RIDGEWAY ADMINISTRATIVE COURT
YASSEN28,
Plaintiff,
v.
RIDGEWAY NATIONAL GUARD;
CONSTANTLYVERBAL, in their
official capacity as Captain of the
Ridgeway National Guard;
BOHBAZINGA, in their official
capacity as Adjutant General of the
Ridgeway National Guard,
Defendant.
Case No.
CIVIL COMPLAINT
PLAINTIFF, Yassen28, for his complaint against the Ridgeway National Guard alleges:
PARTIES
1. Yassen28 is a citizen of the State of Ridgeway.
2. Ridgeway National Guard is an official subsidiary of the State of Ridgeway.
3. ConstantlyVerbal is a citizen of the State of Ridgeway and the Captain of the Ridgeway
National Guard and a command member of the Military Intelligence Services.
4. Bohbazinga is a Citizen of the State of Ridgeway and the Adjutant General of the
Ridgeway National Guard.
JURISDICTION
5. This court has original jurisdiction to hear “all civil claims involving administrative
action, or policy, or rules of governing agencies.” Administrative Procedures Act, § 3.2.
6. This court may also grant “equitable remedy necessary to ensure proper enforcement of
the law.” Administrative Procedures Act, § 3.3(a).
FACTS
7. On August 3rd, 2022, Yassen28 (“Yassen”) applied to the Ridgeway National Guard
(RNG) in a good-faith effort to expand his opportunities in the future, service the citizens
of the State of Ridgeway, and earn an income to sustain himself.
8. Yassen has been a member of ROBLOX since March 22, 2016.
9. He has earned a number of badges playing games throughout those years, has 66 friends,
and 249 followers, and is involved in over 20 groups.
10. Yassen has been a citizen in the State of Ridgeway for roughly one year, joining in the
summer of 2021.
11. Yassen has his inventory open and viewable to the public. It was in this status at the time
that he applied and throughout the time that his application was being disposed of, and
remains open always.
12. Yassen does not associate with any criminal organizations, and has no criminal records to
his name. He has never been convicted in a court of law, and actively makes the effort to
ensure his actions are in accordance with it.
13. Yassen is a good-hearted member of the Ridgeway community and makes a diligent
effort to treat everyone with kindness and fairness.
14. On August 10th, 2022 at about 7pm EST, Yassen’s application to the Ridgeway National
Guard was denied, and the indicated reason for denial was because of the background
check.
15. ConstantlyVerbal is the Captain of the Military Intelligence Services (MIS) who is
responsible for conducting background checks on all applicants and has the final say
about the disposition of the background check.
16. ConstantlyVerbal indicated in a public announcement to applicants that background
checks were complete and not to ask any member of MIS about why an applicant may
have been denied.
17. There was no reason associated with the denial of the Plaintiff’s background check, it
only indicated that he had failed one.
18. Domieisok, a Major in the Ridgeway National Guard who has the authority to review
applications, made a comment on the Plaintiff’s application expressing praise of the
application noting that it had good “detail.”
19. The denial of Plaintiff’s application prevents him from advancing his career in the future
as well as from earning an income and pursuing his calling.
20. More than Plaintiff, the Ridgeway National Guard denied 75% (55) of its applicants
because of the failed background check, accepting only 18.
FIRST CAUSE OF ACTION
(Unfair Hiring Practices)
21. All allegations in this complaint are re-alleged and incorporated as reference in this cause
of action.
22. Subsection 2.8 of the Administrative Procedure Act provides a cause of action when
agencies engage in “prejudicial or unfair hiring practices.”
23. Subsection 2.7 of the same act provides an “objective criteria” for determining whether or
not someone passes a background check.
24. Plaintiff in this case satisfies each of the prongs of his background check.
25. The Ridgeway National Guard applies the wrong standard for determining whether
people pass the background check and did so in this case to deny a number of applicants
including Plaintiff here.
26. The Ridgeway National Guard arbitrarily denied the Plaintiff here, as well as a number of
other applicants as a direct result of their application of the wrong criteria for background
checks.
27. Subsection 2.7(d-e) obligates special notification requirements for those who fail
background checks as a result of the fact that they are an alternative account or if their
inventory is hidden. But not a single applicant had either of these indications.
Additionally, ConstantlyVerbal expressly forbade applicants from asking members of
MIS about why their background check failed.
SECOND CAUSE OF ACTION
(1 R. Stat. § 314 Official Misconduct)
28. All allegations in this complaint are re-alleged and incorporated as reference in this cause
of action.
29. ConstantlyVerbal makes the final determination as to the disposition of background
checks.
30. ConstantlyVerbal applied a standard that is inconsistent with the law to fail the Plaintiff’s
background check.
31. ConstantlyVerbal used his official position as Captain of the Military Intelligence
Services to deny the Plaintiff’s application on an unlawful basis because that denial was
contrary to the Plaintiff’s legal rights.
32. Bohbazinga is the head of the Ridgeway National Guard and makes the final
determination of all employment actions and maintains hiring procedures.
33. Bohbazinga failed to remedy hiring procedures that are contrary to the law and, by and
through his agents, failed the Plaintiff’s background check.
THIRD CAUSE OF ACTION
(1 R. Stat. § 316 Impediation of Privileges)
34. All allegations in this complaint are re-alleged and incorporated as reference in this cause
of action.
35. Plaintiff has a statutory privilege and right to be free from unfair hiring practices, and
background checks that are subjective and not based on the clear legal standards.
36. Yassen passes all of the background check requirements, and the Ridgeway National
Guard, ConstantlyVerbal, and bohbazinga arbitrarily failed his background check on a
subjective basis.
RELIEF
WHEREFORE, Plaintiff requests that the court grant relief as follows:
A. The issuance of an order directing the Ridgeway National Guard,
ConstantlyVerbal, and bohbazinga to comply with all statutory obligations as it
relates to hiring practices.
B. An injunction against ConstantlyVerbal, bohbazinga, and the Ridgeway National
Guard from continuing to make considerations in background checks that are
arbitrary and contrary to the law.
C. Declaratory relief that the denial of the Plaintiff’s application was contrary to the
law and a transgression of his legal rights.
D. Award attorney’s costs and fees.
E. Any other remedy deemed necessary by this court.
Dated: August 10, 2022 Respectfully submitted.
CLIFFORD2
Counsel
10 000
