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
MOTION
PLAINTIFF’S MOTION FOR DISQUALIFICATION AND REASSIGNMENT UNDER
CANON 3C OF THE CODE OF JUDICIAL CONDUCT, OR, IN THE ALTERNATIVE,
FOR DISCLOSURE ON THE RECORD UNDER CANON 3D
COMES NOW the Plaintiff, Halo4asin, pro se, and respectfully moves for the disqualification of
the Hon. xXBoomblast339Xx from further proceedings in this matter and for reassignment to
another judicial officer, or, in the alternative, for full disclosure on the record pursuant to Canon
3D of the Ridgeway Code of Judicial Conduct. This motion rests on no ruling of this Court. It
rests on events occurring on or about July 15, 2026, and is raised promptly upon their
occurrence. In support, Plaintiff states as follows:
I. INTRODUCTION
1. Plaintiff has consistently maintained in this litigation, including when opposing counsel
sought recusal of the previously assigned judge on the basis of Plaintiff’s ministerial role
as a deputy clerk of this Court, that the ordinary overlap of community roles in Ridgeway
is not, standing alone, a ground for disqualification. Plaintiff maintains that position
today.
2. What has now occurred is categorically different. The presiding judicial officer has
executed a declaration for the government, offered as evidence against this same Plaintiff,
in separate pending litigation, Halo4asin v. Ridgeway Parks Service, Case No.
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RSC-CV-0750, in which the judicial officer serves as Chief Ranger of the defendant
agency, and which is defended by the same Office of the Solicitor General that appears
before him here. A judge who is an active adverse declarant against the litigant before
him, in a parallel case arising under the same statutory scheme he has been asked to
interpret, presents precisely the circumstances in which “the judge’s impartiality might
reasonably be questioned.” Canon 3C(1).
II. FACTS
3. Plaintiff is the plaintiff in Halo4asin v. Ridgeway Parks Service, Case No. RSC-CV-0750,
pending before the Hon. EffortlessBrit. That action challenges the Ridgeway Parks
Service’s denial of Plaintiff’s application under the background investigation criteria of 4
R. Stat. Section 122.402, the same statutory scheme at issue in this case.
4. The Hon. xXBoomblast339Xx serves as Chief Ranger of the Ridgeway Parks Service,
the defendant agency in RSC-CV-0750.
5. On or about July 15, 2026, the government filed, in support of its opposition to Plaintiff’s
motion for summary judgment in RSC-CV-0750, a declaration executed by the Hon.
xXBoomblast339Xx in his capacity as Chief Ranger (the “Chief Ranger Declaration,”
Exhibit 1). Among other things, the Chief Ranger Declaration attests that on June 21,
2026 the declarant personally requested and received the specific instances of adverse
action underlying every applicant failed under 4 R. Stat. Section 122.402(f), including
Plaintiff’s. Chief Ranger Decl. paragraphs 3-4, 6.
6. The defense of RSC-CV-0750 is conducted by the Ridgeway Department of Justice,
Office of the Solicitor General; on July 13, 2026, dev_Typ filed a notice of appearance in
that matter expressly on behalf of the Office of the Solicitor General (Exhibit 2). The
same Office of the Solicitor General is defense counsel of record in this case, where
dev_Typ previously appeared and Solicitor General Hecxtro now appears (Exhibit 3).
7. The questions presently submitted for decision in this case include the interpretation of
the notice duties of 4 R. Stat. Sections 122.308 and 122.404 as they apply to denials
under the Section 122.402 criteria, the same duties that govern the denial challenged in
RSC-CV-0750. The standard this Court announces here will bear directly on the defense
of the declarant’s own agency, against the same plaintiff, in the parallel case.
8. The Chief Ranger Declaration was filed approximately three days after this Court’s
Minute Order of July 12, 2026. This motion accordingly could not have been raised
earlier, and Plaintiff raises it within days of the event.
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III. LEGAL STANDARD
9. Canon 3C(1) of the Ridgeway Code of Judicial Conduct provides that a judge shall
disqualify himself in a proceeding in which the judge’s impartiality might reasonably be
questioned, including but not limited to instances of personal bias or prejudice
concerning a party or personal knowledge of disputed evidentiary facts, prior
involvement as a material witness, or an interest that could be substantially affected by
the outcome of the proceeding. The enumerated instances are illustrative; the governing
standard is the appearance of partiality to a reasonable observer.
10. Canon 3D provides that, instead of withdrawing, a judge disqualified under Canon 3C(1)
may in appropriate circumstances disclose on the record the basis of the disqualification,
and may continue to participate only if the parties, after disclosure and without the
judge’s participation in their deliberation, agree.
IV. ARGUMENT
A. The Court is an active adverse participant in litigation against the Plaintiff before it.
That is not role overlap.
11. Holding a community role, even a senior role in a government agency, is common in
Ridgeway and is not by itself disqualifying. Plaintiff has said so on this record and does
not retreat from it. But executing a declaration for the government, offered as evidence
against the very party appearing before the Court, in an active case, is participation in the
adversary process on the government’s side. A reasonable observer, knowing that the
judge deciding Plaintiff’s claims against one arm of the government against the same
person, would reasonably question whether the scales sit even. That is the Canon 3C(1)
standard, and it is met.
B. The question submitted in this case will govern the defense of the Court’s own
agency in the parallel case.
12. Both cases arise under the same statutory scheme: application denials under the Section
122.402 background investigation criteria and the notice duties attending them. The
central legal question now submitted here, what Sections 122.308 and 122.404 require an
agency to disclose about such a denial, is the same question that will confront the
Ridgeway Parks Service in RSC-CV-0750, where the declaration of its Chief Ranger
describes his personal handling of the adverse action files underlying Section 122.402(f)
denials. The Court is, in practical effect, being asked to announce the legal standard that
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will govern its own agency’s defense against this same plaintiff. A institutional interest
that could be substantially affected by the outcome falls squarely within the concerns of
Canon 3C(1).
C. The same Office of the Solicitor General litigates both cases.
13. The Office of the Solicitor General defends this case and RSC-CV-0750 alike, with at
least one attorney, dev_Typ, having appeared in both. The Court is therefore
simultaneously assisting the litigation effort of the same office that argues before it here,
furnishing evidence to that office in one case while adjudicating its arguments in the
other. Whatever the Court’s actual impartiality, the appearance created by that dual
posture is what Canon 3C(1) exists to avoid.
D. This motion is prompt, and it rests on no ruling of this Court.
14. Plaintiff does not ground this motion in any order entered in this case, and expressly
disclaims reliance on the Minute Order of July 12, 2026; adverse rulings are not evidence
of partiality. The event on which this motion rests, the filing of the Chief Ranger
Declaration, occurred on or about July 15, 2026, after that Order, and Plaintiff raises the
matter within days. No waiver or delay can be attributed to Plaintiff.
V. RELIEF REQUESTED
15. Plaintiff respectfully requests that the Court disqualify itself from further proceedings in
this matter and that the case be reassigned to another judicial officer. Reassignment
imposes minimal cost: the matter stands submitted on a complete written record, the
briefing, the State’s sworn production of the screening factors, and the memoranda of
law, which a successor judge may decide on the papers as this Court intended.
16. In the alternative, Plaintiff requests that the Court make full disclosure on the record,
pursuant to Canon 3D, of the nature and extent of its role in Halo4asin v. Ridgeway Parks
Service, RSC-CV-0750, including the circumstances of the Chief Ranger Declaration and
any coordination with the Office of the Solicitor General, so that the parties may consider
remittal in the manner Canon 3D provides.
17. This motion seeks no disturbance of any prior ruling of this Court, and Plaintiff reserves
all rights with respect thereto. Should the Court conclude that disqualification is not
required, Plaintiff respectfully requests that the basis for that conclusion be stated on the
record.
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CERTIFICATE OF SERVICE
I certify that on this date a true copy of this Motion, with exhibits, 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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