Your honor,

the Defense argues that the Defendant can no longer be considered a member (the Membership Premise), and therefore falls outside of the jurisdiction of this body (the Jurisdiction Premise). The Prosecution believes that neither premise survives scrutiny with respect to law and precedent.

In the ruling for HCLQ1708, Justice Kringalia laid out criteria for membership as "a combination of physical presence in either the region or the forum and a reasonable display of good faith". The physical presence was given both through the nation Cormactopia Prime, which can be confirmed via NationStates regional dumps in the months of February to June, as well as the forum account with which the Defendant submitted their plea in this very thread. Good faith at the time was also present; in fact the Defendant admirably served as Chair of Assembly for a brief while. Therefore, it is clear that the Defendant had attained membership status. Moving forward, even though the Defendant renounced all affiliation, this does not revoke the membership status previously attained. First, if this were the case, that would contradict the ruling in HCLQ1708 that states "membership cannot be forfeited once gained". Second, if we assume the Defense's Jurisdiction Premise to be valid, then members could trivially escape responsibility and prosecution for criminal acts by forfeiting their membership. A trial such as The Coalition v. Milograd in 2013 could not take place, which given the historical infractions committed by Milograd in their 2013 coup d’etat attempt is clearly absurd. Therefore, the court must consider the Membership premise invalid.

Prior to filing charges, the Prosecution considered the matter of jurisdiction and concluded that even if a premise such as the Defense's predictable Membership premise were valid, jurisdiction would apply regardless. The laws of the Coalition do not provide a definition for the jurisdiction of the High Court of the South Pacific, therefore we must determine applicability of its jurisdiction to a particular case based on precedent, the spirit of the law, and authoritative definitions of the word itself. The relevant Oxford Dictionary definition defines jurisdiction to be the "territory or sphere of activity over which the legal authority of a court or other institution extends". Given that the High Court is the sole arbiter of criminal matters within the Coalition, the spirit of the law thus shows that jurisdiction applies when the affected area of influence of a crime is (at least in part) operated by the Coalition. Note that this interpretation does not differentiate between classes or types of individuals committing the crime, and this is upheld both by precedent in HCLQ1404 and by the Court Procedures Act which deliberately defines the Accused as “individuals” rather than members, citizens, residents, or other such terms that could imply class or type of any sort. In other words, a crime committed on territory of the Coalition falls under the jurisdiction of the High Court no matter who committed the crime, and therefore the Jurisdiction premise is invalid.

An argument is considered sound if and only if all its premises are valid. We have shown that both premises are invalid, even if the respective other premise is assumed to be valid, and therefore, the argument for a motion to dismiss is unsound. We urge the court to reject the motion.