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RIDGEWAY SUPERIOR COURT
FOR THE COUNTY OF RIDGEWAY
ROBERTSEVIGNE
, Plaintiff
v.
RIDGEWAY DEPARTMENT OF TRANSPORT
, Defendant
CIVIL ACTION.
COMPLAINT
Plaintiff RobertSevigne ("Plaintiff"), seeking all available relief in
their complaint against Defendant Ridgeway Department of Transport
("Defendant"), alleges the following.
INTRODUCTION
On the 1st of August 2025, Plaintiff had sought to apply for a Handicap
Permit ("Permit")
Plaintiff issued a FOI request days earlier requesting information on how
to apply for such a permit.
Defendant failed to publish means and
Plaintiff did not receive such information and therefore has been unable
to gain Permit as per his needs.
JURISDICTION
5. This court has original jurisdiction over "all civil and criminal
cases or controversies". Rid. Const. art. 5, §4.
6. Venue is proper in this court because the actions and omissions
alleged in this complaint took place in the State of Ridgeway.
PARTIES
7. RobertSevigne (“Plaintiff”) is an individual, resident, and citizen of
the State of Ridgeway. Plaintiff brings forth this suit as an individual.
8. Ridgeway Department of Transport ("Defendant" is a government entity
belonging to the executive of Government of Ridgeway. This is established
in the Defendant's handbook (100-5, Authority of the Secretary of
Transportation)
FIRST CAUSE OF ACTION
Constitutional Violation - Rid. Const. art. 1. § 5.
9. All prior paragraphs within this complaint are incorporated as if they
were fully set forth herein.
10. Under Rid. Const. art. 1. § 5 every individual has the right to be
protected in the enjoyment of life, liberty, and property.
11. Defendant, by failing to provide means for disabled members of the
community to access a handicap permit, failed to uphold the rights and
protections in the enjoyment of life and he use of property (i.e
vehicles).
12. Defendant's omission of making applications for handicap permits
accessible directly resulted a violation of the constitution and a
reduction in the enjoyment of life for the plaintiff.
13. As a result of Defendant’s actions, Plaintiff suffered compensable
damages including, but not limited to, suffering and emotional distress.
RELIEF
14. WHEREFORE, Plaintiff prays that the court enter judgment in their
favor and against Defendant as follows:
A. A finding that Defendant is liable for the constitutional
violation (Rid. Const. art. 1. §5)
B. An award of compensatory to be determined at trial;
C. An award of punitive damages not to exceed the statutory limit
of $5,000;
D. Any further relief that the Court deems just and proper.
Dated: August 14th, 2025
RESPECTFULLY SUBMITTED: ROBERTSEVIGNE
