RIDGEWAY SUPERIOR COURT
PRIMAQUORUM,
Plaintiff,
v.
RIDGEWAY DEPARTMENT OF
STATE; ISAYUH, in their official
capacity as Secretary of State,
Defendant.
Case No.
CIVIL COMPLAINT
PLAINTIFF, PrimaQuorom for his complaint against the Ridgeway Department of State, et al.,
alleges:
INTRODUCTION
1. When the government doesn’t do its job the people unequivocally suffer.
2. For 7 months, the Department of State has abandoned its most basic statutory
responsibilities and in doing so, it has betrayed the People of this State, and thwarted
their progression towards a common good. The impacts of the State Department’s cogent
lack of performance are ubiquitous and single handedly impede on the State’s collective
ability to move forward. The State’s consistent decline in activity, functionality, and hope
are in large part due to the pitfalls of the Department of State.
3. The obligation of the executive to be faithful to the people is the bedrock principle of our
democracy. When that value is disturbed, the walls of our institutions cave in. And what
was once the citadel of hope and opportunity is now another testament to broken
promises. Our State is in ruins.
4. Plaintiff brings this suit to remedy the gravest threat to the survival of our
government—abandonment. Each moment that the Department of State fails to do its job,
our State grows more inactive, less transparent, less accountable, and less likely to live to
see the election of another Secretary. The necessity for meaningful relief has never been
more urgent. The continuity of this State hangs in the balance of this case and is reliant
on the even-handed judgement of this court in Plaintiff’s favor.
PARTIES
5. PrimaQuorum is a Resident of the State of Ridgeway who resides in Ridgeway County.
6. The Ridgeway Department of State is a State Agency of the State of Ridgeway.
7. Isayuh is sued in his official capacity as elected Secretary of State.
JURISDICTION
8. This court has original jurisdiction to hear “all civil ... cases or controversies.” Ridgeway
State Constitution Article V, Section IV.
9. This court, as well, may issue “all writs necessary or appropriate in aid of [its] …
jurisdiction.” Rid. Judiciary Act, Section 2.2(a).
FACTS
10. The Ridgeway Department of State (DOS) became fully operational on or around March
29th, 2022.
11. Since its inception, it has hired a number of employees to manage and maintain its
various responsibilities.
12. As it stands, the Ridgeway Department of State has 14 staff members. It has consistently
maintained on or around this number of employees which is a sufficient number of
people to minimally cover its statutory goals.
13. They frequently open up applications to hire more individuals, and just recently began
hiring into leadership roles.
14. DOS has had two elected Secretaries, both elected in profoundly close and contentious
races.
15. The first was ibm03, and the second, who is currently the Secretary is Isayuh.
16. In addition to his role as the Secretary of State, Isayuh is also the director of the Law
Enforcement Training Center.
17. Since its founding, DOS has systematically fallen reprehensibly short of its statutory
responsibilities.
I. The Ibm03 Administration.
18. Ibm03 was elected into office on March 27, 2022.
19. Ibm03 appointed a Deputy Secretary of State on March 30, 2022.
20. Throughout the course of his administration, Ibm03 was profoundly inactive and failed to
deliver on his statutory obligations to effectively manage the Department of State.
21. On April 17, 2022, May 14, 2022, May 18th, 2022, and June 11th, 2022 Secretary Ibm03
announced leaves of absence for varying ranges of time.
22. Ibm03’s Deputy Secretary, NOJOEPG announced various leaves of absence for different
ranges of time on April 10, 2022.
23. Secretary Ibm03 also announced periods of limited availability on May 5th, 2022, May
9th, 2022, and June 11th, 2022.
24. On a number of occasions, the Secretary announced that applications specifically for the
commerce division would be open, but they consistently were delayed over periods of
days and the Secretary's only response was “soon.”
25. The Ibm03 administration ended on July 25th, 2022 when Isayuh was elected to become
the next Secretary of State.
II. Change in Administration; Continuity in Stagnation.
26. Despite the administration changes, the status quo has remained, and the Department of
State is still plagued with inactivity through and through.
27. The Department of State continues to perform poorly in polls of public interest both
before and after the administration changes as a direct consequence of its consistent
failure to deliver on its statutory jobs. Almost 2/3rds of those polled do not approve of the
Department of State.
28. The Senate sought to provide for the common good and to allow the State to
progressively move closer and closer to achieving it when it created the responsibilities
for the Department of State.
29. The Senate recognized the integral function of a reliable Department of State in our
society and established the agency as a vehicle to protect that vital interest.
30. The Department of State’s stagnate disposition harms the State at-large both affirmatively
in failing to protect the interest that the Senate sought to buttress and passively by
hindering the State from moving forward toward achieving a greater common good.
31. In this way, the allegations that follow are concrete harms that manifest as a direct result
of the State Department’s woeful lack of activity.
A. The State Register.
32. The Department of State has the legal responsibility of admitting “all policies and
regulations of all departments” to the State Register which shall be “publish[ed] openly.”
State Administration Act, § 4.2(a-c)
33. DOS during this time period did create a state register but it only housed the department
policies for the Ridgeway State Police and no other department.
34. The DOS did have access to all of the department handbooks. On a number of occasions,
the Department of Justice even sent department handbooks and other state regulations
that needed to be archived in the State Register.
35. The Senate’s clear interest in maintaining “open,” Id., records so that the government is
transparent and intrinsically accountable to the people has been flouted by the
Department of State’s dereliction of duties.
36. The DOS’ clear failure to follow the law prevents citizens from holding law enforcement
officers accountable to their own policies because it precludes private citizens from
knowing the administrative parameters of an officer’s conduct. This is a necessary
function, but often goes completely unseen causing a reprehensible amount of police
violence and abuse throughout our State.
37. Citizens also can’t hold departments accountable for bad policy decisions when they
don’t have access to policies.
38. If there exists a policy on the books that officers regularly enforce that leads to an
impediation of someone’s rights, citizens are incapable of having their day in court to
challenge that policy because it is not available to them. Potential litigants are not able to
know if a policy is the reason they are being harmed if they can’t see the policies in the
first place.
39. Additionally, the publication of policies gives departments the ability to build off of each
other to create better policy mechanisms and rules for their officers by giving agencies
the ability to gain full and complete understanding of what other rule structures are
effective.
40. Despite having all of the materials readily available to them, the Department of State
failed to archive any regulations, policies, or otherwise with the exception of the
Ridgeway State Police policies.
B. The State Reporter
41. The Department of State is duty bound to enter Administrative court decisions, Supreme
Court decisions, cases where the Supreme Court has granted review, records of trials in
the Superior Court, and all orders of the Superior Court into the State Reporter. See State
Administration Act § 4.3.
42. The DOS has not entered any records into the State reporter and have thus far completely
failed to adhere to this statutory obligation.
43. The Ridgeway State Courts have been forced to so far keep their own records, and are in
the process of actively compiling the records so that they may publish their own bound
volume to make up for the DOS’s hands-off approach to following the law.
44. The State Courts currently face difficulties maintaining activity.
45. Forcing the State Courts to allocate resources to record keeping to fill in the gaps that
DOS has left forces the State Courts to distribute already limited resources away from
where they are needed most.
46. Improper archival of cases and the transcripts and records associated with them limits the
ability for them to be easily accessed and referenced as case-law in pending cases—an
exercise that is integral to the efficient litigation and proper disposition of cases before
the Superior Court.
47. Additionally, streamlined case archival enables uniform case citations which increases
communication and decreases confusion in courtrooms and conversations alike.
48. The State Courts lack active legal counsel largely because there are simply too few of
them.
49. The accessibility of legal research and documents hinders the ability of the State to obtain
lawyers.
50. Plaintiff here struggled to take the Bar exam because they found it difficult to access the
necessary legal documents and cases that articulate important legal points.
51. Cases that are not decided correctly or not decided efficiently denigrate the principle of
Justice in our State.
52. This has manifested over the past couple of weeks as criminal trials have slowed, and
criminal case filing has dwindled.
53. This has increased the number of offenders on the streets and decreased the rate of
criminals going to jail.
54. More criminals that are able to operate unchecked in our country contribute to an increase
of law and order throughout the State at-large.
55. The availability of transcripts on the public record also enables citizens to hold
prosecutors accountable—a well-established principle of criminal prosecution.
56. The State has introduced a number of high-profile criminal cases in recent months, at
least one of them was sealed.
57. The availability of these records is a necessity to keep criminal prosecutors in check.
C. Miscellaneous Archives and Codification
58. The Department of State has the responsibility of “codify[ing] all laws…upon their
passage.” State Administration Act, §4.1(a).
59. DOS had codified all of the original inaugural laws, but once Isayuh was elected, they
were deleted.
60. DOS has never codified any laws other than the inaugural ones.
61. Currently, there is a new set of codified laws which only account for about a third of the
inaugural laws.
62. There was a point for about 2 weeks where both the new codification of the laws, and the
old codification existed at the same time and they both had different citations for the
same language.
63. Currently, there are 33 acts passed by the State Senate that have not been codified.
64. The lack of codification denigrates accessibility of the law to the citizens of the State
which harms their ability to do everything from pass bar exams, to hold their Senators
accountable, to ensure they are following the law, to ensure that they’re treated within the
bounds of the law, to general awareness about how the State is supposed to operate.
65. Codification also provides uniformity in citations which increase communication and
efficiency in our courts and all things law-adjacent.
66. The Senate has been forced to keep record of their own laws which not only makes them
more susceptible to abuse or instability or clerical errors, but it also forces the Senate to
allocate resources away from doing the purpose it truly exists for—making laws.
67. If laws are codified properly, or there isn’t a record of them, it thwarts the will of the
People because the laws they passed are not carried out, or on record.
68. When the People’s wishes in a democracy aren’t carried out, or when laws aren’t properly
kept in safe records, it stands to put the legitimacy of the entire democratic State at risk.
69. A lack of codification has led to confusion in the courts when it comes to citing laws,
harming their efficiency and efficacy.
70. Additionally the DOS is responsible for archiving all oaths of elected officials, treaties,
journals of legislative meetings, dishonorable discharges, those who have been convicted
in a court of law, and a backup of all trellos, documents, and relevant information. See
State Administration Act, § 4.4(a).
71. The legitimacy of the entire State government hinges upon proper record keeping because
without a viable record, or proof, our government does not exist.
72. The Senate has been forced to keep track and record of its own legislative meetings.
73. Dishonorable discharges and convictions have gone completely unrecorded except by the
courts which makes it difficult for State agencies to vet people easily for previous
misconduct.
74. And indeed, a backup of our trellos is profoundly important because in the event that they
are deleted, the State has no other recourse but to start anew.
75. If the DOS had existed and maintained a copy of the State trellos and documents, the
long lasting effects of admin abuse by Paul in the County Government would have been
minimalized, and would have kept the Government afloat in the meantime between the
transition from County to State governance. Instead, we failed. Now, the State’s most
critical documents are protected only by prayers and trust.
D. State Publications
76. The Department of State is responsible for video media, the publication of newsletters,
newsfeeds and advertisements. See State Administration Act § 5.
77. Media is integral to the functionality of a democracy in this State because it allows for
full governmental transparency and for full governmental accountability.
78. The lack of news coverage, publications, or transparency as a sole consequence of the
State Department's inadequacy has harmed politics and government in this State by
taking issues out of the hands of the people.
79. Political corruption, criminal prosecutions, court inactivity, major policy developments,
and scandal have all gone unreported by the DOS. The result is a sorry State of affairs for
our government.
80. As a consequence of the lack of State Publications, politics in our State are stagnant.
People don’t know who to vote for, what policies are moving through the legislature, nor
how systems of government are operating fully. All of this hinders the ability of the
People to vote consciously, or protest, or write to their representatives. Long term, this
means the State has not progressed at a meaningful pace—or at any pace for that
matter—all as a result of the Department of State’s failure to do its job.
81. The Department of State’s failure to adhere to this obligation has materially affected the
course of each election subsequent to the DOS’ founding which has harmed the
representation of people and their ideas in our government.
82. When the State doesn’t progress forward, and only continues to spiral towards inactivity
and unproductivity, the Citizens, including Plaintiff here, suffer because their basic needs
in our system of government are not being met, nor are the Constitutional promises to a
good governance being kept.
E. Commerce
83. The Department of State is responsible for managing the State’s commerce. This is the
only statutory responsibility they have taken seriously. They still, however, fall
completely short.
84. Not only is the DOS responsible for approving business operations, but they are also
responsible for maintaining them.
85. The DOS has a statutory obligation to check up on the activity of businesses currently
operational in the State. See State Administration Act § 2.2(a).
86. The Department of State’s failure to maintain the activity of businesses has stagnated the
State economy and prevented the opportunity for citizens to obtain jobs, or services that
they need.
F. Foreign Affairs
87. The Department of State is the principal agency responsible for managing the relationship
between the State of Ridgeway and foreign States. See State Administration Act § 3
88. The Department of State has made no meaningful progress in establishing firm
relationships with other State’s.
89. In their failure to deliver on this statutory obligation, Plaintiff here is prevented from
having the opportunity to experience the implications of a global society.
90. Tourists are less likely, job opportunities over State borders are non-existent, and indeed,
inter-governmental multilateralism does not exist.
91. The lack of foreign affairs contributes to this State’s inactivity and downward sloping
politics.
FIRST CAUSE OF ACTION
(1 R. Stat. § 314 Official Misconduct)
92. The allegations included in this complaint thus far are incorporated as reference as if fully
set forth in this cause of action.
93. Isayuh, as the Secretary of State, has a legal requirement to ensure the statutory
obligations placed upon the Department of State are met.
94. Isayuh, as the Secretary of the Department of State, has failed to manage his agency so
that it adheres to the clear statutory roles assigned to it.
95. As a result of this lack of adherence, the State is tumbling towards its peril. It is
increasingly inactive, lacks records to affirm its legitimacy, less safe, less transparent, less
energetic, less accountable, and more corrupt. All around, the pitfalls of this great State
can be traced back to the failure of the Department of State.
96. Plaintiff is injured when the government does not do its job. The Senate provided this
statute so that he may have a cause of action in these cases.
SECOND CAUSE OF ACTION
(Accountability Clauses—Rid. Const. Art. I § 3)
97. The allegations included in this complaint thus far are incorporated as reference as if fully
set forth in this cause of action.
98. The Department of State’s failure to act on its statutory obligations has caused systematic
issues across the State by failing to provide a slew of necessary services to its citizens and
is actively contributing to its steady demise.
99. In its failure to provide these necessary services, it not only has caused the State to walk
back on its advancements, but it has prevented it from moving forward.
100. The Department of State’s overt decision not to do its job actively harms the common
good and makes it more difficult to move towards it.
101. Plaintiff, as a Resident of the State of Ridgeway, bears the brunt of this categorical
negligence.
102. Across all aspects, the decision by the Department of State to walk away from its
legal obligations have ripple effects throughout the entire State.
103. The Department of State’s lack of performance contributes to inefficiency, corruption,
unaccountability, abuse, and inactivity which all act concurrently to create a reality that is
tangibly more dangerous, less legitimate, and increasingly hostile for this Plaintiff than
would be if not for the Department of State’s lack of performance.
104. The members of the executive branch of government are the “[citizen’s] trustees and
servants; and at all times, in a legal way, accountable to them.” Rid. Const. Art. 1 § 3.
105. The Plaintiff also has a right “to find a certain remedy, by having recourse to the laws,
for all injuries or wrongs which one may receive in person, property or
character…completely and without any denial; promptly and without delay; conformably
to the laws.” Rid. Const. Art. 1 § 1.
106. “That government is, or ought to be, instituted for the common benefit, protection,
and security of the people, nation, or community.” Rid. Const. Art. 1 § IV.
107. These provisions act collaboratively to provide Plaintiff with a legal right to sue to
vindicate his right to hold legal representatives “accountable,” Rid. Const. Art. 1 § 3,
when those legal actors fail to provide for the common benefit, or their dereliction of
duties to the people do not provide for the common benefit.
108. The Department of State’s dereliction of duties means that the government is not
instituted for the “common benefit,” Rid. Const. Art 1 § 4, and that the legal
representatives of this Plaintiff are not acting as “trustees and servants,” Rid. Const. Art 1
§ 3, And when those Constitutional protections are frustrated, and Plaintiff’s right to a
government for the common benefit is transgressed, he has a right to “find a certain
remedy,” Rid. Const. Art. 1 § 1, and hold them “in a legal way, accountable.” Rid. Const.
Art. 1 § 3.
109. The Senate sought to provide for the creation and protection of the common benefit
when it wrote these provisions which are integral to the structure of our government—the
Department of State’s failure to follow through creates a Constitutional bruise.
110. The Senate geniusly created a right to a government advanced for the common good,
officials accountable to the people, and a right to remedy to ensure all of it takes place.
Where these rights intersect is where this cause of action is created. Plaintiff here invokes
that cause of action here to hold the State Department accountable to its statutory roles,
and intrinsically, the People of this State.
RELIEF
WHEREFORE, Plaintiff requests that the court grant relief as follows:
A. An injunction for each cause of action requiring the Secretary of State and the
Department of State to adhere to their statutory obligations.
B. Declaratory relief for each cause of action affirming that the Department of
State’s lack of action violated the law and the Constitutional rights of the Plaintiff
as well as all those similarly situated.
C. If in the interest of justice, this court could also construe this complaint as a
petition for writ of mandamus, and grant the writ the parameters as stated herein.
D. Compensatory damages in attorney’s costs and fees associated with filing and
litigation.
E. Any other remedy deemed necessary by this court.
Dated: August 3, 2022 Respectfully submitted.
CLIFFORD2
Counsel
10 000
TURNTABLE5000
Counsel
10 000
TOTORO987123
Advocate
10 000
