Dr. Allen Palmer v. Jane Drummond, et al.: Complaint (State)
Declaratory Judgment and Injunctive Relief
Plaintiff, Dr. Allen Palmer, by his undersigned attorneys, brings this Petition against the above-named Defendants, their employees, agents, and successors in office, and in support thereof states the following:I. Introductory Statement1. Plaintiff seeks declaratory and injunctive against Defendants’ threatened application of the 2007 Amendment to the Missouri Ambulatory Surgical Center Licensing Law and the Department of Health and Senior Services’s regulations governing ambulatory surgical centers in such a manner as to require existing abortion facilities, such as Plaintiff’s private medical practice in which he has safely provided abortions for over 30 years, to meet physical construction standards applicable to new or newly renovated facilities.2. This action is brought relief under Mo. Rev. Stat. §§ 527.010, 526.030, and 536.050 and the equal protection clause of the Missouri Constitution, Mo. Const. art. I, §