THE STATE OF RIDGEWAY
RIDGEWAY SUPERIOR COURT
thr33six8,
Plaintiff
-against-
RichardLennox
Defendants.
RSC-CV-3173
MOTION FOR SUMMARY
JUDGEMENT
Presiding Judge: Arthur_Chen
Plaintiff thr33six8 moves for summary judgement pursuant to Rule 38(c) of the
Ridgeway Rules of Civil Procedure. Movant's motion for summary judgement is about the
defendant's liability as to the plaintiff's claim of official misconduct (1 R. Stat. § 3114) and the
claim of deprivation of rights (1 R. Stat § 3115) as written in the complaint. Movant is able to
move such a motion as long as it was moved seven days after the commencement of this civil
action (Rule 38(a) of Ridgeway Rules of Civil Procedure).
REASONS TO HOLD DEFENDANT LIABLE
Defendant's actions are not protected by qualified immunity
1. Common law is rulings from other courts.
2. A doctrine is a standard or rule in common law.
3. Liability is whether or not a defendant committed a tort; a defendant who committed a
tort is liable for committing the tort.
4. A (legal) immunity exempts a defendant from liability.
5. Qualified immunity is a doctrine, and it is a legal immunity formed from common law.
6. Qualified immunity applies unless "the facts alleged or shown by the plaintiff make out a
violation of a constitutional right" and "that right was 'clearly established' at the time of
the defendant’s alleged misconduct." See generally Pearson v. Callahan, 555 U.S. 223
(2009). Pp. 224.
7. Art. Ⅰ § Ⅴ of the state of Ridgeway's constitution gives "every member of society" "a
right to be protected in the enjoyment of life, liberty, and property."
8. This is a clearly established right since it is in the constitution, which gives this
government form.
9. Ridgeway's constitution had been around during Defendant's misconduct, so it was also a
law that was clearly established at that moment.
10. Facts and evidence from Plaintiff show that Defendant did shoot and kill Plaintiff as a
police officer of the Palmer Police Department.
11. Defendant's shooting was unlawful since Plaintiff did not pose a significant threat of
death or serious physical injury to others; "such [deadly] force may not be used unless
necessary to prevent the escape and the officer has probable cause to believe that the
suspect poses a significant threat of death or serious physical injury to the officer or
others." See Tennessee v. Garner, 471 U.S. 1 (1985). Pp. 1-33.
12. Defendant's shooting was also against the Use of Force Model because Plaintiff was not
attacking anyone such that serious/grievous bodily harm could occur, and Defendant
knows it is against the Use of Force Model, which is also called the Use of Force
Continuum.
13. Since Defendant (1) violated a right (2) that was clearly established, any claim of
qualified immunity is inapplicable.
14. Therefore, Defendant is not entitled to qualified immunity in this case.
Defendant is liable of 1 R. Stat. § 3114 and 1 R. Stat § 3115 by statutory law
1. 1 R. Stat. § 3114 states:
a. "Any individual who is a public servant and commits an act relating to his office
but constitutes an unauthorized exercise of his official functions, knowing that
such act is unauthorized; or refrains from performing a duty which is imposed
upon him by law or is clearly inherent in the nature of his office."
2. Defendant was a public servant at the time of misconduct.
a. Defendant was the Chief of Police of the Palmer Police Department, a part of the
government created by 6 R. Stat. § 3108.
3. Defendant committed an unauthorized act relating to his office:
a. Defendant shot and killed Plaintiff as a police officer of the Palmer Police
Department; as argued, such shooting was unlawful under common law and
therefore unauthorized since it violates the law, unbecoming of a police officer.
4. Since Defendant was (1) a public servant at the time of misconduct, and (2) Defendant
committed an unauthorized act relating to his office, Defendant is liable for this tort.
5. 1 R. Stat. § 3115 states:
a. Every person who, under color of any statute, ordinance, regulation, custom, or
usage, subjects, or causes to be subjected, any citizen of the State of Ridgeway or
other person within the jurisdiction thereof to the deprivation of any rights,
privileges, or immunities secured by the Constitution and laws, shall be liable to
the party injured in an action at law, suit in equity, or other proper proceeding for
redress, except that in any action brought against a judicial officer for an act or
omission taken in such officer’s judicial capacity, injunctive relief shall not be
granted unless a declaratory decree was violated or declaratory relief was
unavailable.
6. Since Defendant was on-duty as a police officer of the Palmer Police Department,
Defendant was acting under 6 R. Stat. § 3108 to take Plaintiff's life by shooting him.
7. Defendant did deprive Plaintiff of his life, which:
a. is a deprivation of life without due process in the 14th amendment of the U.S.1
constitution, and;
b. deprives the "right to be protected in the enjoyment of life" as written in R.S.C.
Art. Ⅰ § Ⅴ, therefore violating rights secured by law.
8. Since Defendant was acting under 6 R. Stat. § 3108 to take Plaintiff's life, and such act
violates the 14th amendment of the U.S. constitution as well as R.S.C. Art. Ⅰ § Ⅴ,
Defendant is liable for this tort.
9. Therefore, Defendant is liable for both torts.
CONCLUSION
1. By the forgoing conclusions, Plaintiff's motion for summary judgement should be
granted.
DATED: March 29th, 2026
Respectfully submitted,
———————————————
thr33six8
Plaintiff
/s/ thr33six8
1 Due process is equal to "required process;" it's a series of events that are required to take place.
For the layman reading this footnote, don't give into bootlicking DA No. 100 saying there's a million versions of due process. DAs who say that are only
there to get that Twiqbal MTD in every case faster than Scalia hitting a three pointer. Due process is literally "do X right for Y" (or "do not breach the right of X" in
case of substantive due process). That's it.
