RIDGEWAY SUPERIOR COURT
EPIDERMISGUPTA69,
Plaintiff.
-against-
BETATHEWOLFGAMER; in his official
capacity as a Deputy of the Ridgeway
County Sheriff’s Office,
Defendant.
Case No. RSC-CV-844
CIVIL COMPLAINT
Presiding Judge: AlexJCabot
PLAINTIFF, epidermisgupta69, proceeding with counsel hereby brings this civil action
and alleges as follows—
PARTIES TO THE PROCEEDINGS
1. Plaintiff, epidermisgupta69, is a citizen and resident of the State of Ridgeway.
2. Defendant, BetaTheWolfGamer, is a citizen and resident of the State of Ridgeway
who is employed within the County Sheriff’s Office and was on duty during the
time of the tortious actions, but is being sued in quasi-official capacity.
JURISDICTION & VENUE
3. The Ridgeway State Constitution gives the Superior Court the ability to hear all
cases and or controversies. See Article V, Section 4.
4. Venue is proper as the tortious actions occurred within the County of Ridgeway.
FACTUAL ALLEGATIONS
5. The Ridgeway State Police is tasked with bringing to justice all violators of State
law, ensuring equal protection of the laws, and ensuring equal justice is granted to
all.
6. On or about December 30th, 2022, the plaintiff was driving his snowplow within
the city of Palmer, in a rush to get to Sterling, where he had heard that an incident
had occurred.
7. Enroute to Sterling, The plaintiff stopped his car at a red light behind a marked
Ridgeway County Sheriff’s Office (RCSO) vehicle, driven by the defendant.
8. When the light turned green, the plaintiff continued to drive forward until hearing
sirens and realizing that it was likely he was being pulled over.
9. Upon confirming that this was the case, the plaintiff made a left turn on a yellow
traffic light onto the street adjacent to the Palmer City RBX Pharmacy.
10. To avoid blocking the roadway, the plaintiff turned left once again into the RBX
Pharmacy parking lot to stop and allow for the RCSO deputies to make a traffic
stop.
11. The traffic stop was initiated by the defendant, and the vehicle involved was the
same RCSO vehicle the plaintiff had been stuck behind.
12. Following the traffic stop, the plaintiff was cited by the defendant for “Failure to
Yield to a Traffic Control Device” (7.06 Ridgeway Vehicle Code).
13. Following the issuance of this citation, the plaintiff was then immediately arrested
by the defendant for “Driving Wrong Way” (7.08 Ridgeway Vehicle Code) , a
felony charge.
14. The defendant wrote in his arrest affidavit that the plaintiff “...was driving his
vehicle in the wrong lanes…” and “...then hit [his] vehicle before being pulled
over and taken into custody.”
15. The affidavit never stated that the plaintiff drove “the opposite way which traffic is
directed to flow”, as is required by the Ridgeway Vehicle code to meet the criteria
for the offense of “Driving Wrong Way”, nor was there any probable cause for the
defendant to believe that the plaintiff had committed such an offense.
16. Due to the fact that he was immediately incarcerated after being cited, the plaintiff
was unable to pay the first citation issued by the defendant, causing a warrant to be
issued for his arrest for “Failure to Pay Fines” (2.06 Ridgeway Criminal Code),
which he turned himself in and was further incarcerated for.
17. On January 3rd, 2023, the plaintiff appeared in Traffic/Misdemeanor Court in
Palmer before the Honorable Justice Robert H. Jackson a/k/a siteowner.
18. After a nearly hour-long bench trial, Judge siteowner found epidermisgupta69 not
guilty of “Failure to Yield to a Traffic Control Device”, ruling that turning left on a
yellow light does not meet the criteria for a violation of the statute, showing that
the defendant did not have probable cause.
19. Furthermore, Judge siteowner dismissed the “Driving Wrong Way” arrest against
the plaintiff, ruling that it “...violates the due process clause of the United States
Constitution.” (State v. Epidermisgupta69)
20. Finally, Judge siteowner dismissed the “Failure to pay Fines” charge which
stemmed as a result of the defendant’s two other bogus charges against the
plaintiff on December 30th, 2022.
21. Since all three aforementioned records were dismissed and expunged by a court of
law, it is evident that they were issued illegitimately against the plaintiff.
FIRST CAUSE OF ACTION
(1 R. Stat. §3114 - Official Misconduct )
22. Plaintiff incorporates by reference all prior allegations as if being alleged in this
action.
23. The Defendant holds the position of Sergeant of the Ridgeway County Sheriff’s
Office’s Patrol Unit A, which is a part of the Patrol Division.
24. The Patrol Division is tasked specifically with patrolling “the streets of the State
and ensur[ing] general order and tranquility and provid[ing] assistance where
necessary.” Incorporation of Ridgeway County §1.2(a).
25. The duties given to the Defendant are imposed by law, but through issuing a traffic
citation, which was deemed illegitimate by a judge, to the plaintiff for “Failure to
Yield to a Traffic Control Device” (7.06 Ridgeway Vehicle Code), without
probable cause to do so, the Defendant failed to uphold these duties, constituting
concrete harm to the Plaintiff.
SECOND CAUSE OF ACTION
(1 R. Stat. §3114 - Official Misconduct )
26. Plaintiff incorporates by reference all prior allegations as if being alleged in this
action.
27. The Defendant holds the position of Sergeant of the Ridgeway County Sheriff’s
Office’s Patrol Unit A, which is a part of the Patrol Division.
28. The Patrol Division is tasked specifically with patrolling “the streets of the State
and ensur[ing] general order and tranquility and provid[ing] assistance where
necessary.” Incorporation of Ridgeway County §1.2(a).
29. The duties given to the Defendant are imposed by law, but through illegitimately
and without probable cause arresting the plaintiff for “Driving Wrong Way” (7.08
Ridgeway Vehicle Code), the Defendant failed to uphold these duties, constituting
concrete harm to the Plaintiff.
THIRD CAUSE OF ACTION
(1 R. Stat. §3114 - Official Misconduct )
30. Plaintiff incorporates by reference all prior allegations as if being alleged in this
action.
31. The Defendant holds the position of Sergeant of the Ridgeway County Sheriff’s
Office’s Patrol Unit A, which is a part of the Patrol Division.
32. The Patrol Division is tasked specifically with patrolling “the streets of the State
and ensur[ing] general order and tranquility and provid[ing] assistance where
necessary.” Incorporation of Ridgeway County §1.2(a).
33. Through illegitimately issuing a traffic citation to the defendant for “Failure to
Yield to a Traffic Control Device” (7.06 Ridgeway Vehicle Code), and then
immediately (also illegitimately) arresting the “Driving Wrong Way” (7.08
Ridgeway Vehicle Code), the defendant caused the plaintiff to have another
warrant issued for his arrest for “Failure to Pay Fines”.
34. This warrant for “Failure to Pay Fines” was also deemed illegitimate and
expunged by Judge Siteowner on January 3rd, 2023.
35. Due to the fact that this charge and related incarceration was directly caused by the
defendant’s illegitimate citation and arrest, the Defendant failed to uphold his
aforementioned duties, constituting concrete harm to the Plaintiff.
RELIEF REQUESTED
WHEREFORE, the Plaintiff requests the court grant the following relief in order to atone
and redress the injuries formerly alleged—
36. To declare that the Defendant is liable for the tort of Official Misconduct as
described in the first cause of action;
a. To award $3,000 dollars in statutorily allowed punitive damages for this
first cause of action;
37. To declare that the Defendant is liable for the tort of Official Misconduct as
described in the second cause of action;
b. To award $3,000 dollars in statutorily allowed punitive damages for this
second cause of action;
38. To declare that the Defendant is liable for the tort of Official Misconduct as
described in the third cause of action;
c. To award $3,000 dollars in statutorily allowed punitive damages for this
third cause of action;
TENTATIVE EVIDENCE
1. EXHIBIT A - Ruling by siteowner on records issued by defendant (Jan 3rd, 2022)
2. EXHIBIT B - Video of incident
3. EXHIBIT C - Confirmation of expungements
DATED: January 3rd, 2022
Respectfully submitted,
CoastBreeze
Attorney For the Plaintiff
/s/ CoastBreeze
epidermisgupta69
Plaintiff
/s/ epidermisgupta69
