IN THE SUPERIOR COURT OF THE STATE OF RIDGEWAY
ZachCasisbeast
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DOCKET NO. RSC-CV-2317
Plaintiff
v.
The State of Ridgeway
Defendant
The Plaintiff ZachCasisbeast, on behalf of himself, alleges the following:
INTRODUCTION
1. Plaintiff ZachCasisbeast (“Plaintiff”) is a resident of the State of Ridgeway.
2. The Palmer Police Department Officer acted as an agent for the State of Ridgeway, making the
State the Defendant under 1 R. Stat. § 3205.
3. Plaintiff argues that Section 4(b) of The Checkpoint Act (“Section 4(b)”) violates their right from
“unreasonable searches and seizures” guaranteed by the Fourth Amendment (U.S. Const. amend.
IV).
4. Under 1 R. Stat. § 3201, the Plaintiff seeks a preliminary and permanent injunction enjoining the
State of Ridgeway from enforcing Section 4(b).
JURISDICTION
5. Whereas this is a civil case, the Superior Court of Ridgeway has original jurisdiction to hear this
case under Article IV Section IV of the Ridgeway State Constitution.
STATEMENT OF FACTS
6. The Checkpoint Act was passed and signed into law on the 3rd of April, 2022.
7. On February 17th, 2024, Plaintiff was driving their Blue Tremor Sport on Alderpoint Drive
towards the City of Palmer when they encountered a police checkpoint established by the local
police department.
8. iiSandwich_Lawz, a sergeant for Palmer Police Department, was operating the checkpoint.
9. The officer ordered the Plaintiff to present identification upon detention at the checkpoint.
10. Upon refusal, the officer arrested the Plaintiff for § 2.05 under the Ridgeway State Criminal
Code, Failure to Identify.
11. The officer accused Plaintiff of violating the provision that makes it unlawful to fail “to present
identification to a peace officer after having been [sic] lawfully detained.”
12. Section 4(b) allows law enforcement officers and Military Personnel of the National Guard to
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.”
13. The Checkpoint Act allowed the officer to detain Plaintiff, which caused Plaintiff’s arrest when
he refused to identify as required by § 2.05 of the Ridgeway State Criminal Code.
14. The arrest caused irreversible harm by restricting Plaintiff’s freedom, which caused Plaintiff to
lose guaranteed wages.
LEGAL ARGUMENTS
15. It is well established that a vehicle stop at a highway checkpoint effectuates a seizure within the
meaning of the Fourth Amendment. See Michigan Department of State Police v. Sitz, 496 U.S.
444 (1990) at 450.
16. Although the Supreme Court has allowed some checkpoints, they never indicted approval “of a
checkpoint program whose primary purpose was to detect evidence of ordinary criminal
wrongdoing.” Indianapolis v. Edmond, 531 U.S. 32 (2000).
17. Instead, every checkpoint the Supreme Court has approved was “designed primarily to serve
purposes closely related to the problems of policing the border or the necessity of ensuring
roadway safety.” Id.
18. There are only a few offenses that confront society “with the type of immediate, vehicle-bound
threat to life and limb that the sobriety checkpoint in Sitz was designed to eliminate.” Id.
19. The purpose of Section 4(b) does not involve immediate, vehicle-bound threat to life and limb.
20. The Supreme Court ruled that they “cannot sanction stops justified only by the generalized and
ever-present [sic] possibility that interrogation and inspection may reveal that any given motorist
has committed some crime.” Id.
21. Because the purpose of checkpoints, according to The Checkpoint Act, is to “check for any
BOLOs, active warrants, and RFLID cards” and not to check for illegal immigrants or to ensure
roadway safety, the Supreme Court has not approved this type of checkpoint.
22. Because the checkpoint does not prevent an “immediate, vehicle-bound threat to life and limb”
and instead allows inspections that “may reveal that any given motorist has committed some
crime,” the Supreme Court would not rule in favor of this type of checkpoint.
23. Because the checkpoints created by Section 4(b) of The Checkpoint Act are not approved or
likely to be approved by the Supreme Court, Section 4(b) violates the Fourth Amendment right
of a person to be free from “unreasonable searches and seizures.” (U.S. Const. amend. IV).
RELIEF
24. The plaintiff seeks declaratory relief on the basis that Section 4(b) of The Checkpoint Act is
unconstitutional.
25. The plaintiff seeks a preliminary and permanent injunction enjoining the State of Ridgeway, and
by and through him the entire State as a whole, including law enforcement officers, from
enforcing said clause.
26. The immediate expunction of Plaintiff’s criminal record arising from the detention caused by
Section 4(b) of The Checkpoint Act.
Respectfully submitted,
Plaintiff ZachCasisbeast
