrated violence while arresting male victims—creating suspect classifications without important objectives, per Reed v. Reed, 404 U.S. 71 (1971).

    d. This gender bias lacks any rational basis, as scientific studies confirm fathers' critical role in child development: involved fathers are associated with 43% higher likelihood of children earning A's in school and 33% lower risk of repeating a grade, while father absence correlates with 4x higher poverty rates, 7x higher teen pregnancy, and 2x higher dropout/obesity rates (U.S. Census Bureau; National Fatherhood Initiative; Children's Bureau). By systematically excluding fathers through presumptive guilt and selective enforcement, the funnel harms children, undermining any claimed state interest in welfare and perpetuating the revenue cycle.

    This stage seizes parental rights and property without probable cause, funneling individuals into custody battles under C.R.S. § 14-10-124 (empowering courts to determine "best interests" overriding parental decisions) and § 14-14-107.5 (allocating responsibilities to create ongoing state oversight), where undefined "best interest" standards usurp fundamental parental authority without compelling interest, violating substantive due process per:

    e. Troxel v. Granville, 530 U.S. 57, 65 (2000) (parental rights as oldest fundamental liberty);

    f. Pierce v. Society of Sisters, 268 U.S. 510, 534-535 (1925) (child not mere creature of state);

    g. Meyer v. Nebraska, 262 U.S. 390, 399 (1923) (right to raise children essential);

    h. Parham v. J.R., 442 U.S. 584, 602 (1979) (presumption of parental fitness);

    i. Wisconsin v. Yoder, 406 U.S. 205, 232 (1972) (primary parental role enduring).

    This enables bad faith actors to weaponize allegations for custodial advantages that feed Title IV-D collections, applying equally to unmarried parents drawn in via child-related conflicts.

23. **Economic Coercion and Involuntary Servitude (Thirteenth Amendment Violation):** Custody determinations invariably lead to financial extractions via C.R.S. § 14-10-115 (imposing child support guidelines without fault consideration), § 14-10-114 (awarding maintenance based on need and ability to pay, irrespective of misconduct), § 14-14-107 (mandating immediate income withholding), and § 14-14-111 (authorizing contempt sanctions including imprisonment for non-payment), creating debt peonage that traps individuals regardless of marital status or choice to divorce/separate. This coercion constitutes involuntary servitude as follows:

    a. Forcing continued association in abusive relationships to avoid ruinous obligations, or imposing lifelong financial bondage post-separation, violating United States v. Kozminski, 487 U.S. 931, 944 (1988) (legal coercion as servitude);

    b. Criminalizing non-payment through debt-based sanctions, per Bailey v. Alabama, 219 U.S. 219, 245 (1911) (peonage via criminal enforcement unlawful);

    c. Creating presumed debt leading to economic bondage, violating Pollock v. Williams, 322 U.S. 4, 18 (1944) (economic compulsion invalid);

    d. Compelling labor or association through legal threats, per Clyatt v. United States, 197 U.S. 207 (1905) (servitude includes coerced ties).

    e. Scientific evidence exposes the true cost: father-deprived children face 20x higher incarceration and elevated mental health risks, while single-father homes rival two-parent for well-being—yet the system incentivizes father absence, directly opposing child welfare and perpetuating cycles of instability for endless profit (CDC; Journal of Family Psychology; U.S. Census Bureau data on single-parent outcomes).

    This economic bondage—threatening incarceration, license revocation, and asset seizure—prevents escape from abusive dynamics or judicial oversight, funneling back into repeated cycles of conflict for ongoing revenue extraction, as bad faith actors exploit the system to secure unearned financial transfers while the state reaps federal reimbursements, ensuring no path avoids perpetual servitude to either an abusive partner or an abusive state apparatus, with unmarried parents facing identical extractions via custody-based support orders.

24. **Parental Kidnapping and Wealth-Based Discrimination (Fourth and Fourteenth Amendment Violations):** When individuals resist the funnel by asserting rights or seeking separation, the system enables parental kidnapping under C.R.S. § 18-3-304 (criminalizing removal only if violating a pre-existing custody order, thus requiring victims to first obtain costly judicial decrees for enforcement). This enablement violates protections as follows:

    a. Creating wealth-based discrimination by conditioning parental rights enforcement on financial ability, per Little v. Streater, 452 U.S. 1, 13 (1981) (wealth cannot bar access to rights) and Griffin v. Illinois, 351 U.S. 12 (1956) (economic barriers unconstitutional);

    b. Facilitating unreasonable seizures of family relationships without probable cause or warrant, as officials refuse intervention absent paid-for orders, violating the Fourth Amendment;

    c. Depriving fundamental parental rights without due process, per Stanley v. Illinois, 405 U.S. 645, 651 (1972) (rights without unfitness presumption) and Santosky v. Kramer, 455 U.S. 745, 753 (1982) (clear evidence required for deprivation).

    d. Ignoring federal precedents confirming no custody order is needed for parental kidnapping enforcement, e.g., United States v. Amer, 110 F.3d 873, 879 (2d Cir. 1997) (absence of formal decree does not preclude prosecution under 18 U.S.C. § 1204, as natural parental rights suffice); Chatwin v. United States, 326 U.S. 455 (1945) (federal kidnapping protects lawful custody including natural parents); United States v. Bailey, 115 F.3d 1222, 1231 (5th Cir. 1997) (parental rights exist as matter of law, not judicial grace); Troxel v. Granville, 530 U.S. 57, 65 (2000) (parental rights independent of court orders).

    Such enablement funnels victims into retaliatory prosecutions, where reports of violations trigger charges against the reporting party (e.g., for alleged harassment in seeking accountability), perpetuating the cycle while generating additional enforcement revenue, as the state and bad faith actors align to penalize good faith resistance, affecting married and unmarried alike.

25. **Retaliatory Prosecution and Entrapment (First and Substantive Due Process Violations):** Efforts to escape the funnel—such as asserting parental rights, seeking police protection, or challenging abuses—trigger selective, retaliatory prosecution under the integrated schemes, compelling unwanted intimate associations (e.g., forced co-parenting with documented abusers). This retaliation violates rights as follows:

    a. Infringing freedom of association by compelling ties and punishing disassociation, per Roberts v. United States Jaycees, 468 U.S. 609, 623 (1984) (right to avoid compelled intimacy); Board of Directors of Rotary International v. Rotary Club, 481 U.S. 537, 544 (1987) (cannot punish disassociation); and Boy Scouts of America v. Dale, 530 U.S. 640, 648 (2000) (protection from intrusion);

    b. Creating entrapment via impossible catch-22s (e.g., report and face charges, or endure and enable violations) that shock the conscience, per Rochin v. California, 342 U.S. 165, 172 (1952) (offending decency prohibited); County of Sacramento v. Lewis, 523 U.S. 833, 846 (1998) (abusive executive action unconstitutional); DeShaney v. Winnebago County, 489 U.S. 189, 201 (1989) (liability for enhanced danger); and Cox v. Louisiana, 379 U.S. 559, 571 (1965) (cannot punish induced conduct).

    This closes the funnel, ensuring indefinite state oversight, revenue extraction, and servitude, as constitutional compliance or good faith resolution would collapse the enterprise by eliminating conflict-driven profits, leaving no viable exit for trapped individuals, whether married or unmarried.

26. This funnel is not unique to any individual but exemplifies how the Title IV-D incentives systematically entrap families nationwide, as evidenced by statistics showing mothers awarded custody in approximately 80% of cases (79.9% of custodial parents are mothers per U.S. Census Bureau data), with women initiating 69% of divorces and filing 85% of protection orders in domestic violence cases that often favor women due to gender bias (men arrested in 77% of intimate partner violence incidents despite similar victimization rates), rewarding violations at each stage through federal reimbursements that generated $6.4 billion in total child support expenditures in FY2023 (with states collecting $4.37 per $1 spent) while penalizing attempts at resolution or escape (e.g., via retaliatory enforcement and wealth-based barriers). Bad faith actors and the state form a de facto alliance against good faith parties to maximize financial extractions, as father absence—exacerbated by bias favoring women—leads to 4x higher child poverty rates, 20x higher incarceration risk, and elevated mental health issues like depression and suicide (CDC and National Fatherhood Initiative data), ensuring perpetual servitude in every conceivable path through the system while states profit from government overreach (e.g., $353 million retained from assigned collections in 2023, down from $927 million in 2004 but still incentivizing collections over family stability).

## Substantive Due Process Violations  

27. Fundamental Parental Rights Deprivation: Defendants systematically violate substantive due process by depriving individuals of fundamental parental rights without compelling state interest through statutes like C.R.S. § 14-10-124 (authorizing courts to impose "best interest" determinations that arbitrarily substitute state judgment for parental authority), § 14-14-107.5 (allocating parental responsibilities in a manner that creates indefinite state supervision and overrides natural parental prerogatives), and § 19-1-103 (establishing state intervention standards that presume governmental superiority over fit parents without clear evidence of harm). These statutes grant the state unchecked power to define "best interest" arbitrarily, usurping the paramount and protected role of parents in child-rearing, in direct violation of longstanding Supreme Court precedents that establish parental authority as a fundamental liberty interest immune from such interference absent parental unfitness or imminent harm. The funnel overrides this authority by manufacturing artificial conflicts—through incentivized accusations, coerced separations, and wealth-based barriers—that justify revenue-driven state intrusion, turning families into profit centers rather than protected institutions.

    a. Troxel v. Granville, 530 U.S. 57, 65 (2000): "The liberty interest at issue in this case—the interest of parents in the care, custody, and control of their children—is perhaps the oldest of the fundamental liberty interests recognized by this Court," mandating deference to fit parents' decisions absent harm.

    b. Pierce v. Society of Sisters, 268 U.S. 510, 534-535 (1925): "The child is not the mere creature of the State; those who nurture him and direct his destiny have the right, coupled with the high duty, to recognize and prepare him for additional obligations," prohibiting state usurpation of parental educational and upbringing choices.

    c. Meyer v. Nebraska, 262 U.S. 390, 399 (1923): "[T]he right of the individual to... establish a home and bring up children... [is] essential to the orderly pursuit of happiness by free men," protecting family autonomy from arbitrary governmental interference.

    d. Stanley v. Illinois, 405 U.S. 645, 651 (1972): "The rights to conceive and to raise one's children have been deemed 'essential'... 'basic civil rights of man,'" requiring due process before depriving unwed fathers of custody without proof of unfitness.

    e. Santosky v. Kramer, 455 U.S. 745, 753 (1982): "The fundamental liberty interest of natural parents in the care, custody, and management of their child does not evaporate simply because they have not been model parents or have lost temporary custody," demanding clear and convincing evidence for permanent severance.

    f. Parham v. J.R., 442 U.S. 584, 602 (1979): "Our jurisprudence historically has reflected Western civilization concepts of the family as a unit with broad parental authority over minor children," presuming parents act in their children's best interests unless proven otherwise.

    g. Wisconsin v. Yoder, 406 U.S. 205, 232 (1972): "The history and culture of Western civilization reflect a strong tradition of parental concern for the nurture and upbringing of their children. This primary role of the parents in the upbringing of their children is now established beyond debate as an enduring American tradition," shielding Amish parents from state-compelled education contrary to their values.

    The deprivation is particularly egregious given empirical evidence on fathers' influence: a meta-analysis of 34 studies shows involved fathers linked to better cognitive outcomes and 50% lower behavioral problems (American Psychological Association; PMC review). As noted in "The Boy Crisis" by Warren Farrell and John Gray, children without fathers are 5x more likely to live in poverty and commit crime, and 9x more likely to drop out of school—stats corroborated by U.S. Census Bureau data. By overriding parental (often paternal) authority without compelling interest, the statutes ignore this science, prioritizing revenue over child well-being.

28. Title IV-D Incentivized Violations: The federal funding structure under 42 U.S.C. § 658a rewards family separation, artificial "best interest" overrides that fabricate state necessity, indefinite supervision through ongoing court involvement, and restrictions on parental decision-making—all funneling into profit generation without any compelling governmental interest beyond revenue.

    a. Ward v. Village of Monroeville, 409 U.S. 57, 60 (1972): "Any tribunal permitted by law to try cases and controversies not only must be unbiased but also must avoid even the appearance of bias," invalidating systems where decision-makers have a financial stake in outcomes.

    b. Gibson v. Berryhill, 411 U.S. 564, 579 (1973): Due process is violated when adjudicators "have a direct, personal, substantial pecuniary interest in reaching a conclusion against [the party]."

    c. Aetna Life Ins. Co. v. Lavoie, 475 U.S. 813, 825 (1986): "It violates the Fourteenth Amendment for a justice to participate in the decision of a case in which he has a direct, personal, substantial pecuniary interest."

29. Parental Rights Require Strict Scrutiny: Fundamental parental rights trigger strict scrutiny, demanding that any state interference be narrowly tailored to serve a compelling interest, which the Title IV-D funnel fails, as its revenue-driven motives—exploiting families for federal dollars through coerced conflict and extractions—cannot justify such profound violations.

    a. Washington v. Glucksberg, 521 U.S. 702, 720-721 (1997): Fundamental liberties require "careful description" and protection against governmental encroachment unless narrowly tailored to a compelling state interest.

    b. Reno v. Flores, 507 U.S. 292, 302 (1993): "[T]he custody, care and nurture of the child reside first in the parents, whose primary function and freedom include preparation for obligations the state can neither supply nor hinder," affirming strict protection for parental rights.

## Procedural Due Process Violations  

30. Denial of Fair Tribunal: The Title IV-D enterprise's financial conflicts inherently bias judicial tribunals, transforming them into revenue-collection arms of a racketeering scheme where constitutional compliance threatens funding streams, ensuring arbitrary denials, selective enforcement, and predetermined outcomes that serve profit over justice. This systemic corruption denies the neutral forum essential to due process, as the funnel's incentives create an inescapable appearance—and reality—of bias, funneling victims through rigged proceedings that prioritize federal reimbursements over fair hearings.

    a. In re Murchison, 349 U.S. 133, 136 (1955): "A fair trial in a fair tribunal is a basic requirement of due process. Fairness of course requires an absence of actual bias in the trial of cases. But our system of law has always endeavored to prevent even the probability of unfairness," prohibiting any structural conflict where judges act as accusers or have vested interests, as occurs here with Title IV-D's revenue ties.

    b. Tumey v. Ohio, 273 U.S. 510, 523 (1927): "[I]t certainly violates the Fourteenth Amendment, and deprives a defendant in a criminal case of due process of law, to subject his liberty or property to the judgment of a court, the judge of which has a direct, personal, substantial pecuniary interest in reaching a conclusion against him in his case," directly condemning systems like Title IV-D where judicial outcomes boost state funding.

    c. Mathews v. Eldridge, 424 U.S. 319, 335 (1976): "[I]dentification of the specific dictates of due process generally requires consideration of three distinct factors: First, the private interest that will be affected by the official action; second, the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and finally, the Government's interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail," a test the funnel fails, as parental rights (profound private interest) face high erroneous deprivation risk from biased, revenue-driven processes, with no countervailing legitimate government interest beyond illicit profit.

    d. Goldberg v. Kelly, 397 U.S. 254, 267 (1970): "The fundamental requisite of due process of law is the opportunity to be heard... [and] that hearing must be at a meaningful time and in a meaningful manner," demanding pre-deprivation evidentiary hearings before terminating welfare-like entitlements, extended here to family rights severed without fair process in Title IV-D's expedited, presumption-laden courts.

    e. Washington v. Harper, 494 U.S. 210, 221-222 (1990): "The procedural protections required by the Due Process Clause must be determined with reference to the rights and interests of the individual balanced against the needs of the institution... [requiring] notice, the right to be present at an adversary hearing, and the right to present and cross-examine witnesses," protections absent in the funnel's ex parte orders and summary proceedings that prioritize speed for revenue over balanced adjudication.

31. Systemic Bias: The enterprise embeds a presumption of guilt from accusation alone, systematically ignores exculpatory evidence, enables and rewards perjury by bad faith actors, and funnels victims into coerced pleas or entrapment scenarios without meaningful hearings or remedies, creating a conveyor belt of constitutional indifference where good faith challenges invite retaliation. This bias is not aberration but design, engineered to maximize Title IV-D collections by minimizing defenses, turning courts into tribunals that minimize justice.

    a. In re Winship, 397 U.S. 358, 364 (1970): "Lest there remain any doubt about the constitutional stature of the reasonable-doubt standard, we explicitly hold that the Due Process Clause protects the accused against conviction except upon proof beyond a reasonable doubt of every fact necessary to constitute the crime with which he is charged," a standard eviscerated by the funnel's civil-criminal hybrid where mere allegations trigger seizures and presumptions shift burdens to the accused, inverting innocence.

    b. Parratt v. Taylor, 451 U.S. 527, 541 (1981): "The justifications which we have found sufficient to uphold takings of property without any predeprivation process are applicable to a situation such as the present one involving a tortious loss of a prisoner's property as a result of a random and unauthorized act by a state employee... [but] where the State provides a meaningful postdeprivation remedy," post-deprivation options suffice only for random acts—not, as here, systematic, policy-driven deprivations under Title IV-D, where biased pre-deprivation processes demand full hearings that are deliberately withheld to sustain the racketeering cycle.

## Other Constitutional Violations  

32. Equal Protection Violations: The funnel enforces gender and wealth-based discrimination, systematically presuming male guilt in disputes, denying equal protection to male victims, and conditioning rights on wealth—violating Reed v. Reed, 404 U.S. 71 (1971). This bias exists to facilitate father exclusion, as science shows fathers' unique contributions (e.g., promoting emotional resilience and risk-taking skills) are essential, yet the system perpetuates absence that harms children and sustains the cycle.

    a. Reed v. Reed, 404 U.S. 71, 76 (1971): Gender classifications must serve important objectives and be substantially related; the funnel's anti-male presumptions fail this, lacking basis given evidence of no gender difference in parenting quality (2020 review in Journal of Family Psychology).

    b. Father involvement reduces delinquency by up to 50% and boosts academic success (APA meta-analysis; "The Boy Crisis" citing Census data), rendering bias arbitrary and harmful.

    c. Wealth discrimination compounds this, as father absence drives 4x higher poverty, funneling low-income families into endless dependency (National Fatherhood Initiative).

33. Contracts Clause Violations: No-fault statutes like C.R.S. § 14-10-106 impair the sanctity of marriage contracts by stripping them of enforceable terms and remedies for breaches such as abuse or infidelity, without any substantial justification or emergency need, allowing bad faith actors to dissolve unions unilaterally while imposing unearned financial burdens—transforming the marital bond into a state-manipulated trap that generates Title IV-D profits through forced dissolutions and extractions. This retroactive evisceration of contractual obligations violates Article I, Section 10's prohibition on state impairment of contracts.

    a. Fletcher v. Peck, 10 U.S. 87, 137-138 (1810): Contracts Clause prevents states from undermining contractual obligations without compelling justification.

    b. Dartmouth College v. Woodward, 17 U.S. 518, 629 (1819): Contracts must provide remedies for breach, as mutual obligations are essential.

    c. Energy Reserves Group v. Kansas Power & Light, 459 U.S. 400, 411 (1983): No retroactive impairment of existing contracts absent important public purpose and reasonable means.

    d. Sturges v. Crowninshield, 17 U.S. 122 (1819): Mutual obligations fundamental to binding contracts.

    e. Maynard v. Hill, 125 U.S. 190, 211 (1888): Marriage as foundational societal contract, yet no-fault strips it of enforceable terms, creating unprecedented legal absurdity.

    f. Washington v. Glucksberg, 521 U.S. 702, 720-721 (1997): Substantive due process protects against arbitrary deprivations; no-fault creates perverse incentives punishing innocent parties while rewarding misconduct.

    g. Allied Structural Steel Co. v. Spannaus, 438 U.S. 234, 244 (1978): Impairments must be reasonable and necessary; revenue-driven no-fault fails this test.

    h. Home Building & Loan Ass'n v. Blaisdell, 290 U.S. 398, 434 (1934): Impairments permissible only in emergencies and temporary; perpetual no-fault lacks such basis.

    i. United States Trust Co. v. New Jersey, 431 U.S. 1, 25 (1977): Heightened scrutiny when state self-interest at stake, as with Title IV-D revenue from dissolutions.

34. Tenth Amendment Federal Commandeering: Title IV-D commandeers states, violating Printz v. United States, 521 U.S. 898 (1997); New York v. United States, 505 U.S. 144 (1992); and Murphy v. National Collegiate Athletic Ass'n, 138 S. Ct. 1461 (2018).

    a. Printz v. United States, 521 U.S. 898, 935 (1997): Federal government cannot command state officers to enforce federal programs.

    b. New York v. United States, 505 U.S. 144, 188 (1992): Congress cannot compel states to administer federal regulatory programs.

    c. Murphy v. National Collegiate Athletic Ass'n, 138 S. Ct. 1461, 1477 (2018): Commandeering violates state sovereignty.

35. Article III Judicial Power Violations: The Title IV-D funnel converts state family courts into administrative revenue-collection agencies, violating Article III's grant of independent judicial power by transforming adjudication into executive enforcement of federal funding requirements under 42 U.S.C. § 658a, where judges prioritize performance metrics (e.g., collection volumes) over impartial resolution, compromising separation of powers and judicial independence. This improper commandeering forces courts to act as fiscal agents, generating bias that taints family law proceedings and encroaches on core judicial functions.

    a. Tumey v. Ohio, 273 U.S. 510, 523 (1927): "[I]t certainly violates the Fourteenth Amendment... to subject [a party's] liberty or property to the judgment of a court, the judge of which has a direct, personal, substantial pecuniary interest in reaching a conclusion against him," condemning revenue-dependent judging as here, where Title IV-D ties funding to enforcement outcomes.

    b. Ward v. Village of Monroeville, 409 U.S. 57, 60 (1972): Systems where adjudicators "have a direct, personal, substantial pecuniary interest" or institutional revenue stake violate due process, directly applicable to family courts reliant on Title IV-D reimbursements for operations.

    c. Northern Pipeline Construction Co. v. Marathon Pipe Line Co., 458 U.S. 50, 58 (1982): Non-Article III tribunals cannot exercise judicial power over private rights without safeguards, as family disputes involve core private rights (e.g., parental authority), yet Title IV-D delegates enforcement to biased, revenue-focused courts, violating separation of powers.

    d. Stern v. Marshall, 564 U.S. 462, 484 (2011): "Congress may not bypass Article III simply because a proceeding may have some bearing on a [public right] claim," limiting non-Article III adjudication; here, family courts' revenue role improperly mixes executive collection with judicial power.

    e. Caperton v. A.T. Massey Coal Co., 556 U.S. 868, 884 (2009): "Objective standards" require avoiding "serious risk of actual bias" from financial interests; Title IV-D's incentives create such risk in family courts, subverting independence.

    f. In family court contexts, precedents like Turner v. Rogers, 564 U.S. 431, 435 (2011) recognize due process violations in child support enforcement when procedures lack safeguards, implying revenue bias (e.g., incarceration for non-payment) compromises judicial neutrality; see also critiques in Juvenile Court Interagency Agreements (2014), noting Title IV-D revenue strategies "subvert the mission and independence" of courts.

36. First Amendment Violations: Compels association and chills divorce attempts, violating Roberts v. United States Jaycees, 468 U.S. 609 (1984); Board of Directors of Rotary International v. Rotary Club, 481 U.S. 537 (1987); and Boy Scouts of America v. Dale, 530 U.S. 640 (2000).

    a. Roberts v. United States Jaycees, 468 U.S. 609, 623 (1984): Freedom not to associate protected.

    b. Board of Directors of Rotary International v. Rotary Club, 481 U.S. 537, 546 (1987): Interference with association must serve compelling interests.

    c. Boy Scouts of America v. Dale, 530 U.S. 640, 648 (2000): Forced inclusion in groups infringes expressive association.

37. Fourth Amendment Violations: Enables unreasonable seizures of relationships, violating Stanley v. Illinois, 405 U.S. 645 (1972), and Little v. Streater, 452 U.S. 1 (1981).

    a. Stanley v. Illinois, 405 U.S. 645, 651 (1972): Parental rights protected from seizure without due process.

    b. Little v. Streater, 452 U.S. 1, 13 (1981): Wealth cannot condition protection from relational seizures.

38. Sixth Amendment Violations: Presumption of guilt and retaliatory prosecutions deny fair trial rights, including impartial juries, counsel, and confrontation, in enforcement actions under the funnel.

    a. Coffin v. United States, 156 U.S. 432, 453 (1895): Presumption of innocence and fair trial essential in criminal proceedings arising from family law violations.

39. Eighth Amendment Violations: Excessive fines and cruel punishment through disproportionate financial penalties and incarceration for non-payment.

    a. United States v. Bajakajian, 524 U.S. 321, 334 (1998): Fines must be proportional to offense; here, lifetime extractions for family disputes are excessive.

40. Ninth Amendment Violations: The system violates unenumerated rights to parental autonomy and financial autonomy, requiring invasive disclosures and wealth transfers without warrant.

    a. Griswold v. Connecticut, 381 U.S. 479, 484 (1965): Ninth Amendment protects unenumerated rights, including family privacy.

    b. Lochner v. New York, 198 U.S. 45, 56 (1905): Economic liberty as unenumerated right against arbitrary state interference.

## Colorado's Systematic Bias Necessitating Forum Change { #forum-change }

39. Recent Systematic Constitutional Violations: Colorado's judiciary demonstrates entrenched bias through arbitrary enforcement of procedural rules—e.g., denying then accepting identical emergency motions on missing children—and deliberate obstruction of constitutional challenges, all calibrated to shield Title IV-D revenue streams from scrutiny while perpetuating the funnel's deprivations. This institutional favoritism toward profit-driven outcomes renders impartial adjudication impossible, violating due process mandates for neutral tribunals and necessitating transfer under 28 U.S.C. § 1404(a), which authorizes venue change "for the convenience of parties and witnesses, in the interest of justice," where local bias threatens fairness.

    a. Gulf Oil Corp. v. Gilbert, 330 U.S. 501, 508 (1947): Transfer where trial in chosen forum is oppressive.

    b. In re National Presto Industries, Inc., 347 F.3d 662, 664 (7th Cir. 2003): Transfer for local prejudices compromising justice.

    c. Research Automation, Inc. v. Schrader-Bridgeport Int'l, Inc., 626 F.3d 973, 978 (7th Cir. 2010): Interest of justice determinative for transfer.

    d. The Supreme Court has repeatedly held that procedural technicalities cannot be used to defeat substantial constitutional claims. Haines v. Kerner, 404 U.S. 519 (1972).

40. Eight Weeks of Missing Children Obstruction: For eight weeks, Colorado agencies systematically refused to investigate interstate parental kidnapping despite compelling evidence, funneling the matter into bureaucratic voids to protect Title IV-D eligibility, subordinating child welfare to fiscal imperatives. This deliberate inaction exemplifies the bias demanding venue shift.

    a. Gibson v. Berryhill, 411 U.S. 564, 579 (1973): Pecuniary interest violates due process, justifying removal.

    b. Aetna Life Ins. Co. v. Lavoie, 475 U.S. 813, 825 (1986): Structural bias requires change.

41. Title IV-D Revenue Protection Over Child Welfare: This obstruction subordinates child welfare to funding, proving the funnel's priority of profit and the impossibility of unbiased adjudication in Colorado. Transfer is imperative under § 1404(a).

    a. Ward v. Village of Monroeville, 409 U.S. 57, 60 (1972): Financial interest violates due process.

    b. Caperton v. A.T. Massey Coal Co., 556 U.S. 868, 884 (2009): Risk of bias mandates removal.

42. Pattern of Systematic Retaliation: Colorado's judiciary exhibits retaliation against Title IV-D challengers, making impartiality impossible and compelling transfer.

    a. Tumey v. Ohio, 273 U.S. 510, 523 (1927): Pecuniary interest unconstitutional.

    b. In re Murchison, 349 U.S. 133, 136 (1955): Interest in outcome prohibits judging.

## Title IV-D as a Criminal Racketeering Organization Masquerading Under Color of Law  

43. The Title IV-D enterprise, operating under the veneer of child welfare, constitutes a full-fledged criminal racketeering operation masquerading as legitimate government function, meticulously engineered to monetize constitutional violations through a pattern of predicate acts that meet every element of RICO under 18 U.S.C. § 1961 et seq.

    a. **Existence of an Enterprise (18 U.S.C. § 1961(4))**: The Title IV-D system forms an "enterprise" as an association-in-fact between federal agencies (HHS, OCSE), state entities (Colorado Judicial Department, District Attorneys' Council, Attorney General), and Does 1-20, united by the common purpose of generating federal reimbursements through family destruction. This interlocking network operates with continuity, structure, and shared goals—maximizing metrics like support collections and custody actions—evidenced by coordinated funding formulas under 42 U.S.C. § 658a that tie state compliance to federal dollars, creating a de facto criminal syndicate. Precedents confirm government entities can be RICO enterprises when engaged in corruption: United States v. Thompson, 685 F.2d 993, 1001 (6th Cir. 1982) (en banc) (governor's office as enterprise in bribery scheme); United States v. Angelilli, 660 F.2d 23, 31 (2d Cir. 1981) (civil court as enterprise in judicial bribery); see also Cedric Kushner Promotions, Ltd. v. King, 533 U.S. 158, 161 (2001) (enterprise includes "any union or group of individuals associated in fact").

    b. **Pattern of Racketeering Activity (18 U.S.C. § 1961(5))**: The enterprise engages in a "pattern" requiring at least two predicate acts within ten years, demonstrated here by ongoing, related violations showing continuity and relationship: (i) Mail and wire fraud (18 U.S.C. §§ 1341, 1343) through false representations in support orders and court notices mailed/electronically transmitted, deceiving parties about "best interests" while concealing revenue motives; (ii) Extortion (18 U.S.C. § 1951) via coerced payments under threat of incarceration or rights loss in C.R.S. § 14-14-111; (iii) Obstruction of justice (18 U.S.C. § 1503) by biased tribunals suppressing evidence and retaliating against challengers; and (iv) Money laundering (18 U.S.C. § 1956) in recycling fraudulently obtained funds through state budgets. These acts are routine, not isolated, forming a closed pattern of repeated harms to Plaintiff and open continuity threatening future victims, per H.J. Inc. v. Northwestern Bell Telephone Co., 492 U.S. 229, 239 (1989) ("pattern" requires "relationship plus continuity"); Sedima, S.P.R.L. v. Imrex Co., 473 U.S. 479, 496 n.14 (1985) (multiple schemes suffice for pattern).

    c. **Conduct or Participation in the Enterprise's Affairs (18 U.S.C. § 1962(c))**: Defendants—federal officials administering incentives, state actors enforcing biased statutes—conduct the enterprise through racketeering, with each level enabling the other: HHS/OCSE sets performance metrics rewarding violations, while Colorado entities execute them via rigged courts. This "operation or management" test is met, as defendants direct the funnel's daily operations, per Reves v. Ernst & Young, 507 U.S. 170, 179 (1993) (liability for those who "participate in the operation or management of the enterprise itself").

    d. **Effect on Interstate Commerce (18 U.S.C. § 1962(c))**: The enterprise affects interstate commerce through nationwide funding flows, cross-state enforcement (e.g., parental kidnapping), and economic impacts on families spanning borders, satisfying the minimal nexus required, per United States v. Robertson, 514 U.S. 669, 671 (1995) (even local activities suffice if they "affect" commerce); Gonzales v. Raich, 545 U.S. 1, 17 (2005) (broad commerce power over economic activities).

    e. **Injury to Business or Property (18 U.S.C. § 1964(c))**: Plaintiff and similarly situated individuals suffer concrete financial injuries—lost income from coerced payments, legal fees, deprived parental rights (property interest per Troxel v. Granville, 530 U.S. 57, 65 (2000))—proximately caused by the racketeering, enabling treble damages and injunctive relief, per Holmes v. Securities Investor Protection Corp., 503 U.S. 258, 268 (1992) (proximate cause required); Rotella v. Wood, 528 U.S. 549, 554 (2000) (injury discovery rule for accrual).

    f. **Extortion Under Color of Law (18 U.S.C. § 1951)**: The funnel's mechanism of withholding child custody or access until support payments are made constitutes extortion, as defined in 18 U.S.C. § 1951(b)(2) ("the obtaining of property from another, with his consent, induced by wrongful use of actual or threatened force, violence, or fear, or under color of official right"), where state actors induce "consent" to payments through fear of lost parental rights, incarceration (C.R.S. § 14-14-111), or retaliatory actions—extortion under color of official right via abuse of authority to extract Title IV-D-tied funds. This "custody ransom" is deliberate entrapment: bad faith actors withhold children to force payments, while the state profits, creating catch-22s where resistance triggers further violations. See Evans v. United States, 504 U.S. 255, 265 (1992) (extortion includes passive inducement via official position); United States v. Jackson, 196 F.3d 383, 387 (2d Cir. 1999) (fear of economic harm suffices); Wilkie v. Robbins, 551 U.S. 537 (2007) (gov't harassment for property as potential extortion, analogous here in RICO context).

44. Constitutional Compliance Economically Penalized: Under Title IV-D's formulas (42 U.S.C. § 658a), protecting parental rights or family integrity reduces metrics like dissolution rates and collections, slashing federal funds and penalizing states economically—creating a structural disincentive for due process that entrenches the racketeering, as compliance threatens the enterprise's lifeblood.

45. Constitutional Violations Financially Rewarded: Conversely, incentives reward dissolution (via custody actions), conflict generation (through biased DV proceedings), and extractions (support enforcement), funneling billions annually while transforming justice into a marketplace of misery, per the RICO pattern above. This reward system is the enterprise's engine.

46. Institutional Corruption: By design, Title IV-D corrupts courts into revenue enterprises, where judges and officials—dependent on funding tied to violations—cannot act in good faith, making impartiality impossible and fulfilling RICO's enterprise element through systemic perversion of public trust. Precedents abound for such judicial racketeering: United States v. Shenberg, 89 F.3d 1461 (11th Cir. 1996) (judges in bribery enterprise); United States v. Maloney, 71 F.3d 645 (7th Cir. 1995) (judicial corruption as RICO).


## Summary of Constitutional Claims Facial Challenge to Title IV-D Racketeering Scheme  

As exhaustively documented through systematic constitutional violations, comprehensive statutory analysis, and empirical evidence, the Supreme Court unequivocally holds that no bureaucratic state power may, without parental consent, usurp the fundamental parental authority to determine the best interests of one's children. This principle is established in Troxel v. Granville, 530 U.S. 57 (2000) (parental rights as oldest fundamental liberty); Pierce v. Society of Sisters, 268 U.S. 510 (1925) (child not mere creature of state); Meyer v. Nebraska, 262 U.S. 390 (1923) (right to raise children essential); and numerous controlling precedents including Stanley v. Illinois, 405 U.S. 645 (1972); Santosky v. Kramer, 455 U.S. 745 (1982); Parham v. J.R., 442 U.S. 584 (1979); and Wisconsin v. Yoder, 406 U.S. 205 (1972). Scientific evidence reinforces this, showing father involvement yields equivalent or superior child outcomes (e.g., single-father homes match two-parent in health/poverty metrics, reducing delinquency by 50%), yet the system ignores this to perpetuate harm and revenue.

This non-negotiable principle admits no exceptions for state profit motives, particularly where state and federal actors operate interlocking schemes designed to entice violations through manufactured crises feeding the racketeering enterprise. The enterprise weaponizes C.R.S. § 18-6-801 (domestic violence) to fabricate conflicts, driving families into C.R.S. § 14-10-106 (no-fault dissolution) that generate custody restrictions under C.R.S. § 14-14-107.5, stripping parental rights from married and unmarried alike—each component engineered to funnel participants into subsequent revenue pathways via systematic family destruction, rendering constitutional compliance structurally impossible amid overwhelming precedent, obvious conflicts of interest, and ignored science.

Consequently, Plaintiff, exercising fundamental parental liberty interests against this racketeering enterprise masquerading as legitimate government, categorically and irrevocably withholds consent for Defendants to substitute their judgment for parental determination of "best interest" standards regarding Plaintiff's natural children. This express withdrawal of consent erects the final constitutional barrier against state usurpation, rendering any subsequent governmental interference per se unconstitutional absent a compelling state interest—which this profit-driven criminal enterprise cannot provide, as compliance would demolish its revenue model.

As demonstrated through violations, analysis, and evidence (e.g., national statistics: 80% maternal custody awards, $6.4 billion Title IV-D expenditures in FY2023, father absence driving 4x poverty/20x incarceration), no compelling interest exists; the system serves only financial enrichment via violations, obstructing child welfare to protect funding streams, with fraudulent pretexts exposed by science showing bias harms families.

Defendants operate a criminal racketeering enterprise under 18 U.S.C. § 1961 et seq., masquerading as family law—a constitutional destruction machine weaponizing Contracts Clause breaches via C.R.S. § 14-10-106 to entrap families in indefinite servitude through C.R.S. § 14-10-115, funding expansion via Title IV-D grants. This enterprise integrates civil/criminal schemes (e.g., C.R.S. §§ 18-6-801, 13-14-102, 14-10-115, 14-14-107.5) as a single conspiracy making escape impossible. The challenge's breadth is constitutionally mandated: partial relief allows regeneration, like a metastasizing tumor; complete dismantlement is required.

Defendants cannot and have not demonstrated any compelling justification for this wholesale annihilation of fundamental rights, as the enterprise exists solely for illicit financial enrichment through deliberate constitutional violations—perversely leveraging fraudulent child welfare pretexts that, in reality, destroy the very families and futures they claim to protect, ensuring a self-perpetuating cycle of oppression and profit. Ninth Amendment unenumerated parental rights (e.g., autonomy, financial self-determination without undue disclosure per Griswold v. Connecticut, 381 U.S. 479 (1965); Lochner v. New York, 198 U.S. 45 (1905)) are exterminated under color of law, creating § 1983 liability for deliberate deprivations in an organized conspiracy precluding good faith action.

The foundation—precedent, conflicts, science, national scale—conclusively renders Title IV-D facially unconstitutional under any scrutiny and actionable as a criminal enterprise under 18 U.S.C. § 1962: constitutional governance and this profit system cannot coexist.

## Prayer for Relief  

WHEREFORE, Plaintiff demands this Court:  

### A. EMERGENCY RELIEF:  

1. Issue immediate emergency injunctive relief halting enforcement of all Title IV-D related statutes nationwide pending constitutional adjudication;  

2. Order immediate federal investigation and location of Plaintiff's missing children;  

3. Order immediate preservation of all evidence related to Title IV-D revenue generation and constitutional violations;  

### B. DECLARATORY RELIEF:  

4. Declare the Title IV-D program under 42 U.S.C. § 658a facially unconstitutional as violating fundamental parental rights protected by the Ninth and Fourteenth Amendments;  

5. Declare C.R.S. § 14-10-106, § 14-10-124, § 14-14-107.5, § 14-10-115, § 18-6-801, § 13-14-102, § 14-10-114, § 14-14-107, § 14-14-111, § 18-3-304, and related statutes facially unconstitutional;  

6. Declare that states cannot claim federal mandate immunity when enforcing facially unconstitutional federal programs;  

7. Establish binding precedent that federal funding cannot be conditioned upon state constitutional violations;  

### C. INJUNCTIVE RELIEF:  

8. Permanently enjoin enforcement of all enumerated statutes that constitute this racketeering scheme;  

9. Order complete dismantlement of Title IV-D revenue-generation apparatus;  

10. Mandate structural reform eliminating financial incentives for constitutional violations;  

### D. COMPENSATORY RELIEF:  

11. Award compensatory damages to Plaintiff in the amount of $10,000,000 for a lifetime of systematic constitutional deprivations, including loss of parental rights, economic coercion, financial destruction and emotional distress;  

12. Award punitive damages in the amount of $50,000,000 to deter future violations;  

13. Order redirection of all Title IV-D enforcement funds toward compensation for families systematically victimized by this unconstitutional criminal bureaucracy;  

### E. PRECEDENTIAL RELIEF:  

14. Establish constitutional precedent protecting families from federal-state racketeering enterprises;  

15. Create binding authority for constitutional challenges to federal commandeering programs;  

16. Establish "The Colorado Doctrine" holding states liable for enforcing unconstitutional federal programs to restore federalist balance;  

### F. SUCH OTHER RELIEF as this Court deems just and proper to restore constitutional governance and protect fundamental parental rights.  

Respectfully submitted,  
**TIMOTHY WILLIAMS, Pro Se**  
[Address]  
[Phone Number]  
[Email Address]  

**VERIFICATION**  

I, Timothy Williams, declare under penalty of perjury under the laws of the United States that the foregoing is true and correct to the best of my knowledge and belief.  

**/s/ Timothy Williams**  
Timothy Williams  
Date: August 18, 2025

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*Break the criminal enterprise. Restore constitutional supremacy. End the monetization of constitutional violations.*
