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 Plaintiff’s petition for writ of mandamus as follows:
INTRODUCTION
The defense fully reincorporates, reiterates, and exemplifies that there was no violation of
the plaintiff’s rights. In order for the court to grant a writ of mandamus, the constitution sets the
following requirements: (1) the petitioner must “demonstrate[] entitlement of relief”; (2) the
respondent needs to execute a clearly written duty; (3) the relief demonstrated alleviates
personal, not institutional injury; and (3) that the failure to execute that duty results in personal,
concrete, and particular injury. The defense will show that Plaintiff’s request does not meet these
requirements.
DEMONSTRATE ENTITLEMENT OF RELIEF
1. To demonstrate entitlement of relief means to demonstrate that there was a specific right
that was entitled to the petitioner that was violated. The Petitioner claims that his denial
bears unexplained reasoning while he claims at the same time that he was provided a
reason “alternate account.”
2. Ridgeway State law specifically lists “alternate account” as a reason for failure. There is
no requirement in the law for a department to provide lengths of evidence to support their
reasoning, rather, just to clarify which background check the applicant failed—in this
case, the alternate account portion. Further, if departments would be required to specify
exactly how they reach their determinations in background checks, this would serve a
major security risk, thus, the law specifically does not require such.
a. Reading, “it shall notify the applicant and specify the reasoning for the negative
result.” (4 R. Stat. §122.404), not requiring anythign more than a specification
which was met by providing the reason “alternate account”
3. For the reasons above, this prong requirement has failed.
FAILURE TO PERFORM — WAS PERFORMED
4. The Plaintiff misconstrues the meaning of the law to require full factors and reasoning.
As mentioned above, 4 R. Stat. §122.404 merely requires a reasoning, which the Plaintiff
himself affirms was given to him which was “4 R. Stat. Section 122.402(a)” —
“"whether factors indicate or suggest that the individual is an alternate account”
(emphasis).
5. The Plaintiff in his own response seems to think that the law requires full documentation
of reasoning for a background investigation failure. Both the letter and spirit of the law
merely require a brief reasoning, which was provided to the Plaintiff and acknowledged
by him.
THE DEFENSE DID THEIR DUTIES
6. Defense again denies that no reasoning was given to the Plaintiff for failure
7. The Plaintiff misapplies the requirement of transparency. The cited requirement for
transparency that the Plaintiff cites (4 R. Stat. §121.103) is meant for when a department
denies an application merely on its merits (reading, "all attributes of merit and demerit").
Either way, the Plaintiff himself states that a reason was provided to him which is
sufficient in accordance with the law.
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”
