SUPERIOR COURT OF RIDGEWAY
Civil Action No. RSC-CV-2573
DEFENDANTS’ FULL ANSWER AND AFFIRMATIVE DEFENSES
Pursuant to Rid. R. Civ. P. 7(a), Defendants Techiey, Commissioner_Jason,
DanielReagan, SquareHeadDude, Robloxwolf123, BrandonnLUV, and Matrix_oc
(collectively “Defendants”), proceeding by and through their undersigned counsel,
hereby submits their response to the numbered paragraphs of Plaintiff’s Complaint.
COMPLAINT
The introductory paragraph of Plaintiff’s Complaint contains no substantive
factual arguments and draws legal conclusions to which no response is warranted.
In the event a response is warranted, Defendants deny Paragraph 1.
PARTIES
1. Admitted.
ZACHCASISBEAST,
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,
Defendants.
2. Admitted.
3. Admitted.
4. Admitted.
5. Admitted.
6. Admitted.
7. Admitted.
8. Admitted.
9. Admitted.
10.Admitted.
11.Admitted.
12.Admitted.
13.Admitted.
14.Admitted.
JURISDICTION & VENUE
15.Admitted.
FACTUAL BACKGROUND
16.Admitted.
17.Admitted.
18.Admitted.
19.Admitted/Denied. Defendant admits that the arrest was a ‘seizure’ of Plaintiff.
Defendant denies that such a seizure was unlawful.
20.Admitted.
21.The allegations of the first sentence of paragraph 21 of the Complaint state legal
conclusions that require no answer from Defendants, but to the extent that such
allegations require an answer, they are denied. Defendants deny the allegations
of the second sentence of paragraph 21 of the Complaint.
22.The allegations of the first sentence of paragraph 22 of the Complaint state legal
conclusions that require no answer from Defendants, but to the extent that such
allegations require an answer, they are denied. Defendants deny the allegations
of the second sentence of paragraph 22 of the Complaint.
23.The allegations of the first sentence of paragraph 23 of the Complaint state legal
conclusions that require no answer from Defendants, but to the extent that such
allegations require an answer, they are denied. Defendants deny the allegations
of the second sentence of paragraph 23 of the Complaint.
24.The allegations of the first sentence of paragraph 24 of the Complaint state legal
conclusions that require no answer from Defendants, but to the extent that such
allegations require an answer, they are denied. Defendants deny the allegations
of the second sentence of paragraph 24 of the Complaint.
CLAIMS FOR RELIEF
FIRST CAUSE OF ACTION
(1 R. Stat. § 3201 – Unlawful Policy, Order, Procedure, or Directive)
25.All paragraphs under this heading are denied. Defendants assert that Plaintiffs are
not entitled to any relief.
SECOND CAUSE OF ACTION
(Injunctive Relief)
26.All paragraphs under this heading are denied. Defendants assert that Plaintiffs are
not entitled to any relief.
AFFIRMATIVE DEFENSES
27. Defendants set forth their affirmative defense. By setting forth these affirmative
defenses, Defendants do not assume the burden of proving any fact, issue, or
element of a cause of action.
First Affirmative Defense
28. The First Cause of Action for a violation of the Fourth Amendment to the U.S.
Constitution fails to state a claim upon which relief can be granted because the
allegation set forth in the Complaint, even if presumed as true, would not give
rise to any statutory relief in equity or damages.
Second Affirmative Defense
29. The Second Cause of Action for injunctive relief fails to state a claim upon which
relief can be granted because “injunctive relief” is not a codified civil tort.
Injunctive relief is at all times a mechanism for equitable relief that, in the
ordinary course of civil proceedings, must be requested by a plaintiff by means
of a motion for a preliminary injunction; injunctive relief is not a cause of action.
Third Affirmative Defense
30. Plaintiff lacks standing. Plaintiff lacks standing for a suit against Defendants
because he has not alleged that he has suffered an injury in fact from any of
Defendant’s alleged acts, including allegations of any actual, impending, or
threatened criminal enforcement actions against Plaintiffs. Plaintiff’s allegations
are strictly limited to threadbare recitals of precedent regarding the legality of
checkpoints; they do not allege that Defendants’ conduct actively—or at the time
of the alleged offense—facilitate(s) or effectuate(s) the “unlawful” statute.
PRAYER
WHEREFORE, considering the premises set forth herein, Defendant prays
that his answer be deemed good and sufficient and all claims by Plaintiff against
Defendants be dismissed, with prejudice, and such other and further relief, legal and
equitable, be awarded in favor of Defendant.
Dated: April 15, 2024.
Palmer, Ridgeway.
Respectfully submitted,
/s/ S. Stickza
Stickza
Solicitor General
Ridgeway Department of Justice
1 County Annex
Palmer, Ridgeway 33368
Counsel for Defendant
