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RIDGEWAY SUPERIOR COURT
NEVPLAYSGAMES and
THEAVENGERNICK, on behalf of all
other similarly situated,
Plaintiff,
v.
STATE OF RIDGEWAY; largeTitanic2
in his official capacity as Governor of
the State of Ridgeway,
Defendant.
Case No. RSC-CV-798
CIVIL COMPLAINT
Plaintiff, NevPlaysGames (“Nev” or “Plaintiff”) and TheAvengerNick (“Nick” or
“Plaintiff”) (collectively “Plaintiffs”), files this collective action against Defendants, the State of
Ridgeway (“the State” or “Ridgeway”) and Governor largeTitanic2 (“Governor” or “Defendant”)
(collectively, “Defendant”), seeking all available declaratory relief pursuant to the Civil Claims
Act, S1: 3 et seq. (“CCA”), on behalf of themselves and all current Citizens subject to the
unconstitutional deprivations of the Modified Sedition Act (“MSA”), who face repercussions on
their positions, and protected liberties, solely due to their affiliation in Pauljkl’s United States of
America, and its subsidiary communities. Plaintiffs, by and through their undersigned counsel,
for their claims against the State of Ridgeway, allege:
INTRODUCTION
1. Overstepping constitutional limitations is a grave, and consequential action. The State of
Ridgeway has done exactly that. It has enacted a statute that essentially strips individuals
of their right to hold public office, to seek recourse within the courts system, and to hold a
position in an external community solely due to their affiliation with that community. The
very presence of such a statute violates the Fourteenth Amendment of the United States
Constitution, and requires immediate attention. The Supreme Court of the United States,
to provide adequate recourse to individuals who are stripped of their rights, held that “[i]f
a state law denies or impairs [a] right, in violation of the Constitution or of a valid federal
law, the courts are the proper and traditional forum for redress.” Engquist v. Oregon Dep't
of Agric., 553 U.S. 591, 609 (2008); Engle v. Isaac, 456 U.S. 107 (1982); Smith v.
Phillips, 455 U.S. 209 (1982).
2. The State of Ridgeway enacted the Modified Sedition Act in translucent defiance of the
Constitution. The statute strictly prohibits employment in any government agency due to
an individual's affiliation in the aforementioned communities. It also prohibits any effort
to seek–or, indeed, any intent to file–an expungement within the Ridgeway Superior
Court, a provision that proves contrary to a constitutionally protected liberty to seek
redress within the courts system. The Modified Sedition Act, which clearly violated the
constitution, was denied within its first presentation before the State Senate. Only one day
later, however, the State Senate made minute revisions to the bill, in a clear effort to make
it harder to challenge within the courts.
3. The Modified Sedition Act, § 1, Sub. S. 1.3 states that a person may be discharged from
their position in the State of Ridgeway “[if] they hold [any] office,” in Pauljkl’s United
States of America or Boulder County. Subsection 1.3 furthermore provides that an
individual may be discharged if “[a] department head or the Governor finds [the
individuals] continued employment to be a security risk.” This section alone establishes a
substantial risk to any person who holds any office within Pauljkl’s U.S. and Boulder
County, Colorado. The plaintiffs, who both are employed with the Boulder County
Transit Authority (“BCTA”) and the Ridgeway County Sheriff’s Office (“RCSO”), fall
victim to the damning risk of termination from the RCSO solely due to their employment
in a foreign municipal agency, a risk that should not be imminent in the first place.
Moreover, the Modified Sedition Acts unconstitutionally broad terms purport to subject
department heads, and the Governor who carry out those abilities to civil liability and
penalties.
4. The plaintiffs bring forth this action to protect the interests of our Constitution that the
Modified Sedition Act unconstitutionally impairs. The plaintiffs therefore seek a
declaratory judgment that the Modified Sedition Act is invalid under, and violates the
Fourteenth Amendment. The plaintiffs also seek an order preliminarily and permanently
enjoining the State of Ridgeway, including its officers, employees, and agents from
implementing or enforcing the Modified Sedition Act.
PARTIES
5. Plaintiff NevPlaysGames is a Citizen of the State of Ridgeway.
6. Plaintiff TheAvengerNickis a Citizen of the State of Ridgeway.
7. Defendant largeTitantic2 is the Governor of the State of Ridgeway.
JURISDICTION AND VENUE
8. This Court has jurisdiction pursuant to Article V, Section IV of the Constitution of the
State of Ridgeway.
9. Venue is proper in this Court because the incident took place within Ridgeway County.
FACTS
10. On November 28th, 2022, the Governor of the State of Ridgeway, collectively the
Defendant, signed the Modified Sedition Act into law.
11. When a bill is signed into law, the provisions and subsections within are then regulated,
and forced upon those in which it affects.
12. The Modified Sedition Act, which has countless unconstitutional bounds, was imposed
upon a substantial populus of the State of Ridgeway.
13. The consequential, yet compulsory singing of this divisive bill establishes the substantial
risk of future harm as a result thereof.
14. Plaintiff’s, like many other Citizens, face the risk of termination from their positions in
the State of Ridgeway solely due to their employment in an external foreign entity.
15. Countless Citizens have been forced to resign from their jobs in Boulder County and
Pauljkl’s United States of America given the repercussions of the Modified Sedition Act.
16. The Modified Sedition Act conflicts with the United States Constitution,
unconstitutionally stripping basic rights and liberties from a plethora of Citizens of the
State of Ridgeway who retain various positions within Boulder County and Pauljkl’s
United States of America.
I. Pre-Enforcement Challenge Standing
17. In a free society, with basic rights and liberties such as the State of Ridgeway, no one
should have to be punished before they can challenge an unconstitutional law.
MedImmune, Inc. v. Genentech, Inc., 549 U.S. 118, 129 (2007). See also Steffel v.
Thompson, 415 U. S. 452, 459 (1974) (noting that litigants “should not be required to
await and undergo a criminal prosecution as the sole means of seeking relief.”)
18. The Supreme Court of the United States provides that “[a]n allegation of future injury
may suffice if the threatened injury is “certainly impending,” or there is a ‘substantial
risk’ that the harm will occur.” Clapper v. Amnesty Int'l USA., 568 U. S. 398 (2013); see
also Susan B. Anthony List v. Driehaus, 134 S.Ct. 2334 (2014).
19. The Supreme Court’s ruling in Clapper, in essence, provides recourse of the test that was
established in Lujan v. Defenders of Wildlife to determine whether a Plaintiff has
standing to bring forth a claim to the court in which the case is filed. In this case, where
imminent and substantial risk is probable, the Supreme Court permits a Plaintiff to
overlook the Lujan test.
20. To establish that there was a “substantial risk,” See Clapper, Plaintiff must demonstrate
that the Modified Sedition Act, and its provisions, are encroaching upon concrete harm to
the plaintiff. In doing so, we refer to The Modified Sedition Act, § 1, Sub. S. 1.3 states
that a person may be discharged from their position in the State of Ridgeway “[if] they
hold [any] office,” in Pauljkl’s United States of America or Boulder County.
21. This subsection alone provides the imminent, and substantial risk of harm to the
plaintiff’s who: (1) Are employed within the Boulder County Transit Authority; and (2)
Are employed within the Ridgeway County Sheriff’s Office. At any given time, upon the
discretion of the Sheriff of Ridgeway County, the plaintiffs may be discharged from their
duties solely due to their affiliation with Boulder County.
22. Under no circumstances should an individual be deprived of their constitutionally
protected rights. The Governor of the State of Ridgeway, however, has done exactly that
by signing this unconstitutional, impermissible bill into law. Its consequential provisions
now extend to every Citizen of Rideway who is in an agency, or department within
Pauljkl’s U.S. and Boulder County. These very individuals also fall under the substantial
risk of being terminated from the positions that they applied themselves to, and worked
hard for.
II. The Right To Seek Redress in a Court of Law
23. Under the 14th amendment to the United States Constitution, all persons in the United
States, and by extension, all regions therein, are subject to equal protection under the law.
In the current reading of the State of Ridgeway Constitution, the State of Ridgeway is a
part of that union. Accordingly, the 14th amendment must be upheld in this Court.
24. In Boddie v. Connecticut, 401 U. S. 371 (1971), the Supreme Court held that access to
the courts is universal, and must not be disallowed to any person. The limiting of
“frivolous litigation” is not grounds for the dismissal of any demographic’s ability to file
suit. Furthermore, in Plyler v. Doe, 457 U. S. 202 (1982) the Supreme Court held that
non-citizens are people “in any ordinary sense of the term” and, therefore, are afforded
Fourteenth Amendment protections.
25. The Modified Sedition Act, however, embeds contrary provisions to these very basic
liberties, and rights. Specifically, the plaintiff refers to The Modified Sedition Act, § 2,
Sub. S. 2.1(c) in which it reads “All persons who petition for an expungement, and hold
public office in Pauljkl’s United States of America shall be denied,” and that “All persons
who petition for an expungement, and hold public office in Boulder County, Colorado
shall be denied.”
26. This provision, upon entrance of the Modified Sedition Act into law, encroaches upon the
right to seek recourse within the Superior Court of the State of Ridgeway, a “universal
[access].” Id. This act, along with its provisions, restrict Citizens and even Tourists from
clearing their record to pursue a career in Ridgeway, and it is in doing so solely due to
their professional affiliation with the aforementioned communities. The plaintiffs, who are
consolidated with a plethora of individuals similarly situated, can not file for an
expungement of their records due to such affiliation.
27. Under no circumstances should the basic right to file for redress be constricted by our
legislators, as it is translucently afforded by the Constitution of the United States of
America.
III. Conflicting Legislation of The Constitution is Null and Void.
28. When passed legislation conflicts with our very own federal constitution and the basic
rights afforded within, the “federal law prevails.” Leroy v. Great W. United Corp., 443
U.S. 173, 190 (1979). Further, State Legislation “may not contravene federal law.” Shelby
Cnty. v. Holder, 570 U.S. 529, 22 (2013).
29. In being so provided that basic rights and liberties have been stripped from Citizens and
Tourists of the State of Ridgeway, the Modified Sedition Act conclusively quarrels within
our Federal Constitution, imbricating a plethora of rights afforded to Citizens of the
United States.
FIRST CAUSE OF ACTION
(Civil Action for Deprivation of Rights—Fourteenth Amendment)
30. Plaintiffs reallege and incorporate by reference all of the allegations contained in all of
the preceding paragraphs.
31. The Supremacy Clause provides that “[t]his Constitution, and the Laws of the United
States which shall be made in Pursuance thereof…shall be the supreme Law of the
Land…any Thing in the Constitution or Laws of any State to the Contrary
notwithstanding.” U.S. Const., art. VI, cl. 2.
32. The Modified Sedition Act violates the Fourteenth Amendment of the U.S. Constitution,
by depriving Citizens of the State of Ridgeway the ability to file for an expungement of
their records within the courts, and conclusively the basic right to seek redress within a
court of law. The Modified Sedition Act therefore is invalid under the Fourteenth
Amendment and the Supremacy Clause.
33. The State of Ridgeway deliberately impeded upon the ability of Citizens to seek redress
within the Ridgeway Superior Court, despite being accordingly afforded to Citizens by
the Constitution of the United States, and Supreme Court Precedent. In doing so,
Ridgeway has precluded the ability whatsoever to seek relief solely due to their
affiliations with Boulder County and Pauljkl’s United States. Plaintiff therefore brings
this suit to vindicate their interest, alongside an entire community's interest in ensuring
that the State of Ridgeway respects its obligations under the Constitution.
RELIEF
WHEREFORE, Plaintiff requests that the court grant relief as follows:
A. Declaratory judgment stating that the Modified Sedition Act is unconstitutional
and is thus invalid, null, and void;
B. Preliminary and permanent injunction enjoining the State of Ridgeway, including
its department heads, officers, employees, and agents from enforcing the Modified
Sedition Act, as well as any applicable rules and regulations regarding those
provisions, against Citizens and Tourists of the State of Ridgeway who are
affected;
C. Any and all other relief necessary to fully effectuate the injunction against the
Modified Sedition Acts enforcement;
D. Award to Plaintiff his reasonable attorneys’ fees, costs, and expenses of litigation;
and
E. Such other and further relief as the Court deems appropriate
Respectfully Submitted.
STICKZA
Managing Partner
COHN, CICERO, & GOODRICH, LLC
Suite 3B, Palmer Apartments
Palmer, RW 33328
D: stick#0677
E: [email protected]
MATTHEWSANDRINGHAM
Senior Associate
COHN, CICERO, & GOODRICH, LLC
Suite 3B, Palmer Apartments
Palmer, RW 33328
D: a carlyle #0924
E: [email protected]
DAVIDLCLARKE
Senior Associate
COHN, CICERO, & GOODRICH, LLC
Suite 3B, Palmer Apartments
Palmer, RW 33328
D: dave .#9695
E: [email protected]
TURNTABLE5000
Counsel
10 000
HOLYROMANRYAN
Advocate
10 000
Counsel for the Plaintiff
APPENDICES
APPENDIX A - The Modified Sedition Act
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COMPLAINT
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Notes
NevPlaysGames v. largeTitanic2 Amended Complaint.pdf — archived from the Trello docket (https://trello.com/c/WGLWLL3O)
