IN THE SUPERIOR COURT OF THE STATE OF RIDGEWAY
ZACHCASISBEAST
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DOCKET NO. RSC-CV-2354
Plaintiff
v.
STATE OF RIDGEWAY
Defendant
AMENDED COMPLAINT
On April 3, 2022, the Senate of the State of Ridgeway passed the Checkpoint Act, and
the act was immediately signed into law. The act allows Law Enforcement to set up checkpoints
anywhere in the state and request identification from drivers to check for BOLOs, active
warrants, and RFLIDs. This type of checkpoint is unconstitutional because it violates
Amendment IV of the U.S. Constitution. The Court should declare that 6 R. Stat. § 6102 is
unconstitutional.
PARTIES
1. ZachCasisbeast is the plaintiff. He is a resident of the State of Ridgeway.
2. The Palmer Police Department acted as an agent for the State of Ridgeway, making the
State the Defendant under 1 R. Stat. § 3205.
JURISDICTION AND VENUE
3. 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.
FACTUAL BACKGROUND
A. 6 R. Stat. § 6102 caused injury to the plaintiff.
4. On February 17, 2024, the plaintiff was driving their Blue Tremor Sport on Alderpoint
Drive towards the City of Palmer when they were detained at a police checkpoint
established under 6 R. Stat. § 6102 by the Palmer Police Department.
5. The officer operating the checkpoint requested the plaintiff’s identification, and upon
refusal, arrested the plaintiff for § 2.05 under the Ridgeway State Criminal Code, Failure
to Identify.
6. Failure to Identify makes it a crime to fail “to present identification to a peace officer
after having been [sic] lawfully detained.”
7. The detention caused by 6 R. Stat. § 6102 allowed the plaintiff to be arrested for Failure
to Identify, which caused irreparable injury by seizing the plaintiff, and not allowing him
to travel freely.
B. Fourth Amendment of the U.S. Constitution.
8. The Fourth Amendment states that:
The right of the people to be secure in their persons, houses, papers, and effects,
against unreasonable searches and seizures, shall not be violated, and no Warrants
shall issue, but upon probable cause, supported by Oath or affirmation, and
particularly describing the place to be searched, and the persons or things to be
seized.
U.S. Const. amend. IV.
1. The type of checkpoint described in 6 R. Stat. § 6102 is not sanctioned by the
Supreme Court.
9. Supreme Court precedent 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.
10. Supreme Court precedent has allowed some checkpoints, but the Supreme Court 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).
11. 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.
12. 6 R. Stat. § 6102 does neither. Instead, it justifies stops “by the generalized and
ever-present [sic] possibility that interrogation and inspection may reveal that any given
motorist has committed some crime”, which Edmond specifically does not sanction. Id.
CLAIMS FOR RELIEF
A. Count I: Declaration on Violation of the Fourth Amendment
13. The Fourth Amendment protects citizens from “unreasonable searches and seizures”. It is
unconstitutional for any act to violate the Fourth Amendment. A person is considered
seized at a checkpoint, and Supreme Court precedent specifically does not sanction the
type of checkpoint described in 6 R. Stat. § 6102. It therefore violates the Fourth
Amendment. The plaintiff is entitled to a declaration to that effect.
B. Count II: Injunctive Relief Under 1 R. Stat. § 3201
14. The plaintiff is entitled to both preliminary and permanent injunctions preventing the
State from enforcing the Act’s unconstitutional seizure. Each of the factors governing the
award of injunctive relief favors the plaintiff.
1. The plaintiff is likely to prevail on the merits.
15. The plaintiff is likely to prevail when this case reaches final judgment. The Constitutional
violation is clear: a person is considered seized at a checkpoint and 6 R. Stat. § 6102
describes a type of checkpoint the Supreme Court has specifically not sanctioned. The
Plaintiff was injured 6 R. Stat. § 6102 when his freedom of movement was restricted
while incarcerated.
16. The violation and the injury are clear. The remedy is to stop the government from
carrying the illegality into effect.
2. The plaintiff is suffering irreparable harm.
17. The harm to the plaintiff’s freedom from unreasonable seizures is irreparable. Every time
a checkpoint is created, the plaintiff loses his protection from unreasonable seizures that
he is entitled to enjoy.
3. Balance of hardships and public interests.
18. Public interest and the balance of equities combine when the government is a party in an
action. That merger makes clear that the plaintiff enjoys the greater equity here.
19. On the one hand, the plaintiff is irreparably harmed by the State’s enforcement of an
unconstitutional law. He can never recover the freedom lost while unreasonably seized.
20. On the other hand, the State suffers no injury if their behavior is enjoined. It is always in
the public interest to enforce the Constitution when it conflicts with a mere statute.
4. The plaintiff is entitled to an injunction.
21. The plaintiff is entitled to a decree enjoining the State from enforcing 6 R. Stat. § 6102 of
the Checkpoint Act.
PRAYER FOR RELIEF
The plaintiff respectfully requests that the Court:
1. Declare that section 6 R. Stat. § 6102 of the Checkpoint Act is unconstitutional.
2. 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.
3. The immediate expunction of Plaintiff’s criminal record arising from the detention caused
by 6 R. Stat. § 6102 of the Checkpoint Act.
Respectfully submitted.
Plaintiff ZachCasisbeast
