SUPERIOR COURT OF THE STATE OF RIDGEWAY
FOR THE COUNTY OF MILTON
------------------------------------------------------------------------X
ALEXBLUBEAR,
Plaintiff, INDEX No.
v.
RIDGEWAY DEPARTMENT OF STATE,
AB_BAE in her official capacity as
SECRETARY OF STATE,
Defendant.
------------------------------------------------------------------------X
COMPLAINT
Plaintiff, Alexblubear, hereby brings action against RIDGEWAY DEPARTMENT OF
STATE and AB_BAE (herein after collectively known as “Defendants”) for declaratory
judgment and alleges as follows:
BACKGROUND
1. The Department of State of the State of Ridgeway discord server is a public
communication server that is authorized for operation by Group Management as set forth
in their own rules and regulations for operations.
2. The Defendants on 12:06 AM Eastern Standard Time (“EST”) on July 27, 2025 deleted
their public communication channel that allows for the general public to be able to
communicate with Department officials, but allows for people to criticize the lack of
progress and functionality that the Department of State has made.
3. The Department of State is required to follow the constitution of the State of Ridgeway
and also required to uphold the laws of the State of Ridgeway.
4. On July 27, 2025 the Plaintiff, via electronic means, gave notice to the Defendants1 that
their actions were in direct violation of the statutory and constitutional laws of the State
of Ridgway as it directly prohibits free speech and bans any form of communication,
critical or not.
5. The letter outlined that their actions were in direct violation of State law and gave them a
time limit of twenty-four (24) hours of the date of service of the letter. That time expired
at 3 PM Eastern Standard Time on July 28, 2025.
PARTIES, JURISDICTION & VENUE
6. Plaintiff, Alexbluber, is a resident of the State of Ridgway and resides within the City of
Milton.
7. Defendant Department of State of Ridgeway is an executive agency of the State of
Ridgeway and derives its power from Title 2 of the Ridgeway Code of Statues labelled
“The Executive”
8. Defendant Ab_bae is the Secretary of State of the Ridgeway Department of State and that
agency's highest ranking official. She is charged with the supervision and management of
all decisions and actions of that agency. She is sued in her official capacity. See 2 R. Stat.
§ 1101 and 2. R. Stat. § 1103
9. This court has jurisdiction to hear these claims pursuant to Art. V Sec. IV of the
Ridgeway State Constitution.
10. The court has the jurisdiction to grant relief sought by Plaintiff pursuant to 1 R. Stat §
3201
1https://docs.google.com/document/d/1AyLreAK-0hGyJUdLdCwpakMgMIbXfwRUQkXH1gQhoFQ/edit?us
p=sharing
11. Venue is proper as all the acts or omissions as outlined take place within the State of
Ridgeway in whole or in part.
FACTUAL ALLEGATIONS
I. REVOCATION OF THE RIGHT OF SPEECH
12. The defendants in this matter revoked the right to speech when they outright banned
communications in their discord server2
13. In the Supreme Court case of Lindke v. Freed, 601 U.S. 187 (2024)3 The Supreme Court,
in a unanimous decision, ruled that a government official can not ban a person(s) right to
free speech on a social media account in accordance with 42 U.S.C. § 1983.
14. A government's action to restrict free speech under Lindke set a standard that it is a state
action if (1) the defendant possessed actual authority to speak on the State’s behalf on a
particular matter; and (2) they purported to exercise that authority when speaking in the
relevant social-media.
15. As set forth in Lindke points, the plaintiff alleges that:
a. The Defendants are officially charged and possess the actual authority to speak on
behalf of the State on a particular matter (i.e. governmental operations), and;
b. The Defendants by act or omission purported that authority by stating the cease of
the public channel in the Department of State's own governmental announcements
channel.
3 https://www.supremecourt.gov/opinions/23pdf/22-611_ap6c.pdf
2 https://discord.gg/nPCb6BpGep
16. The revocation of the right to speech as outlined in Article I Sec. IX of the Ridgeway
State Constitution leads to the deprivation of rights under the color of the law from the
defendants.
17. The state duties that are entrusted to the defendants provide that they must defend and
protect the constitution of the State of Ridgeway including those person(s) critical of the
department.
18. In banning overall communication, even for a minuscule amount of time, in the discord
server, the defendants violated State law and the plaintiff suffered real harm for their
actions and causes irreparable injury4 and is the duty of the courts to rectify such.
CAUSES OF ACTION
FIRST CAUSE OF ACTION
1 R. Stat. § 3115
Violation of Rights under the Color of the Law
19. Plaintiff incorporates by reference the allegations set forth in paragraphs numbered “1”
through “18” as if fully set forth herein.
20. The State of Ridgeway under the Constitution pursuant to Article I Section 9 grants the
right to free speech for all individuals and provides that no person(s) shall be deprived of
that right.
21. Defendants, by act or omission, deprived the plaintiff of the right to free speech under the
color of the law by banning all public communications within their discord server which
is in direct contradiction to the laws of this state specifically 1 R. Stat. § 3115.
22. The defendants, even after being notified by the Plaintiffs that their actions are illegal and
are in direct violation of the laws of the State of Ridgeway continued to violate the rights
of the Plaintiff.
4 Elrod V. Burns, 427 U.S. 347, 373 (1976)
PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests that the Court:
A. Issue a declaratory judgment against the defendants holding that they violated the
constitutional rights of the Plaintiff;
B. Enjoin Defendants from continuing to violate the listed violations in the sections
above and order that the defendants take measures to further reinforce the rights
afforded by the State constitution;
C. Install a monitor for the Department of State to ensure that Defendants are
properly executing their jobs and ensuring that all operations are well within the
laws of the State of Ridgeway;
D. Award the plaintiff court filing fees; and
E. Grant such other and further relief as the Court deems just and proper.
DATED
July 27, 2025
Respectfully Submitted
/s/ Alexblubear
Alexblubear
Represented Pro Se
