RIDGEWAY SUPERIOR COURT
FOR THE COUNTY OF RIDGEWAY
Detachment_Result,
Plaintiff,
v.
bengeben1,
Defendant.
Case No.: RSC-CV-9588
PLAINTIFF’S RESPONSE TO MOTION
TO DISMISS
Plaintiff Detachment_Result (“Plaintiff”), by and through the undersigned counsel,
respectfully submits this response opposing Defendant’s Motion to Dismiss pursuant to
Rule 12(b)(6). For the reasons set forth below, the motion should be denied in its entirety.
INTRODUCTION AND JURISDICTION
This is a civil tort action alleging false imprisonment under 1 R. Stat. § 3104. The
case arises from Defendant’s willful and deliberate obstruction of Plaintiff’s armoured
truck, which directly prevented Plaintiff from leaving a commercial parking lot while on
duty as an RCU Corporate Security personnel. This Court exercises original jurisdiction
over this matter pursuant to Article V, Section IV of the Constitution of the State of
Ridgeway, which provides jurisdiction over all civil and criminal cases or controversies
under the rules set by the Supreme Court. Accordingly, this case is governed by the
Ridgeway Rules of Civil Procedure, not the Federal Rules.
DEFENDANT MISAPPLIES FEDERAL LAW AND PROCEDURAL
STANDARDS
Defendant bases their motion entirely on Federal Rules of Civil Procedure
(12)(b)(6) and references federal cases such as Twombly and Iqbal. However, this case is
not in federal court, nor does it invoke federal law. It arises under Ridgeway state law,
and no authority is cited by Defendant to show that the Ridgeway Rules of Civil
Procedure incorporate the federal plausibility pleading standard. State courts are not
bound by federal procedural doctrines unless explicitly adopted by the state’s judiciary or
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legislature. Without such authority, Defendant’s reliance on Twombly and Iqbal is
improper, and their motion should be denied on this ground alone.
PLAINTIFF HAS PLAUSIBLY ALLEGED FALSE IMPRISONMENT UNDER 1.
R. STAT. § 3104
01. Legal Standard
a. 1 R. Stat. § 3104 provides: “Any individual who, without legal authority or
justification, restrains or restricts a person's movement within an area, or
restrains the person's permission is false imprisonment and shall be liable
for punitive damages up to $6,000.” False imprisonment does not require
physical force or locked rooms. Restraint may be physical, psychological,
or situational - and the method of confinement may be subtle or indirect.
02. Defendant’s Conduct Clearly Restrained Plaintiff’s Movement
a. Plaintiff was on duty as an RCU Corporate Security truck driver, operating
a large, job-issued armored vehicle. After parking to conduct business,
Plaintiff returned to find the Defendant’s vehicle deliberately positioned to
block the only possible path of exit. There was a fence directly behind the
truck, making movement physically impossible. Further, the Defendant
stood near the back of the truck and stated, “I want the money… im poor.”
indicating intent to interfere with Plaintiff’s duties. Despite being asked
multiple times to move,
b. Despite being asked to move multiple times, Defendant refused. This
conduct was deliberate, without justification, and left Plaintiff unable to
leave. Restraining them.
c. The freedom to leave includes the ability to depart by reasonable and
available means. Plaintiff could not proceed with their job route, secure
valuable cargo, or leave the area using their only vehicle - all directly due to
Defendant’s actions.
d. Federal courts have held that false imprisonment can result from blocking a
person’s only means of exit, even if no physical touching occurs. See
Rodriguez v. Farrell, 280 F.3d 1341, 1352 (11th Cir. 2002), Fleming v. U.S.,
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928 F. Supp. 906, 911 (W.D. Mo. 1996), Lopez v. U.S., 373 U.S. 427, 440
(1963).
e. Defendant’s conduct placed Plaintiff in a situation of confinement - not by
locking a door, but by physically preventing departure and signaling a
threat to Plaintiff’s lawful duties. That satisfies both the federal and state’s
understanding of restraint sufficient for false imprisonment.
PLAINTIFF HAS MET THE PLEADING STANDARD
Plaintiff’s complaint includes:
- A detailed factual account of the incident;
- Identification of the applicable statue (1 R. Stat. § 3104);
- Specific allegations that Defendant’s conduct was willful and unjustified;
- A clear explanation of how Plaintiff was restrained.
Ridgeway’s Rules of Civil Procedure follow the traditional notice pleading
standard, as codified in Rule 8(a), which requires only a “short and plain statement of the
claim showing that the pleader is entitled to relief.” Nowhere do the Ridgeway Rules
adopt or incorporate the “plausibility” standard articulated in Bell Atl. Corp. v. Twombly,
550 U.S. 544 (2007), or Ashcroft v. Iqbal, 556 U.S. 662 (2009); really, just Control+F for
“plausibility” in the civil procedures!
Therefore, Defendant’s reliance on federal pleading standards is misplaced, and
this Court should instead apply the Ridgeway pleading rules as adopted under state law.
CONCLUSION
Plaintiff has sufficiently stated a cause of action for false imprisonment under
State law. Defendant’s motion should be denied because:
- It improperly relies on inapplicable federal rules;
- It fails to address the totality of the circumstances demonstrating confinement;
- It ignores Ridgeway’s broad statutory language, which prohibits restraint of a
person’s movement by any means without justification;
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WHEREFORE, Plaintiff respectfully requests that this Court:
1. Deny Defendant’s Motion to Dismiss in its entirety;
2. Allow this matter to proceed to discovery and trial;
3. And grant any other relief this Court deems just and proper
Dated: July 13th, 2025 Respectfully submitted,
/s/ Detachment_Result
Detachment_Result (State Bar No. 11103)
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