IN THE SUPERIOR COURT OF RIDGEWAY
FOR THE STATE OF RIDGEWAY
HALO4ASIN
Plaintiff,
v.
RIDGEWAY COUNTY SHERIFF’S
OFFICE;
ERRCORE, in his official capacity;
AZAP634, in his official capacity,
Defendants.
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Case No. RSC-CV-5191
Presiding Judge: Hon. Arthur_Chen
PLAINTIFF’S FINAL AMENDED COMPLAINT FOR DECLARATORY AND
INJUNCTIVE RELIEF
COMES NOW the Plaintiff, Halo4asin, appearing pro se, and for his Final Amended Complaint
against the Ridgeway County Sheriff’s Office, errcore, and Azap634, respectfully states and
alleges as follows:
I. NATURE OF THE ACTION
1. This is an action for declaratory and injunctive relief arising from the unlawful denial of
Plaintiff’s application for appointment as a Deputy of the Ridgeway County Sheriff’s
Office (“RCSO”).
2. Plaintiff does not seek monetary damages of any kind. Plaintiff seeks only declaratory
relief and equitable relief within the power of this Court under 4 R. Stat. Sections
141.010 and 141.011.
3. In short, RCSO denied Plaintiff’s application on the stated ground that he was a
suspected alternate account, but (a) it gave only a bare statutory citation with no factual
basis or particularized reasoning, in violation of the duty to specify the reasoning for a
negative background result; (b) it ignored Plaintiff’s exculpatory evidence; (c) the denial
was approved by an officer, Defendant Azap634, who labored under an undisclosed
conflict of interest and who had a retaliatory motive arising from a misconduct report
Plaintiff had filed against Azap634’s own subordinate days earlier; and (d) it reached the
opposite result from the Ridgeway Department of Transportation, which evaluated the
identical question on the identical evidence and reversed its determination to a pass.
II. THE PARTIES
4. Plaintiff Halo4asin is a resident of the State of Ridgeway, a member in good standing of
the Ridgeway State Bar (License No. 18110), a peace officer certified by the Law
Enforcement Training Center (Class 19), and a Lieutenant in the Ridgeway County Fire
Department (“RCFD”). He applied for appointment to the civil service position of
Deputy at RCSO and is therefore an “applicant” within the meaning of 4 R. Stat. Section
111.020.
5. Defendant Ridgeway County Sheriff’s Office is an agency of the County of Ridgeway
established under 9 R. Stat. Section 331.001 and is a civil service agency within the
meaning of 4 R. Stat. Section 111.001. RCSO is the appointing authority that denied
Plaintiff’s application. It is served through Sheriff Cephal as its administrative head
pursuant to 7 R. Stat. Section 131.105.
6. Defendant errcore is, and at all relevant times was, a Captain in the Criminal
Investigations Division of RCSO. He is sued in his official capacity. Errcore conducted a
self-described “third review” of Plaintiff’s screening result, affirmed the denial, and
thereafter refused to respond to Plaintiff further.
7. Defendant Azap634 is, and at all relevant times was, a Lieutenant in the Criminal
Investigations Division of RCSO. He also holds the rank of Captain in the Military Police
of the Ridgeway National Guard (“MPI”) and the rank of Captain in the Fire
Investigations Division of RCFD (“FID”). He is sued in his official capacity. Azap634
approved the result that failed Plaintiff’s screening and personally generated a
badge-tracking report on Plaintiff’s account during the relevant period.
8. Because Plaintiff and Defendant Azap634 both serve within RCFD, and because Plaintiff
had filed a misconduct report implicating Azap634’s direct MPI subordinate immediately
before the screening was failed, Azap634’s participation in and approval of the adverse
result was conflicted within the meaning of the merit principles set forth in 4 R. Stat.
Section 121.001.
III. JURISDICTION AND VENUE
9. This Court has original jurisdiction over this matter pursuant to 4 R. Stat. Section
141.007, which confers original jurisdiction over all matters involving the internal policy
or rules of a civil service agency. This action challenges the internal
background-investigation policy and rules of RCSO, a civil service agency, and the
application of those policies and rules to Plaintiff.
10. In the alternative, and to the extent the denial of Plaintiff’s application constitutes an
adverse employment action, this Court has jurisdiction under 4 R. Stat. Section 141.101
and Section 141.006 to hear and decide an administrative claim asserting that the action
was arbitrary or taken without due observance of state statute.
11. Plaintiff further invokes 4 R. Stat. Section 123.501(g) and Section 123.501(h), which
secure to all persons the right to seek review from the courts over prejudicial or harmful
practices relating to their employment, and the right freely to petition the courts.
12. This Court is empowered to grant the relief sought. Under 4 R. Stat. Section 141.010, this
Court may grant equitable remedy as necessary to ensure the proper enforcement of law,
and under 4 R. Stat. Section 141.011, this Court may issue declaratory relief. Plaintiff
seeks no damages, and accordingly the bar on damages in Section 141.010 presents no
obstacle to the relief requested.
13. Venue is proper because the acts complained of accrued within the County of Ridgeway,
where RCSO operates and where Plaintiff resides, consistent with 7. R. Stat. Section
131.001.
IV. STATEMENT OF FACTS
A. Plaintiff’s Qualifications
14. Plaintiff is certified as a peace officer by the Law Enforcement Training Center, having
completed Class 19, as reflected in Exhibit A.
15. Plaintiff is a member in good standing of the Ridgeway State Bar, holding License No.
18110, as reflected in Exhibit B.
16. Plaintiff serves as a Lieutenant in the Ridgeway County Fire Department, and his
community standing and rank are reflected in Exhibit C.
17. At all relevant times Plaintiff satisfied the minimum qualifications and the residency
requirement for appointment to the civil service position of Deputy.
B. The Application and Its Sudden Reversal
18. In May 2026, Plaintiff applied to RCSO for appointment as a Deputy.
19. Plaintiff’s application results tracker, attached as Exhibit D, reflects the following
progression: Primary Screening, Passed; Application, Passed; Screening, Failed; and,
thereafter, Committee Decision and Request, which had been listed as Pending, flipped to
Failed on or about May 27 to 28, 2026.
20. No explanation accompanied the flipping of the Committee Decision and Request
statuses from Pending to Failed.
C. Plaintiff’s Protected Misconduct Report and Its Aftermath
21. On or about May 21 to 22, 2026, and before his screening was failed, Plaintiff filed a
misconduct report with the Military Police (MPI) of the Ridgeway National Guard
concerning spoookdan. spoookdan had been the only individual to search Plaintiff’s
vehicle during a National Guard training exercise, after which a Suppressed Cline
belonging to Plaintiff went missing.
22. spoookdan is the direct MPI subordinate of Defendant Azap634.
23. Defendant Azap634 personally denied summary review of Plaintiff’s misconduct report,
stating to Plaintiff that Plaintiff “could also just be attempting to frame spookdab” and
that it was “your word against his.” This denial is reflected in Exhibit I.
24. Although Plaintiff had disclosed the existence of the misconduct report to no person other
than Defendant Azap634, spoookdan thereafter made unsolicited contact with Plaintiff
concerning the report, as reflected in Exhibit Z. Defendant Azap634 later asserted that
spoookdan learned of the report through supervisory MPI access rather than through any
disclosure by Azap634.
D. The Conflicted and Unreasoned Screening Denial
25. Plaintiff’s RCSO screening was failed by a Criminal Investigations Division detective
whose identity has not been disclosed to Plaintiff.
26. The application results tracker attributes the screening result to “LT Azap634, CID,” and
cites the Background Investigation Criteria provision now codified at 4 R. Stat. Section
122.402(a), which concerns whether factors indicate or suggest that an individual is an
alternate account. The tracker note is attached as Exhibit E.
27. The sole reason given for the denial was that bare statutory citation. The tracker
identified no specific factual basis, no particularized findings, and no identification of
which “factors” were deemed indicative of an alternate account.
28. Defendant Azap634 later admitted to Plaintiff that “all but about two factors were
deemed indicative for your account being alternative,” yet never identified those factors.
This admission is reflected in Exhibit H.
29. The basis for the alternate-account suspicion is innocent and documented. Plaintiff’s
current account became his primary account in July 2025 after his prior accounts (49dz
and Flimzee) were terminated by the platform. The termination records, dated for review
July 12, 2025, are attached as Exhibit R. The badge curve commencing in July 2025 and
totaling 287 badges, is attached as Exhibit K.
30. Defendant Azap634 admitted that Plaintiff’s exculpatory information was not considered:
“If we were informed, your background check may not have been failed.” This admission
is reflected in Exhibit F.
31. Defendant Azap634 further admitted that “my personal knowledge of you was not one of
those factors that we assessed.” This admission is reflected in Exhibit G.
E. The Retaliatory Badge-Tracking Report
32. On May 25, 2026, at 1:18 PM, three days after Plaintiff filed his MPI misconduct report
and one day before Plaintiff’s appeal, Defendant Azap634 personally generated a
badge-tracking report on Plaintiff’s account. The request and the resulting chart are
attached as Exhibits J and K.
33. The timing and authorship of the badge-tracking report, taken together with Azap634’s
role in approving the adverse screening result, evidence a retaliatory motive connected to
Plaintiff’s protected misconduct report.
F. Notice of Retaliation and errcore’s Affirmance
34. On May 25, 2026, at approximately 10:47 PM, Plaintiff forwarded written notice of
retaliation to Defendant errcore, to Sheriff Cephal, and to Deputy Sheriff
redawesomeoby. These notices are attached as Exhibits O, P, and Q. None of the
recipients intervened.
35. Defendant errcore first stated to Plaintiff that “it doesnt look like Azap even did your
bgc,” as reflected in Exhibit V.
36. After Plaintiff showed errcore the tracker note attributing the result to Azap634, errcore
confirmed: “Yes because he approved of the result from another CID detective.” This
admission is reflected in Exhibit L.
37. errcore conducted a self-described “third review” of the screening result and upheld it, as
reflected in Exhibit M.
38. errcore thereafter stated to Plaintiff, “I will not respond to anything further,” as reflected
in Exhibit N.
G. The State Auditor Proceeding
39. On or about May 25 to 26, 2026, Plaintiff filed a complaint with the Office of the State
Auditor, docketed as Case No. PC-0019-0526.
40. The State Auditor initially adopted Defendant Azap634’s framing, inquired of errcore,
who did not substantively respond, and then dismissed the complaint without findings on
the merits.
41. In the course of dismissing the complaint, the State Auditor found that Plaintiff’s
evidence “appeared factually credible, and did not present any form of falsification,” and
indicated that the matter should be resolved between the parties or through the courts.
The tipline transcript and the materialized report are attached as Exhibits Y and BB.
42. In the State Auditor proceeding, Defendants represented that Plaintiff’s background
check “was not finalized” and that the evidence “remained under review.”
Notwithstanding those representations, Defendants finalized the denial without any
remedy three days later, as set forth below.
H. The Identical RDOT Determination and Its Reversal
43. The Ridgeway Department of Transportation (“RDOT”) had earlier made the same
alternate-account determination against Plaintiff under the same statutory criterion.
44. The RDOT investigator, Vaevilo, reversed that determination upon review of Plaintiff’s
exculpatory evidence. The formal RDOT record states: “Reversed and changed to a pass
as the individual sent proof and statements proving that they were not an alternative
account.” That record is attached as Exhibit AA, and the related correspondence is
attached as Exhibits S, T, W, and X.
45. RDOT and RCSO thus reached opposite conclusions on the identical question, applying
the identical criterion, on the identical evidence. RCSO’s contrary result, reached without
consideration of that evidence, was arbitrary.
I. Finalization Without Remedy
46. On May 29, 2026, the final application results were posted. The denial was finalized and
has never been reversed, notwithstanding Plaintiff’s appeals. The finalized tracker is
attached as Exhibit D.
J. Post-Filing Admissions
47. After Plaintiff commenced this action, Defendant Azap634 repeatedly contacted Plaintiff
and, in the course of those communications, reaffirmed that “my personal knowledge of
you was not considered,” confirmed that he personally generated the badge chart, and
characterized spoookdan’s unsolicited contact with Plaintiff as “inappropriate.” These
admissions are consistent with and corroborate the documentary record.
48. Each Exhibit referenced in this Complaint is identified and listed in Plaintiff’s Exhibit
List, filed concurrently herewith, and is incorporated herein by reference.
V. CAUSES OF ACTION
COUNT I - FAILURE TO SPECIFY THE REASONING FOR A NEGATIVE BACKGROUND
RESULT (4 R. Stat. Sections 122.404 and 122.404(a); 4 R. Stat. Section 122.402)
49. Plaintiff realleges and incorporates by reference paragraphs 1 through 48 as though fully
set forth herein.
50. Under 4 R. Stat. Section 122.404, where an appointing authority denies an individual on
the basis that the individual’s background investigation has yielded a negative result, the
authority “shall notify the applicant and specify the reasoning for the negative result.”
51. Under 4 R. Stat. Section 122.404(a), an appointing authority may satisfy this duty by
publishing its reasoning on an application results tracker accessible to the applicant.
52. RCSO denied Plaintiff on the basis of a negative background result and was therefore
required to specify the reasoning for that result.
53. RCSO published only a bare citation to 4 R. Stat. Section 122.402(a) on the application
results tracker. It specified no factual basis, no particularized findings, and no
identification of which factors were deemed indicative of an alternate account. A bare
statutory citation is not a specification of “the reasoning” within the meaning of Section
122.404.
54. RCSO’s failure to specify the reasoning deprived Plaintiff of the notice the statute
guarantees and rendered meaningful response and appeal impossible.
55. Plaintiff is entitled to a declaration that the denial violated 4 R. Stat. Section 122.404 and
to injunctive relief as set forth in the Prayer for Relief.
COUNT II - FAILURE TO PROVIDE A CLEAR AND DEFINED REASON AND TO HONOR
THE RIGHT TO REQUEST INFORMATION (4 R. Stat. Section 122.308; 4 R. Stat. Sections
123.501(c) and 123.501(d))
56. Plaintiff realleges and incorporates by reference paragraphs 1 through 48 as though fully
set forth herein.
57. Under 4 R. Stat. Section 122.308, where an appointing authority determines that an
applicant lacks the minimum qualifications or selective criteria, the applicant “shall be
notified of the reasons for the determination.”
58. Under 4 R. Stat. Section 123.501(c), all persons have the right to a clear and defined
reason for their denial from the civil service, and under 4 R. Stat. Section 123.501(d), all
persons have the right to request information pertaining to the reason for their denial.
59. RCSO provided no clear and defined reason for Plaintiff’s denial, offering only a bare
statutory citation, and it failed to provide the specific factual basis for the determination
even after Plaintiff sought that information.
60. Plaintiff is entitled to a declaration that the denial violated 4 R. Stat. Sections 122.308,
123.501(c), and 123.501(d), and to injunctive relief as set forth in the Prayer for Relief.
COUNT III - BIASED REVIEW AND CONFLICT OF INTEREST (4 R. Stat. Section
123.501(b); 4 R. Stat. Sections 121.001(b) and 121.001(g))
61. Plaintiff realleges and incorporates by reference paragraphs 1 through 48 as though fully
set forth herein.
62. Under 4 R. Stat. Section 123.501(b), all persons have the right to be free from a biased
review of their applications and materials for employment within the civil service.
63. Under 4 R. Stat. Section 121.001(b), all applicants for employment should receive fair
and equitable treatment with proper regard for their constitutional rights, and under 4 R.
Stat. Section 121.001(g)(1), employees and applicants should be protected against
arbitrary action and personal favoritism.
64. Defendant Azap634 approved the adverse screening result while laboring under an
undisclosed conflict of interest: Plaintiff had days earlier filed a misconduct report
against Azap634’s direct MPI subordinate, and Plaintiff and Azap634 both serve within
RCFD.
65. A review approved by a conflicted officer with a personal stake in the outcome is, by
definition, a biased review, and Plaintiff was denied the fair and equitable treatment the
merit principles require.
66. Plaintiff is entitled to a declaration that the review was biased and conflicted in violation
of 4 R. Stat. Sections 123.501(b), 121.001(b), and 121.001(g), and to injunctive relief as
set forth in the Prayer for Relief, including the removal of Defendants Azap634 and
errcore from screening, investigative, and internal affairs functions.
COUNT IV - ARBITRARY ACTION AND FAILURE OF DUE OBSERVANCE OF STATUTE
(4 R. Stat. Section 141.101; 4 R. Stat. Sections 123.401 and 123.402)
67. Plaintiff realleges and incorporates by reference paragraphs 1 through 48 as though fully
set forth herein.
68. Under 4 R. Stat. Section 141.101, an administrative claim asserts that an adverse action
was arbitrary or taken without due observance of state statute. Under 4 R. Stat. Section
123.401, arbitrary action includes action with no factual backing and action that takes no
account of mitigating factors, circumstances, or evidence, and under 4 R. Stat. Section
123.402, no appointing authority shall take arbitrary action.
69. RCSO’s denial was arbitrary because it rested on no disclosed factual backing, ignored
Plaintiff’s documented and exculpatory evidence, and reached a result opposite to that
reached by RDOT on the identical question and the identical evidence.
70. Plaintiff is entitled to a declaration that the denial was arbitrary and taken without due
observance of state statute, and to injunctive relief as set forth in the Prayer for Relief.
COUNT V - RETALIATION FOR PROTECTED ACTIVITY (4 R. Stat. Sections 123.501(f)
and 123.501(i); 4 R. Stat. Section 121.001(h))
71. Plaintiff realleges and incorporates by reference paragraphs 1 through 48 as though fully
set forth herein.
72. Under 4 R. Stat. Section 123.501(i), all persons have the right to report misconduct,
harassment, fraud, waste, or abuse; under 4 R. Stat. Section 123.501(f), all persons have
the right to be free from coercion, obstruction, or oppression in connection with their
employment; and under 4 R. Stat. Section 121.001(h), employees and applicants should
be protected against reprisal for the lawful disclosure of information evidencing a
violation of law or an abuse of authority.
73. Plaintiff engaged in protected activity when he filed a misconduct report concerning
spoookdan.
74. Days after that protected activity, Defendant Azap634 personally generated a
badge-tracking report on Plaintiff’s account and approved the adverse screening result,
and RCSO finalized the denial. The close temporal proximity and the identity of the actor
evidence retaliation for Plaintiff’s protected activity.
75. Plaintiff is entitled to a declaration that adverse action was retaliatory in violation of 4 R.
Stat. Sections 123.501(f), 123.501(i), and 121.001(h), and to injunctive relief as set forth
in the Prayer for Relief.
COUNT VI - FAILURE TO EVALUATIVE TRANSPARENCY (4 R. Stat. Section 121.103)
76. Plaintiff realleges and incorporates by reference paragraphs 1 through 48 as though fully
set forth herein.
77. Under 4 R. Stat. Section 121.103, during the vacancy process an appointing authority
shall indicate all attributes of merit and demerit and weigh each application according to
stated principles.
78. RCSO never identified the “factors” it deemed indicative of an alternate account, and
Defendant Azap634 admitted that “all but about two factors were deemed indicative”
without ever identifying them. RCSO thereby failed to indicate the attributes on which it
relied, in violation of the transparency duty.
79. Plaintiff is entitled to a declaration that RCSO violated 4 R. Stat. Section 121.103 and to
injunctive relief as set forth in the Prayer for Relief.
COUNT VII - UNLAWFUL INTERNAL POLICY AND PROCEDURES OF A CIVIL
SERVICE AGENCY (4 R. Stat. Sections 141.007 and 141.010)
80. Plaintiff realleges and incorporates by reference paragraph 1 through 48 as though fully
set forth herein.
81. RCSO maintains and applies background-investigation policy and practice that permits
denial on the basis of a bare statutory citation, without specification of reasoning, without
consideration of exculpatory evidence, and without safeguards against conflicted review.
82. Pursuant to 4 R. Stat. Section 141.007, this Court has original jurisdiction over this matter
involving the internal policy and rules of a civil service agency, and pursuant to 4 R. Stat.
Section 141.010, this Court may grant equitable relief necessary to ensure the proper
enforcement of law.
83. Plaintiff is entitled to a permanent injunction restraining RCSO from applying its
deficient background-investigation procedures as set forth in the Prayer for Relief.
COUNT VIII - DECLARATORY RELIEF (4 R. Stat. Section 141.011; Const. Art. I, Sec. I;
Const. Art. V, Sec. I)
84. Plaintiff realleges and incorporates by reference paragraphs 1 through 48 as though fully
set forth herein.
85. An actual controversy exists between Plaintiff and Defendants concerning the lawfulness
of the denial and of RCSO’s procedures.
86. Under Article I, Section I of the Constitution of the State of Ridgeway, every person
ought to obtain right and justice, freely, completely, and without denial or delay, and
under Article V, Section I, the courts shall administer justice impartially and without
unnecessary delay.
87. Pursuant to 4 R. Stat. Section 141.011, Plaintiff is entitled to a declaration of the rights
and obligations of the parties as set forth in the Prayer for Relief.
VI. PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in his favor and
grant the following relief:
A. A DECLARATION that RCSO’s denial of Plaintiff’s application violated 4 R. Stat.
Section 122.404 (duty to specify reasoning), 4 R. Stat. Section 122.308 and Section
123.501(c)-(d) (clear and defined reason; right to request information), 4 R. Stat. Section
123.501(b) and Section 121.001(b) and (g) (biased and conflicted review; fair and
equitable treatment), 4 R. Stat. Section 141.101 and Sections 123.401-123.402 (arbitrary
action), 4 R. Stat. Section 123.501(f), (i) and Section 121.001(h) (retaliation), and 4 R.
Stat. Section 121.103 (evaluative transparency);
B. AN ORDER vacating the finalization of Plaintiff’s application entered on or about May
29, 2026;
C. AN ORDER restoring the Screening, Committee Decision, and Request statuses of
Plaintiff’s application to Passed, and advancing Plaintiff’s application accordingly;
D. AN ORDER granting Plaintiff appointment as a Deputy of RCSO or, in the alternative,
an order directing RCSO to re-evaluate Plaintiff’s application through a conflict-free
Criminal Investigations Division detective and to provide Plaintiff with a written
identification of the specific criteria relied upon and the specific factual basis for any
determination;
E. AN ORDER restraining Defendants Azap634 and errcore from participating in screening,
investigative, and internal affairs functions, removing them from any such role with
respect to Plaintiff, and barring them from such roles with respect to Plaintiff in any
future Ridgeway agency;
F. A PERMANENT INJUNCTION restraining RCSO from applying its
background-investigation procedures in a manner that denies applicants without
specification of reasoning, without consideration of exculpatory evidence, or through
conflicted review;
G. AN ORDER setting this matter for administrative hearing within seventy-two (72) hours
of filing pursuant to 4 R. Stat. Section 141.108;
H. AN AWARD of Plaintiff’s court costs and charges to the extent permitted by laws; and
I. SUCH OTHER AND FURTHER equitable relief as this Court deems just and proper.
Plaintiff expressly seeks no monetary damages.
VII. VERIFICATION
I, Halo4asin, declare under the pains and penalties of perjury that I am the Plaintiff in this action,
and that the factual statements contained herein are true and correct to the best of my knowledge,
information, and belief.
Respectfully Submitted,
_________________________
/s/ Halo4asin
HALO4ASIN
Plaintiff, Pro Se
Ridgeway State Bar License No. 18110
