A delegate to the Republican national convention from Virginia filed a federal lawsuit Friday to avoid being bound to vote for Donald Trump on the first ballot in Cleveland.

The delegate, Carroll Boston Correll, is a longtime local GOP official who claims Trump is “unfit to serve” as President. Correll alleges in the lawsuit that state law which binds him to vote for Trump on the first ballot at the convention violates his constitutional right to free speech. Correll is seeking class action status for the suit on behalf of other bound delegates in Virginia, where Trump won 17 delegates in March.

The lawsuit was filed Friday in the U.S. District Court for the Eastern District of Virginia. It list as its defendants Mark Herring, the attorney general of Virginia, and other state and local elections officials. Correll is being represented by a major D.C. law firm, BakerHostetler.

“Correll believes that Donald Trump is unfit to serve as President of the United States and that voting for Donald Trump would therefore violate Correll’s conscience,” the complaint said. “Accordingly, Correll will not vote for Donald Trump on the first ballot, or any other ballot, at the national convention. He will cast his vote on the first ballot, and on any additional ballots, for a candidate whom he believes is fit to serve as President, thereby violating Section 545(D).”

Correll is seeking an injunction that would relieve him of any criminal penalties under state law for voting for someone other than the primary winner on the first ballot at a national convention. The lawsuit notes that in Virginia, delegates are not chosen directly by the voters according to whom they will support, but rather in separate local party conventions.

The complaint is below: