1
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
IN THE SUPERIOR COURT OF
THE STATE OF RIDGEWAY
Robin5D,
Plaintiff,
v.
KeenPack, in their quasi-official capacity as a
Trooper,
Defendant.
Case No. RSC-CV-2780
Complaint in a Civil Action
Hon. Judge koala4life
Plaintiff, in pro per, alleges, for their complaint against the defendant, as follows:
PARTIES
1. Plaintiff Robin5D is a resident of the State of Ridgeway.
2. Defendant KeenPack is a resident of the State of Ridgeway and a Trooper of the
Ridgeway State Police.
JURISDICTION AND VENUE
3. Plaintiff invokes the jurisdiction of the Superior Court contained in Article V, Section IV
of the state Constitution, giving jurisdiction for “all civil or criminal cases.”
4. Venue is proper as the conduct involved took place within Ridgeway County.
ESSENTIAL FACTS
5. On May 1, 2024, Plaintiff was standing idle in the parking lot of Bloxmart, located with-
in the City of Palmer.
6. At 4:22 pm (UTC-7), an individual by the name of Olivia_Pope (hereinafter “Assailant”)
drove into the parking lot of Bloxmart, parking their vehicle directly adjacent to
Plaintiff’s position.
7. Assailant exited their vehicle, proceeding to begin battering Plaintiff with a crowbar,
aa
2
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
inflicting serious injuries.
8. Upon Plaintiff gaining awareness of the battery-in-progress, Defendant began to flee to
avoid being fatally injured by Assailant.
9. While fleeing Assailant, Plaintiff withdrew a Wesler shotgun, firing in the direction of
Assailant with one round. Immediately after firing, within one second, Plaintiff holstered
the firearm.
10. After Plaintiff holstered their firearm, within three seconds, Defendant withdrew a Para
17 handgun, firing upon and fatally injuring Plaintiff.
CAUSES OF ACTION
COUNT 1
1 R. Stat. § 3114 – Official Misconduct
11. Plaintiff incorporates all essential facts as part of this cause of action.
12. Under 1 R. Stat. § 3114, official misconduct constitutes “an unauthorized exercise of his
official functions, where a reasonable person with his training, expertise, and experiences
should know that such act is unauthorized.”
13. Defendant violated State Police policy through an excessive use of lethal force against
Plaintiff. See State Police Dept. Policy Guide § 306-2(c)(5); “such level of force is
specifically reserved for circumstances in which a subject presents a threat towards the
life of peace officers or others around them.”
14. At no point did Plaintiff present a threat towards the life of peace officers or others, other
than Assailant. Plaintiff was engaging in an act of self defense against an active threat.
See See State Police Dept. Policy Guide § 306-3; “troopers shall use only an amount of
force which reasonably appears necessary given the facts and totality of the
circumstances known to or perceived by the trooper at the time of the time of the event.”
15. Lethal force against an individual defending himself from a lethal threat would at no
point “reasonably appear necessary”, especially after Plaintiff holstered their firearm.
aa
3
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
16. A violation of State Police policy constitutes an “unauthorized exercise [of] official
functions.” Departmental policy describes all authorized exercise of official functions.
17. Plaintiff suffered “concrete injury” from the use of lethal force, as it resulted in his death
and loss of firearms.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff prays that the Court–
18. Award Plaintiff compensatory damages in the cost of a Wesler shotgun ($150), Cline 911
handgun ($235), three boxes of shell ammunition ($99), and three boxes of nine
millimeter (9mm) ammunition ($75), totaling five hundred and fifty-nine dollars ($559);
19. Award Plaintiff six thousand ($6000) dollars in punitive damages;
20. Award Plaintiff all costs of litigation, including court fees;
21. Award Plaintiff any additional relief not requested herein that the Court may determine to
be reasonable.
Dated this 3rd day of May, 2024.
Respectfully submitted,
/s/ Robin5D
Robin5D
4500 Magellan Way
Sterling, Ridgeway
aa
4
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
APPENDIX A
Video: https://streamable.com/56f5u2
• 00:00 – 00:04: Plaintiff stands idle.
• 00:05: Assailant drives adjacent to Plaintiff, parking.
• 00:07 – 00:08: Assailant batters Plaintiff with a crowbar.
• 00:09: Plaintiff flees, drawing a Wesler shotgun.
• 00:10: Plaintiff fires upon the vehicle of Assailant.
• 00:13: Plaintiff is killed by Defendant with a Para 17 handgun.
aa
