DISTRICT COURT OF THE STATE OF RIDGEWAY
COUNTY OF RIDGEWAY
richardm,
-against-
XDINOMANX, in his individual
capacity, and Palmer Police Department
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 xdinomanx is, upon information and belief, a law enforcement officer
employed by the Palmer Police Department and is sued in his individual capacity
for monetary damages.
5. Defendant Palmer Police Department is a municipal agency of the City of Palmer,
responsible for law enforcement within its jurisdiction. It is sued in its official
capacity for injunctive and declaratory relief.
FACTUAL ALLEGATIONS
6. On or about July 22, 2025, Plaintiff was operating his motor vehicle in Ridgeway
County.
7. Following an alleged traffic violation, members of the Palmer Police Department
initiated a pursuit of Plaintiff's vehicle.
8. During the course of the pursuit, a separate civilian vehicle collided with Plaintiff's
vehicle, causing it to leave the roadway and come to a stop.
9. Immediately thereafter, Plaintiff was removed from his vehicle by Officer
battaliongavin of the Palmer Police Department, placed under arrest, and secured in
the back of a police car.
10. At this moment, the scene was secure. Plaintiff was fully in police custody,
handcuffed, and had no access to his vehicle or any ability to pose a threat to officers
or destroy any potential evidence within the vehicle.
11. Sometime after Plaintiff was secured, Defendant xdinomanx, acting under color of
law and pursuant to the policies and/or customs of the Palmer Police Department,
proceeded to conduct a warrantless search of the interior of Plaintiff's vehicle.
12. This search was conducted without a warrant, without Plaintiff's consent, and
without any legal justification or applicable exception to the warrant requirement.
FIRST CAUSE OF ACTION (Violation of Civil Rights 1 R. Stat. § 3115)
(Against Defendant xdinomanx in his Individual Capacity)
13. Plaintiff realleges and incorporates by reference the preceding paragraphs.
14. The Fourth Amendment to the United States Constitution protects all persons
from unreasonable searches and seizures. A warrantless search is presumptively
unreasonable.
15. The warrantless search of Plaintiff's vehicle by Defendant xdinomanx was
unconstitutional and illegal because it did not fall under any recognized
exception to the warrant requirement, including the “search incident to arrest”
exception as defined in Arizona v. Gant, as Plaintiff was secured and could not
access the vehicle.
16. Defendant's act deprived Plaintiff of his right to be free from unreasonable
searches as guaranteed by the Fourth and Fourteenth Amendments.
SECOND CAUSE OF ACTION (Municipal Liability 1 R. Stat. § 3115)
17. Plaintiff realleges and incorporates by reference the preceding paragraphs.
18. Upon information and belief, the unconstitutional search conducted by
Defendant xdinomanx was a result of official policy, practice, or custom of the
Defendant Palmer Police Department.
19. This policy or custom includes, but is not limited to, inadequately training and
supervising its officers regarding the constitutional limits of warrantless vehicle
searches post-Arizona v. Gant, thereby demonstrating a deliberate indifference to
the constitutional rights of persons like the Plaintiff.
20. This unconstitutional policy or custom was the moving force behind the
violation of Plaintiff's Fourth Amendment rights.
WHEREFORE, Plaintiff, richardm, respectfully requests that this Court enter
judgment in his favor and against Defendants as follows:
a. Against Defendant xdinomanx:
i. Awarding compensatory and punitive damages in an amount to be
determined at trial;
b. Against Defendant Palmer Police Department:
i. Issuing a declaratory judgment that its policy or custom of conducting
such vehicle searches is unconstitutional;
c. c. Against Defendant Palmer Police Department:
i. Issuing a permanent injunction ordering the department to cease its
unconstitutional search practices and to adequately train its officers on
the constitutional limits of vehicle searches;
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 22, 2025
/s/0xSyns
0xSyns
