RIDGEWAY SUPERIOR COURT
FOR THE COUNTY OF RIDGEWAY
TOBYRULLES4568,
Plaintiff-Petitioner,
v.
STATE OF RIDGEWAY;
REFRESHEDMANGO, in his
official capacity as Governor of the
State of Ridgeway; DEPARTMENT
OF JUSTICE; TOBYRULLES4568,
in his official capacity as Attorney
General of the State of Ridgeway;
PALMER POLICE
DEPARTMENT; JAMESGARDAI,
in his individual and official
capacities as a Lieutenant in the
Palmer Police Department,
Defendants-Respondents.
Civil Action No.
COMPLAINT AND PETITION FOR WRIT OF
HABEAS CORPUS
Plaintiff Tobyrulles4568, by and through the undersigned counsel, seeking
all available relief, in his complaint and petition against Defendants, alleges the
following:
INTRODUCTION
1. State law criminalizes the mere possession of so-called
“government-issue equipment” as a civilian. This scheme truly defies law and
logic. The statute prescribes severe punishment—sending people to prison for 20
minutes, and of course, the loss of property by extension. With this statute and
other amorphous criminal statutes, the state seeks to advance its political agenda at
the expense of the life, liberty, and property of thousands. That is not just illegal. It
is also wrong.
2. Plaintiff is the Attorney General of the State of Ridgeway. Despite
this, he has been arrested and imprisoned for 25 minutes for unlawful possession of
government-issued equipment. Plaintiff brings this hybrid habeas corpus and civil
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rights action under 1 R. Stat. §§ 3201, 3115 and 2210, challenging the
constitutionality of R.C.C. § 5.08(a), his seizure, and his arrest. He seeks
declaratory relief, injunctive relief, and monetary relief.
JURISDICTION
3. This court has original jurisdiction over “all civil and criminal cases or
controversies.” Rid. Const. art. 5, § 4.
4. Venue is proper in this court because the actions and omissions
alleged in this complaint took place in the State of Ridgeway.
PARTIES1
5. Tobyrulles4568 (“Plaintiff Toby”) is an individual, resident, and
citizen of the State of Ridgeway. Plaintiff Toby is the Attorney General of the State
of Ridgeway.
6. RefreshedMango (“Governor Mango”) is named in his official
capacity as Governor of the State of Ridgeway. In this capacity, Governor Mango
is the chief executive officer of the state, and is responsible for the faithful
execution of state law. See Rid. Const. art. 2, § 3; art. 4, § 1.
7. Tobyrulles4568 (“Attorney General Toby”) is named in his official
capacity as the Attorney General of the State of Ridgeway. In this capacity,
Attorney General Toby is the chief law enforcement officer of the state, and has the
final authority over how the law is interpreted and implemented by law
enforcement in the state. See 2 R. Stat. §§ 2201-02.
8. JamesGardai (“Defendant JamesGardai”) is an individual, resident,
and citizen of the State of Mayflower. Defendant is a Lieutenant in the Palmer
Police Department. Defendant JamesGardai was at all relevant times a police
officer acting under the color of the law. Defendant JamesGardai is sued in his
individual and official capacities.
1 All individuals and entities sued in their official capacities shall be collectively referred to as “Government
Defendants,” and all individuals and entities sued in their individual capacities shall be collectively referred to as
“Individual Defendants.”
2
FACTS
9. Plaintiff Toby is the Attorney General of the State of Ridgeway.
10. Plaintiff Toby is the chief attorney, chief prosecutor, and chief law
enforcement officer of the State of Ridgeway.
11. On July 25, 2025, Plaintiff was acting in his capacity as the Attorney
General of the State of Ridgeway and was on the Department of Justice team.
12. Plaintiff was under the protection of the Ridgeway State Police and
was in a vehicle convoy.
13. Plaintiff Toby was at the Sterling Gun Club in Sterling Heights,
Ridgeway, seeking to lawfully purchase a firearm.
14. Plaintiff Toby was detained and handcuffed by Defendant
JamesGardai.
15. Defendant JamesGardai suspected that Plaintiff Toby possessed a
radio earlier that day.
16. Defendant JamesGardai searched Plaintiff Toby and found that he did
not possess a radio.
17. Plaintiff Toby did not possess a radio at the time he was detained.
18. Defendant JamesGardai placed Plaintiff Toby in his patrol vehicle.
19. Plaintiff Toby was taken to the Ridgeway County Sheriff’s Office
Sub-Station in Sterling Heights, Ridgeway.
20. Plaintiff Toby was booked by Defendant JamesGardai for unlawful
possession of government-issued equipment, in violation of R.C.C. § 5.08(a).2
21. R.C.C. § 5.08(a) states:
“The act of unlawfully possessing any government-issue
equipment in any off-duty or civilian storage device,
capacity, or other inventory not mentioned of which is
not authorized by state law or relevant department
policy.”
2 See Exhibit A.
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22. R.C.C. § 5.08(a) is a felony and carries a maximum sentence of 20
minutes.
23. Upon being booked, Plaintiff Toby was remanded to the custody of
the Ridgeway Department of Corrections for 25 minutes.
24. Plaintiff Toby has no criminal history besides traffic infractions.3
FIRST CAUSE OF ACTION
(Void-for-Vagueness, Fourteenth Amendment – 1 R. Stat. § 3201)
Against Government Defendants
25. All prior paragraphs within this complaint are incorporated as if they
were fully set forth herein.
26. The Fourteenth Amendment to the United States Constitution
provides that “No State shall…deprive any person of life, liberty, or property,
without due process of law.” U.S. Const. amend. XIV.
27. “It is a basic principle of due process that an enactment is void for
vagueness if its prohibitions are not clearly defined.” Grayned v. City of Rockford,
408 U.S. 104, 108 (1972). Laws can be vague either because they (1) fail to inform
people of what they prohibit or (2) lend themselves to arbitrary and discriminatory
enforcement. See City of Chicago v. Morales, 527 U.S. 41, 58-59 (1999);
Papachristou v. Jacksonville, 405 U.S. 156, 162 (1972).
28. The term “government-issue equipment” as used in R.C.C. § 5.08(a)
does not provide sufficient notice of what type of conduct is prohibited under the
statute.
29. The term “off-duty or civilian storage device, capacity, or other
inventory not mentioned” as used in R.C.C. § 5.08(a) does not provide sufficient
notice of what type of conduct is prohibited under the statute.
30. The phrase “not authorized by state law or relevant department
policy” as used in R.C.C. § 5.08(a) does not provide sufficient notice of what type
of conduct is prohibited under the statute.
3 See Exhibit A.
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31. Because these terms are poorly and vaguely defined, R.C.C. § 5.08(a)
vests law enforcement with wide discretion to determine what conduct is criminal.
32. Alternatively, R.C.C. § 5.08(a) is so standardless that it invites
arbitrary enforcement because it criminalizes conduct by Plaintiff Toby but permits
identical conduct by Defendant JamesGardai.
FOURTH CAUSE OF ACTION
(Unreasonable Seizure, Fourth Amendment – 1 R. Stat. § 3115)
Against Individual Defendant
33. All prior paragraphs within this complaint are incorporated as if they
were fully set forth herein.
34. The Fourth Amendment to the United States Constitution protects “the
right of the people to be secure in their persons…against unreasonable searches
and seizures.” U.S. Const. amend. IV.
35. Defendant JamesGardai was acting under the color of the law at all
relevant times.
36. Defendant JamesGardai seized Plaintiff Toby when he approached
him and placed him in handcuffs.
37. Defendant JamesGardai did not have reason to believe that Plaintiff
Toby had committed, was committing, or was about to commit a crime at any point
during his seizure of Plaintiff Toby.
FITH CAUSE OF ACTION
(False Arrest, Fourth Amendment – 1 R. Stat. § 3115)
Against Individual Defendant
38. All prior paragraphs within this complaint are incorporated as if they
were fully set forth herein.
39. The Fourth Amendment to the United States Constitution protects “the
right of the people to be secure in their persons…against unreasonable searches
and seizures.” U.S. Const. amend. IV.
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40. Defendant JamesGardai was acting under the color of the law at all
relevant times.
41. Defendant JamesGardai arrested Plaintiff Toby without probable
cause.
SIXTH CAUSE OF ACTION
(Ultra Vires, False Imprisonment – 1 R. Stat. § 3104)
Against Individual Defendant
42. All prior paragraphs within this complaint are incorporated as if they
were fully set forth herein.
43. Defendant JamesGardai placed Plaintiff Toby in handcuffs and
arrested him, restraining and restricting his movement.
44. Plaintiff was acting in his capacity as the Attorney General of the
State of Ridgeway and was on the Department of Justice team.
45. Plaintiff Toby was an on-duty law enforcement officer as defined
under the Department Cooperation Act (S.B. 8-18).
46. Plaintiff Toby was an on-duty civil service employee as defined under
the Department Cooperation Act (S.B. 8-18).
47. Defendant JamesGardai did not possess legal authority to detain and
arrest Plaintiff Toby under Section 4 and Section 5 of the Department Cooperation
Act (S.B. 8-18).
48. Alternatively, Defendant JamesGardai did not possess legal
justification to seize, detain, and arrest Plaintiff Toby because he did not have
reasonable suspicion or probable cause.
SEVENTH CAUSE OF ACTION
(Habeas Corpus – 1 R. Stat. § 2210)
Against Official Defendants
49. All prior paragraphs within this complaint are incorporated as if they
were fully set forth herein.
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50. R.C.C. § 5.08(a) criminalizes “unlawfully possessing any
government-issue equipment in any off-duty or civilian storage device, capacity, or
other inventory not mentioned of which is not authorized by state law or relevant
department policy.”
51. Defendant JamesGardai did not have probable cause to arrest Plaintiff
Toby for R.C.C. § 5.08(a) because Plaintiff Toby did not possess a radio. And even
if Plaintiff Toby possessed a radio, Defendant JamesGardai did not have probable
cause to arrest Plaintiff Toby because Plaintiff Toby was an on-duty law
enforcement official acting in his capacity as Attorney General, possessing the
statutory and constitutional authority to carry government-issued equipment as
necessary for official duties. Alternatively, Plaintiff Toby is actually innocent for
the same reasons and because he did not possess an evil-meaning mind because he
was acting in furtherance of his official duties.
52. Further, the arrest should be vacated because R.C.C. § 5.08(a) is
facially unconstitutional under the Fourteenth Amendment to the United States
Constitution.
RELIEF
WHEREFORE, Plaintiff prays that the court enter judgment in their favor
and against Defendants as follows:
a. Declaratory relief declaring that R.C.C. § 5.08(a) is unconstitutionally
vague and is facially unconstitutional under the Fourteenth Amendment to the
United States Constitution;
b. Declaratory relief that the seizure and arrest of Plaintiff was
unconstitutional under the Fourth and Fourteenth Amendments to the United
States Constitution;
c. Injunctive relief enjoining Defendants from enforcing R.C.C. §
5.08(a);
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d. Injunctive relief ordering the vacature, expungement, and sealing of
the arrest record of Plaintiff;
e. Awarding compensatory damages to Plaintiff in an amount to be
determined at trial;
f. Awarding punitive damages to Plaintiff not to exceed the statutory
limit;
g. Awarding pre- and post-judgment interest;
h. Awarding the costs of this action, including attorney fees, to Plaintiff;
i. Such further relief as the court deems just and proper.
Dated: July 23, 2025
Palmer, Ridgeway Respectfully submitted,
/s/ Tobyrulles4568
Tobyrulles4568(Bar No. 10264)
Counsel of Record
Representing Pro Se
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Exhibit A
