STATE OF RIDGEWAY
SUPERIOR COURT
ARTHUR_CHEN;
Plaintiff(s);
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CODKING2318;
Defendant(s).
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Case No.: RSC-CV-2186
CIVIL COMPLAINT
Presiding Judge: Hon. EnforcementBeyond
CIVIL COMPLAINT
I. The Parties to This Complaint
A. The Plaintiff(s)
1. The Plaintiff is ARTHUR_CHEN, a sworn Sheriff’s Deputy of the Ridgeway County
Sheriff’s Office and a citizen of the State of Ridgeway.
B. The Defendant(s)
1. The Defendant is CODKING2318, a citizen of the State of Ridgeway.
II. Jurisdiction and Venue
1. Pursuant to Article V, Section IV of the Constitution of the State of Ridgeway, this
Honorable Court is vested with the authority to entertain and adjudicate “all civil or
criminal cases or controversies.”
2. Venue is proper as the incident giving rise to the present litigation occurred within the
geographical bounds of Sterling Heights, a municipality situated within Ridgeway
County, and thus subject to the jurisdiction and laws of the State of Ridgeway.
III. Statement of Facts
1. ARTHUR_CHEN, hereinafter referred to as "Corporal Chen", is an active and serving
member of the Ridgeway County Sheriff's Department, affiliated with the training unit of
the Field Operations Branch. Corporal Chen has completed his training at the Law
Enforcement Training Center, Class 4, and the Ridgeway County Sheriff's Academy,
Class 19.
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CIVIL COMPLAINT
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2. On or about the first day of October, two thousand and twenty-four, at approximately
23:02 Eastern Standard Time, Corporal Chen was performing his duties as a peace officer
while patrolling Ridgeway County donning his complete uniform, including a patrol vest
that displayed the clearly written text "SHERIFF" on the front and back.
3. Corporal Chen was patrolling Sterling Heights within a clearly marked Percivel police
vehicle bearing the distinctive Ridgeway County Sheriff's Office livery prominently
featuring the word "SHERIFF" in gold bold lettering on both sides of the vehicle. He had
also engaged the emergency lighting system, thereby illuminating the red and blue lights
located on the roof-mounted lightbar, the front ram bar, rear windows, and the rear
windscreen area.
4. At 23:02 hours, a dark gray Percivel traveling south-bound. The Percivel failed to have
it’s headlights illuminated during nighttime hours and made two unsignaled lane charges,
both offenses according to the Ridgeway Vehicle Code.
5. Corporal Chen then attempted to perform a traffic stop on the Percivel. The Percivel
yielded to Corporal Chen’s emergency lights and pulled into the parking lot of the
Sterling Boxing Club.
6. As soon as Corporal Chen followed the Percivel into the parking lot, CODKING2318
emerged from the vehicle and drew a Stetson M2-A rifle. CODKING2318 quickly and
discharged his firearm, deliberately shooting Corporal Chen through his patrol car’s
windscreen and killing him.
7. Following the shooting, CODKING2318 hastily fled the scene in the aforementioned
dark gray Percivel.
IV. Allegations
FIRST CAUSE OF ACTION - WRONGFUL DEATH
(5 R. Stat. § 209)
1. All preceding Paragraphs of this Complaint are hereby incorporated by reference.
2. Wrongful Death is defined in the Civil Claims Act as, “Any individual who causes the
death of another without legal cause or justification shall be wrongful death and liable for
compensatory damages and punitive damages up to $2,500.”
3. Defendant, CODKING2318 , caused the death of the Plaintiff, ARTHUR_CHEN,
without any legal cause or justification. CODKING2318 used a firearm to inflict fatal
injury upon the said Plaintiff who was attempting to carry out his lawful duties as a sworn
peace officer of the county.
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CIVIL COMPLAINT
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SECOND CAUSE OF ACTION - BATTERY
(5 R. Stat. § 202)
4. All preceding Paragraphs of this Complaint are hereby incorporated by reference.
5. Battery is defined in the Civil Claims Act as, “Any individual who brings unconsented
harmful or offensive contact against another person shall be liable for punitive damages
up to $2,500”
6. Defendant, CODKING2318, did commit the act of battery by shooting the Plaintiff,
ARTHUR_CHEN. CODKING2318, without any legal cause or justification, used a
high-powered illegal Stetson M2-A to inflict unwarranted injury upon the said Plaintiff
who was attempting to carry out his lawful duties as a sworn peace officer of the county.
V. Relief
WHEREFORE, Plaintiffs prays for judgment, against Defendant, and requests that the relief for
all cause(s) of action be as follows:
1. To order the payment of $5000, by the Defendant to the Plaintiff for punitive damages;
2. To order the payment of $1,000 in for attorney’s and court filing fees by the Defendant;
3. To provide a judgment from this court providing that the Defendant violated the laws of
the State of Ridgeway in committing the death of Plaintiff;
4. To produce a statement and/or opinion from this court that the plaintiff is not to be
retaliated against for filing this or any other civil action in the future;
5. To issue an order enjoining Defendant from contacting or approaching Plaintiff within a
radius of 50 studs for any cause whatsoever.
6. For such or other reliefs as the court may deem just and proper.
DATED: January 26th, 2023
Respectfully submitted,
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Cpl. Arthur_Chen, RCSO
R. Bar. No. 20104
Plaintiff
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CIVIL COMPLAINT
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