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COMPLAINT - 1
0xSyns
Attorneys’ Business Address
4000 Majellan Way, Sterling Heights
D: notsinz
DISTRICT COURT OF THE STATE OF RIDGEWAY
COUNTY OF RIDGEWAY
RICHARDM,
Plaintiff,
vs.
CYERMAZIKEEN, IN HIS INDIVIDUAL
CAPACITY, AND THE RIDGEWAY COUNTY
SHERIFF'S OFFICE,,
Defendant
Case No.: tbd
COMPLAINT
Plaintiff, by their attorney, 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 0xSyns is an individual and a citizen and resident of the State of Ridgeway.
4. Defendant CyerMazikeen is, upon information and belief, a law enforcement officer and Deputy
with the Ridgeway County Sheriff's Office. He is sued in his individual capacity for monetary
damages.
5. Defendant Ridgeway County Sheriff's Office is a governmental agency responsible for law
enforcement within Ridgeway County. It is sued in its official capacity for declaratory relief.
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COMPLAINT - 2
BASIS FOR INDIVIDUAL CAPACITY CLAIMS
6. Defendant CyerMazikeen is sued in his individual capacity for his personal actions taken under
the color of law. The legal authority for such claims is well-established under both state law (1 R.
Stat. § 3115) and foundational federal law (42 U.S.C. § 1983). The United States Supreme Court, in
the seminal case of Monroe v. Pape, 365 U.S. 167 (1961), definitively interpreted the phrase "under
color of law." The Court held that an official's actions are "under color of law" even if those
actions are a direct violation of state law or policy. The Court reasoned that the "misuse of power,
possessed by virtue of state law and made possible only because the wrongdoer is clothed with
the authority of state law, is action taken 'under color of' state law." Id. at 184.
7. Furthermore, the claims for the intentional torts of Assault and Battery are brought against the
Defendant personally because such malicious and excessive actions—using a patrol vehicle as a
weapon to strike a restrained and compliant individual—fall far outside the lawful scope of a
police officer’s duties. Such conduct is not a legitimate exercise of police power but a sadistic
abuse of it, for which the officer must be held individually accountable.
FACTUAL ALLEGATIONS
8. On or about August 1, 2025, Plaintiff richardm was on a public road, had already been detained
by another officer, and was in handcuffs.
9. Plaintiff was walking away from the other officer.
10. Defendant CyerMazikeen, operating a Ridgeway County Sheriff's Office patrol vehicle, was
present at the scene. He observed the Plaintiff from a distance and had a clear and unobstructed
view of the fact that Plaintiff was in handcuffs and walking.
11. Despite having ample time and space to stop, slow down, or maneuver his vehicle safely,
Defendant CyerMazikeen, with malicious and willful intent, aimed his vehicle at the Plaintiff and
accelerated.
12. Defendant CyerMazikeen intentionally rammed his patrol vehicle into the Plaintiff.
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COMPLAINT - 3
13. The force of the impact was severe, causing the Plaintiff to be violently flung through the air,
resulting in serious physical injury.
14. This use of force was not a mistake or an accident; it was a deliberate, calculated, and punitive act
of aggression against a person who was already in custody and completely defenseless.
FIRST CAUSE OF ACTION (Deprivation of Rights – Excessive Force & Unreasonable Seizure
- 1 R. Stat. § 3115) (Against Defendant CyerMazikeen in his Individual Capacity)
15. Plaintiff realleges and incorporates by reference the preceding paragraphs.
16. Defendant CyerMazikeen's act of intentionally ramming a patrol car into a handcuffed individual
constituted an application of extreme, deadly, and wholly unjustified force, and an unreasonable
seizure of Plaintiff's person in clear violation of the Fourth Amendment to the United States
Constitution.
17. This act, committed under color of law, deprived Plaintiff of his rights, privileges, and
immunities secured by the Constitution, making him liable for redress pursuant to 1 R. Stat. §
3115.
SECOND CAUSE OF ACTION (Assault) (Against Defendant CyerMazikeen in his Individual
Capacity)
18. Plaintiff realleges and incorporates by reference the preceding paragraphs.
19. Defendant’s act of accelerating his vehicle and aiming it directly at the Plaintiff intentionally
caused Plaintiff to suffer a reasonable apprehension of an immediate and severe battery. This act
constitutes the tort of assault pursuant to 1 R. Stat. § 3103.
THIRD CAUSE OF ACTION (Battery) (Against Defendant CyerMazikeen in his Individual
Capacity)
20. Plaintiff realleges and incorporates by reference the preceding paragraphs.
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COMPLAINT - 4
21. Defendant’s act of striking the Plaintiff with his vehicle constituted an unconsented, harmful, and
offensive contact with Plaintiff’s person. This act constitutes the tort of battery pursuant to 1 R.
Stat. § 3102.
FOURTH CAUSE OF ACTION (Municipal Liability for Unconstitutional Policy or Custom - 1
R. Stat. § 3115) (Against Defendant Ridgeway County Sheriff's Office)
22. Plaintiff realleges and incorporates by reference the preceding paragraphs.
23. Upon information and belief, the unconstitutional use of force by Defendant CyerMazikeen was a
result of an official policy, practice, or custom of the Defendant Ridgeway County Sheriff's Office
of failing to adequately train, supervise, and discipline its deputies on the constitutional limits of
the use of force, particularly with respect to using patrol vehicles as weapons against subdued
individuals.
24. This unconstitutional policy or custom was the moving force behind the violation of Plaintiff's
rights, subjecting the Ridgeway County Sheriff's Office to liability under 1 R. Stat. § 3115.
WHEREFORE, Plaintiff, richardm, respectfully requests that this Court enter judgment in his
favor and against Defendants as follows:
a. Against Defendant CyerMazikeen: Awarding compensatory and punitive damages in an
amount to be determined at trial;
b. Against Defendant Ridgeway County Sheriff's Office: Issuing a declaratory judgment that its
policies or customs regarding the use of patrol vehicles as a force option are unconstitutional;
c. 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.
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COMPLAINT - 5
Respectfully submitted, /s/0xsyns
0xSyns
