THE STATE OF RIDGEWAY
RIDGEWAY SUPERIOR COURT
HALO4ASIN,
-against-
RIDGEWAY COUNTY SHERIFF’S
OFFICE, errcore, and Azap634,
Defendants.
Case No. RSC-CV-1654
Presiding Judge: Arthur_Chen
dev_Typ, Ridgeway County Sheriff’s Office, errcore, Azap634, by and through the
Department of Justice, answers the civil complaint as follows:
INTRODUCTION
Summary judgment is appropriate only where no genuine dispute of material fact exists
and the moving party is entitled to judgment as a matter of law. The Court must view all
evidence and reasonable inferences in favor of the non-moving party. Because Defendants
dispute the material facts underlying Plaintiff's claims of bias, retaliation, conflict of interest,
arbitrariness, and statutory noncompliance, summary judgment must be denied.
RESPONSE
1. The plaintiff applied in a regular application process which, by law, would make him
eligible for conditional employment. Thus, the plaintiff’s notion that his application
would have guaranteed him full employment is false in nature—if accepted, his
application would have given him an opportunity to be a conditional employee and
undergo training as a cadet, pursuant to the law.
2. Plaintiff's motion improperly characterizes disputed facts as undisputed and asks the
Court to draw inferences in Plaintiff's favor. On summary judgment, where competing
reasonable inferences exist, judgment must be denied.
3. Plaintiff incorrectly characterizes the pleadings as admissions. Defendants specifically
identify the following genuine disputes of material fact:
a. whether the notice provided was legally sufficient;
b. whether any review was biased;
c. whether any officer possessed a conflict of interest;
d. whether retaliation occurred;
e. whether the application denial was arbitrary;
f. whether any statute was violated.
4. Section 122.404 requires publication of the reasoning. Defendants complied by
identifying the basis for the denial as failure to satisfy the background investigation
requirements under §122.402. The statute does not require disclosure of every
investigative factor, weight assigned to each factor, or internal deliberative process.
a. 4 R. Stat. §122.404(a) explicitly states, “A department or agency may meet this
requirement by publishing their reasoning on an application results tracker
accessible to the applicant.” As affirmed by the Plaintiff, the defense marked
their reasoning of denial on the tracker, thus, defense has met their requirements.
i. The Plaintiff affirms he knew the reasoning of his denial in his own
exhibits (Plaintiff’s Exhibits F, G, and J).
b. The plaintiff was also provided an appeal (Plaintiff’s Exhibit L , M , and N ).1 2 3
5. The Plaintiff improperly and falsely claims that he was subject to bias review, a claim
denied by the defense and not backed by the Plaintiff.
a. The defense explicitly affirms that no individuals who had say in the Plaintiff’s
application had or have any “personal states in [the] outcome”
b. Further:
i. filing a complaint against a subordinate does not automatically create a
conflict;
ii. no evidence exists that Azap634 had a personal interest;
iii. no evidence exists that Azap634 acted because of the complaint;
iv. no evidence exists that the outcome would have differed;
v. the complaint and the background determination are unrelated events;
vi. temporal proximity alone does not establish retaliation as a matter of law.
6. The Plaintiff's assertion that the approval of his background investigation by the
Ridgeway Department of Transportation upon appeal precludes any other department
from reaching a different suitability determination based on the same underlying facts is
without merit.
a. Different agencies have different hiring standards and different agencies exercise
independent discretion. RDOT's decision is irrelevant to whether Defense
complied with its own statutory obligations.
3 Show’s appeal
2Show’s Defense giving reasoning again and end result of appeal
1Shows appeal
7. Plaintiff improperly treats partial admissions and denials of legal conclusions as
admissions of liability. Defendants' Answer expressly denies bias, retaliation,
arbitrariness, conflict of interest, and all alleged statutory violations.
Genuine Issues of Material Fact Exist
8. The defense reiterates:
a. Defendants provided legally sufficient notice; and
b. the Plaintiff was not subject to biased review; and Azap634 did not possess a
conflict of interest just because of his position in another department; and
c. Plaintiff's misconduct complaint played zero role in the determination of his
background investigation; and
d. Defense's denial was not arbitrary; and
e. the Defendants acted in good faith.
f. the notice provided to Plaintiff contained sufficient reasoning under the
applicable statutes; and
g. the Plaintiff’s background check failure would have occurred regardless of
Plaintiff's complaint.
WHEREFORE, Defendants respectfully request that:
1. Plaintiff's Motion for Summary Judgement denied.
2. The Court grants such other and further relief as it deems just and proper.
DATED: Jun 9, 2026
Respectfully submitted,
dev_Typ, Esq.
OFFICE OF THE SOLICITOR
GENERAL
/s/ dev_Typ
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“Only two things are infinite, the universe and human stupidity, and I'm not sure about the
former”
