THE STATE OF RIDGEWAY
RIDGEWAY SUPERIOR COURT
DANNLABS,
-against-
STANLEY_LABSON,
Defendant.
Case No. RSC-CV-421
RESPONSE TO MOTION TO DISMISS
Presiding Judge: Hecxtro
RESPONSE
In response to the motion to dismiss from the defence, I strongly urge the courts to deny this
motion, as I can prove there is infact a very valid cause for action in this case.
To begin on the defence’s first point on being unable to prove there was intentional deception
to secure gain, to which end I would like to refer back to the evidence submitted in the original
complaint, showing a billboard made by Mr. Labson intentionally misrepresenting fact, and
while the gains from this act are not monetary or political, it does give Mr. Labson an advantage
over me in the eyes of the public for perhaps “exposing me.” The defence then tries to dismiss
this charge on the ground of free speech, however as has been made clear multiple times by the
Supreme Court, such as in Gerts V. Robert Welch Inc. (1974) that “There is no constitutional
value in false statements of fact.”, to which end, the plaintiffs billboards clearly try and
misrepresent the fact at hand by stating in large, bold lettering “FACT” at the head of them. The
defence then also attempts to plainly interpret section X of the ridgeway constitution, trying to
assert that simply because this case arises from a misuse of free speech, it should not be allowed
to persist.
On the second point the defence raises that because of my position on the bench, I should not
be allowed to bring this case against the plaintiff, alleging that my actions are unethical..
However, I am just as entitled to seek Justice for wrongs committed against me as any other
person in this state, and to assert something as frivolous as that is in poor taste. And while yes,
the constitution is in fact the founding basis for many things in our country (and state), its word
is not law. That is the responsibility of the senate to make statutes. Referring to Bauer v. Acheson
(1952) states simply “The liberty granted by the constitution is not absolute.”, and that
“…Liberty itself would be lost in the excesses of unrestrained abuses.” The sentiments applied
by Bauer must be applied here as well in the interests of the public welfare. The defence also
implies that this lawsuit is on the basis of a constitutional issue regarding free speech, which is
again, simply false. The defence then brings up how this advertisement came to be, a ruling I had
made Lx1nas v. State (2022), where I declared the restrictions and hunting of “Furries” to be
unconstitutional. While I have faced my fair share of criticisms and the like, I have never thought
to challenge persons on the basis of their opinions, and have stated such in my previous rulings
that one’s opinion on a matter is not slander nor libel (see BattalionGavin v. SecretiveRBLX,
2022) However, this is not a case of opinion, it is one of plainly misrepresented facts, causing
harm to my reputation and career as a judge.
With the following facts and references in mind, I urge the court again to dismiss this motion, or
at least only grant it partially. This is not a case about the right to free speech, nor politics, nor
grandstanding. It is as simple as the harm done by the plaintiffs' false statements against myself,
and my career as a Judge of the Superior Court. I hope my sentiment is clear that I do not bring
cases against people for fun or because I’m upset, it is to hopefully set a precedent that will keep
other members of the state, private or public office, safe from blatantly false statements.
DATED: June 9th, 2022
Respectfully submitted,
Dannlabs
Plaintiff
/s/ Dannlabs