IN THE SUPERIOR COURT OF RIDGEWAY
FOR THE STATE OF RIDGEWAY
HALO4ASIN
Plaintiff,
v.
RIDGEWAY COUNTY SHERIFF’S
OFFICE;
ERRCORE, in his official capacity as
Captain, Criminal Investigations
Division;
AZAP634, in his official capacity as
Lieutenant, Criminal Investigations
Division,
Defendants.
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Case No. RSC-CV-5191
Presiding Judge: Hon. Arthur_Chen
PLAINTIFF’S MOTION FOR SUMMARY JUDGMENT, WITH MEMORANDUM OF
POINTS AND AUTHORITIES IN SUPPORT
COMES NOW the Plaintiff, Halo4asin, appearing pro se, and moves this Court for summary
judgment on all counts of his Final Amended Complaint. The pleadings are closed and the case
is at issue. There is no genuine dispute as to any material fact, and Plaintiff is entitled to
judgment as a matter of law.
I. INTRODUCTION
1. Plaintiff is an applicant, not an employee. He applied to RCSO for appointment as a
Deputy, passed two phases, and was failed at the background phase as a suspected
alternate account. His claims rest on the duties an appointing authority owes to an
applicant and on the rights this State secures to “all persons.”
2. This Court need not resolve a single contested fact, because the Defendants’ Answer
concedes the spine of the case. An admission in a pleading is binding and requires no
proof. The Defendants admit the application was denied (Answer ¶¶1, 46); that the notice
identified only the background-investigation criterion (Answer ¶26); that 4 R. Stat.
Section 122.404 requires the notice and that a tracker may carry the reasoning (Answer
¶¶50-51); that applicants are entitled to an unbiased review (Answer ¶62); that “reviews
conducted by conflicted officers with personal stakes in outcomes are biased reviews”
(Answer ¶65); that Plaintiff filed a misconduct complaint (Answer ¶73); that they told the
State Auditor the matter “remained under consideration” and then finalized the denial
(Answer ¶¶42, 46); and that RDOT “reached a different conclusion” on the same account
(Answer ¶44). They further concede that the exhibits speak for themselves (Answer ¶48).
3. What the Defendants deny are legal characterizations and causation. But a
characterization that follows from admitted facts is a question of law, and a bare denial of
a legal conclusion does not create a genuine dispute of fact.
II. THE EVIDENCE BEFORE THE COURT IS ADMISSIBLE
4. Administrative procedures follow the Ridgeway Rules of Evidence, subject to the
Judiciary Act. Under Sec. 406(e) of that Act, hearsay “shall be admissible where it uses
the statements of the accused,” and under Sec. 406(d) all evidence shall be authenticated
by an appropriate witness.
5. Every fact on which this Motion depends satisfies that rule. The Defendants’ admissions
are statements of the accused. The communications of Azap634 (Exhibits F, G, H) and
errcore (Exhibits L, N, V) are statements of the accused. The application tracker (Exhibits
D, E) is RCSO’s own record, and the Defendants concede its contents (Answer ¶¶26, 48).
The conclusions reached by RDOT and the State Auditor are established here not by their
records standing alone but by the Defendants’ own admissions (Answer ¶¶42, 44, 40-41);
the records corroborate, and Plaintiff has subpoenaed their custodians to authenticate
them at any hearing the Court may hold.
III. STATEMENT OF UNDISPUTED MATERIAL FACTS
1. Plaintiff applied to RCSO for appointment as a Deputy and is an “applicant” under 4 R.
Stat. Section 111.020. He applied in May 2026 (Answer ¶18), and the application was
denied and finalized (Answer ¶¶1, 46).
2. RCSO is a county civil service agency that processed the application (Answer ¶5);
errcore held the rank of Captain (Answer ¶6); and Azap634 held every position alleged,
Lieutenant CID, Captain MPI, and Captain FID (Answer ¶7).
3. RCSO conducted a background review (Answer ¶25) and issued a negative background
determination (Answer ¶52).
4. The notice to Plaintiff identified only the criterion at 4 R. Stat. Section 122.402(a) and
stated no factual basis and no factor (Answer ¶26; Exhibits D, E).
5. Azap634 stated that “all but about two factors were deemed indicative” without
identifying any (Exhibits H); 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).
6. errcore stated that Azap634 “approved of the result from another CID detective” (Exhibit
L) and that he “will not respond to anything further” (Exhibit N).
7. Plaintiff’s prior accounts were terminated by the platform in July 2025, after which his
current account became primary, with a normal badge accumulation (Exhibits R, K).
8. Plaintiff filed a misconduct complaint concerning spoookdan, the direct subordinate of
Azap634, before the screening was failed (Answer ¶73; Exhibit I). Three days later
Azap634 generated a badge-tracking report on Plaintiff’s account (Exhibits J, K), and
Azap634 approved the adverse result (Exhibit L).
9. The Defendants told the State Auditor the review “remained under consideration,” and
then finalized the denial (Answer ¶¶42, 46).
10. RDOT evaluated the identical alternate-account question and reached a different
conclusion (Answer ¶44; Exhibit AA).
IV. ARGUMENT
A. COUNT I - FAILURE TO SPECIFY THE REASONING (Section 122.404).
11. Section 122.404 provides that 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,” and that it may meet this duty “by publishing their
reasoning on an application results tracker.” The Defendants admits the statute requires
this (Answer ¶¶50-51) and admit the notice identified only the criterion (Answer ¶26). A
criterion is not a reason; a citation to the rule under which one is judged does not state the
reasoning for the judgment. Judgment should enter on Count I.
B. COUNT II - NO CLEAR REASON; RIGHT TO REQUEST INFORMATION
12. Section 122.308 requires that an applicant found to lack the criteria “shall be notified of
the reasons for the determination,” and Section 123.501(c)-(d) secures to all persons a
“clear and defined reason” and the “right to request information pertaining to the reason”
for a denial. The Defendants admit these statutes (Answer ¶¶57-58). The notice gave only
the criterion (Answer ¶26), and the factors were withheld even when Plaintiff pressed for
them (Exhibits H, F, G). Judgment should enter on Count II.
C. COUNT III - BIASED AND CONFLICTED REVIEW (Section 123.501(b), 121.001(b)
and (g)).
13. Section 123.501(b) secures to all persons the right to be free from a biased review, and
Section 121.001(b) entitles applicants to fair and equitable treatment with proper regard
for their constitutional rights. The Defendants admit applicants are entitled to an unbiased
review (Answer ¶62) and admit the governing premise that “reviews conducted by
conflicted officers with personal stakes in outcomes are biased reviews” (Answer ¶65).
They admit Azap634’s positions (Answer ¶7) and admit Plaintiff filed a misconduct
complaint against Azap634’s subordinate (Answer ¶73), and the record shows Azap634
approved the adverse result (Exhibit L). The admitted premise, applied to the admitted
facts, yields a biased review as a matter of law. Judgment should be entered on Count III.
D. COUNT IV - ARBITRARY ACTION AND FAILURE OF DUE OBSERVANCE
(Section 141.001; Section 123.401-123.402).
14. An administrative claim asserts that an action was “arbitrary or without due observance
of state statute” (Section 141.101). Both prongs are satisfied, and either is independently
sufficient. The denial was without due observance of state statute because it was carried
out in violation of Sections 122.404, 122.308, 123.501, and 121.103, as set forth above. It
was independently arbitrary because it rested on no disclosed factual basis (Answer ¶26),
ignored documented exculpatory evidence (Exhibits F, R, K), and reached the opposite
result from RDOT on the same account (Answer ¶44). The Defendants further admit they
represented to the State Auditor that the matter “remained under consideration” and then
finalized the denial without further review (Answer ¶¶42, 46), which is the signature of a
pretextual process. Judgment should enter on Count IV.
E. COUNT V - RETALIATION (Sections 123.501(f) and (i); 121.001(h)).
15. Section 123.501(i) secures to all persons the right to report misconduct. The Defendants
admit the retaliation protections exist (Answer ¶72) and admit Plaintiff filed the
misconduct complaint (Answer ¶73). Within three days, the officer Plaintiff reported
through generated a badge report on his account and approved the adverse result, and the
denial was finalized (Exhibits J, K, L; Exhibit D). The close proximity in time and the
identity of the actor establish retaliation. Judgment should enter on Count V.
F. COUNT VI - FAILURE OF EVALUATIVE TRANSPARENCY (Section 121.103).
16. Section 121.103 requires that during the vacancy process of the appointing authority
“shall indicate all attributes of merit and demerit.” The Defendants admit the statute
(Answer ¶77). RCSO identified no factor, and Azap634 admitted “all but about two
factors were deemed indicative” while naming none (Exhibit H). Judgment should enter
on Count VI.
G. COUNT VII - UNLAWFUL INTERNAL POLICY (Section 141.007, 141.010).
17. This Court holds original jurisdiction over “all matters involving the internal policy or
rules of a civil service agency” (Section 141.007); that jurisdiction does not depend on
Plaintiff’s status as an employee. The Defendants admit the statutes (Answer ¶82). The
admitted record establishes a practice of denying applicants on a bare criterion, without
reasoning, through conflicted review, and finalized after a representation that the matter
remained under review. Under Section 141.010 this Court may grant equitable relief to
ensure the proper enforcement of law. Judgment should enter on Count VII, with a
permanent injunction.
H. COUNT VIII - DECLARATORY RELIEF (Section 141.011; Const. Art. I, Sec. I; Art. V,
Sec. I).
18. An actual controversy exists (Answer ¶85), and the constitutional provisions are admitted
(Answer ¶86). Article I, Section I guarantees a certain remedy and that every person
obtain right and justice completely and without any denial, and Article V, Section I
commands that justice be administered without unnecessary delay. Section 141.011
empowers this Court to declare the rights of the parties. Judgment should enter on Count
VIII.
V. THE AFFIRMATIVE DEFENSES FAIL
19. Failure to state a claim. By answering and admitting the controlling duties (Answer ¶¶50,
62) and the operative facts, the Defendants have themselves established that a claim
exists.
20. No violation. The admitted facts establish each violation as a matter of law, as shown
above.
21. Discretion. The duties to specify reasoning (Answer ¶50) and to provide an unbiased
review (Answer ¶62) are mandatory. Discretion over the ultimate appointment does not
license a denial that disregards those duties or that is arbitrary or retaliatory.
22. No causation. Causation rests on admitted facts: the misconduct complaint (Answer ¶73),
the badge report pulled three days later by the same officer, and his approval of the denial
(Exhibits J, K, L). A bare denial does not raise a genuine dispute on this admitted
timeline.
23. No bias, conflict, retaliation, arbitrariness, or bad faith. The Defendants admitted the
controlling premise that a conflicted officer’s review is biased (Answer ¶65) and admitted
the facts that establish the conflict (Answer ¶¶7, 73; Exhibit L).
24. Good faith. Good faith is no defense to the breach of a mandatory duty, and the admitted
representation that the matter remained under review followed by finalization (Answer
¶¶42, 46) is inconsistent with good faith.
VI. RELIEF
25. WHEREFORE, Plaintiff requests that the Court grant summary judgment and order:
A. A DECLARATION that the denial violated 4 R. Stat. Sections 122.404, 122.308,
123.501(b), (c), (d), (f), and (i), 121.001(b) and (h), 121.103, and 141.101;
B. AN ORDER vacating the finalization of Plaintiff’s application;
C. AN ORDER restoring the application to active status and, the sole stated basis
having been refuted on the same evidence on which RDOT reversed, directing the
Defendants to advance Plaintiff through the remaining phases and, pursuant to 4
R. Stat. Section 401, to confer conditional-employee (Cadet) status conditioned
on Plaintiff’s completion of the required training program or academy, after which
probationary status shall be conferred as the statute directs, absent a lawful,
specified, and non-pretextual basis established through a conflict-free Criminal
Investigations Division detective with written specification of the reasoning;
D. AN ORDER, as an equitable restraint and not as a separation or removal of any
civil servant within the meaning of 4 R. Stat. Section 141.012, restraining
Defendants Azap634 and errcore from any participation in, supervision of, or
influence over any screening, background investigation, internal affairs, or review
function concerning Plaintiff, in this or any future Ridgeway agency;
E. A PERMANENT INJUNCTION restraining RCSO from denying applicants
without specification of reasoning, without consideration of exculpatory evidence,
or through conflicted review;
F. COURT COSTS to the extent permitted by 4 R. Stat. Section 306; and
G. SUCH FURTHER equitable relief as is just and proper.
Plaintiff seeks no monetary damages.
VII. CONCLUSION
26. The Defendants admitted the duties, admitted the operative facts, and admitted that a
conflicted officer’s review is biased. What remains are denials of legal characterizations
that the admitted facts compel. There is no material fact to try. Plaintiff respectfully
requests summary judgment on all counts and the relief set forth above.
Respectfully Submitted,
_________________________
/s/ Halo4asin
HALO4ASIN
Plaintiff, Pro Se
Ridgeway State Bar License No. 18110
CERTIFICATE OF SERVICE
I, Halo4asin, certified that on the 5th day of June, 2026, I served a true and correct copy of the
foregoing Motion for Summary Judgment upon dev_Typ, Office of the Solicitor General,
counsel for Defendants, by electronic means pursuant to 7 R. Stat. Section 131.103.
_________________________
/s/ Halo4asin
HALO4ASIN
Plaintiff, Pro Se
Ridgeway State Bar License No. 18110
