Page:Spencer v. Nigrelli.pdf/5

 worshippers in the case of violent confrontation.” Id.

Unfortunately, Pastor Spencer “regularly receive[s] suspicious and threatening mail.” Id. ¶ 34. He has “received at least two death threats” that prompted the involvement of law enforcement. Id. On one occasion, an individual sent Pastor Spencer a Facebook message conveying a desire that “someone execute[]” Pastor Spencer and his wife. Id. ¶ 35. In addition, the Church “has experienced several other security threats, including multiple occasions of burglary and vandalism.” Id. ¶ 38. Spencer desires “to carry [his] concealed pistol” and “allow others to carry their concealed firearms on the Church’s New York campuses” because he believes that “such concealed carry will protect” worshippers from violence. Id. ¶ 29. He also believes that “such concealed carry effectuates” the Church's “religious beliefs” that they “must protect the physical safety of the flock.” Id.

Since the State “enacted and began enforcing” the houses of worship exclusion, Pastor Spencer “expected the Church’s security volunteers to comply with the law” and he, himself, “stopped carrying” his “pistol onto the Church’s New York campuses.” Id. ¶ 26. But for the “enactment and enforcement” of the houses of worship exclusion, Pastor Spencer “would carry” concealed firearms “on the Church’s New York campuses” and “would permit other licensed churchgoers to do the same.” Id. ¶ 31.