ADMINISTRATIVE COURT
State of Ridgeway
IN RE
JAMESGARDAI
Petitioner
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ADMINISTRATIVE CLAIM
CLAIM NO. RSC-CV-57477
PETITIONER’S MEMORANDUM OF LAW IN SUPPORT OF MOTION TO HOLD
CEPHALGPT AND DARIEL_POWELL IN CIVIL AND CRIMINAL CONTEMPT
Petitioner JamesGardai respectfully submits this memorandum of law in support of his
motion to hold CephalGPT, Sheriff of Ridgeway County, and Dariel_Powell, Attorney General
of the State of Ridgeway, in civil contempt for violating the post-deprivation hearing tribunal’s
order to reinstate Petitioner back to his position.
I. CEPHALGPT AND DARIEL_POWELL SHOULD BE HELD IN CIVIL
CONTEMPT
LEGAL STANDARD
“District courts enjoy wide discretion to fashion an equitable remedy for [civil] contempt
that is appropriate to the circumstances.” United States v. City of Miami, 195 F.3d 1292, 1298
(11th Cir. 1999) (internal quotations marks and citations omitted). Civil contempt is appropriate
when “(1) the order the contemnor failed to comply with is clear and unambiguous, (2) the proof
of noncompliance is clear and convincing, and (3) the contemnor has not diligently attempted to
comply in a reasonable manner.” Paramedics Electromedicina Comercial, Ltda. v. GE Med. Sys.
Info. Techs., Inc., 369 F.3d 645, 655 (2d Cir. 2004) (citing King v. Allied Vision, Ltd., 65 F.3d
1051, 1058 (2d Cir. 1995)); see also BOC Aviation Ltd. v. AirBridgeCargo Airlines, LLC, No.
22-cv-2070 (LJL), 2022 WL 17581775, at *7 (S.D.N.Y. Dec. 12, 2022). Indeed, “[t]he absence
of willfulness does not relieve from civil contempt.” McComb v. Jacksonville Paper Co., 336
U.S. 187, 191 (1949).
ARGUMENT
CephalGPT and Dariel_Powell are plainly in contempt of the tribunal’s order.
A. The Order is Clear and Unambigious
“[T]he ‘clear and unambiguous’ standard applies to the language of the relevant court
order, not to its effectiveness.” Goya Foods, Inc. v. Wallack Mgmt. Co., 290 F.3d 63 (1st Cir.
2002) (emphasis in original). This tribunal’s order was clear and unambiguous. It requires that
Petitioner be "taken off of administrative leave and reinstated back to duty effective
immediately.”
a. CephalGPT and Dariel_Powell cannot circumvent the Tribunal’s Order by
issuing an at-will termination to JamesGardai
CephalGPT and Dariel_Powell, in no circumstance, can circumvent the Tribunal’s Order,
as he has done, issuing an at-will termination and honorably discharging Petitioner. The
Tribunal’s Order leaves no room for interpretation. It expressly mandates that Petitioner be
“taken off of administrative leave and reinstated back to duty effective immediately.” This
language is direct, mandatory, and unconditional. There are no qualifying provisions,
contingencies, or discretionary clauses that would permit delay or alternative compliance.
B. The Proof of Non-Compliance is Clear and Convincing
CephalGPT and Dariel_Powell cannot circumvent the Tribunal’s Order by issuing an
at-will termination and labeling it an “honorable discharge.” Such conduct is not compliance—it
is evasion. The duty imposed by the Tribunal was reinstatement; terminating Petitioner
immediately after the order issues is functionally indistinguishable from outright refusal to
comply. Not only that, but it is illegal and retaliatory-in-nature. Ridgeway Legislature ex rel The
State v. Techiey, 3 Rid. ___, ___ (2024).
This is precisely the type of conduct civil contempt is designed to address: deliberate
attempts to frustrate, nullify, or evade a directive while maintaining a façade of technical
compliance. Allowing such tactics would render judicial orders meaningless.
C. CephalGPT and Dariel_Powell Did Not Attempt to Comply in a Diligent Manner
CephalGPT and Dariel_Powell have not even attempted diligent compliance. Instead,
they have openly disregarded the Tribunal’s Order and taken affirmative steps to evade it entirely.
First, when ordered to restore Petitioner, they ranked him in the group, sent the log in the
Ridgeway County Sheriff’s Office discord server, and seconds later discharged him at-will. This
action does not comply with the Tribunal’s directive—it directly contradicts it. The order
required reinstatement, not separation. Substituting termination in place of reinstatement is the
antithesis of diligent compliance.
Second, reinstating Petitioner then terminating him seconds later is not a reinstatement at
all. It violates the plain spirit and text of the tribunal’s order, even if it had been done innocently.
See Star Fin. Servs., Inc. v. AASTAR Mortgage Corp., 89 F.3d 5, 13 (1st Cir. 1996); accord
McComb, 336 U.S. at 191, 69 S. Ct. 497 ("An act does not cease to be a violation of a law and of
a decree merely because it may have been done innocently.").
II. DARIEL_POWELL AND CEPHALGPT SHOULD BE HELD IN CRIMINAL
CONTEMPT
CephalGPT and Dariel_Powell are plainly in criminal contempt of Court for intentionally
disregarding and failing to abide by the tribunal’s order.
LEGAL STANDARD
The power to punish for contempt is “inherent in all courts,” essential to the very
“administration of justice.” Michaelson v. United States ex rel. Chicago, St. P., M. & O.R. Co.,
266 U.S. 42, 65–66 (1924); see also United States v. Hudson & Goodwin, 11 U.S. (7 Cranch) 32,
34 (1812) (“Certain implied powers must necessarily result to our courts of justice from the
nature of their institution…To fine for contempt, imprison for contumacy, enforce the observance
of orders, &c., are powers which cannot be dispensed with in a court, because they are necessary
to the exercise of all others.”)
ARGUMENT
The Tribunal issued a lawful and binding Order requiring that Petitioner be “taken off of
administrative leave and reinstated back to duty effective immediately.” As established supra, this
directive was clear, specific, and unequivocal. There can be no dispute that the Tribunal acted
within its authority in issuing such an order following a post-deprivation hearing, nor that
Respondents were bound to obey it.
CephalGPT and Dariel_Powell had actual knowledge of the Tribunal’s Order. They
participated in the proceedings, were present for the issuance of the ruling, and were fully aware
of the obligations imposed upon them. Their subsequent actions demonstrate not confusion, but
conscious awareness of the Order and its requirements.
CephalGPT and Dariel_Powell did not merely fail to comply—they willfully disobeyed
the Tribunal’s directive. Criminal contempt requires a showing of intentional or reckless
disregard of the tribunal’s order, and that standard is plainly satisfied here
First, Respondents reinstated Petitioner in name only, immediately followed by an at-will
termination seconds later. This sequence of events cannot reasonably be characterized as
compliance. Rather, it reflects a calculated effort to create the appearance of adherence while
ensuring that the substance of the Order was defeated.
Second, the timing and nature of Respondents’ actions demonstrate intent. The
near-instantaneous termination following reinstatement shows that Respondents never intended
to comply with the Tribunal’s mandate in good faith. Instead, they engaged in a deliberate
scheme to nullify the Order while attempting to shield themselves from consequence
Such conduct constitutes a direct affront to the authority of the Tribunal. Criminal
contempt exists to punish precisely this kind of intentional defiance—where a party, fully aware
of a court’s command, chooses to disregard it. Absent criminal sanctions, the Tribunal’s authority
would be rendered illusory. Respondents’ conduct was not accidental, negligent, or
ambiguous—it was deliberate. Where parties openly defy a clear and lawful order, punitive
measures are necessary not only to address the violation, but to uphold the integrity of the
process itself.
CONCLUSION
For the foregoing reasons, CephalGPT and Dariel_Powell should be held in civil and
criminal contempt.
Respectfully submitted.
Date: 04/17/2026
_________________________________
JamesGardai, Esq.
Newfounding Father
HOUSE OF GARDAI
Rid. Bar No. 24101
Gardai Island
United States Virgin Islands
D: fishfromocean
APPENDIX OF EVIDENCE
A. Transcript of Post-Deprivation Hearing:
https://www.youtube.com/watch?v=5k-Wjpu-F_8
B.
