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 MOTION FOR PRELIMINARY INJUNCTION, WITH MEMORANDUM OF
POINTS AND AUTHORITIES IN SUPPORT
COMES NOW the Plaintiff, Halo4asin, appearing pro se, and respectfully moves this Court,
pursuant to its equity power under 4 R. Stat. Section 131.001 and Article V, Section IV of the
Constitution of the State of Ridgeway, for a preliminary injunction against the Defendants. In
support, Plaintiff states as follows:
I. RELIEF REQUESTED
A. Restraining the Defendants from treating the May 29, 2026 finalization of Plaintiff’s
application as final, conclusive, or preclusive of further review;
B. Restraining Defendant Azap634 and errcore from any further participation in, supervision
of, or influence over any screening, background investigation, internal affairs, or review
function concerning Plaintiff;
C. Directing the Defendants to preserve, and not to delete, alter, or destroy, all records
relating to Plaintiff’s application, including the background investigation file, the
badge-tracking report generated on May 25, 2026, and all communications among the
Defendants and any RCSO officer concerning Plaintiff; and
D. Preserving Plaintiff’s eligibility and application status so that complete relief remains
available at final judgment.
II. STATEMENT OF FACTS
Plaintiff incorporates by reference the verified factual allegations of his Complaint and the
documents identified in his Exhibit List. In brief: RCSO denied Plaintiff’s application on the
stated ground that he was a suspected alternate account; it provided only a bare citation to 4 R.
Stat. Section 122.402(a), with no factual basis or particularized reasoning (Exhibit E); it ignored
Plaintiff’s documented exculpatory evidence (Exhibits R and K); the result was approved by
Defendant Azap634 (Exhibit L), an officer against whose direct subordinate Plaintiff had filed a
misconduct report days earlier (Exhibit I), and who personally generated a badge-tracking report
on Plaintiff’s account on May 25, 2026 (Exhibits J and K); and the Ridgeway Department of
Transportation reached the opposite result on the identical question and the identical evidence,
reversing its determination to a pass (Exhibit AA). Defendant Azap634 has admitted that “if we
were informed, your background check may not have been failed” (Exhibit F) and that “my
personal knowledge of you was not one of those factors that we assessed” (Exhibit G).
III. MEMORANDUM OF POINTS AND AUTHORITIES
A preliminary injunction is appropriate where the movant demonstrates a likelihood of success
on the merits, a likelihood of irreparable harm absent relief, that the balance of equities favors
relief, and that relief serves the public interest. This Court, sitting in equity under 4 R. Stat.
Section 131.001, is empowered to grant such relief, and Article I, Section I of the Constitution
guarantees that every person obtain right and justice completely and without denial or delay.
A. PLAINTIFF IS LIKELY TO SUCCEED ON THE MERITS.
First, the denial violated the duty to specify the reasoning for a negative background result.
Under 4 R. Stat. Section 122.404, enacted by the Administrative Procedure Act of 2026 (S.B.
006), where an appointing authority denies an individual on the basis of a negative background
result, it “shall notify the applicant and specify the reasoning for the negative result.” RCSO
published only a bare statutory citation (Exhibit E). A citation is not a specification of reasoning.
The violation is established on the face of the tracker.
Second, the denial violated the Civil Service Employee Bill of Rights. Under 4 R. Stat. Section
123.501(c) and (d), all persons have the right to a clear and defined reason for denial and the
right to request information pertaining to that reason. RCSO gave neither.
Third, the review was biased and conflicted. Under 4 R. Stat. Section 123.501(b) and the merit
principles of 4 R. Stat. Section 121.001(b) and (g), Plaintiff was entitled to an unbiased review
free of personal favoritism. Defendant Azap634 approved the adverse result (Exhibit L) while
laboring under an undisclosed conflict arising from Plaintiff’s misconduct report against his
subordinate and the parties’ shared service in RCFD.
Fourth, the denial was arbitrary. Under 4 R. Stat. Section 123.401, arbitrary action includes
action with no factual backing and action that disregards mitigating evidence. RCSO ignored
Plaintiff’s exculpatory evidence and reached a conclusion opposite to that of RDOT on identical
evidence (Exhibit AA), confirming arbitrariness.
Fifth, the denial was retaliatory. Under 4 R. Stat. Section 123.501(i) and Section 121.001(h),
Plaintiff was protected in reporting misconduct. The badge-tracking report and the adverse result
followed within days of his protected report (Exhibits J and I).
Sixth, the conduct constitutes a deprivation of statutory rights under color of law within the
meaning of 7 R. Stat. Section 121.403, and the underlying agency policy is subject to injunctive
correction under 7 R. Stat. Section 122.101.
B. PLAINTIFF WILL SUFFER IRREPARABLE HARM ABSENT RELIEF.
Plaintiff seeks no damages, and damages would not in any event remedy the loss of a civil
service appointment, the continuing effect of an unexplained and unsupported “alternate
account” label on his record, or the ongoing violation of his statutory rights. The harm is to status
and reputation, which money cannot repair, and which compounds with each day the unlawful
finalization stands.
C. THE BALANCE OF EQUITIES FAVORS PLAINTIFF.
The burden on the Defendants is slight. They are asked only to refrain from treating an unlawful
finalization as conclusive, to keep two conflicted officers away from Plaintiff’s matter, and to
preserve records they are already obligated to keep. The burden on Plaintiff absent relief is the
loss of his appointment and the continued operation of a denial reached in violation of statute.
D. The public has a strong interest in a civil service that is merit-based, transparent, free of
retaliation, and free of conflicted decision-making, as declared in the principles of 4 R.
Stat. Section 121.001. An injunction vindicates, rather than disserves, that interest.
IV. EXPEDITED CONSIDERATION
Plaintiff respectfully requests expedited consideration of this Motion given the continuing nature
of the harm and the imminence of service upon the Defendants.
V. CONCLUSION
For the foregoing reasons, Plaintiff respectfully requests that this Court grant the preliminary
injunction as set forth above, and grant such further relief as is just and proper.
Respectfully Submitted,
_________________________
/s/ Halo4asin
HALO4ASIN
Plaintiff, Pro Se
Ridgeway State Bar License No. 18110
