RIDGEWAY SUPERIOR COURT
FOR THE COUNTY OF RIDGEWAY
ROBERTSEVIGNE
, Plaintiff, pro-se
v.
RIDGEWAY DEPARTMENT OF TRANSPORT
, Defendant
Civil Action No. RSC-CV-0813
AMENDED COMPLAINT
INTRODUCTION
• On August 1, 2025, the Plaintiff came to the Defendant to apply for a Handicap Permit
(‘Permit’).
• On other occasions, the Plaintiff made a `Freedom of Information’ request in order to get
information about the procedures involved.
• The Defendant did not post information regarding the application, nor did he provide
information relating to the application Permit.
• The Plaintiff was not able, on account of his medical condition, to get a Permit, which he
required to have.
• The Defendant was in violation of the Plaintiff’s rights under the Ridgeway Constitution, and
the Constitution of the United States, as well as under the ADA, Title II.
JURISDICTION
• This Court has original jurisdiction over “all civil and criminal cases or controversies.” Rid.
Const. art. 5, § 4.
• Venue is proper in this Court because the actions and omissions alleged in this complaint took
place in the State of Ridgeway.
PARTIES
• Plaintiff RobertSevigne is an individual, resident, and citizen of the State of Ridgeway. Plaintiff
brings forth this suit as an individual.
• Defendant Ridgeway Department of Transport is a government entity belonging to the executive
branch of the Government of Ridgeway, as established in Defendant’s handbook (100-5,
Authority of the Secretary of Transportation).
EXHAUSTION OF ADMINISTRATIVE REMEDIES
• Generally, plaintiffs have to complete an administrative process before filing constitutional or
statutory claims against a state agency.
• This case, however, lacks administrative remedies. Defendants have not published or established
any way for a Plaintiff to apply for a Handicap Permit or appeal the denial of such a Permit.
• Defendants for whom the process would be complete, need not comply to this requirement. See
McCarthy v. Madigan, 503 U.S. 140, 147 (1992) ("exhaustion may not be required where the
administrative remedy is inadequate or cannot provide the relief sought,”).
• In addition, the U.S. Supreme Court also notarized that not all state remedies need to be
exhausted before filing a claim under 42 U.S.C. § 1983 for the infringement of constitutional
rights. See Patsy v. Board of Regents, 457 U.S. 496 (1982)
• The Plaintiff has the right to claim breaches of the Constitution and ADA Acts directly to this
Court.
FIRST CAUSE OF ACTION
Violation of Ridgeway Constitution — Art. 1 § 5
• All prior paragraphs are incorporated as if fully set forth herein.
• Rid. Const. art. 1 § 5 guarantees that every individual is “protected in the enjoyment of life,
liberty, and property.”
• By failing to make accessible a process for obtaining handicap permits, Defendant denied
Plaintiff reasonable access to his property (vehicle use) and limited his enjoyment of life.
• Plaintiff has therefore suffered a constitutional violation under state law.
SECOND CAUSE OF ACTION
Violation of U.S. Constitution — Fourteenth Amendment (Due Process and Equal Protection)
• No state may deprive ‘any person of life, liberty, or property, without due process of law’
• Defendants’ denials of due process regarding the lack of any processes for disabled residents to
obtain handicap permits is blatant. The Plaintiff was effectively denied access to due process
without a notice or hearing, nor a meaningful chance of engaging with the program.
• In Goldberg v. Kelly, 397 U.S. 254 (1970) the Supreme Court held that a set of parameters that
govern due process should point toward the fairness of the processes that are taken toward the
access and deprivation of indispensable rights. Here, the Plaintiff was denied any formal process
whatsoever.
• The Equal Protection Clause has also been breached, as it is the second half of the law regarding
the administration of justice to people in the same legal situations. The Defendant in this
situation controlled the access of disabled residents to the permits, hence, was able to
discriminate against disabled people as a whole.
• In City of Cleburne v. Cleburne Living Center, Inc., 473 U.S. 432 (1985) the Court held that any
classification that makes distinctions on the basis of a disability must, as a minimum, undergo
rational basis scrutiny. The rational or legitimate omission for the Defendant here was absent.
• In addition, the inaccessibility of crucial social services like the census also raises issues of
equal protection. See Plyler v. Doe, 457 U.S.
THIRD CAUSE OF ACTION
Violation of the Americans with Disabilities Act (Title II, 42 U.S.C. § 12131 et seq.)
• According to the ADA their Title II states that “no qualified individual with a disability shall,
solely by reason of her or his disability, be excluded from or denied the benefits of the services,
programs, or activities of any public entity.”
• Defendant, in the sense of 42 U.S.C. § 12131, their publicly described.
• In his or her amble, the defendant blocked the plaintiff from accessing a publicly available
service because he or she failed the criteria to develop and advertise a method to obtain
handicap permits.
• In the silence of such accommodations, the Defendant’s primary services within his or her
region, as was ruled, would not be available to individuals with disabilities as outlined in the
ADA and U.S. v. Lane.
• Such failure to provide reasonable accommodations as outlined by the ADA would, thus be
construed as discrimination in the breach of federal statutory law.
RELIEF
WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in his favor and against
Defendant as follows:
A. A declaration that Defendant’s actions and omissions violated Plaintiff’s rights under the
Ridgeway Constitution (Art. 1 § 5).
B. A declaration that Defendant violated Plaintiff’s rights under the Fourteenth Amendment to
the United States Constitution.
C. A declaration that Defendant violated Title II of the Americans with Disabilities Act.
D. An injunction requiring Defendant to create and publish an accessible application process for
Handicap Permits.
E. Any further relief the Court deems just and proper.
Dated: September 23, 2025
Respectfully submitted,
ROBERTSEVIGNE
