DISTRICT COURT OF THE STATE OF RIDGEWAY
COUNTY OF RIDGEWAY
richardm,
-against-
midfoley,
Defendant.
Case No. tbd
COMPLAINT
Plaintiff, brings this action for damages against Defendant and alleges as follows:
JURISDICTION AND VENUE
1. This court has original jurisdiction over “all civil and criminal cases or
controversies.” Rid. Const. art. 5, § 4.
2. Venue is proper in this Court as the events giving rise to this Complaint occurred
within the State of Ridgeway.
PARTIES
3. Plaintiff is an individual and a citizen and resident of the State of Ridgeway.
4. Defendant midfoley is, upon information and belief, an individual residing within
the State of Ridgeway.
FACTUAL ALLEGATIONS
5. On or about July 21, 2025, richardm lawfully withdrew $600 from an Automated
Teller Machine (ATM).
6. Following the withdrawal, richardm entered a gun store with the intention of
making a lawful purchase.
7. While richardm was inside the store, Defendant midfoley approached him,
brandishing a crowbar in a threatening manner.
8. This action caused richardm to experience a reasonable apprehension of imminent
and severe harmful contact.
9. Immediately thereafter, Defendant intentionally and without legal justification used
the crowbar to repeatedly strike richardm.
10. This violent and unconsented contact continued until richardm succumbed to his
injuries and died.
11. After killing richardm, Defendant wrongfully took the $600 in cash from richardm's
person and fled the scene.
12. The Defendant’s actions were the direct and proximate cause of the death of
richardm and the loss of his personal property.
FIRST CAUSE OF ACTION (Assault)
13. Plaintiff realleges and incorporates by reference the preceding paragraphs.
14. Defendant’s act of running up to richardm while brandishing a crowbar
intentionally caused richardm to suffer a reasonable apprehension of an immediate
battery.
15. This act constitutes the tort of assault pursuant to 1 R. Stat. § 3103.
16. SECOND CAUSE OF ACTION (Battery)
17. Plaintiff realleges and incorporates by reference the preceding paragraphs.
18. Defendant’s act of striking richardm with a crowbar constituted an unconsented,
harmful, and offensive contact with richardm’s person.
19. This act constitutes the tort of battery pursuant to 1 R. Stat. § 3102.
THIRD CAUSE OF ACTION (Trover)
20. Plaintiff realleges and incorporates by reference the preceding paragraphs.
21. Defendant wrongfully and without legal justification took personal property,
namely $600 in cash, belonging to richardm with the intent of permanently
depriving him of it.
22. This act constitutes the tort of trover pursuant to 1 R. Stat. § 3113.
FOURTH CAUSE OF ACTION (Wrongful Death)
23. Plaintiff realleges and incorporates by reference the preceding paragraphs.
24. Defendant’s wrongful and intentional act of beating richardm with a crowbar
directly resulted in the death of richardm without legal cause or justification.
25. This act constitutes the tort of wrongful death pursuant to 1 R. Stat. § 3109.
WHEREFORE, Plaintiff, richardm, respectfully requests that this Court enter
judgment in its favor and against Defendant, midfoley, and grant the following
relief:
a. Compensatory damages in the amount of $1,000;
b. Punitive damages for the act of assault in an amount up to the maximum allowed
by law, Three Thousand Five Hundred Dollars ($3,500), pursuant to 1 R. Stat. § 3103;
c. Punitive damages for the act of battery in an amount up to the maximum allowed
by law, Two Thousand Five Hundred Dollars ($2,500), pursuant to 1 R. Stat. § 3102;
d. Punitive damages for the act of trover in an amount up to the maximum allowed
by law, Four Thousand Five Hundred Dollars ($4,500), pursuant to 1 R. Stat. § 3113;
e. Punitive damages for the act of wrongful death in an amount up to the maximum
allowed by law, Five Thousand Dollars ($5,000), pursuant to 1 R. Stat. § 3109;
f. Any and all other relief that this Court deems just and proper.
Respectfully submitted,
Dated: July 21, 2025
/s/0xSyns
0xSyns
