IN THE SUPERIOR COURT OF RIDGEWAY
FOR THE STATE OF RIDGEWAY
HALO4ASIN,
Plaintiff,
v.
RIDGEWAY PARKS SERVICE,
Defendants.
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Case No. RSC-CV-____
CIVIL COMPLAINT
COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF AND DAMAGES
Plaintiff Halo4asin (“Plaintiff”), appearing on his own behalf, brings this civil action against
Defendant Ridgeway Park Service (“Defendant” or “RPS”) and alleges as follows:
I. NATURE OF THE ACTION
1. This is an action under 7 R. Stat. § 122.101 to remedy Defendant’s denial of Plaintiff’s
application for appointment as a full-time Park Ranger, a civil-service position, in
Defendant’s Ranger Class 22. Plaintiff satisfied every merit-based stage of Defendant’s
hiring process and was rejected only at the final, background-investigation stage on a
basis that does not exist in fact: a purported prior termination or other adverse
consequence within a department or agency. Plaintiff has never been terminated from, nor
received any adverse consequence within, any department or agency in the State of
Ridgeway.
2. Defendant’s determination and the resulting denial impeded rights secured to Plaintiff by
state statute, including the Government Civil Service System statutes at 4 R. Stat. §§
121.001, 122.402, and 122.404. Plaintiff seeks a declaratory judgment, a permanent
restraining order, injunctive relief reversing the harm, and damages as permitted against
the government.
II. PARTIES
3. Plaintiff. Plaintiff Halo4asin is a resident of the State of Ridgeway and was, at all
relevant times, a qualified application for civil-service appointment. Plaintiff’s Roblox
user identification is 7681 and Plaintiff’s Discord handle is flimzee. Plaintiff is a member
in good standing of the Ridgeway State Bar (License No. 18110) and appears pro se.
4. Defendant. Defendant Ridgeway Park Service is an agency of the State of Ridgeway
established under 2 R. Stat. § 331.001 (therein designated the “Parks Service”) and
placed under the executive administration of the Superintendent of the Parks Service (2
R. Stat. §§ 331.101-331.103). Defendant is the appointing authority for the position to
which Plaintiff applied (2 R. Stat. § 331.105).
III. JURISDICTION AND VENUE
5. This Court has subject-matter jurisdiction. The Superior Court of the State of Ridgeway
is a court of law and equity vested with original jurisdiction over all civil cases and
controversies. See Const. of the State of Ridgeway, art. V, § IV; 4 R. Stat. § 131.001.
6. This action is one permitted against the government notwithstanding sovereign immunity.
While the State and its agencies are generally immune (7 R. Stat. § 122.002), 7 R. Stat. §
122.101 expressly authorizes relief where an agency’s policy, order, procedure, or
directive impedes an individual’s rights, immunities, or privileges secured by state statute
or the Constitution. This action is brought under that provision.
7. This Court, rather than the Administrative Court of the State of Ridgeway, is the proper
forum. The Administrative Court’s original jurisdiction extends to adverse personnel
actions against a civil-service employee (4 R. Stat. § 141.006); Plaintiff is an applicant,
not an employee, and possesses no property interest in continued employment under 4 R.
Stat. § 121.207. The Administrative Court also may not award damages (4 R. Stat. §
141.010), which Plaintiff seeks here.
8. Venue is proper in the County of Ridgeway because the action accrued in that county,
where Defendant maintains its operations and where the challenged determination issued.
See 7 R. Stat. § 131.001.
9. Plaintiff is further entitled to a remedy by recourse to the courts for the injury to his
person and character alleged herein. See Const. of the State of Ridgeway, art. I, § I.
IV. STATUTORY FRAMEWORK
10. The position of full-time Park Ranger is a peace-officer position (2 R. Stat. § 331.302)
and a civil-service position within Schedule C of the Civil Service Classification System
(4 R. Stat. § 121.204). Appointment to that position is governed by the Government Civil
Service System (4 R. Stat. tit. IV).
11. An appointing authority must conduct a background investigation prior to appointment,
and the criteria for that investigation are limited by statute. 4 R. Stat. § 122.402 provides
that “Background investigation criteria shall be limited to” an enumerated list. The only
enumerated criterion concerning prior service is 4 R. Stat. § 122.402(f): “whether the
individual has been terminated, or has received other adverse consequence, within a
department or agency.”
12. Where an appointing authority denies an applicant on the basis of a negative
background-investigation result, it “shall notify the applicant and specify the reasoning
for the negative result.” 4 R. Stat. § 122.404. That requirement may be satisfied “by
publishing their reasoning on an application result tracker accessible to the applicant.” 4
R. Stat. § 122.404(a).
13. The Government Civil Service System further requires that selection be “determined
solely on the basis of relative ability, knowledge and skills, after fair and open
competition” (4 R. Stat. § 121.001(a)); that applicants receive “fair and equitable
treatment” with “proper regard for their privacy and constitutional rights” (4 R. Stat. §
121.001(b)); and that applicants be “protected against arbitrary action” (4 R. Stat. §
121.001(g)). During the vacancy process, an appointing authority “shall indicate all
attributes of merit and demerit” and weigh each application accordingly (4 R. Stat. §
121.103).
V. FACTUAL ALLEGATIONS
14. Defendant opened recruitment for full-time and volunteer Park Ranger positions
designated “Ranger Class 22” and accepted applications through an application process
administered by Defendant. Plaintiff applied for a full-time Park Ranger position on or
about June 6 through June 13, 2026.
15. Plaintiff met the eligibility and training prerequisites for the position. Plaintiff holds a
valid Law Enforcement Training Center (LETC) certification, as reflected by the “Yes”
entry in the “LETC CERT” column of Defendant’s Application Tracker.
16. Defendant evaluated applications in successive stages reflected on its Application
Tracker under the column headings “PRIMARY SCREENING,” “APPLICATION,”
“FINAL SCREENING,” and “OUTCOME.”
17. Plaintiff is listed on the Application Tracker as Entry No. 26, username “Halo4asin,” for
the full-time position. Plaintiff’s entry reflects the following results: PRIMARY
SCREENING - “Passed”; APPLICATION - “Passed”; FINAL SCREENING - “Failed”;
OUTCOME - “Failed.” A true and correct copy of the relevant portion of Defendant’s
Application Tracker is attached as Exhibit A.
18. Plaintiff thus passed every merit-based stage of Defendant’s process - the Primary
Screening and the evaluation of his Application - and was rejected only at the Final
Screening stage.
19. The Final Screening stage is the background-investigation stage required by 4 R. Stat. §
122.401, conducted after evaluation of the application and immediately prior to
appointment. Upon information and belief, Plaintiff’s “Failed” result at Final Screening
reflects a negative background-investigation result within the meaning of 4 R. Stat. §
122.402 and 122.404.
20. Of the criteria to which a background investigation is limited under 4 R. Stat. § 122.402,
the only criterion concerning prior departmental or agency service is subsection (f) -
whether the individual has been terminated, or has received other adverse consequence,
within a department or agency. Upon information and belief, Defendant’s negative
determination rested upon a finding that Plaintiff had been terminated or had received an
adverse consequence within a department or agency. A true and correct copy of 4 R. Stat.
§ 122.402, with subsection (f) highlighted, is attached as Exhibit B.
21. Plaintiff has never been terminated from any department or agency in the State of
Ridgeway, and has never received any adverse consequence within any department
or agency in the State of Ridgeway. Any determination to the contrary is false.
22. Defendant has not notified Plaintiff of, or specified, any reason for the negative result of
Plaintiff’s Final Screening other than the determination published on its Application
Tracker. As of the date of this Complaint, the Application Tracker reflects only the word
“Failed” in the “FINAL SCREENING” and “OUTCOME” columns as to Plaintiff, with
no stated reasoning for the negative result, and Defendant has provided no further
explanation by direct message, comment, or otherwise.
23. As a direct and proximate result of Defendant’s determination and denial, Plaintiff
suffered concrete, non-hypothetical harm, including the loss of appointment to a position
for which he was qualified and had successfully competed, and the creation and
maintenance of a false record indicating that he had been terminated or sanctioned within
a department or agency - a record that injures Plaintiff’s character and standing and that
may impair future applications subject to background investigation under 4 R. Stat. §
122.402(f).
VI. CAUSES OF ACTION
COUNT I
Violation of Rights Secured by State Statute - 7 R. Stat. § 122.101
(Background Investigation Exceeding, or Resting on a False Application of, 4 R. Stat. § 122.402)
24. Plaintiff re-alleges and incorporates by reference each preceding paragraph as though
fully set forth herein.
25. 4 R. Stat. § 122.402 limits the permissible criteria of a background investigation and
confers on applicants the right to be screened only upon those limited criteria, accurately
applied.
26. Defendant’s negative Final Screening determination rested upon 4 R. Stat. § 122.402(f) -
a purported prior termination or adverse consequence within a department or agency - a
circumstance that does not exist as to Plaintiff. The determination therefore either rested
on a factually false finding under subsection (f) or relied on a consideration outside the
criteria to which § 122.402 is expressly limited.
27. Defendant’s determination is an order, procedure, or directive that impeded a right
secured to Plaintiff by state statute, within the meaning of 7 R. Stat. § 122.101, and
caused Plaintiff concrete, non-hypothetical harm within the meaning of 7 R. Stat §
122.101(a).
COUNT II
Violation of Rights Secured by State Statute - 7 R. Stat. § 122.101
(Failure to Notify and Specify Reasoning - 4 R. Stat. § 122.404)
28. Plaintiff re-alleges and incorporates by reference each preceding paragraph as though
fully set forth herein.
29. 4 R. Stat. § 122.404 requires that, where an appointing authority denies an individual on
the basis that a background investigation has yielded a negative result, it shall notify the
applicant and specify the reasoning for the negative result, and confers on applicants a
corresponding right to such notice.
30. Defendant denied Plaintiff on the basis of a negative Final Screening result but did not
specify the reasoning for that result, whether on its application results tracker (4 R. Stat. §
122.404(a)) or otherwise.
31. Defendant’s failure to provide the required notice is an order, procedure, or directive that
impeded a right secured to Plaintiff by state statute, within the meaning of 7 R. Stat. §
122.101, and caused Plaintiff concrete, non-hypothetical harm, including the inability to
identify and contest the basis for his denial.
COUNT III
Violation of Rights Secured by State Statute - 7 R. Stat. § 122.101
(Arbitrary Action and Failure of Transparency - 4 R. Stat. §§ 121.001, 121.103)
32. Plaintiff re-alleges and incorporates by reference each preceding paragraph as though
fully set forth herein.
33. The Government Civil Service System entitles applicants to selection on the basis of
relative ability, knowledge, and skills after fair and open competition (4 R. Stat. §
121.001(a)); to fair and equitable treatment with proper regard for privacy and
constitutional rights (4 R. Stat. § 121.001(b)); to protection against arbitrary action (4 R.
Stat. § 121.001(g)); and to an evaluation in which the appointing authority indicates all
attributes of merit or demerit (4 R. Stat. § 121.103).
34. Plaintiff passed every merit-based stage - his LETC certification, the Primary Screening,
and the evaluation of his Application - and was rejected only at Final Screening on a
basis that does not apply to him, without Defendant indicating any lawful attribute of
demerit supporting the rejection. Defendant’s action was arbitrary and failed the
transparency required by statute.
35. Defendant’s arbitrary action is an order, procedure, or directive that impeded rights
secured to Plaintiff by state statute, within the meaning of 7 R. Stat. § 122.101, and
caused Plaintiff concrete, non-hypothetical harm.
VII. PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests that this Court:
A. Enter a declaratory judgment, pursuant to Rid. R. Civ. P. 39, that Defendant’s denial of
Plaintiff’s application and the underlying Final Screening and background-investigation
determination violated 4 R. Stat. § 122.402, 122.404, 121.001, and 121.103, and impeded
rights secured to Plaintiff by state statute within the meaning of 7 R. Stat. § 122.101;
B. Enter a permanent restraining order, pursuant to 7 R. Stat. § 122.101 and Rid. R. Civ. P.
47, prohibiting Defendant from relying upon, enforcing, maintaining, or republishing any
determination that Plaintiff has been terminated from, or has received an adverse
consequence within, any department of agency;
C. Order injunctive relief reversing the harm, pursuant to 7 R. Stat. § 122.101, directing
Defendant to (i) vacate the “Failed” Final Screening result and outcome as to Plaintiff;
(ii) correct its records, including the Application Tracker and any internal
background-investigation record, to remove the false finding; and (iii) re-evaluate
Plaintiff’s application in conformity with 4 R. Stat. §§ 122.402 and 122.404;
D. Award monetary damages pursuant to 7 R. Stat. § 122.003 in an amount to be proven, not
to exceed $8,000.00 in compensatory damages and $5,000.00 in punitive damages;
E. Award Plaintiff his costs of this action, including the filing fees paid; and
F. Grant such other and further relief as the Court deems just and proper.
Exhibits. Exhibit A - relevant portion of Defendant’s Application Tracker (Ranger Class 22)
reflecting Plaintiff’s Entry No. 26. Exhibit B - 4 R. Stat. § 122.402, with subsection (f)
highlighted.
Respectfully Submitted,
_________________________
/s/ Halo4asin
HALO4ASIN
Plaintiff, Pro Se
Ridgeway State Bar License No. 18110
