IN THE SUPERIOR COURT
OF THE STATE OF RIDGEWAY
SOLOMONNOMIKOS,
Petitioner,
v.
TYYLIES, in his official capacity as a Sergeant
First Class of the Ridgeway National Guard,
Respondent.
Case No. RSC-CV-XXX
Petition for Writ of Habeas Corpus
Hon. Judge Unassigned
Petitioner SolomonNomikos, 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 SolomonNomikos is a citizen of the State of Ridgeway.
2. Respondent tyylies is a Sergeant First Class within the Ridgeway National Guard, specifically
within the Military Police, 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 State of
Ridgeway, supplemented by 1 R. Stat. § 2210, which authorizes the Superior Court of the State of
Ridgeway to hear petitions for habeas corpus.
4. Venue is correct as the actions in question occurred in the geographic boundaries of the City of
Sterling Heights, within the State of Ridgeway.
CUSTODY
5. Petitioner was held in the custody of Ridgeway County Corrections on July 13th, 2025.
STATEMENT OF FACTS
6. On July 13th, 2025, Petitioner was within the city of Sterling Heights, Ridgeway County, RW, on
its singular main arterial road.
7. Petitioner was driving down the road, before parking his black SUV behind a National Guard
humvee that had just crashed into another humvee.
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8. Guardsmen boosta_z and Tga_bot1, neither of whom hold LETC certification nor are employed
as Military Police or in any other law enforcement agency, confront Petitioner, telling him to
move his car.
9. Around five seconds later, the guardsmen previously mentioned placed Petitioner into handcuffs,
placed him into a humvee, and transported him to the Ridgeway National Guard base.
10. Once Petitioner arrived, the guardsmen handed Petitioner to the Respondent, who booked him at
the jail inside the Ridgeway National Guard base for Failure to Comply.
11. Respondent booked Petitioner with an arrest description/LOV of: “Out of City Limits; RCU;
Suspect refused to comply with a guardsmen order after being told to move due to them
obstructing the guardsmen from moving their vehicle.”
12. Failure to Comply, R.C.C. § 2.04, is defined as: “The act of disobeying a lawful order which has
been given by a peace officer prior.”
CLAIMS FOR RELIEF
13. The statements contained in paragraphs 1 through 12 of this Petition are incorporated by
reference as if fully set forth herein.
14. Pursuant to 1 R. Stat. § 2210, an individual may petition this court for habeas relief. Section 2210
creates a special “cause of action” for habeas proceedings.
15. In reviewing habeas petitions, this Court must first determine “whether the police were legally
entitled to make [an] arrest.” See In re ZachCasisbeast, 1 R. Supp. 12 (2022). Indeed, If the arrest
was not lawful at the outset, “the inquiry ends there; the record must be removed.” Id.
16. Although ZachCasisbeast is not binding upon the Court, no precedent exists within our reborn
State, and ZachCasisbeast presents a reasonable standard that adequately protects the due process
rights of habeas petitioners. It has been historically cited in almost every, if not every single
habeas petition, in the legacy state since it was ruled upon.
17. Petitioner contends that, with the arrest description admitting the order to move the vehicle was
given by guardsmen, agreeing with paragraph 8 of this petition, and where those guardsmen were
not law enforcement officers nor certified by LETC, probable cause can not exist for the offense
of failure to comply. The Criminal Code clearly states that failure to comply only takes place
when a lawful order is given by a “peace officer,” not simply any government employee. R.C.C. §
2.04.
18. As a result of the unlawfulness of the arrest of the Petitioner, the charge must be vacated and the
record must be removed.
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19. In the event the arrest may be determined lawful at its outset, the Court must move to the next
line of inquiry for its review of this petition; being “whether the petitioner is actually innocent.”
In re ZachCasisbeast, 1 R. Supp. 12 (2022).
20. The petitioner’s actual innocence may be determined “by establishing facts that make the
prospect of a hypothetical conviction on the charges virtually impossible,” 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.” Id.
21. Given the facts established in paragraphs 1 through 12 of this petition, the argument raised in
paragraph 17 of this petition, and similarly supported at trial by the testimony of the Petitioner, a
reasonable and well-informed jury could not convict the petitioner.
22. As a result of the Petitioner’s actual innocence, the charge must be vacated and the record must be
removed.
PRAYER FOR RELIEF
WHEREFORE, Petitioner respectfully prays the court for relief as follows:
23. Issue a permanent injunction ordering immediate reversal and vacatur of the criminal record with
ID 202575f5b23f268.
DATED: July 13, 2025 Respectfully submitted,
Robin5D
R. Bar No. 10274
D: checkraisefold
Counsel of Record
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