Motion 10: Account for Every Gun You Took — Firearm Seizure, Possession & Return

The government took or restricted my firearms. Fine — courts can impose lawful conditions. But I should not be left guessing what was taken, why it's being held, what condition actually applies, and how I get a hearing. Firearm restrictions have to be written, specific, and tied to a lawful order — not built on rumor and public escalation.

The motion as filed — page one.

What I'm asking the court to do

• Order a written inventory of all firearms, ammunition, accessories, licenses, and property seized or surrendered.
• Identify the agency holding each item and the legal authority for continued retention.
• Produce any written bond condition restricting firearms.
• Set a hearing if the State seeks continued restriction or retention.
• Confirm that no firearm restriction will be expanded based on public rumor, unproduced evidence, or unsupported allegations.

Why it matters

The whole gun narrative against me grew online from the official wording. The Harrison County Sheriff's Office press release said the allegation was that I "raised his shirt up to display a firearm and placed his hand upon grip of the firearm." Not "pulled." Not "pointed." Not "fired."

The official wording — "hand upon grip," not a shot fired.

A constitutional right shouldn't be stripped indefinitely, without paper and without process, on the back of a rumor that outran that wording.

The law behind it

• U.S. Const. amend. II and Tex. Const. art. I, § 23 — the right to keep and bear arms, subject to lawful regulation.
• U.S. Const. amends. V, VIII, XIV — due process, bail, and pretrial-liberty protections.
• District of Columbia v. Heller, 554 U.S. 570 (2008) — the individual Second Amendment right.
• N.Y. State Rifle & Pistol Assn. v. Bruen, 597 U.S. 1 (2022) — modern firearm regulations are measured against constitutional text and history.
• United States v. Rahimi, 602 U.S. 680 (2024) — temporary disarmament can be constitutional after a court finding of a credible threat; process and tailoring matter. It does not authorize rumor-based, unwritten, indefinite deprivation.
• United States v. Salerno, 481 U.S. 739 (1987) — pretrial restrictions must be regulatory.

The facts, and how I've classified them

• RYAN STATEMENT: Firearms were taken or restricted after my arrest.
• RYAN STATEMENT: I dispute allegations that I drew, pulled, pointed, brandished, or fired a weapon.
• FACT: Public reporting described the allegation as hand-on-grip conduct, not a shot fired.
• NEEDS AUTHENTICATION: The seizure record, property receipt, bond conditions, and agency custody records must be produced.

My declaration

My name is Ryan Nichols. DOB December 6, 1990. I am the Defendant. Under penalty of perjury (Tex. Civ. Prac. & Rem. Code § 132.001):

• I understand that the Court may impose lawful bond conditions.
• I dispute allegations that I drew, pointed, pulled, brandished, or fired a firearm.
• I need a written inventory, property receipt, and legal basis for any continued firearm-related restriction or retention.

Executed June 1, 2026, in Harrison County, Texas. /s/ Ryan Nichols

The proposed order

• The State and/or holding agency shall provide a written inventory and legal basis for any firearm seizure or continued retention by a deadline set by the Court.
• The State shall produce any written bond condition restricting firearms.
• The Court will set a hearing if continued restriction or retention is disputed.
• No firearm restriction shall be expanded based on public rumor, unproduced evidence, or unsupported allegations.

The bottom line

Give me a property receipt, a written condition, and a hearing. Rahimi allows disarmament after a finding and a process — not because the internet decided I'm dangerous.