STATE OF RIDGEWAY
Governor Matrix_oc )
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DOCKET NO. RSC-CV-2461
JUDGE. HON. _______
CIVIL COMPLAINT
Plaintiff
v.
Techiey,
in his official capacity as Attorney General;
Stickza,
in his official capacity as Special Counsel
Defendants
CIVIL COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF
Plaintiff Governor matrix_oc, by and through his undersigned attorneys, and based upon
belief and personal knowledge, hereby brings suit against Attorney General Techiey and Special
Counsel Stickza to obtain, inter alia, declaratory judgment that the appointment of a Special
Counsel under Section 6.4 of the Judiciary Act violates the Article IV, Section V of the
Constitution of the State of Ridgeway. Plaintiff further seeks injunctive relief enjoining both
Section 6.4 of the Judiciary Act and any conduct thereunder. Plaintiff, for its Complaint against
Defendants, alleges the following:
INTRODUCTION
1. Our government is one of limited and enumerated powers. The Constitution vests the
legislative power in the Senate, the executive power in a governor, and the judicial power
in the Supreme Court and all inferior courts. Rid. Const., Art. II, § II; Rid. Const., Art. II,
§ III; Rid. Const., Art. II, § IV. These departments are to be “separate and distinct, so that
neither exercise the powers properly belonging to others.” Rid. Const., Art. II, § V.
2. Our state follows a dual-executive mode of governance. The state Constitution
distinguishes the executive power by separately naming the “power to prosecute,” as a
function that is solely provided to the Attorney General. Rid. Const., Art. IV § V.
3. Few powers are as sacrosanct as the ability to deprive an individual of their liberty.
Former Attorney General Robert H. Jackson once noted that “[t]he prosecutor has more
control over life, liberty, and reputation than any other person in America. His discretion
is tremendous.” Robert H. Jackson, The Federal Prosecutor, Address at Conference of
United States Attorneys (Apr. 1, 1940). Absent any checks, the position remains
susceptible to political influence and tampering. “Under our system of government, the
primary check against prosecutorial abuse is a political one.” Morrison v. Olson, 487 U.S.
654, 728 (1988) (Scalia, J., dissenting).
4. This prosecution of Matrix_oc, as well as other members of the Ridgeway National
Guard, comes days after an oversight on the part of the Department of Justice. Attorney
General Techiey, State of Ridgeway Discord, #government-updates (Mar. 11, 2024) (“We
offer our apologies to w6ster for this situation and will be conducting a thorough review
of the criminal investigative pipeline to ensure this does not happen again.”). The
Department of Justice indicted a law enforcement officer based on erroneous evidence
that was not properly analyzed by their investigators and prosecutors. Prosecutors must
be “accountable to elected officials.” In re Grand Jury Investigation, 315 F. Supp. 3d 602,
612 (D.D.C. 2018). In a free and democratic state that values the rule of law, the public
must know “who to credit or blame for exercises of prosecutorial authority.” Ibid. Here,
the people were able to distinctly pinpoint a singular figurehead and hold them
responsible for the decision to indict. The upcoming election provides an opportunity for
the citizens of Ridgeway to reflect on and shape prosecutorial policy. The same cannot be
said for the role of Special Counsel and the prosecutions spearheaded by his office.
Independent from the Attorney General, he is ultimately insulated from the will of the
people, depriving them of their voice in our government.
5. The Framers of the state Constitution explicitly made the Attorney General elected by the
people in furtherance of this goal. See Rid. Const., Art. IV, § VI. The public can trace any
policy action made by Department of Justice officials solely to the Attorney General. The
same cannot be said for the Office of Special Counsel. This is a position that is not
“subject to any day-to-day supervision by a member of the Attorney General’s Office,”
and can decide “whether and to what extent to inform or consult the Attorney General
about the conduct of their responsibilities.” 2 R. Stat. § 2220; 2 R. Stat. § 2218. It is a
position that has “ full autonomy and authority to decide which charges would be brought
before the Grand Jury,” and the Attorney General has stated that he has “no part in the
decision to bring [any] charges,” when the Special Counsel is involved. Attorney General
Techiey, State of Ridgeway Discord, #government-updates (Mar. 12, 2024).
6. It is a position devoid of any accountability and it is antithetical to the constitutional
structure of our government. Any position that divests the Attorney General of his “sole
power to prosecute” is unconstitutional. Once Special Counsel has been appointed, the
Attorney General maintains no control whatsoever over their duties and is unable to
remove them from their position.
7. Such unrestrained, unadulterated, and unaccountable power is in direct violation of the
Constitution of the Great State of Ridgeway.
8. Plaintiff brings suit to correct and end the grave constitutional injustice committed
against him and all those similarly situated.
JURISDICTION AND VENUE
9. This Court has jurisdiction pursuant to Article V, Section IV of the Constitution of the
State of Ridgeway.
10. Venue is proper in this Court because the incident took place within Ridgeway County,
State of Ridgeway.
PARTIES
11. Plaintiff Matrix_oc (herein Plaintiff) is the Governor of the State of Ridgeway and a
law-abiding citizen.
12. Defendant Techiey (“Defendant Techiey” or “Attorney General Techiey” or “Attorney
General”) is sued in his official capacity as the Attorney General of the State of
Ridgeway. As Attorney General, he is responsible for enforcing the State’s laws.
13. Defendant Stickza (“Defendant Stickza” or “Special Counsel Stickza” or “Special
Counsel”) is sued in his official capacity as a Special Counsel of the Department of
Justice. As a special counsel, he was tasked with investigating the Governor, whom he
ultimately decided to prosecute.
FACTUAL ALLEGATIONS
14. On March 9th, 2024, the Attorney General announced the appointment of Stickza as
Special Counsel “to investigate potential crimes committed by a government official who
will not be publicly named until it is deemed appropriate to do so.” See Attorney General
Order No. 53.
15. This appointment was made under 2 R. Stat. § 2215, which purports to permit the
Attorney General “to appoint a special counsel to investigate any county board member,
department head, an individual running for election, or other government officials.” 2 R.
Stat. § 2215.
16. Subsequently, the Special Counsel began investigating the unknown defendants and
initiated grand jury proceedings.
17. On March 13, 2024, the Special Counsel released a statement informing the public that
the plaintiff, Governor Matrix_oc, has been indicted by a grand jury for conspiring with
two generals of the Ridgeway National Guard to employ unlawful employment practices.
18. Plaintiff was indicted by the grand jury for one count of Conspiracy to Commit a Crime
(R.C.C. § 6.02).
19. As a result of this prosecution, Plaintiff has suffered and continues to suffer irreparable
damage to reputation and has been put in jeopardy of criminal punishment.
FIRST CAUSE OF ACTION
1 R. Stat. § 3201
20. Plaintiff incorporates the allegations within all prior paragraphs within this Complaint as
if they were fully set forth herein.
21. 1 R. Stat. § 3201 provides a cause of action which allows the Superior Court to “review
any ‘policy, order, procedure, or directive’ for whether it is legally or constitutionally
compatible.” Titanic v. Nev, 1 Rid. 80, 89 (2023) (citing 1 R. Stat. § 3201).
22. The Constitution of the State of Ridgeway provides that “There shall be an Attorney
General who is the Chief Prosecutor and Chief Attorney of the State; and shall have the
sole power to prosecute; and to enact other duties as prescribed by law.” Rid. Const., Art.
IV, § V. (emphasis added).
23. The Attorney General’s “sole power” to prosecute vests him with a power that nobody
else may hold.
24. Our Constitution nonetheless expects that the Attorney General will have subordinate
officers who assist in carrying out his lofty duties. However, the prosecutorial power
must ultimately belong to the Attorney General alone. Analogizing to the President of the
United States, “These lesser officers must remain accountable to the President, whose
authority they wield. As [James] Madison explained, ‘[I]f any power whatsoever is in its
nature Executive, it is the power of appointing, overseeing, and controlling those who
execute the laws.’” Seila Law LLC v. Consumer Financial Protection Bureau, 591 U.S.
___, 140 S. Ct. 2183, 2197 (2020) (citing 1 Annals of Cong. 463 (1789)).
25. Section 6.4 of the Judiciary Act, which permits the Attorney General to appoint
unaccountable and wholly independent Special Counsels removable only for cause,
violates Article IV, Section V, of the Constitution of the State of Ridgeway. Specifically,
we take issue with 2 R. Stat. § 2217, 2218, and 2220, each of which intrudes upon
exclusive power of the Attorney General and which makes the Special Counsel
unaccountable.
26. Morrison v. Olsen, 487 U.S. 654 (1988), which held that Congress could provide for the
appointment of an independent counsel outside the supervision of the executive branch,
does not shield defendants’ conduct for two reasons:
a. First, Morrison is wrong — egregiously wrong. The decision ought not be binding
upon this court. The Supreme Court of Ridgeway has made clear that courts
generally should defer to federal or state precedent when there is a mirroring of
rules or clauses. It has not, however, held that these decisions are binding. Justice
Scalia’s powerful dissent in Morrison has borne fruit, and the coercive decision
must be rejected.
b. Second, Morrison is inapplicable to the current case. The Supreme Court held that
an Independent Counsel was constitutional because the Appointments Clause of
Article II says “the Congress may by Law vest the Appointment of such inferior
Officers, as they think proper, in the President alone, in the Courts of Law, or in
the Heads of Departments.” U.S. Const., Art. II, § 2, cl. 2. Since the Court
concluded that the Independent Counsel was an inferior office, his appointment
by a special court created by Congress was lawful. Our Constitution, however,
admits of no difference between principal and inferior officers. Deference to other
courts for guidance on relative issues is done when provisions of our law or
constitution have been obviously derived from some other source. Indeed,
“[o]wing to the mirroring of these rules, this Court tends to rely on federal
precedent to guide its interpretation of relative issues.” 1 Rid. 101, 104 (2023)
(citing Titanic v. Nev, 1 Rid. at 84; State v. Lx1nas, 1 Rid. 46, 46, 51, 52-54
(2023)). “We believe that where a provision from our Constitution has obviously
been derived from a provision of a real-life state constitution, we should adopt the
interpretation of the provision from that state’s highest appellate court.” State v.
Lx1nas, 1 Rid. at 51. The Ridgeway Constitution does not have an appointments
clause obviously derived from the United States Constitution, nor does the latter
have a clause giving the Attorney General the “sole power to prosecute” like the
former. Rid. Const., Art. IV, § V. (emphasis added). Morrison also concerned
intra-branch appointments, while this case deals with unconstitutional
sub-delegation within a single branch. For the aforementioned reasons, Morrison
— even if correct — would be an inappropriate and inapplicable guide on this
issue.
27. As a direct and proximate result of both Defendant’s above-mentioned violation of the
Ridgeway Constitution, Plaintiff has suffered — and continues to suffer — concrete,
non-hypothetical, and irreparable harm.
PRAYER FOR RELIEF
28. WHEREFORE, Plaintiff demands that this Court enter judgment:
a. Declaring that Section 6.4 of the Judiciary Act is unconstitutional under Article
IV, Section V, of the Constitution of the State of Ridgeway OR declaring that 2 R.
Stat. § 2217, 2218, and 2220 are each unconstitutional under Article IV, Section
V, of the Constitution of the State of Ridgeway.
b. Declaring that Special Counsel Stickza was unconstitutionally appointed and that
he lacks any legal authority to prosecute under 2 R. Stat. § 2217 on behalf of the
State of Ridgeway;
c. Declaring that any criminal cases brought by the Special Counsel Stickza were
done so unconstitutionally and unlawfully;
d. Enjoining Attorney General Techiey from enforcing or acting under the entirety
of Section 6.4 of the Judiciary Act or under specifically 2 R. Stat. § 2217, 2218,
and 2220;
e. Enjoining Special Counsel Stickza from invoking any power under the authority
of Section 6.4 of the Judiciary Act, including but not limited to prosecuting any
Plaintiff;
f. Enjoining Special Counsel Stickza from invoking any power under the authority
of 2 R. Stat. § 2217, 2218, and 2220, including but not limited to prosecuting the
Plaintiff;
g. For such other and further relief deemed just and proper by this Court.
Respectfully submitted,
/s/ Totoro987123, Esq.
State Bar No. 17148
Counsel of Record
/s/ Turntable5000, Esq.
State Bar No. 17111
/s/ David Clarke
Managing Partner
Clarke and Associates, LLP
State Bar No. 17134
