IN THE SUPERIOR COURT OF RIDGEWAY
FOR THE STATE OF RIDGEWAY
HALO4ASIN,
Plaintiff,
v.
RIDGEWAY PARK SERVICE,
Defendant.
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Case No. RSC-CV-0750
FIRST AMENDED 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 in Ranger Class 22. The
Superintendent of the Parks Service has confirmed that the denial rested on a
background-investigation finding that Plaintiff “had an activity strike within RCFD” - a
determination under 4 R. Stat. § 122.402(f).
2. That basis is invalid. The Ridgeway County Fire Department, which issued the warnings,
has confirmed that Plaintiff’s record is listed as clean. One of the two warnings was a
conceded clerical error in the department’s logging system and is being removed; the
other is retained only as a historical note and is not a valid active adverse action. Plaintiff
passed every merit-based stage of the process and was denied solely on the basis of an
adverse consequence that does not validly exist. 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 (Roblox ID 7681; Discord flimzee) is a resident of the State
of Ridgeway and was, at all relevant times, a qualified applicant for civil-service
appointment. 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. Defendant
is the appointing authority for the position to which Plaintiff applied.
III. JURISDICTION AND VENUE
5. This Court has subject-matter jurisdiction as a court of law and equity vested with
original jurisdiction over civil cases. See Const. of the State of Ridgeway, art. V, § IV.
6. This action is 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 authorizes relief where an agency’s policy, order, procedure, or directive
impedes an individual’s rights secured by state statute. This action is brought under that
provision.
7. This Court, rather than the Administrative Court, is the proper forum: that 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 the Administrative Court
may not award damages (4 R. Stat. § 141.010).
8. Venue is proper in the County of Ridgeway, where the action accrued. See 7 R. Stat. §
131.001.
IV. STATUTORY FRAMEWORK
9. The position of full-time Park Ranger is a peace-officer position (2 R. Stat. § 331.302)
and a Schedule C civil-service position (4 R. Stat. § 121.204). An appointing authority
must conduct a background investigation prior to appointment, and the permissible
criteria are limited: 4 R. Stat. § 122.402 provides that “Background investigation criteria
shall be limited to” an enumerated list, of which the only criterion concerning prior
departmental service is subsection (f) - “whether the individual has been terminated, or
has received other adverse consequence, within a department or agency.”
10. Where an appointing authority denies an applicant on the basis of a negative background
result, it “shall notify the applicant and specify the reasoning for the negative result.” 4 R.
Stat. § 122.404. Selection must rest on relative ability after fair and open competition (4
R. Stat. § 121.001(a)), with applicants protected against arbitrary action (4 R. Stat. §
121.001(g)).
V. FACTUAL ALLEGATIONS
11. Defendant opened recruitment for Ranger Class 22 and accepted applications. Plaintiff
applied for a full-time Park Ranger position on our about June 6 through June 13, 2026.
12. Plaintiff met the eligibility and training prerequisites, including a valid Law Enforcement
Training Center (LETC) certification, reflected by the “Yes” entry in the “LETC CERT”
column of Defendant’s Application Tracker.
13. Defendant evaluated applications in successive stages reflected on its Application
Tracker: “PRIMARY SCREENING,” “APPLICATION,” “FINAL SCREENING,” and
“OUTCOME.” Plaintiff is listed as Entry No. 26, with results: PRIMARY SCREENING
- “Passed”; APPLICATION - “Passed”; FINAL SCREENING - “Failed”; OUTCOME -
“Failed.” A true and correct copy of the relevant portion of the Application Tracker is
attached as Exhibit A.
14. Plaintiff thus passed every merit-based stage - the Primary Screening and the evaluation
of his Application - and was rejected only at the Final Screening, which is the
background-investigation stage required by 4 R. Stat. § 122.401.
15. The Superintendent of the Parks Service, ItzCrazyAaron, has confirmed that the denial
rested on a finding, at the time of reviewing Plaintiff’s background check, that Plaintiff
“had an activity strike within RCFD.” That is a determination under 4 R. Stat. §
122.402(f). A true and correct copy of the Superintendent’s statement is attached as
Exhibit D.
16. The warnings referenced are two activity-related warnings issued to Plaintiff by the
Ridgeway County Fire Department, each recording an administrative demerit (4 R. Stat.
§ 111.022) and an adverse action (4 R. Stat. § 111.024): Warning I, concerning the
activity cycle of June 1-7, 2026; and Warning II, concerning the week of June 8-14, 2026.
A true and correct copy of the warnings is attached as Exhibit C.
17. The basis does not validly exist. The Ridgeway County Fire Department has confirmed
that Plaintiff’s record is listed as clean, and was clean as of his separation from the
department by honorable discharge. A true and correct copy of that confirmation is
attached as Exhibit E.
18. Of the two warnings, the Fire Chief has acknowledged that Warning I resulted from a
clerical error in the department’s RidgeLog logging system - not an actual missed log -
and has agreed to strike it from the record.
19. Warning II is retained only as a historical record-keeping note and is not treated by the
issuing department as a valid active adverse action; Plaintiff’s record is listed as clean
notwithstanding it. It is also factually contested: Activity Policy 303-2 requires only a
single call log of twenty (20) minutes or longer per weekly cycle, and Plaintiff’s logging
activity reflects double logs recorded in the weekly cycles immediately preceding and
following the cycle at issue, corroborating the recording errors the department has
acknowledged in that same system.
20. At the time of the denial, Defendant did not specify on its Application Tracker or
otherwise any reasoning for the negative Final Screening result, contrary to 4 R. Stat. §
122.404; the basis was articulated only afterward, as set forth in Exhibit D.
21. As a direct and proximate result of Defendant’s determination and denial, Plaintiff
suffered concrete, non-hypothetical harm, including the loss of an appointment for which
he was qualified and had successfully competed, and the maintenance of a record
indicating a disqualifying adverse consequence that does not validly exist.
22. Impartial consideration. The official who articulated the stated basis for the denial, and
to whom Plaintiff’s request for reconsideration is directed, previously declined Plaintiff’s
request for a secondary review of an earlier application while disclaiming membership on
the application committee at that time, and has since become the Superintendent of the
Parks Service. To the extent that official participates in the disposition of Plaintiff’s
candidacy or his request for reconsideration, Plaintiff is entitled to the impartial,
merit-based consideration guaranteed by 4 R. Stat. § 121.001.
VI. CAUSES OF ACTION
COUNT I
Violation of Rights Secured by State Statute - 7 R. Stat. § 122.101
(Denial Resting on an Adverse Consequence That Does Not Validly Exist - 4 R. Stat. §
122.402(f))
23. Plaintiff re-alleges and incorporates each preceding paragraph.
24. 4 R. Stat. § 122.402 limits a background investigation to the enumerated criteria,
accurately applied, and subsection (f) reaches only an actual adverse consequence within
a department. Defendant’s determination rested on a purported activity strike within
RCFD. That strike does not validly exist: the issuing department confirms Plaintiff’s
record is clean, one warning was a conceded clerical error being removed, and the other
is not a valid active adverse action.
25. Defendant’s reliance on a non-existent or erroneous adverse consequence to deny
Plaintiff’s application 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 under 7 R. Stat. § 122.101(a).
COUNT II
Violation of Rights Secured by State Statute - 7 R. Stat. § 122.101
(Failure to Specify Reasoning at the Time of Denial - 4 R. Stat. § 122.404)
26. Plaintiff re-alleges and incorporates each preceding paragraph.
27. 4 R. Stat. § 122.404 required Defendant, upon denying Plaintiff on the basis of a negative
background result, to notify Plaintiff and specify the reasoning for that result. Defendant
specified no reasoning at the time of the denial, whether on its application results tracker
or otherwise, and articulated the basis only afterward. That failure impeded a right
secured to Plaintiff by statute and caused him concrete harm, including the inability to
identify and contest the basis when the denial issued.
COUNT III
Violation of Rights Secured by State Statute - 7 R. Stat. § 122.101
(Arbitrary Action - 4 R. Stat. § 121.001)
28. Plaintiff re-alleges and incorporates each preceding paragraph.
29. The Government Civil Service System entitles applicants to selection on the basis of
relative ability after fair and open competition (4 R. Stat. § 121.001(a)) and to protection
against arbitrary action (4 R. Stat. § 121.001(g)). Plaintiff passed every merit-based stage
and was rejected only at Final Screening, on the basis of a strike that the issuing
department has acknowledged as erroneous and agreed to remove or a residual historical
note that the issuing department does not treat a valid adverse action. Denial on that basis
is arbitrary and impeded rights secured to Plaintiff by statute, causing concrete harm.
VII. PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests that this Court:
A. Enter a declaratory judgment that Defendant’s denial of Plaintiff’s application violated 4
R. Stat. §§ 122.402, 122.404, and 122.001, 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, prohibiting
Defendant from denying Plaintiff’s application in reliance upon any administrative
demerit that is non-existent, erroneous, removed, or not a valid active adverse action;
C. Order injunctive relief reversing the harm, directing Defendant to (i) vacate the “Failed”
Final Screening result and outcome as to Plaintiff; and (ii) re-evaluate Plaintiff’s
application on the corrected record 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 the statutory caps;
E. Award Plaintiff his costs of this action; and
F. Grant such other and further relief as the Court deems just and proper.
Exhibits. Exhibit A - Application Tracker (Ranger Class 22), Entry No. 26. Exhibit B - 4 R. Stat.
§ 122.402. Exhibit C - the two activity warnings. Exhibit D - the Superintendent’s statement on
the basis for the denial. Exhibit E - RCFD confirmation of a clean record and removal of the
RidgeLog clerical strike.
Respectfully Submitted,
_________________________
/s/ Halo4asin
HALO4ASIN
Plaintiff, Pro Se
Ridgeway State Bar License No. 18110
