SEAL_LOVE
Plaintiff,
v.
L3_G0, in his individual and official
capacity as a Trooper of the State
Police;
Defendant.
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IN THE SUPERIOR COURT OF
RIDGEWAY COUNTY
Civil Action No.
Plaintiff Seal_love, by and through his undersigned counsel, seeking all available
relief, hereby files this civil action against Defendant and alleges as follows:
INTRODUCTION
1. The Firearm Freezone Act, enacted April of 2022, was created with the intent to
prohibit individuals from carrying or possessing firearms in government buildings and
facilities.
2. Of course, the framers and legislators who created the Firearm Freezone Act were
purposeful—they knew that giving police officers the blanket authority to unconstitutionally
search individuals who enter government buildings and facilities is illegal.
3. Similarly, the Public Security Act provides strict and explicit guidelines on when
a police officer may search an individual before entering a government facility. The
legislature is clear in that an individual must “consent to [a] search,” and if they don’t, the
individual may be restricted from the event. Rid. Public Security Act, Sec 2.1(a).
4. This isn’t a new concept—Solicitor General turntable5000 opined to the
Ridgeway State Police in May 2022 that police officers may not search an individual solely
for seeking to enter a government building, and instead, they may bar the individual from
entering the event. See Solicitor General’s Memorandum to the State Police (May 10, 2022).1
5. Officers cannot justify illegal searches because “it’s a freezone.” They knew the
law, and instead, they engaged in a gross abuse of their powers—and that is unacceptable.
JURISDICTION AND VENUE
6. This Court has jurisdiction over this matter consistent with Art. V, Sec. IV of the
State Constitution.
7. Venue is proper because the incident set forth below took place within the City of
Palmer, State of Ridgeway.
PARTIES
8. Plaintiff Seal_love is a citizen of the State of Ridgeway.
9. Defendant L3_G0 is a citizen of the State of Ridgeway. He is sued in his
individual and official capacity.
FACTS
The Incident
10. On February 13, 2023, Plaintiff entered the courthouse building located inside of
the Palmer Police Department.
11. Shortly thereafter, he was followed by three police officers, including Defendant.
Defendant chased Plaintiff into the courtroom with a taser, until he eventually cuffrushed him
into custody.
12. When Plaintiff was brought back outside, Palmer Police officer supramqrk5
informed Defendant that “[he] cant [sic] legally search him.”
1 Private Memorandum to the State Police. Accessed February 13, 2024.
https://drive.google.com/file/d/1kutpBYcSCvWN_mW3V6laQpeH3QiTq1za/view?usp=drivesdk
13. Despite this admonition, Defendant L3_G0 continued with the search and
requested Plaintiff’s consent to search, only to override it immediately after.
14. Trooper thetribe56 informed Plaintiff, incorrectly, at that, that he must be
searched before entering the courthouse.
15. After conducting his illegal search, Defendant L3_G0 dragged Plaintiff to the
lobby of the Palmer Police Department, took him to a sign and said as follows through
Roblox voice chat: “think you have rights in this situation? Read that sign and tell me you
still have rights. That’s not how it works. We did have cause to search you… this says no
firearms.”
16. Like the situation in which General turntable opined, Defendant L3_G0 justified
his search by saying “you ran right past us, so,” once again through Roblox voice chat.
17. He finished the interaction by saying, “sue me, try it.” Well, Trooper, we tried it.
See you in court.
COUNT I
1 R. Stat. § 3115 – Deprivation of Rights
Defendant L3_G0
18. The prior allegations within this Complaint are fully incorporated as if they were
fully set forth herein.
19. Defendant, acting under color of state law, did cause a citizen of the State of
Ridgeway, to-wit: Seal_love, to be subjected to a deprivation of his Fourth Amendment right.
a. On February 13, 2024, Defendant did, without cause, search the person of
Seal_love, knowing that such an action is prohibited under the Public Security
Act.
b. The Public Security Act provides that while the government may search
individuals who want to enter a government event, that person must consent to
such a search.
c. The Solicitor General told the State Police that nearly two years ago—though it
seems they didn’t listen hard enough.
COUNT II
1 R. Stat. § 3114 – Official Misconduct
Defendant L3_G0
20. The prior allegations within this Complaint are fully incorporated as if they were
set forth herein.
21. Defendant, who is a public servant, did commit an act relating to his office, but
constituting an unauthorized exercise of his official functions, knowing that such act is
unauthorized.
a. On February 13, 2024, Defendant did, without cause, detain and unlawfully
search Plaintiff, in direct contravention of Section 2.1(a) of the Public Security
Act.
b. Defendant had no cause to effectuate a search to begin with—even noting that he
“ran right past us,” implying that is what led to his search.
c. Defendant was told by another police officer that searching Plaintiff would be
illegal. Yet, Defendant continued his acts knowing they were without cause.
PRAYER FOR RELIEF
22. WHEREFORE, Plaintiff prays that this Court:
a. Enter judgment against Defendant on all counts;
b. Award monetary damages for Plaintiff and against Defendant in the following
amounts:
i. $3,500.00 in punitive damages as to Count One
ii. $3,000.00 in punitive damages as to Count Two
c. That the Court award attorneys’ fees and costs;
d. That this Court grant any other relief deemed appropriate.
Respectfully submitted,
David Clarke
Managing Partner
Clarke and Associates, LLP
Counsel of Record
Attorney for Plaintiff
Date: February 13, 2024
