STATE OF RIDGEWAY
SUPERIOR COURT FOR RIDGEWAY COUNTY
Avalonaiii
Petitioner,
v.
RangeetKumar, in his official capacity
as an Assistant Sheriff of the Ridgeway
County Sheriff’s Office,
Respondent,
Case No. TBD
Petition for a Writ of Habeas Corpus
Hon. TBD
Petitioner avalonaiii, by and through their undersigned counsel, hereby requests this court to
issue relief consistent with habeas remedies under law. Habeas corpus proceedings are governed
and recognized pursuant to Rid. R. Civ. P. 54(a)(1)(1), and 1 R. Stat. § 2210-2213.
PARTIES
1. Petitioner Avalonaiii is a citizen of the State of Ridgeway.
2. Respondent RangeetKumar is an Assistant Sheriff within the Ridgeway County Sheriffs
Office and a citizen of the State of Ridgeway.
JURISDICTION AND VENUE
3. This court has jurisdiction pursuant to Article V, Section IV of the Constitution of the 4.
4. State of Ridgeway, supplemented by 1 R. Stat. § 2210, which authorizes the Superior
5. Court of the State of Ridgeway to hear petitions for habeas corpus.
6. Venue is proper as the actions in question occurred in the geographic boundaries of the
7. City of Sterling Heights, within the State of Ridgeway.
STATEMENT OF FACTS
8. On or around July 10th, 2025, Avalonaiii was travelling southbound in the City of
9. Sterling Heights as a passenger in a Grey Pioneer, bearing license plate AKZ-594.
10. The driver of the vehicle, later identifiable as rammaarchangel, collided with a curb at
a high rate of speed, consequently the vehicle flipped upside down.
11. Respondent RangeetKumar pulled up beside the flipped vehicle with his emergency
lighting and sirens enabled.
12. Petitioner exited the vehicle on the passenger sidebefore stating that she was infact
not the operator of the vehicle.
13. Despite this, the respondent proceeded to handcuff the petitioner. Respondent then
drove to the Ridgeway County Sheriffs Office (herein abbreviated RCSO) substation in
Sterling Heights, and booked petitioner for reckless driving and evasion.
14. Reckless driving is defined as “the act of committing three or more traffic infractions
within a timespan of 60 seconds, or driving in a manner which disregards the safety of
persons or property in their vicinity” in the Ridgeway State Database, R.C.C. § 7.02.
CLAIMS FOR RELIEF
15. The statements contained in paragraphs 1 through 14 of this Petition are incorporated
by reference as if fully set forth herein.
16. In reviewing habeas petitions, the court follows a two prong test in determining
whether a petitioner is entitled to habeas relief. The first prong that the court looks at is if
the police were, “legally entitled to make [an] arrest.” See In re ZachCasisbeast, 1 R.
Supp. 12 (2022) If the arrest is legally insufficient, then, “the inquiry ends there; the
record must be removed.” Id.
17. Petitioner asserts that because she was not the operator of the vehicle, she could not
have committed, “three or more traffic infractions within a timespan of 60 seconds,” nor
“[driven] in a manner which disregards the safety of persons or property in their vicinity,”
Respondent had no probable cause to believe that Petitioner had committed the crime of
Reckless Driving because the respondent had no way of confirming that petitioner was
the operator of the vehicle, other than the fact the vehicle was registered in petitioners
name. The respondent detained the petitioner after she exited from the passenger side of
the vehicle, which further dispels probable cause to believe that petitioner was the
operator of the vehicle.
18. As a result of the lack of probable cause supporting the arrest of the petitioner, the
charge must be vacated and the record removed.
19. In the event that the arrest is determined to be lawful and fulfilling of the probable
cause requirement, the Court must now direct its focus to the next prong for its review of
this petition; being “whether the petitioner is actually innocent.” In re ZachCasisbeast, 1
R. Supp. 12 (2022).
20. The petitioners innocence may be determined by establishing the facts and evidence
presented would dispel any chance of a conviction on the charge, specifically showing
that “a reasonable and well-informed jury could not convict the petitioner in a
hypothetical trial if they were aware of those facts, and those facts were admissible
evidence.”
21. Given the facts established in paragraphs 1 through 14 of this petition, supported at
trial by the testimony of the Petitioner and a review of the video recording, a reasonable
and well-informed jury could not convict Petitioner. As Petitioner was not the operator of
the vehicle at the time. With these facts in mind, we conclude with the finding that no
mens rea or actus reus exist.
22. As a result of the petitioners proven innocence, the charge is rendered invalid and
must be vacated, and the consequential record removed.
CONCLUSION AND REMEDY
For the foregoing reasons, the charge presented should be considered null and void.
Plaintiff requests that:
for the aforementioned items:
a. Issue a permanent injunction ordering immediate reversal and vacatur of the charge
against petitioner for “Reckless Driving” and “Evasion”
b. Award cost of court to the petitioner, in the amount of $435.00 and the cost of any other
cost arising from court fees associated with this matter.
Respectfully submitted,
/s Avalonaiii
Petitioner
