SUPERIOR COURT OF RIDGEWAY
0XSYNS,
Plaintiff,
v.
SHADOWCULTURE, Undersheriff of the
Ridgeway County Sheriff’s Office, in his
quasi-official capacity,
Defendants.
Civil Action No. RSC-CV-8149
DEFENDANT’S ANSWER AND AFFIRMATIVE DEFENSES
Defendant, proceeding by and through the Solicitor General of Ridgeway, submits his
answer and affirmative defenses to Plaintiff’s Complaint pursuant to Rid. R. Civ. P. 8. Defendant
hereby denies any allegations not admitted herein.
Dated: August 1, 2025 Respectfully submitted,
Palmer, Ridgeway.
/s/ BrendaPopplewell
BrendaPopplewell
Solicitor General
EffortlessBrit
Deputy Solicitor General
Ridgeway Department of Justice
1 County Annex
Palmer, Ridgeway 33368
Attorneys for Defendant
SUPERIOR COURT OF RIDGEWAY
0XSYNS,
Plaintiff,
v.
SHADOWCULTURE, Undersheriff of the
Ridgeway County Sheriff’s Office, in his
quasi-official capacity,
Defendants.
Civil Action No. RSC-CV-8149
DEFENDANT’S ANSWER AND AFFIRMATIVE DEFENSES
1
JURISDICTION AND VENUE
1. The allegations in paragraph 1 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
2. The allegations in paragraph 2 contains one or more legal conclusions to which no
answer is required; if one is required, denied.
PARTIES
3. Admitted.
4. Admitted.
FACTUAL ALLEGATIONS
5. Admitted.
6. Admitted.
7. Admitted.
8. Admitted.
9. Denied. By way of further answer, Defendant asserts that he arrived at the scene
while Plaintiff left the store and the ATM alarm was activated, and deployed his Taser with lawful
justification because he had probable cause to believe Plaintiff had robbed the ATM and was
attempting to flee in his vehicle. Further, Defendant asserts that a reasonable officer, confronted
with the same circumstances, would have similarly deployed their Taser.
10. Admitted.
11. Admitted.
12. Admitted.
13. Denied. By way of further answer, Defendant asserts that he deployed his Taser
reasonably and in good faith. Because a reasonable officer, confronted with the same
2
circumstances, would have similarly deployed their Taser, Defendant’s actions were lawful and
reasonable under the Fourth Amendment to the U.S. Constitution.
FIRST CAUSE OF ACTION
14. Paragraph 14 contains a recitation of the foregoing paragraphs to which no answer
is required; if one is required, denied.
15. The allegations in paragraph 15 contains one or more legal conclusions to which
no answer is required; if one is required, denied.
16. The allegations in paragraph 16 contains one or more legal conclusions to which
no answer is required; if one is required, denied.
SECOND CAUSE OF ACTION
17. Paragraph 17 contains a recitation of the foregoing paragraphs to which no answer
is required; if one is required, denied.
18. The allegations in paragraph 18 contains one or more legal conclusions to which
no answer is required; if one is required, denied.
19. The allegations in paragraph 19 contains one or more legal conclusions to which
no answer is required; if one is required, denied.
First Affirmative Defenses
(Qualified Immunity)
1. Defendant asserts that he is entitled to qualified immunity actions because his
actions were reasonable and did not violate clearly established law.
Second Affirmative Defense
(Statutory Immunity)
2. Defendant asserts that he is entitled to statutory, or sovereign, immunity because he
is being sued in his individual capacity for official acts.
3
Third Affirmative Defense
(Good Faith)
3. Defendant asserts that he is not liable because his acts—though mistaken—were
made in good faith and reasonably.
Dated: August 1, 2025 Respectfully submitted,
Palmer, Ridgeway.
/s/ BrendaPopplewell
BrendaPopplewell
Solicitor General
EffortlessBrit
Deputy Solicitor General
Ridgeway Department of Justice
1 County Annex
Palmer, Ridgeway 33368
Attorneys for Defendant
Certificate of Service
I, the undersigned counsel, do hereby provide notice of my appearance as counsel of record
for Defendant(s) and certify that a copy of this document and its contents have, on August 1, 2025,
been filed with the Clerk of Court by CM/ECF system and that the CM/ECF system will serve a
copy of this document on all parties and counsel of record.
Dated: August 1, 2025 Respectfully submitted,
Palmer, Ridgeway.
/s/ BrendaPopplewell
BrendaPopplewell
Solicitor General
EffortlessBrit
Deputy Solicitor General
Ridgeway Department of Justice
1 County Annex
Palmer, Ridgeway 33368
Attorneys for Defendant
