Rendered from the court's authenticated repository
Searchable full text
23,767 characters extracted
—
STATE OF RIDGEWAY
SUPERIOR COURT aaaaaCOUNTY OF RIDGEWAY
THR33SIX8,
Plaintiffs,
-against-
ZARTALOX, in his quasi-official capacity as a Senior
Trooper of the Ridgeway State Police,
THORSTRUCKED, in his quasi-official capacity as a
Captain of the Ridgeway State Police and Director of
the Ridgeway State Police Internal Affairs, and the
RIDGEWAY STATE POLICE, a government entity.
Defendants.
COMPLAINT
Case No.: RSC-CV-2201
The above-named Plaintiff, thr33six8, by and through his undersigned counsel, for his Complaint
herein alleges as follows:
PRELIMINARY STATEMENT
1. Plaintiff thr33six8 brings this action to redress the State’s brazen violation of fundamental rights
and the systemic failure of law enforcement to hold its own accountable. On July 3, 2025, Senior
Trooper Zartalox of the Ridgeway State Police pursued Plaintiff through Sterling Heights and
unleashed deadly force against him. The violent assault resulted in the destruction of Plaintiff’s
body and property, an outcome that no person should ever face under the Constitution. When
Plaintiff sought recourse through official channels, the officers entrusted with accountability
simply protected their comrade. Captain Thorstrucked, Director of Internal Affairs under his own
hand or via subordinate officers, dismissed Plaintiff’s complaint as “not sustained,” and no
discipline was ever imposed on Trooper Zartalox. In this way, Defendants Zartalox,
Thorstrucked, and the Ridgeway State Police have inflicted grave constitutional injuries on
Plaintiff – depriving him of life, liberty, bodily integrity, due process, and equal protection – and
have betrayed the constitutional promise that the government exists to secure “equal protections
of the laws” and bring “equal justice to all.” This action demands structural judicial intervention
to vindicate Plaintiff’s rights, hold Defendants accountable, and restore the rule of law.
2. As a result of Defendants’ actions and inaction, Plaintiff has suffered irreparable harm. Trooper
Zartalox shot Plaintiff to death and destroyed Plaintiff’s car without justification. Plaintiff was
thus deprived of life, bodily autonomy, and property without due process. Defendants’ refusal
even to investigate or punish that lethal misconduct reflects a broken system that tolerates
impunity for violence by state actors. Such conduct affronts basic principles of dignity, fairness,
and accountability enshrined in the First and Fourteenth Amendments and the Ridgeway
Constitution. By allowing an officer to kill with impunity, Defendants have diminished the
humanity and liberty of Plaintiff and all citizens of Ridgeway. Through this suit, Plaintiff asserts
his rights to life, liberty, and justice, and seeks damages and equitable relief to prevent future
abuses.
JURISDICTION AND VENUE
3. This Court has subject-matter jurisdiction over Plaintiff’s claims pursuant to Article I, Section I
of the Ridgeway Constitution1 as well as Article V, Section IV2. Venue is proper in this Court
because all events giving rise to the claims occurred within Ridgeway County, State of
Ridgeway. Defendant Zartalox and Defendant Thorstrucked are Ridgeway residents and
2 “There shall be a Superior court which shall exercise original jurisdiction for all civil and
criminal
cases or controversies under the rules as set by the Supreme Court…”
1 BILL OF RIGHTS ART I. SECTION 1. “Every person within this state ought to find a certain
remedy, by having recourse to the laws, for all injuries or wrongs which one may receive in
person, property or character; every person ought to obtain right and justice, freely, and without
being obliged to purchase it; completely and without any denial; promptly and without delay;
conformably to the laws.”
- 2 -
employees acting in their official capacities within this State. Defendant Ridgeway State Police
is a state agency performing its official functions in Ridgeway. Plaintiff, Defendants, and the key
incidents are all located in Sterling Heights, Ridgeway, well within this Court’s jurisdiction.
PARTIES
4. Plaintiff thr33six8 is a citizen of the State of Ridgeway.
5. Defendant Zartalox is a citizen of the State of Ridgeway and a Senior Trooper of the Ridgeway
State Police. At all relevant times, Zartalox was acting under color of state law.
6. Defendant Thorstrucked is a citizen of the State of Ridgeway and a Captain in the Ridgeway
State Police. At all relevant times, Thorstrucked was acting under color of state law.
7. Defendant Ridgeway State Police is the state law-enforcement agency for the State of
Ridgeway, created by 6 R. Stat. § 1101. The Ridgeway State Police is a part of the
executive branch of Ridgeway’s government and is charged with enforcing the laws of
Ridgeway.
FACTUAL ALLEGATIONS
8. On July 3, 2025, Plaintiff thr33six8 was present in the city of Sterling Heights, Ridgeway.
Earlier that day, Plaintiff had engaged in certain unlawful conduct, before dying and
respawning when these events took place (not at issue here). While Plaintiff was in
Sterling Heights, Defendant Zartalox began to chase Plaintiff in an attempt to apprehend
him.
9. The pursuit soon became a foot chase. Plaintiff ran on foot, then slipped through an
opening in a backyard fence to evade capture. Meanwhile Plaintiff’s black Cavela
automobile (the “Black Cavela”) was stationary nearby. When Plaintiff emerged from the
- 3 -
fence opening and approached his car, Senior Trooper Zartalox also exited his patrol
vehicle and approached Plaintiff on foot.
10. Fearing for his life, Plaintiff retrieved a firearm (a pistol) from his Black Cavela. As
Zartalox closed in, Plaintiff fired the Solami in self-defense, striking Trooper Zartalox.
(According to the known facts, this was the only time Plaintiff fired his gun at Zartalox.)
11. Approximately two minutes later, the chase continued elsewhere in Sterling Heights. At
this time, Trooper Zartalox was in pursuit of a different vehicle. Two officers from the
Ridgeway Parks Service were on the scene: Park Ranger II Asianible and Park Ranger I
Ontario_RBLX. These rangers were observing the events when Defendant Zartalox
emerged from his patrol car.
12. Defendant Zartalox drew his sidearm (a Stetson M2-A pistol3) and began firing at
Plaintiff. Zartalox discharged his weapon repeatedly, allowing no safe opportunity for
Plaintiff to escape. Plaintiff’s Black Cavela was struck by multiple bullets; the vehicle
sustained heavy damage as Plaintiff sought cover.
13. In the chaos, Plaintiff attempted to flee. Because Plaintiff had inadvertently set the
parking brake at an inopportune moment, his damaged Cavela was unable to move freely
and Trooper Zartalox proceeded to unload his magazine into the Cavela4. The dragging,
damaged vehicle skidded along a metal fence before igniting into flames and exploding,
4 Without showing regard to the decent and judicially accepted law enforcement practice which
“requires careful attention to the facts and circumstances of each particular case, including the
severity of the crime at issue, whether the suspect poses an immediate threat to the safety of the
officer or others, and whether [the suspect] is actively resisting arrest or attempting to evade
arrest by flight.” Graham v. Connor 490 U.S. 386, 396 (1989).
3 A pistol, in legal terms, is generally defined as a handgun designed to be fired with one hand,
having a chamber that is part of or permanently aligned with the barrel. It also has a short stock
designed to be gripped with one hand, and is not intended to be fired from the shoulder. It is by
all means a lethal weapon.
- 4 -
being sent approximately 50 feet into the air. This further demonstrated how Plaintiff’s
life and property were endangered by Zartalox’s attack.
14. Plaintiff returned fire at Trooper Zartalox in self-defense. In the initial exchange of
gunfire, one of Plaintiff’s shots accidentally struck Park Ranger I Ontario_RBLX in the
head. As a result of that gunshot wound, Ontario_RBLX suffered severe injury.
15. Ultimately, Plaintiff could not withstand Zartalox’s assault5. Trooper Zartalox’s final
rounds proved fatal, and Plaintiff, a member of the marginalized African-Ridgewayan
community, succumbed to his injuries right then and there, leaving the two rangers and
nearby civilians dumbfounded.6 Plaintiff thr33six8 was shot to death by Trooper Zartalox.
6 It must be noted, as a standard of review that “[t]he calculus of reasonableness must embody
allowance for the fact that police officers are often forced to make split-second judgments-in
5 Plaintiff sustained over 35 bullet rounds fired into his Cavela, followed by over 5 rounds fired
into his body in vital areas.
- 5 -
The Black Cavela was also destroyed – blown into smithereens by Zartalox’s gunfire –
before it could escape.
16. Two days later, on July 5, 2025, Plaintiff submitted a formal misconduct complaint to the
Ridgeway State Police, reporting Trooper Zartalox’s conduct. The Ridgeway State Police
had provided an official online “complaints form” for this purpose. The form’s preface
stated: “This document will serve as the official complaints form for the Ridgeway State
Police. If you have witnessed or collected evidence of any form of wrongdoing by a
member of the Ridgeway State Police, this is the form you should use to file a formal
complaint.” The form also informed complainants: “Please keep your DMs open, and
allow up to 72 hours for a response back by an Internal Affairs Investigator. We
appreciate your effort in making the Ridgeway State Police a better agency.” Plaintiff’s
complaint, filed on July 7, 2025, detailed Trooper Zartalox’s reckless use of deadly force
and the resulting harm.
17. On July 10, 2025, Lieutenant drjack0— identified in Ridgeway State Police records as
the “Head Investigator” in Internal Affairs— communicated with Plaintiff (via direct
message) regarding the complaint. In that message, drjack0 stated: “The complaint you
submitted to the Ridgeway State Police Internal Affairs Office has been declared: not
sustained. The department appreciates your wishes to hold our employees accountable for
their actions. If you have any questions, please reach out to Internal Affairs Command.”
circumstances that are tense, uncertain, and rapidly evolving-about the amount of force that is
necessary in a particular situation.” Id. at 396-97. In addition, “[t]he 'reasonableness' of a
particular use of force must be judged from the perspective of a reasonable officer on the scene,
rather than with the 20/20 vision of hindsight." Id. at 397. “[T]he question is whether the
officers' actions are 'objectively reasonable' in light of the facts and circumstances confronting
them.” Id.
- 6 -
This curt response provided no explanation or follow-up and made clear that Plaintiff’s
complaint was dismissed without substantive review.
18. At all relevant times, Captain Thorstrucked had a statutory and constitutional duty to
investigate legitimate complaints against Ridgeway officers. Under applicable RSP
policies and Ridgeway law, including the mandates of RSC Article I and R. Statutes, a
law enforcement commander may initiate discipline for any good cause, even if no
specific rule was cited. Trooper Zartalox’s conduct on July 3 — discharging his weapon
without justification, causing death and destruction — would reasonably violate both
Ridgeway criminal law and the code of conduct expected of officers. Thorstrucked was
not barred from investigating Zartalox in his position as the head investigator; on the
contrary, when faced with a complaint implicating constitutional rights, he had an
affirmative obligation to act.
19. On July 11, 2025, the Solicitor General of the State of Ridgeway, Mx. BrendaPopplewell,
reflecting the opinions of the department’s leadership, issued a memorandum on law
enforcement use of force. That memorandum warned officers against overreliance on
deadly force7, emphasizing the use of less-than-lethal alternatives whenever feasible. This
official guidance underscored that Zartalox’s lethal response on July 3 was contrary to
best practices and state policy8.
8 “A. Deadly force may not be used solely to prevent the escape of a fleeing suspect. B. Firearms
may not be discharged solely to disable moving vehicles. Specifically, firearms may not be
discharged at a moving vehicle unless: (1) a person in the vehicle is threatening the officer or
7 “Law enforcement should strive to value and preserve human life. Officers may use only the
force that is objectively reasonable to effectively gain control of an incident, while protecting
the safety of the officer and others, in keeping with the standards set forth in Graham v. Connor,
490 U.S. 386 (1989). Officers may use force only when no reasonably effective, safe, and
feasible alternative appears to exist and may use only the level of force that a reasonable officer
on the scene would use under the same or similar circumstances.” Rid. Sol. Gen., Memorandum
on Use of Force (2025) p.p 1
- 7 -
20. Despite these clear imperatives, Defendants took no corrective action. Captain
Thorstrucked imposed no discipline on Trooper Zartalox—within the Ridgeway State
Police nor through any LETC process—for the shooting of Plaintiff. The Ridgeway State
Police similarly declined to sanction Zartalox. No internal affairs inquiry was initiated
beyond the perfunctory dismissal, and no accountability was exacted. By contrast, in the
aftermath of July 3, those same Defendants protected Zartalox’s career while leaving the
most fundamental rights of Plaintiff and the public unvindicated.
21. Trooper Zartalox’s wanton use of force and the Ridgeway State Police’s institutional
cover-up deprived Plaintiff of the life and liberty that the Constitution is meant to guard.
The facts and policies described above demonstrate a systemic breakdown in Ridgeway
law enforcement: police empowered to kill at will and administrators who refuse to check
that power. This breakdown caused Plaintiff’s death and must be remedied by the courts.
COUNT I: Violation of Rights (1 R. Stat. § 3115) and Constitutional Violations (14th
Amendment, Ridgeway Const. Art. I §§ 1, 4, 5)
another person with deadly force by means other than the vehicle; or (2) the vehicle is operated
in a manner that threatens to cause death or serious physical injury to the officer or others, and
no other objectively reasonable means of defense appear to exist, which includes moving out of
the path of the vehicle.
C. If feasible and if to do so would not increase the danger to the officer or others, a verbal
warning to submit to the authority of the officer shall be given prior to the use of deadly
force.
D. Warning shots are not permitted outside of the prison context.
E. Officers should be trained in alternative methods and tactics for handling resisting subjects,
which must be used when the use of deadly force is not authorized by this policy. F. Deadly
force should not be used against persons whose actions are a threat solely to themselves or
property unless an individual poses an imminent danger of death or serious physical injury to
the officer or others in close proximity.” Rid. Sol. Gen., Memorandum on Use of Force (2025)
p.p 2
- 8 -
22. Plaintiff incorporates all preceding paragraphs as though fully set forth herein.
23. Defendants’ conduct constitutes a violation of Plaintiff’s rights under the civil tort
codified at 1 R. Stat. § 3115. Under this statute, it is an actionable wrong for any public
officer to wrongfully deprive a person of their legal or constitutional rights. All
Defendants are liable under 1 R. Stat. § 3115 for the unlawful deprivation of Plaintiff’s
rights9.
24. Trooper Zartalox’s deliberate, deadly attack on Plaintiff deprived Plaintiff of life, liberty,
and property without due process of law. By shooting Plaintiff to death and destroying
Plaintiff’s car, Zartalox violated Plaintiff’s right to life and bodily security – rights
protected by the Fourteenth Amendment’s Due Process Clause and by Article I, §§ 1 and
5 of the Ridgeway Constitution (which guarantees that “no person shall be deprived of
life, liberty or property” without due process, and that every member of society has the
right to be protected in the enjoyment of life and liberty). Zartalox’s conduct was not only
unlawful under criminal statutes, it was a willful abuse of his authority. No exigent
circumstance justified executing a citizen in that manner.
25. Trooper Zartalox’s actions also affronted Plaintiff’s dignity and bodily autonomy — core
components of liberty. The right to bodily integrity is safeguarded by the Fourth and
Fourteenth Amendments against unreasonable intrusion by the state. Zartalox’s
unprovoked shooting constituted an unconstitutional seizure of Plaintiff’s person. By
9 Every person who, under color of any statute, ordinance, regulation, custom, or usage, subjects,
or causes to be subjected, any citizen of the State of Ridgeway or other person within the
jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the
Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or
other proper proceeding for redress, except that in any action brought against a judicial officer
for an act or omission taken in such officer’s judicial capacity, injunctive relief shall not be
granted unless a declaratory decree was violated or declaratory relief was unavailable.
- 9 -
violently ending Plaintiff’s life, Zartalox stripped Plaintiff of all constitutional
protections.
26. Defendants’ refusal to investigate or punish this fatal misconduct further violated
Plaintiff’s constitutional rights. By shielding Zartalox from accountability, Defendants
denied Plaintiff the equal protection of the laws. The Ridgeway Constitution itself
declares that government must exist for the “common benefit, protection, and security of
the people” (Art. I, § 4) and that every person has a right to a prompt and lawful remedy
for injuries (Art. I, § 1). Defendants’ actions subvert these mandates. When state actors
intentionally allow a fellow officer to kill with impunity, they create a class of citizens –
any person who might challenge police power – who are not entitled to equal protection.
This essentially institutionalizes a bill of attainder by law enforcement, condemning a
citizen without trial. Plaintiff was entitled to an impartial investigation and fair
enforcement of law following the shooting. Instead, Defendant Thorstrucked simply
declared Plaintiff’s complaint “not sustained” and the Ridgeway State Police took no
action, effectively nullifying Plaintiff’s right to justice.
27. The totality of these violations – lethal force without cause, and the systematic denial of
redress – breached multiple constitutional guarantees. Plaintiff was deprived of life,
personal security, and property without due process; was denied the equal protection of
the laws; and was abandoned by the very government whose purpose is to protect its
citizens. These harms violate the U.S. Constitution (including the First, Fourth, and
Fourteenth Amendments) and the Ridgeway Constitution (Art. I, §§ 1, 4, 5). Plaintiff
accordingly seeks relief under 1 R. Stat. § 3115 to vindicate his constitutional and
statutory rights.
- 10 -
COUNT II: Official Misconduct (1 R. Stat. § 3114)
28. Plaintiff incorporates all preceding paragraphs as though fully set forth herein.
29. Defendants’ conduct also constitutes official misconduct in violation of 1 R. Stat. § 3114.
That statute makes it an offense for a public officer, “having knowledge that it is his duty
to perform or cause to be performed any act,” knowingly to omit or fail to perform that
duty. By their acts and omissions described above, Defendants knowingly failed to
perform their duties and thus committed official misconduct.
30. First, Defendant Zartalox, by engaging in unlawful conduct and using lethal force without
justification, knowingly abused the authority of his office. Zartalox’s actions were willful
and unlawful, and they were not in furtherance of any legitimate police duty. This
constitutes official misconduct by an officer of the Ridgeway State Police.
31. Second, Defendant Thorstrucked knowingly failed to fulfill his duty as a law enforcement
commander. Under RSP policies and constitutional law, Thorstrucked had a duty to
investigate and discipline misconduct by police officers, especially when the misconduct
involved possible constitutional violations. Instead, Thorstrucked dismissed Plaintiff’s
complaint without adequate investigation. By doing so, Thorstrucked refused to perform
the duty imposed on him by law and policy. This deliberate inaction is the very definition
of official misconduct.
32. Third, the Ridgeway State Police, as an entity, failed to uphold its statutory and
constitutional obligations. The State Police had a duty to “bring all violators of state law
to justice” and to ensure equal protection under the laws. By allowing an officer to kill a
citizen and then refusing to discipline that officer, the Ridgeway State Police itself
- 11 -
committed official misconduct. The Department’s tacit approval of Zartalox’s actions
violated the public trust and subverted the law.
33. Each Defendant thus engaged in official misconduct. The clear hierarchy of command
and policy at the Ridgeway State Police makes Defendant Thorstrucked’s omission
particularly blameworthy: as a lieutenant of the Ridgeway State Police, he had the
authority and duty to act, and yet intentionally stood down. The compound effect of these
failures – by the officer in the field, by his supervisor, and by the agency – exemplifies a
systemic breakdown and warrants the remedies requested.
PRAYER FOR RELIEF
34. On Count I (Violation of Rights): Declare that Defendants Zartalox, Thorstrucked, and
the Ridgeway State Police violated Plaintiff’s rights under 1 R. Stat. § 3115 and the
Fourteenth Amendment to the U.S. Constitution and Article I, Sections 1, 4, and 5 of the
Ridgeway Constitution. That all Defendants be held liable for these violations; and that
the Court award Plaintiff the following damages from each Defendant: Defendant
Zartalox: $1,000 in punitive damages; Defendant Thorstrucked; $1 in punitive damages;
and Defendant Ridgeway State Police: $850 in punitive damages.
35. On Count II (Official Misconduct): Declare that Defendants Zartalox, Thorstrucked,
and the Ridgeway State Police committed official misconduct under 1 R. Stat. § 3114.
That all Defendants be held liable for these violations; and that the Court award Plaintiff
the following damages from each Defendant: Defendant Zartalox: $2,000 in punitive
damages; Defendant Thorstrucked: $50 in punitive damages; and Defendant Ridgeway
State Police: $4,000 in punitive and/or compensatory damages.
- 12 -
36. Injunctive and Equitable Relief: Pursuant to 1 R. Stat. § 3114(b) and the Court’s
equitable powers, order the following: Terminate Trooper Zartalox’s employment with
the Ridgeway State Police; Issue a formal reprimand or verbal warning to Lieutenant
Thorstrucked for his failure to act; and a thorough investigation of Zartalox’s conduct to
be completed, including consideration of any necessary revocation of Zartalox’s training
certification, should the termination of Trooper Zartalox take place.
37. Award Plaintiff such other and further relief as the Court deems just and proper to
redress Defendants’ misconduct and ensure future compliance with the law.
DATED: July 15, 2025
Chairman of the State Board for Black Rights
By: _______________________________
Singhski
Ridgeway Bar No. 10251
Black Rights Legal Defense Fund
Chairman
E: [email protected]
By: thr33six8
Plaintiff & Client of Attorney Singhski
- 13 -
