SUPERIOR COURT OF RIDGEWAY
Civil Action No. RSC-CV-2654
DEFENDANT IMTHUNDERR’S BRIEF IN OPPOSITION
TO PETITIONER’S APPLICATION FOR HABEAS CORPUS
Respondent ImThunderr, by and through his undersigned counsel,
respectfully asks this Court to dismiss Petitioner’s Verified Complaint and
Application for Habeas Corpus because state law does not entitle him to habeas
relief. In support of these grounds, a brief in opposition is attached below.
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
SEAL_LOVE,
Petitioner,
v.
IMTHUNDERR,
Respondent.
INTRODUCTION
On or about March 15, 2024, Respondent arrested Petitioner for ATM Fraud.
Petitioner subsequently filed a civil action that poses a unique and unprecedent
procedural quagmire. Petitioner seeks relief through this Court’s habeas jurisdiction
and through civil damages, welding two historically independent avenues of relief
into one singular case. In a traditional sense, civil damages are awarded by way of a
codified civil tort. To the contrary, habeas relief is in and of itself an extraordinary
remedy that, on its face, is distinguishable from the ordinary channels of civil
damages. The petition brought before this Court is especially dicey because it asks
this Court to dislodge the textual barrier between Ridgeway’s habeas corpus relief
and statutory damages. For these reasons, this Court should dismiss the Petition.
STANDARD OF REVIEW
In reviewing a petition for habeas corpus, this Court “shall either grant or deny
review of the petition based on its merits.” 1 R. Stat. § 2211. Accordingly, “[t]he
Court may…deny or grant a petition…” Id. Habeas corpus should be denied here.
ARGUMENT
I. Petitioner’s Application for Habeas Relief Should Be Denied.
A. The Provisions of 1 R. Stat. § 2211 Do Not Create a Cause of Action;
Habeas Relief Is Procedurally Incompatible With Civil Claims for Relief.
Ridgeway habeas procedure is particularly unlike federal habeas corpus
proceedings. In contrast to federal procedure which requires a petitioner to be
incarcerated, state procedures position the bar much lower—as long as an arrest was
rendered, a petitioner may challenge its lawfulness. But despite their functional
dissimilarities, both federal and state habeas procedures share one notable common
ground—habeas relief is requested in a manner independently of the traditional
course of civil claims. A joinder of habeas relief under a civil complaint is simply
not acceptable. Indeed, for habeas proceedings to exist at all, “[t]he petitioner [must]
file a petition with the Superior Court…” 1 R. Stat. § 2211. (emphasis added).
1. The Whole-Text Canon Affirms That Habeas Proceedings Are Separate.
The text of state law confirms that the legislature intended to separate habeas
relief from statutory damages—applying the basic canons of statutory construction
confirms this. In doing so, this Court must “presume that a legislature says in a
statute 'what it means' and means in a statute 'what it says there’” Ridgeway Parks
Service, et al. v. SteKing2008, 1 Rid. 1, 6 (2022) (quoting Connecticut Nat. Bank v.
Germain, 503 U. S. 249, 253-254 (1992)). Because the entire text of 1 R. Stat. §
2211 is unequivocally clear in its intent, this Court should construe the text “as a
whole,” considering “the entire text, in view of its structure and of the physical and
logical relation of its many parts.” Scalia & Garner, Reading Law: The
Interpretation of Legal Texts 167 (2012) (emphasis added).
In applying the whole-text canon, we first turn to the legislature’s usage of
“petition” in its habeas statute. Under 1 R. Stat. § 2211, habeas proceedings follow
a specific process, beginning with the filing of a “petition” in the Superior Court.
This term is repeated frequently throughout the habeas statute, clarifying that the
filing of a “petition” initiates habeas proceedings. In this case, Petitioner seeks to
initiate habeas proceedings through a civil cause of action. However, this filing runs
afoul to the clear-cut procedure defined in the habeas statute. Indeed, 1 R. Stat. §
2211 does not permit the filing of habeas corpus through a civil complaint, and it
instead requires that an exclusive petition for writ of habeas corpus be filed.
The legislature knew when it enacted 1 R. Stat. § 2211 that habeas corpus was
separate from the traditional avenues of civil litigation; in fact, the legislature has
used the term “civil complaint” nonsynonymous with “petition.”1 And “[w]hen the
legislature uses certain language in one part of the statute and different language in
another,” the court assumes “different meanings were intended” Sosa v. Alvarez-
Machain, 542 U.S. 692, 712 n.9 (2004) (quoting 2A N. Singer, Statutes and Statutory
Construction § 46:06, p. 194 (6th ed. 2000)). Here, the construction is no different—
the legislature’s liberal usage of “civil complaint” in other statutes indicates that it
carries a different meaning than “petition.”2 As such, it is clear that the legislature
1 See e.g., 1 R. Stat. §§ 2403, 2404, 2405, and 2406.
2 “A provision that may seem ambiguous in isolation is often clarified by the remainder of the
statutory-scheme because the same terminology is used elsewhere in a context that makes its
meaning clear.” United Sav. Ass'n of Tex. v. Timbers of Inwood Forest Assocs., Ltd., 484 U.S. 365,
371 (1988) (cleaned up). In this context, the use of “civil complaint” in statutes concerning court
proceedings indicates that it is distinct from a “petition” for habeas corpus.
intended for habeas corpus to be initiated through different means—that is, of
course, through a petition for habeas corpus, not a civil complaint.
The whole-text inquiry of 1 R. Stat. § 2211 comes to an end when its logical
relation is considered. The structure of the statute indicates that its contents were
meant to be separate from the traditional avenues of civil litigation. That is, of
course, why the legislature did not amalgamate habeas corpus relief under the Civil
Claims Act (“S1.3”). If habeas corpus relief was meant to take form as a cause of
action, the legislature would have made its inclusion patently clear. However, it did
not include habeas relief in S1.3, and for good reason. After all, a petition for habeas
corpus must be specific in its contents. Furthermore, the courts are limited in the
relief that it may issue for habeas corpus.3 Because the language and structure of 1
R. Stat. § 2211 sets apart the filing of habeas corpus from that of civil cases, this
Court must reject any attempt to fuse the two independent proceedings together,
effectively denying habeas corpus in this case.
CONCLUSION
For the foregoing reasons, this Court should deny habeas corpus.
See signature block below
3 See 1 R. Stat. § 2212 ((i) The only remedies for all petitions under this subsection are: (a)
Immediate release from prison or detainment; or (b) Expungement of record).
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
