Franklin Armory, Inc. designed, developed, and began the manufacture of a series of firearms called the "Title I" that, before August 6, 2020, was legal to transfer, possess, and own in California, but are neither "rifles," "shotguns," or "pistols" as the state defines those terms. Before August 6, 2020, Franklin Armory lawfully took preorders from buyers across the state who were interested in obtaining a Title 1 firearm as soon as they became available. Thousands of Californians put deposits down for the purchase of one or more centerfire Title 1 firearms but they could not take possession of those firearms because the California Department of Justice ("DOJ") refused to process the lawful transfers of those firearms, as it statutorily mandated to do, waiting to correct known deficiencies in its systems until well after it had successfully worked with the legislature to pass Senate Bill 118, which effectively designated Franklin Armory's centerfire Title 1 firearm as an "assault weapon" in California.

This class action lawsuit, to which you may be an unnamed party if you made a deposit for the purchase of one or more centerfire Franklin Armory Title 1 firearms before August 6, 2020, challenges the DOJ's unlawful ban on the transfer of your Franklin Armory Title 1 firearm(s) to you. The complaint alleges that the government defendants violated the rights of Franklin Armory's intended customers under the Second and Fourteenth Amendments. And it seeks a judgment declaring that DOJ's conduct was unconstitutional and ordering Defendants to allow you to finalize the lawful transfer of your centerfire Title 1 firearm(s), if you still wish to do so, and to register it as required by Senate Bill 118 notwithstanding the fact that you did not possess the firearm before September 1, 2020. This relief, if we obtain it however, is potentially years down the road.

You might recall that when the Title 1 lawsuit site first launched in late July 2020, the case was anticipated to be a "mass action," requiring individual plaintiff participation from every person impacted by the DOJ's illegal conduct who sought relief through the lawsuit. Part of this process required you to sign an engagement agreement to serve as an individually named plaintiff and to enter into an official attorney-client relationship with Michel & Associates, PC. In late August 2020, however, we notified all prospective "mass action" clients via email that our legal team decided it would be best to litigate the matter as a "class" action and we terminated our individual representation of all those who signed the engagement agreement.

The class action is, in many ways, more efficient and simpler for all members of the potential "class," of which you are automatically a member by virtue of making a Title 1 deposit. The "class" action avenue does not require you to sign the MAPC engagement agreement or to actively participate in the lawsuit, unless you are a named class representative. Even so, if you choose to remain part of the class, as opposed to "opting out" and seeking independent representation, you will benefit from any relief we obtain on behalf of the class, just as you would if you were an individually named plaintiff.