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THE STATE OF RIDGEWAY
RIDGEWAY SUPERIOR COURT
JAMESGARDAI,
-against-
RIDGEWAY NATIONAL GUARD
Defendant.
Case No. RSC-CV-7404
RESPONSE
Presiding Judge: Arthur_Chen
dev_Typ answers on behalf of the Ridgeway National Guard, as the Department of
Justice:
STATEMENT OF REPLY - RESPONSE
1. Admitted that Petitioner was employed as a Staff Sergeant.
2. Admitted that Petitioner served in the National Guard; Respondent lacks knowledge as
to the characterization of “seasoned veteran” and therefore denies same.
3. Admitted that the National Guard maintains internal disciplinary structures.
4. Admitted that Petitioner was terminated pursuant to 2 R. Stat. § 3324.
5. Denied. Respondent denies that public employees have a guaranteed expectation of
continued employment.
6. Denied. Any alleged “guarantee” is denied absent strict proof.
7. Admitted that no reason was provided; further stated that none is required under §
3324.
8. Admitted, but Respondent states such notice is not required under at-will termination.
9. Admitted, but denied as legally required.
10. Admitted, but denied that any opportunity to respond is required.
11. Admitted.
12. Denied. Respondent lacks sufficient information and denies the characterization of
“good behavior.
AFFIRMATIVE DEFENSES
1. LACK OF JURISDICTION
a. Petitioner’s claim is barred as a matter of law. 2 R. Stat. § 3324 explicitly provides that
at-will terminations “may not be reviewed by any court. Accordingly, this Court lacks
jurisdiction over the subject matter.
2. FAILURE TO STATE A CLAIM
a. Petitioner fails to state a claim upon which relief can be granted because: (i) the
termination was lawful under § 3324 (ii) No procedural protections are required for
at-will honorable discharge
3. NO PROPERTY INTEREST
a. Petitioner had no protected property interest in continued employment.
i. Ridgeway law does not create automatic employment rights
ii. § 3324 expressly allows termination at any time, for any reason not prohibited by
law
4. STATUTORY COMPLIANCE
a. Respondent fully complied with all applicable statutes.
i. This was not a disciplinary discharge
ii. Therefore, no Internal Affairs investigation or hearing was required
5. CONSTITUTIONAL CLAIM FAILS
a. Petitioner’s constitutional argument fails because: (i) No recognized property interest
exists (ii) Statutory at-will employment is lawful (iii) The Court cannot override clear
legislative authority
PRAYERS FOR RELIEF
WHEREFORE, Respondent respectfully requests that this Court:
1. Dismiss the Complaint with prejudice;
2. Find that 2 R. Stat. § 3324 bars judicial review;
3. Deny all requested relief; and
4. Grant such other relief as the Court deems just and proper.
DATED: APRIL 20th, 2026
Respectfully submitted,
THE HONORABLE dev_Typ, Esq.
ATTORNEY AT LAW
/s/ dev_Typ
