IN THE
SUPERIOR COURT OF THE STATE OF RIDGEWAY
JAMESGARDAI,
Plaintiff,
v.
DRJACK0, in his official capacity as
Director of the Law Enforcement Training
Center
Defendant.
Case No.
VERIFIED COMPLAINT
VERIFIED COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF
Plaintiff JamesGardai, for his complaint against Defendant drjack0, alleges as follows:
PARTIES
1. Plaintiff JamesGardai is a resident of the State of Ridgeway.
2. Defendant drjack0 is the Director of the Law Enforcement Training Center.
JURISDICTION & VENUE
3. The jurisdiction of the Court originates from Art. V, Sec. IV which states “There
shall be a Superior court which shall exercise original jurisdiction for all civil and criminal cases
or controversies…”
4. Venue is proper as the actions that took place as stated within this complaint
occurred in Ridgeway County or an area which is subject to the jurisdiction thereof.
FACTUAL ALLEGATIONS
5. On July 28th, Plaintiff’s law enforcement training certification was indefinitely
suspended by Director drjack0.
6. Plaintiff received no prior notice or opportunity to contest the charges against
him.
7. The reasoning for such suspension was because Plaintiff was under investigation
by the Ridgeway Department of Justice.
8. Plaintiff does not have a criminal record, nor has he ever received one.
FIRST CAUSE OF ACTION
(Due Process Violation—1 R. Stat. § 3201)
9. Pursuant to 1 R. Stat. § 3201, “[a]ny policy, order, procedure, or directive that
impedes on an individuals rights, immunities, or privileges secured by law, charter, or the
constitution shall be subject to the injunctive relief of a permanent restraining order against the
government prohibiting them from enacting this policy, order, procedure, or directive; and
injunctive relief reversing any harm done.”
10. Plaintiff is entitled to notice of any and all allegations and an opportunity to
respond to them.
11. drjack0 never afforded Plaintiff this right when suspending his certification.
12. The Law Enforcement Training Center is prohibited from investigating any
instance of misconduct. 8 R. Stat. § 1301.
13. The Law Enforcement Training Center Director, when issuing disciplinary
actions to certifications, shall solely rely on recommendations from department heads and
reported findings from internal affairs agencies. 8 R. Stat. § 1302.
14. At no time did drjack0 receive a recommendation from a department head or a
reported finding from an internal affairs agency to issue a suspension or otherwise discipline
Plaintiff.
15. The Director is further prohibited from taking any action against a certified
individual without a prior investigation from an internal affairs entity. 8 R. Stat. § 1303 et seq.
16. No investigation has ever been submitted nor has any ever occurred.
17. The suspension constituted a directive and order issued by drjack0, a government
official with authority, that imposed a binding and enforceable restriction on Plaintiff’s rights.
18. The suspension impedes on Plaintiff’s rights, privileges, and immunities secured
by the Due Process Clause of the Fourteenth Amendment and state law.
19. Plaintiff is therefore entitled to declaratory relief and a permanent restraining
order against drjack0 and the Law Enforcement Training Center.
PRAYERS FOR RELIEF
WHEREFORE, the plaintiff requests that the court grant relief as follows:
20. A declaratory judgment that Defendant’s imposed suspension on Plaintiff is
unlawful;
21. A preliminary and permanent restraining order enjoining Defendant from
carrying out such suspension;
22. Any other relief that the court deems just and proper.
Respectfully submitted.
Date: 07/28/2025
_________________________________
JamesGardai, Esq.
Rid. Bar. No. 10244
Palmer, Ridgeway
D: fishfromocean
VERIFIED COMPLAINT AFFIDAVIT
I, the undersigned Plaintiff, that I have read the foregoing complaint and know the
contents thereof. I swear under the pains and penalties of perjury that my foregoing statements
and contents are true to my knowledge except as to matters alleged on information and belief,
and as to those matters I believe them to be true.
Respectfully submitted.
Date: 07/28/2025
_________________________________
JamesGardai, Esq.
Rid. Bar. No. 10244
Palmer, Ridgeway
D: fishfromocean
