DISTRICT COURT OF THE STATE OF RIDGEWAY
COUNTY OF RIDGEWAY
richardm,
-against-
ERRCORE, in his individual capacity,
and RIDGEWAY COUNTY SHERIFF'S
OFFICE,
Defendants.
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 errcore is, upon information and belief, a law enforcement officer
employed by the Ridgeway County Sheriff’s Office and is sued in his individual
capacity for monetary damages.
5. Defendant Ridgeway County Sheriff's Office is a governmental agency responsible
for law enforcement within Ridgeway County. It is sued in its official capacity for
injunctive and declaratory relief.
FACTUAL ALLEGATIONS
6. On or about July 22, 2025, Plaintiff was lawfully operating his motor vehicle. The vehicle
was emitting smoke, and was in a state of imminent explosion should it be damaged any
further.
7. Plaintiff was prudently attempting to drive the vehicle to a nearby auto repair shop to prevent
further damage or a potential explosion.
8. Defendant errcore, a deputy with the Ridgeway County Sheriff's Office, observed Plaintiff's
vehicle and, acting under color of law, approached in his patrol vehicle.
9. Without provocation, legal cause, or justification, Defendant errcore intentionally and
maliciously rammed his patrol vehicle into Plaintiff's vehicle.
10. Upon information and belief, Defendant errcore’s act of ramming the vehicle was done with
the specific intent to cause Plaintiff's vehicle to explode and/or to cause the serious injury or
death of the Plaintiff.
11. After the initial ramming, Plaintiff exited his vehicle to approach Defendant errcore, at which
time Defendant errcore was seen instructing another deputy to “revoke his rflid,” indicating a
malicious intent to use official power to punish the Plaintiff without due process.
FIRST CAUSE OF ACTION (Deprivation of Rights – Excessive Force /
Unreasonable Seizure - 1 R. Stat. § 3115) (Against Defendant errcore in his
Individual Capacity)
12. Plaintiff realleges and incorporates by reference the preceding paragraphs.
13. Defendant errcore’s act of intentionally ramming Plaintiff's vehicle constituted an
unreasonable seizure and an application of excessive, life-threatening force
without any law enforcement justification.
14. This act, committed under color of law, deprived Plaintiff of his rights,
privileges, and immunities secured by the Constitution, including the right to be
free from unreasonable seizures and the right to life and bodily integrity, making
him liable for redress pursuant to 1 R. Stat. § 3115.
SECOND CAUSE OF ACTION (Assault) (Against Defendant errcore in his
Individual Capacity)
15. Plaintiff realleges and incorporates by reference the preceding paragraphs.
16. Defendant’s act of intentionally driving his vehicle at the Plaintiff's vehicle
caused Plaintiff to suffer a reasonable apprehension of an immediate and
potentially fatal battery.
17. This act constitutes the tort of assault pursuant to 1 R. Stat. § 3103.
THIRD CAUSE OF ACTION (Battery) (Against Defendant errcore in his
Individual Capacity)
18. Plaintiff realleges and incorporates by reference the preceding paragraphs.
19. Defendant’s act of ramming his vehicle into the vehicle occupied by the Plaintiff
constituted an unconsented, harmful, and offensive contact with Plaintiff’s
person.
20. This act constitutes the tort of battery pursuant to 1 R. Stat. § 3102.
FOURTH CAUSE OF ACTION (Trover - Destruction of Property) (Against
Defendant errcore in his Individual Capacity)
21. Plaintiff realleges and incorporates by reference the preceding paragraphs.
22. Defendant errcore intentionally and wrongfully interfered with Plaintiff's
possessory interest in his vehicle by ramming it, causing significant damage.
23. This act constitutes the tort of trover pursuant to 1 R. Stat. § 3113.
FIFTH CAUSE OF ACTION (Municipal Liability for Unconstitutional Policy or
Custom - 1 R. Stat. § 3115) (Against Defendant Ridgeway County Sheriff's Office)
24. Plaintiff realleges and incorporates by reference the preceding paragraphs.
25. Upon information and belief, the unconstitutional use of force by Defendant
errcore was a result of an official policy, practice, or custom of the Defendant
Ridgeway County Sheriff's Office of using or permitting the use of patrol
vehicles as deadly weapons without proper justification, and/or failing to
adequately train and supervise its deputies on the constitutional limits of the use
of force.
26. This unconstitutional policy or custom was the moving force behind the
violation of Plaintiff's rights, subjecting the Ridgeway County Sheriff's Office to
liability under 1 R. Stat. § 3115.
WHEREFORE, Plaintiff, richardm, respectfully requests that this Court enter
judgment in his favor and against Defendants as follows:
a. Against Defendant errcore: Awarding compensatory and punitive damages
in an amount to be determined at trial;
b. Against Defendant Ridgeway County Sheriff's Office: Issuing a declaratory
judgment that its policies or customs are unconstitutional;
c. Against Defendant Ridgeway County Sheriff's Office: Issuing a permanent
injunction ordering the department to cease its unconstitutional practices and
to adequately train its deputies;
d. Awarding the costs of this action, including reasonable attorneys' fees, as
allowed by law; and
e. Granting any and all other relief that this Court deems just and proper.
Respectfully submitted,
Dated: July 23, 2025
/s/0xSyns
0xSyns
