IN THE SUPERIOR COURT OF THE STATE OF RIDGEWAY
ZACHCASISBEAST
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DOCKET NO. RSC-CV-2317
Petitioner
v.
IISANDWICH_LAWZ
Respondent
PETITION FOR A WRIT OF HABEAS CORPUS UNDER 1 R. STAT. § 2210
Parties
1. Petitioner ZachCasisbeast (“Petitioner”) is a resident of the State of Ridgeway.
2. Respondent iiSandwich_Lawz (“Respondent”) is a resident of the State of Ridgeway and
currently employed by Palmer Police Department (“PPD”) as a sergeant.
Statement of Facts
3. On Febuary 17th of the year 2024, PPD officers were running a checkpoint at the end of Palmer
Tunnel.
4. While at the checkpoint, Petitioner was detained by Respondent and eventually issued a citation
for § 7.09 Failure to Maintain Lane.
5. After being released, Petitioner remained at the checkpoint within the sight of Respondent and
eventually Petitioner returned to their vehicle and reentered the checkpoint where they were
originally detained.
6. Respondent then demanded Petitioner’s username.
7. When Petitioner did not comply with the Respondent’s demand, Petitioner was detained and
eventually arrested for § 2.05 Failure to Identify by Respondent.
8. The time between the release of Petitioner from the original detainment and the arrest in question
was less than four minutes.
Standard of Review
9. When reviewing a petition for a writ of habeas corpus, the Court must first ask “whether the
police were legally entitled to make the arrest – that is, the police either had a judicial warrant
ordering an arrest, or the police had probable cause that a crime was committed.” See In re
ZachCasisbeast, RSC-CV-367 (R.d. Sup. Ct. 2022). If the police lacked cause to effectuate the
arrest, “the inquiry ends there; the record must be removed.” Id.
10. Next the court must ask if “a reasonable and well-informed jury could not convict the petitioner
in a hypothetical trial if they were aware of those facts, and those facts were admissible
evidence.” Id. If they could not, the record must be removed.
Ground 1
Unlawful Arrest
11. A person commits § 2.05 Failure to Identify under the Ridgeway County Code (“Failure to
Identify”) if they fail to present a county issued identification to a peace officer that has a
reasonable articulable suspicion that a crime has, is or is about to take place.
12. Because Petitioner was merely stopped at a checkpoint, the criminal code does not apply in this
situation.
13. Under 6 R. Stat. § 6102, Law enforcement officers have the right to ask for the Identification of
those who stop at a checkpoint to check for any BOLOs, active warrants, and RFLID cards.
Failure to comply with 6 R. Stat. § 6102 shall be enforceable under § 2.04 of the Ridgeway
County Code, Failure to Comply (“Failure to Comply”).
14. Whether or not Petitioner violated 6 R. Stat. § 6102 is not relevant in this case because it is not
enforced under Failure to Identify, but instead under Failure to Comply.
15. Because Respondent did not have probable cause to arrest the Petitioner for Failure to Identify,
and the Petitioner did not have an active warrant this arrest must be removed.
Ground 2
Unconstituional Vagueness
16. A criminal offense is unconstitutional when it is “so vague that it fails to give ordinary people
fair notice of the conduct it punishes, or so standardless that it invites arbitrary enforcement.”
Kolender v. Lawson, 461 U. S. 352, 357–358.
17. A person commits Failure to Identifty if they fail to present a county issued identification or
gives fictitious information to a peace officer that has a reasonable articulable suspicion that a
crime has, is or is about to take place.
18. An ordinary person would not know what they are expected to present to an officer upon request
of identification because the only form of identification listed is a nonexistent county issued
identification.
19. Because the code also fails to define when a person has properly identified, it allows for officers
to arbitrarily request identification even if the person’s identity is already known by the officer,
like it was in this case since the Respondent had recently cited the Petitioner.
20. Because the offense of Failure to Identify is unconstituionally vague this arrest must be removed.
Evidence
Exhibit 1 - Video of the Arrest
Exhibit 2 - Screenshot of the Citations
Relief
21. The plaintiff requests the expungement of the arrest mentioned.
Respectfully Submitted,
Petitioner ZachCasisbeast
