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RIDGEWAY SUPERIOR COURT
FOR THE COUNTY OF RIDGEWAY
CHIEF_VINEXY,
Plaintiff,
v.
GOODCHUDLIFE, in his individual
capacity,
Defendant.
Action No.
COMPLAINT
Plaintiff Chief_Vinexy (“Plaintiff”), by and through the undersigned counsel,
seeking all available relief, in his complaint against Defendant GoodChudLife
(“Defendant”), alleges the following:
INTRODUCTION
1. In a jurisdiction where open-carry is lawful, a law enforcement officer may
not seize a person simply because they are exercising that right. Yet that is precisely what
happened here. Defendant stopped Plaintiff on the side of the street and detained him for
one reason alone: he was visibly carrying a firearm he was entirely and lawfully entitled
to carry. Defendant demanded, and his sole objective was to demand, proof of a firearms
license.
2. Because open-carry is lawful in Ridgeway, the visible presence of a
firearm, without more, does not give rise to reasonable suspicion of criminal activity. To
hold otherwise would invert constitutional logic entirely—transforming the exercise of a
lawful right into automatic justification for detention and subjecting every lawfully armed
person to suspicionless stops simply for being armed.
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3. Plaintiff accordingly brings this action for declaratory relief establishing
that the seizure of a person solely for openly carrying a firearm—without individualized
reasonable suspicion of criminal activity—is unconstitutional under the Fourth
Amendment to the United States Constitution, and for damages reflecting the deprivation
of rights he suffered at the hands of Defendant.
JURISDICTION
4. The Ridgeway Superior Court has original jurisdiction over “all civil and
criminal cases or controversies.” RID. CONST. art. 5, § 4.
5. Venue is proper as the acts and omissions which give rise to this complaint
occurred in the State of Ridgeway.
PARTIES
6. Plaintiff is an individual, resident, and citizen of the State of Ridgeway.
7. Defendant is an individual, resident, and citizen of the State of Ridgeway.
Defendant is a Lieutenant in the Ridgeway State Police, and is the Special
Agent-in-Charge of the Counterterrorism and Special Operations Bureau of the Ridgeway
State Police. Defendant is sued in his individual capacity.
FACTS
8. On or about March 13, 2026, Plaintiff was walking on and around a public
roadway near the Palmer Courthouse in Palmer, Ridgeway.
9. Plaintiff was on a team designated for the Ridgeway Department of Justice.
10. Plaintiff lawfully possessed a firearm which was visible on his person.
11. Plaintiff lawfully possessed a state-issued firearms license.
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12. Defendant approached Plaintiff while he was recovering his car after
accidentally flipping it over when entering it due to a bug.
13. Defendant was acting as a law enforcement officer on behalf of the
Ridgeway State Police. He was wearing a department-issued uniform and using
department-issued equipment.
14. Defendant asked Plaintiff “lets see ur rflid.”
15. Plaintiff explained that he was “DOJ” and Defendant responded “cool,”
“lets see ur rflid.”
16. Plaintiff subsequently responded “you’re gonna have to search me for it.”
17. Defendant asked “are you refusing” and Plaintiff responded “no i am
stating you’ll have to get it yourself.”
18. In response, Defendant handcuffed Plaintiff.
19. While handcuffed, a vehicle began speeding towards Plaintiff, Defendant,
and other law enforcement officers at the Palmer Courthouse.
20. The driver exited the vehicle, drew an automatic firearm, and shot and
killed Plaintiff, Defendant, and other law enforcement officers.
FIRST CAUSE OF ACTION
(Unreasonable Seizure, U.S. CONST. amend. IV – 1 R. Stat. § 3115)
21. Plaintiff repeats and reincorporates paragraphs 1–20 above as though fully
incorporated herein.
22. Defendant was, at all times relevant, acting under the color of state law and
in the course and scope of his employment.
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23. Defendant stopped Plaintiff when Plaintiff was walking on and around a
public roadway with a firearm visible on his person.
24. Defendant proceeded to handcuff Plaintiff.
25. Defendant had no indication that Plaintiff was unable to possess a firearm.
26. Defendant had no indication that Plaintiff was dangerous or threatening.
27. Defendant had no reasonable suspicion or probable cause to believe that
Plaintiff had committed, was committing, or would commit any crime.
28. The Fourth Amendment to the United States Constitution provides that “the
right of the people to be secure in their persons, houses, papers, and effects, against
unreasonable searches and seizures, shall not be violated.” U.S. CONST. amend. IV.
29. A person is seized when, “in view of all the circumstances surrounding the
incident, a reasonable person would have believed he was not free to leave.” United
States v. Mendenhall, 446 U.S. 544, 554 (1980).
30. Plaintiff reasonably believed he was not free to leave. Any reasonable
person in his position would have reached the same conclusion after being confronted by
an armed and uniformed officer and asked whether he would refuse to comply with a
demand to see his state-issued firearms license and then was handcuffed for declining.
31. It is clearly established that an investigatory detention of a citizen by an
officer “must be supported at least by a reasonable and articulable suspicion that the
person seized is engaged in criminal activity.” Terry v. Ohio, 392 U.S. 1, 21 (1968); Reid
v. Georgia, 448 U.S. 438, 440 (1980). The level of suspicion must be a “particularized
and objective basis for suspecting the particular person stopped of criminal activity.”
United States v. Cortez, 449 U.S. 411, 417–18 (1981). As such, “the officer must be able
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to point to specific and articulable facts which, taken together with rational inferences
from those facts, reasonably warrant that intrusion.” Terry, 392 U.S. at 21.
32. It is clearly established that in states where open-carry is legal, the mere act
of carrying a firearm—without individualized suspicion that the person is prohibited from
doing so—cannot justify an investigatory detention. See, e.g., United States v. Ubiles,
224 F.3d 213, 218 (3d Cir. 2000); United States v. Black, 707 F.3d 531, 540 (4th Cir.
2013); United States v. Roch, 5 F.3d 894, 899 (5th Cir. 1993); Northrup v. Toledo Police
Department, 785 F.3d 1128, 1131–34 (6th Cir. 2015); United States v. King, 990 F.2d
1552, 1559 (10th Cir. 1993).
33. There was no legal basis for the seizure and investigatory detention of
Plaintiff, as described above. No objectively reasonable law enforcement officer would
have reason to believe that they have authority to conduct a seizure or investigatory
detention of a person lawfully open-carrying a firearm without reasonable suspicion.
34. The actions taken by Defendant were objectively unreasonable, willful,
wanton, intentional, and done with a callous and reckless disregard for the constitutional
rights of Plaintiff.
RELIEF
WHEREFORE, Plaintiff prays that the court enter judgment in his favor and
against Defendant as follows:
a. Declare that seizing a person solely for carrying a firearm, without
reasonable suspicion of criminal activity, is unconstitutional under the Fourth
Amendment to the United States Constitution;
b. Award compensatory damages in an amount to be determined at trial;
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c. Award punitive damages in an amount to be determined at trial;
d. Award pre- and post-judgment interest;
e. Grant an award of the fees and costs incurred in filing this suit;
f. Grant such further relief as the court deems just and proper.
Dated: April 26, 2026
Palmer, Ridgeway Respectfully submitted,
/s/ Nicklaus_s
Nicklaus_s (Rid. Bar No. 10241)
NICKLAUS & ASSOCIATES LLP
1 Jackson Road
Palmer, Ridgeway 90025
(123) 456-7890
[email protected]
Attorney for Plaintiff
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