STATE OF RIDGEWAY
RIDGEWAYFARMING_ALT )
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DOCKET NO. RSC-CV-339
PRESIDING JUDGE. zac2524
Plaintiff
v.
YOUFOUNDSEAL
Defendant
MOTION TO DISMISS
The State of Ridgeway moves to dismiss the above-named 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. In the case before us, we are faced with a Plaintiff who seeks
relief, yet he himself, does not maintain clean hands prior to the entry of a suit. The rule of law
expressed in the maxim ex turpi causa, non oritur actio, wholeheartedly applies to this suit and all the
facts that surround it; the Plaintiff was evading from a law enforcement officer after numerous warnings
and refused to comply with the officer’s lawful demands. See Appendix A. The Plaintiff cannot expect
that he has a valid cause of action that arose solely due to an illegal action that he conducted. The
Plaintiff continued to evade from a law enforcement officer and attempted to enter the driver seat of his
vehicle to drive away on an opposite lane of the highway. It goes without saying that such an action
imperils the lives of all drivers who utilize not only that tunnel route, but also all those who decide to
follow the law by driving on the correct side of the road. Whereas pursuits often go at incredibly
hazardous speeds, the Defendant not only assisted an officer that day, but he also assisted and shielded
the public through his decision to prevent the Plaintiff from causing any more harm to society. The
prevention of such, ensures that the people of our state remain safe. The Defendant is protected by the
Rid. Good Samaritan Act (2022), thus rendering the Plaintiff’s torts to shreds; with the absence of a
valid tort, paving the way for a proper cause of action, the Plaintiff will indubitably fail to acquire the
relief he requested. To allow such a suit to continue would be a grave injustice, therefore, we move to
dismiss this suit for the undermentioned contentions.
ARGUMENT
I. THE GOOD SAMARITAN ACT SHIELDS THE DEFENDANT FROM LIABILITY
The Plaintiff alleges that the Defendant satisfies the elements that are required for one to be
found liable for both the torts of trespassing (1 R. Stat. § 201) and trover (1 R. Stat. § 213). The Plaintiff
is incorrect in this contention because the descriptions of both torts in their entirety, fail to affix any
liability onto the Defendant due to the protections that come with the Rid. Good Samaritan Act (2022).
There is a decent amount of pretext to both torts that the Plaintiff wishes to invoke in this
situation, that being both trespassing (1 R. Stat. § 201) and trover (1 R. Stat. § 213); to further specify
this pretext, we move on to introduce the language utilized by our codified statutes regarding these two
torts specifically. In order for someone to be liable for trespassing, one must “unlawfully enter[] the
land of another individual without lawful excuse […]” See 1 R. Stat. § 201; see also Rid. Civil Claims
Act (2022)(1)(a)(emphasis added). For someone to be liable for trover, one must “wrongfully take[]
another's personal property without legal reason or justification […]” See 1 R. Stat. § 213; see also
Rid. Civil Claims Act (2022)(1)(m)(emphasis added). With the definitions, and their respective words
emphasized, we move on to apply these definitions to the situation presented before us.
The Plaintiff was actively evading from an on-duty, uniformed law enforcement officer who
utilized voice commands to assert his demands. The uniformed law enforcement officer commanded the
Plaintiff to stop evading, and to comply with the officer’s orders. The Plaintiff refused and instead he
continued to evade the law enforcement officer by jumping through the various seats of his vehicle. The
Defendant realized that if the Plaintiff entered his vehicle, the officer on top of his vehicle would be put
into a state of danger, and any innocent bystander who chooses to pass through that tunnel would come
into a head-on collision with the Plaintiff if he were to have escaped the grasps of the law enforcement
officer. In the best interests of the people, and for the administration of justice, the Defendant rushed to
prevent the Plaintiff from putting more peoples’ lives at risk by entering the Plaintiff’s vehicle and
blocking him from using the vehicle to escape and put more people into a state of jeopardy.
The Rid. Good Samaritan Act (2022) was an act that was designed 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.” While we contend that “a prefatory clause does not limit or
expand the scope of the operative clause,” we intend to use the prefatory clause as a vehicle to clarify
any doubts that will arise from further claims asserted in this motion. See District of Columbia v. Heller,
554 US 570 (2008). The operative clause, in this case, refers to enforceable sections of the Rid. Good
Samaritan Act (2022), namely the third section. roughout the Rid. Good Samaritan Act (2022), the act
consistently asserts that individuals who follow through with any action protected in the act will be
shielded from criminal liability. However, we contend that the immunity from criminal liability levied
by the act stems to shield one from civil liability as well. We gather this because the statute is explicitly
clear when it 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” See Sec. (3)(c) of the Good
Samaritan Act (2022)(emphasis added). The Defendant would be otherwise liable if this section was not
implemented and added to the list of statutes promulgated by our legislature. However, this is not the
case in this situation as the Defendant is protected by this statute. This section explicitly grants
immunity from criminal liability so long as the individual acted in good-faith, and in this case, the
Defendant did act in good-faith as he successfully assisted the law enforcement officer throughout the
situation that unfolded. Therefore, we successfully established that the Defendant is immune from
criminal liability. Now, we return to the definitions previously specified in the abovementioned
paragraphs, and we recognize the language utilized by both torts. First, let us focus on the tort for
trespassing (1 R. Stat. § 201). The language stresses that one may not unlawfully enter another’s land
without a lawful excuse. In this case, the lawful excuse that was utilized to enter the Plaintiff’s vehicle
would be Sec. (3)(c) of the Rid. Good Samaritan Act (2022). It granted the Defendant the ability to aid a
law enforcement officer in the prevention of a crime as it stripped criminal liability from hanging over
the Defendant’s head so long as he acted in good faith. All the facts point in favor of the Defendant as he
not only acted in good faith, he also successfully helped the people of our state and the law enforcement
officer that day. With the elimination of criminal liability, nothing else attaches to the language of the
tort for trespassing, so it grants the lawful excuse that is required for one to not be liable for the tort. Due
to the Rid. Good Samaritan Act (2022), the Defendant is immune from being liable for the tort of
trespassing, and the tort should therefore be stricken. We then move to address the issue of the tort of
trover (1 R. Stat. § 213). The language of the statute emphasizes that for one to be found liable for the
tort of trover, one must have no legal reason or no justification for taking someone else’s property. The
Plaintiff is granted the legal reason implicitly to take the property of someone else’s property so long as
it was involved in the prevention of a crime. Because one is absolved from criminal liability if their
behavior is in line with the text of Sec. (3)(c) of the Rid. Good Samaritan Act (2022), they are also
absolved of civil liability and are immune from the tort of trover. This is because they are given a legal
reason implicitly to assist a law enforcement officer so long as it was in the prevention of a crime, or it
was used to mitigate the adverse effects that could occur for one’s failure to take proper action against
someone who intends to do harm to others. Therefore, the Defendant is also immune from the tort of
trover, and therefore the Plaintiff has no valid cause of action to pursue with this case. Without a valid
cause of action, this case cannot continue. This sort of immunity from civil liability that stems from
immunity from criminal liability is not a brand-new notion, rather it is one that has been specified and
clarified in the past before. For example, if one were to have shot another individual to defend
themselves, the person they shot cannot sue the individual defending themselves so long as it was
proportional and justifiable. See New Orleans & Northeastern R. Co. v. Jopes, 142 US 18 (1891)(“If the
injury was done by the defendant in justifiable self-defence [sic], he can neither be punished criminally
nor held responsible for damages in a civil action. Because the act was lawful, he is wholly relieved
from responsibility for its consequences.”) While this case may not directly involve the deployment of
lethal force, the holding is incredibly relevant as it involves a situation where one has utilized a
justification delegated to them from statutory authority. It directly ties in similar circumstances when
one compares the actions taken by the Defendant in this case. All his actions were lawful and protected
under the Rid. Good Samaritan Act (2022), and therefore, he should enjoy the same benefits. Therefore,
not only is the Defendant immune from criminal liability, but he is also immune from civil liability.
The people should not be in fear to aid their local law enforcement officers. To allow this case to
continue would not only cast doubt as to whether aiding an officer is worthwhile, it could freeze
bystanders from aiding a law enforcement officer especially in perilous situations. The people should be
free from the fear of both criminal liability and civil liability, so long as their behavior was conducted in
good-faith and was proportional. In this case the Defendant’s behavior demonstrated both outstandingly.
Therefore, this case cannot be allowed to go any further and should be dismissed at this stage to protect
the interests of both the people of the state, and the state itself.
II. A CAUSE OF ACTION CANNOT ARISE FROM A FOUL AND ILLEGAL ACT
The legal maxim, ex turpi causa non oritur actio, is not a brand-new maxim, rather it is an
exceedingly relevant one. In this case, this legal maxim fully applies to the situation at hand. A criminal
cannot expect to get their problems rectified if the injury that they sustained was directly because of
their own unlawful actions. The sole reason as to why the Defendant denied the Plaintiff access to his
vehicle, was because of the illegal actions that stemmed because of the Plaintiff’s choices. The Plaintiff
chose to continue evading from a law enforcement officer and attempted to evade in his vehicle onto the
opposite side of the road which not only puts the lives of other bystanders into jeopardy, but it also puts
the lives of the officers who are pursuing him into a state of jeopardy. The Defendant, lawfully and
pursuant to the Rid. Good Samaritan Act (2022) exercised his powers to assist a local law enforcement
officer in the prevention of a crime. As we contended in the prior argument, the Defendant is already
immune to all the torts brought forward by the Plaintiff. However, this argument shall serve to deny
relief to those who wish to plague our courts with suits against those who protect others in good faith
simply because the ill-will of the Plaintiff could not fully follow through. The maxim of ex turpi causa
non oritur actio applies fully in this situation, and as held in the past, “[n]o court will lend its aid to a
party who founds his claim for redress upon an illegal act,” and neither should this court. See THE"
FLORIDA", 101 US 37 (1879).
To add another claim to highlight the erroneous mistakes made in the Plaintiff’s contentions, we
would like to introduce a situation where the court would never grant favorable relief to the Plaintiff.
Under the logic of the Plaintiff, if a criminal was to drop a weapon that he purchased, and prior to
dropping it he killed five others in the area, as he attempts to pick it up another bystander (in this case, a
“Good Samaritan”) picks it up and refuses to hand it to the criminal. The criminal cannot sue the Good
Samaritan as the criminal fully intended to shoot another nearby individual with the very rifle. No court
would ever grant favor to the criminal, and this court should not be the first to do so.
This court should deny all relief that the Plaintiff has requested and should dismiss this case to
ensure that criminals cannot come to this court to bring forward a cause of action that arose directly
because of their illegal action. This should not be misconstrued into a statement that claims a criminal
should never be allowed to sue, rather, it should be read to prevent instances where a criminal can
instead file a suit to redress damages that directly stem from their decision to follow through with an
action that is not only blatantly illegal, but it also adversely affects another individual.
III. THE PLAINTIFF IS NO LONGER ELIGIBLE TO ACQUIRE THE RELIEF HE
REQUESTS
As of May 10th, 2022, the State intervened in this matter. The relief that the Plaintiff requested in
this matter, is solely limited to monetary damages; specifically punitive damages that amount to a total
of $1,400 in in-game currency. As soon as the State intervened in this matter as the State proved that it
had a substantial interest in the outcome of the case, the relief that the Plaintiff requested was swept of
the table. It can no longer be granted to the Plaintiff if the Defendant were to be found liable. Of course,
it has already been established that the Defendant is immune from liability in this scenario, it should also
be noted that as soon as the government has intervened into a case, monetary damages can no longer be
awarded. See 1 R. Stat. § 219; see also Rid. Civil Claims Act (2022)(2)(c)(“No monetary damage shall
be awarded in a case against the government, cases where the government is a party, or cases where the
government has intervened.”)(emphasis added). Because the government has intervened into this case,
monetary damages can no longer be awarded. Whereas monetary damages were the sole relief requested
by the Plaintiff, and because it can no longer be levied as a method of relief, this case cannot proceed.
See Uzuegbunam v. Preczewski, 141 S. Ct. 792 (2021)(“[I]f in the course of litigation a court finds that
it can no longer provide a plaintiff with any effectual relief, the case generally is moot.”); see also
Chafin v. Chafin, 568 US 165 (2013)(“ [A] case becomes moot only when it is impossible for a court to
grant any effectual relief whatever to the prevailing party.”)(internal quotations omitted)(quoting Knox
v. Service Employees, 567 U.S. 298, 307, 132 S.Ct. 2277, 2287, 183 L.Ed.2d 281). Therefore, because
the Defendant cannot acquire the requested relief, this matter should be dismissed.
CONCLUSION
For the reasons above, the State of Ridgeway moves to dismiss this suit.
TURNTABLE5000
Solicitor General
Department of Justice
Counsel of Record
Dated: May 13th, 2022
APPENDICES
APPENDIX A – Video of the Incident (https://www.youtube.com/watch?v=CrIrrYpiZF0)
