STATE OF RIDGEWAY
RIDGEWAYFARMING_ALT )
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DOCKET NO. RSC-CV-339
Presiding Judge. zac2524
Plaintiff
v.
YOUFOUNDSEAL
Defendant
STATE’S MOTION TO INTERVENE AS A DEFENDANT
The State of Ridgeway moves to intervene as a defendant in the above-mentioned civil
suit.
INTRODUCTION
Per the Plaintiff’s civil suit, the allegations lined up against the Defendant are both
invalid and arbitrary in nature. The Plaintiff rests upon the notion that the actions that the
Defendant committed were somehow unlawful. We disagree. The State has a substantial interest
in the outcome of this case and therefore, we motion to intervene as a defendant in this civil suit
to protect the interests of both the State, and to protect the interests of the People.
The State invokes the right to intervene in any civil case where the “government has a
substantial interest in the outcome of the suit.” See 1 R. Stat. § 223; see also Rid. Civil Claims
Act (2022)(2)(g). The interest must be substantial; however, this case further emboldens our
claim that we have a significant stake in the matter. We contend that our interest relies upon
three important principles which we will further explicate in this document: (1) the Good
Samaritan Act (2022) should be interpreted and applied properly in this case to protect the Good
Samaritans of our state from arbitrary lawsuits, (2) a criminal should not be able to sue someone
because they were complacent during the commission of a crime, and (3) one who enters a suit
of equity may not enter without clean hands.
ARGUMENT
I. THE GOOD SAMARITAN ACT MUST BE APPLIED CORRECTLY IN THE
LIGHT OF THESE CIRCUMSTANCES
The State has a compelling interest in seeing that the statute is interpreted and applied
properly as the legislators intended. Before us is a case where the Defendant was actively aiding
law enforcement officers on scene to prevent the Plaintiff from committing a crime. The
Defendant was well within his bounds to aid the law enforcement officers on scene pursuant to
Sec. (3)(c) of the Good Samaritan Act (2022) which states that “[i]ndividuals who, in good-faith,
assist an on-duty member of emergency service[s] in the prevention of a crime […] can not be
charged with a crime” (emphasis added). The Plaintiff alleges in his civil complaint that the
Defendant was “helping an officer in distress.” See Plaintiff’s Civil Complaint, at page 1. The
Plaintiff then alleges that he was “placed in[to] custody at the back of the trooper[‘s] vehicle,”
and that then the Defendant said the words “good samartin act [sic]” over voice chat. See
Plaintiff’s Civil Complaint, at page 1.
From the Plaintiff’s civil complaint, we can gather that the Plaintiff was either in the
commission or was about to enter and contribute to the commission of a crime but was
interrupted and stopped by a Good Samaritan, the Defendant in this case. Due to the actions of
the Defendant, the law enforcement officer on the scene was able to successfully apprehend the
individual. It is safe to conclude that the Plaintiff had no reason to enter his vehicle during the
short timespan witnessed in between the two events that the Plaintiff described. It is perfectly
probable that the Defendant exercised his abilities pursuant to the Good Samaritan Act (2022) to
properly aid in the “prevention of a crime.”
There are many reasons as to why this suit possesses such substantial interest for both the
People and the State. One of which would be the notion that the actions conducted by the
Defendant were even remotely close to being unlawful; the interest lies upon the necessity of
such an act to be correctly understood to protect our citizens and to promote assisting law
enforcement officers in situations where they would only benefit from the aid provided. This was
one of those exact situations. Neither trespassing (5 R. Stat. § 201) nor trover (5 R. Stat. § 213),
can pave the way for a proper cause of action demonstrated by the Plaintiff since the definitions
fail to reach the minimum threshold required for such torts to be alleged as well as the pivotal
point that highlights the differences exhibited by the actions of the Defendant when compared to
the definitions of the torts that were brought forward.
This is because both torts require at the very minimum that the Defendant committed
actions that were either “unlawful,” without a proper “lawful excuse,” or a general “lack of
justification.” The Good Samaritan Act (2022) is clear not only in the header of the statute which
stipulated that it was created to “offer legal protection in the form of exemption from lawsuits,
and liability, acting as a safeguard to those who help another in an emergency, life-threatening
situation.” It should also be noted that this cannot be misconstrued to limit these exceptions
solely for “life-threatening situations” because Sec. (3)(c) of the Good Samaritan Act (2022) is
unequivocally clear in its wording.
Because the State has properly expressed its interests, as well as the People’s, we move to
intervene as a Defendant in this lawsuit.
II. THE PLAINTIFF CANNOT AND SHOULD NOT BE ABLE TO SUE
SOMEONE BECAUSE THEY WERE COMPLACENT DURING THE
COMMISSION OF A CRIME
To properly expand upon not only the premier argument, but we also wish to delve into
the minimal background information passed upon via the Plaintiff’s Civil Complaint. The
Plaintiff makes an interesting mention of the behavior exhibited by the Defendant as they were
both presumably in a voice call together, perhaps in direct messages or even in a larger voice
channel, nonetheless, the Plaintiff mentions how the Defendant “laugh[ed] until the Plaintiff was
placed into custody.” See Plaintiff’s Civil Complaint, at page 1. It becomes evident not only
from the actions of the Defendant but also from the alleged behavior that he was complacent
during the commission of the crime. This is demonstrated by his direct assistance to on-scene
law enforcement officers.
III. ONE MAY NOT ENTER A CLAIM OF EQUITY WITHOUT CLEAN HANDS
After a general comprehension of all the past contentions contained within this document,
one can easily concluded that the Plaintiff was either involved in the commission of a crime or
was about to enter a commission of a crime with himself being a directly involved individual.
The long-recognized doctrine, ex turpi causa non oritur actio, or rather a unique legal maxim that
directly correlates with the situation. We are faced with a suit where the Plaintiff bringing forth
the suit has his hands soiled from actions that he conducted prior to bringing this suit forward.
The “clean hands” doctrine is one that has been recognized in the past and is one that is highly
relevant to the situation above as it directly ties and affixes itself to the statement of facts. There
is indeed a nexus in between the wrongful act of the Plaintiff, and the rights that he wishes to be
enforced upon the Defendant who reacted to the situation not only appropriately, but also
lawfully. If the Plaintiff executes an unlawful action, then he cannot justify a cause of action if
the tort he alleges against the Defendant occurred directly because of his illegal action. By
violating such a maxim, the Plaintiff cannot possibly receive any equitable, or monetary relief as
a result of this lawsuit. It must also be understood that the actions taken by the Plaintiff need not
have directly affected the Defendant in an adverse matter, but rather a societal impression. The
Plaintiff does not satisfy the necessity of maintaining clean hands prior to entering a claim of
equity, therefore, the State should be allowed to intervene in this matter as it attracts attention of
the State, whereas we have a substantial interest in intervening.
CONCLUSION
For the reasons above, and with the establishment of the substantial interest that is
necessary pursuant to 1 R. Stat. § 223, the State moves to intervene as a defendant in this suit.
TURNTABLE5000
Solicitor General
Department of Justice
Counsel of Record
Date: May 9th, 2022
