IN THE SUPERIOR COURT OF RIDGEWAY
FOR THE STATE OF RIDGEWAY
HALO4ASIN,
Plaintiff,
v.
RIDGEWAY COUNTY SHERIFF’S
OFFICE,
Defendant.
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Case No. RSC-CV-5191
NOTICE
PLAINTIFF’S NOTICE OF SUPPLEMENTAL AUTHORITY
Plaintiff respectfully notifies the Court of supplemental authority bearing on the unresolved
questions of statutory interpretation identified in the Court’s Minute Order of July 12, 2026
denying summary judgment: the Order of the Attorney General, Disclosure of Investigative
Materials and Protection of Witnesses in Administrative Investigations (July 12, 2026) (the
“Order”), issued by Attorney General AdamStratton pursuant to Sections 602(c), 602(d), 606(a),
and 606(e) of the Judiciary Act of 2026. A copy of the Order accompanies this Notice.
The Order establishes uniform rules for administrative investigations conducted by or on behalf
of every law enforcement agency of the State. As relevant here, it provides that the subject of an
investigation shall receive a written summary of the allegations sufficient to permit a meaningful
response (Section IV); that “disclosure is the default” and the subject “shall be given access to
the investigative materials considered against the employee” (Section V(a)); that material may be
withheld only where disclosure would reveal the identity of a witness and subject to in camera
review by the presiding officer (Sections V(b), V(d)); and that even where material is withheld, a
redacted copy or a written summary of its substance must ordinarily still be provided (Section
V(c)). The Order states its animating principle expressly: “Procedural fairness to the subject and
the protection of witnesses are complementary obligations, not competing ones” (Section II).
Section VI further provides that retaliation against any person participating in an administrative
investigation is itself independent grounds for disciplinary action.
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The Court’s Minute Order identified as unresolved whether the notice duties of 4 R. Stat. §
Sections 122.308 and 122.404 are qualified where a challenged determination arises from a
background investigation implicating governmental security interests. The Order is the
considered judgment of the State’s chief legal officer, rendered in the more sensitive context of
active misconduct investigations where witness safety is directly at stake, that meaningful
disclosure to the subject and legitimate confidentiality interests coexist: disclosure is the default,
withholding is narrow, documented, and reviewable, and a summary sufficient to permit a
meaningful response is required even where material is withheld. A fortiori, specifying to an
applicant which statutory factors were deemed indicative of a negative background result, with
any genuinely sensitive detail summarized or withheld with documentation, is compatible with
any security interest an appointing authority may assert. The theory that Section 122.404’s
command to “specify the reasoning” must yield wholesale to undifferentiated security concerns
cannot be squared with the State’s own uniform policy.
Section VI of the Order likewise reflects the State’s recognition, consonant with 4 R. Stat.
Sections 123.501(f) and 123.501(i) and Section 121.001(h), that persons who provide
information in administrative investigations are to be protected from retaliation.
For completeness, Plaintiff does not contend that the Order applies retroactively to the events of
May 2026, nor that it directly regulates background investigations of applicants. It is submitted
as persuasive authority on the interpretive and policy questions the Court has identified for
resolution.
CERTIFICATE OF SERVICE: I certify that on this date a true copy of this Notice, together with
the accompanying Order of the Attorney General, was served on counsel for the Defendants by
electronic means through the case channel and e-filing system.
Respectfully Submitted,
_________________________
/s/ Halo4asin
HALO4ASIN
Plaintiff, Pro Se
Ridgeway State Bar License No. 18110
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