IN THE SUPERIOR COURT OF THE STATE OF RIDGEWAY
ZACHCASISBEAST )
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DOCKET NO. RSC-CV-2573
Plaintiff
v.
TECHIEY; DEPARTMENT OF JUSTICE;
COMMISSIONER_JASON; PALMER
POLICE DEPARTMENT;
DANIELREAGAN; RIDGEWAY
COUNTY SHERIFF’S OFFICE;
SQUAREHEADDUDE; STATE POLICE;
ROBLOXWOLF123; RIDGEWAY PARKS
SERVICE; BRANDONNLUV; RIDGEWAY
NATIONAL GUARD; MATRIX_OC
Defendant
COMPLAINT
On April 3, 2022, the Senate of the State of Ridgeway passed the Checkpoint Act and the
Governor immediately signed it 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. Defendant Techiey is the Attorney General of the State of Ridgeway. He is sued in his
official capacity.
3. Defendant Department of Justice is an Executive Department of the state government.
4. Defendant Commissioner_Jason is the Chief of Police of the Palmer Police Department.
He is sued in his official capacity.
5. Defendant Palmer Police Department is a Homeland Security Department of the state
government.
6. Defendant DanielReagan is Sheriff of the County of Ridgeway. He is sued in his official
capacity.
7. Defendant Ridgeway County Sheriff’s Office is a Homeland Security Department of the
state government.
8. Defendant mattcern is Superintendent of the Ridgeway State Police. He is sued in his
official capacity.
9. Defendant State Police is a Homeland Security Department of the state government.
10. Defendant robloxwolf123 is the Superintendent of the Ridgeway Parks Service. He is
sued in his official capacity.
11. Defendant Ridgeway Parks Service is a Public Welfare Department of the state
government.
12. Defendant BrandonnLUV is the Major General of the Ridgeway National Guard. He is
sued in his official capacity.
13. Defendant Ridgeway National Guard is a Military Department of the state government.
14. Defendant Matrix_oc is the Governor of the State of Ridgeway. He is sued in his official
capacity.
JURISDICTION AND VENUE
15. 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.
16. 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.
17. 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.
18. Failure to Identify makes it a crime to fail “to present identification to a peace officer
after having been [sic] lawfully detained.”
19. The detention caused and created 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.
20. 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.
21. 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.
22. 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).
23. 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.
24. 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
25. 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
26. The plaintiff is entitled to a permanent injunction prohibiting the Defendants from
enacting the Act’s unconstitutional seizure.
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. Issue permanent injunctive relief enjoining the Defendants prohibiting them from
enacting 6 R. Stat. § 6102.
3. Award such other relief as the Court deems equitable and just.
Respectfully submitted.
Plaintiff ZachCasisbeast
