SUPERIOR COURT OF RIDGEWAY
Civil Action No. RSC-CV-2789
DEFENDANT W6STER’S BRIEF IN OPPOSITION
TO APPLICATION FOR HABEAS CORPUS
Respondent W6ster, by and through the Solicitor General of the State of
Ridgeway, respectfully asks this Court to dismiss Petitioner’s 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 hereto.
Dated: May 7, 2024.
Palmer, Ridgeway.
Respectfully submitted,
/s/ S. Stickza
Stickza
Solicitor General
Ridgeway Department of Justice
1 County Annex
Palmer, Ridgeway 33368
Counsel for Defendant
SUPERCYBER,
Petitioner,
v.
W6STER,
Respondent.
FACTUAL BACKGROUND
On the evening of April 25, 2024, Lieutenant W6ster switched on his lights
and sirens, kicked his vehicle into gear, and swiftly jumped into action to respond to
a high-speed chase involving numerous law enforcement agencies. He was in a
remote area surrounded only by a freeway and foliage, leaving him with little options
to respond quickly. Despite the narrow obstacles of his environment, Lieutenant
W6ster hopped on the freeway and began driving at high speeds to respond to the
pursuit. As he was driving the three-lane highway, his patrol vehicle quickly
approached a curb. But Lieutenant W6ster’s vision was faint, and he could not see
what was behind the curve. Unbeknownst to him, Petitioner Supercyber was about
to turn at the curve, showing no signs of stopping. Both vehicles collided, and
Lieutenant W6ster was disabled from responding to the pursuit.
ARGUMENT
I. Petitioner’s Application for Habeas Relief Should Be Denied.
A. Petitioner’s construction of the traffic code is fundamentally flawed.
Section 7.02 of the Ridgeway Traffic Code criminalizes the act of operating a
motor vehicle and “committing three or more traffic infractions * * * or striking
another vehicle.” Rid. Tr. C. § 7.02. At first glance, Section 7.02 applies to drivers
who commit three or more infractions or strike another vehicle. In function, one of
the two offenses—either committing traffic infractions or striking a vehicle—does
not need to occur before the statute is legally enforceable. If a driver commits one
offense but does not commit the other, he is still accountable for the former offense.
The petitioner asserts that the enforcement of Traffic Code 7.02 in his arrest
is “absurd” because it “produces a result ‘so gross as to shock the general moral or
common sense.’” P. App. Hab. ¶ 12. To that point, “interpretations of a statute which
would produce absurd results are to be avoided if alternative interpretations
consistent with the legislative purpose are available.” Griffin v. Oceanic
Contractors, Inc., 458 U.S. 564, 575 (1982). Here, the as-applied interpretation of
Traffic Code 7.02 is not absurd, and this Court need not exhaust—nor exert—its
judicial authority to rewrite a patently clear statute.
1. Judicial construction of the traffic code is not necessary because the plain
meaning of its language is clear and unambiguous.
It is a well-established canon of statutory construction that a court “should go
beyond the literal language of a statute if reliance on that language would defeat the
plain purpose of the statute.” Bob Jones University v. United States, 461 U.S. 574,
586 (1983). Indeed, in certain circumstances, “the absurdity doctrine * * * justifies
[the] departure from the general rule that courts will apply a statute's plain language.”
See State v. Hackley, 95 So. 3d 92, 95 (Fla. 2012) (non-binding precedent). But
immediately applying the absurdity canon would jump the gun and blatantly
disregard the plain meaning of the statute—plain language is always the first judicial
inquiry in statutory construction. See Lamie v. United States Trustee, 540 U.S. 526,
534 (2004) (“[O]ur analysis begins with the plain language of the statute.).
When statutory language is plain, the courts must “enforce it according to its
terms.” Id. At issue here is whether Traffic Code 7.02 criminalizes the act of striking
an emergency vehicle while it is responding to an emergency situation. Like in all
situations where an emergency vehicle is utilizing its lights and sirens, “[t]raffic shall
be required to yield to emergency vehicles.” 7 R. Stat. § 3501. In some cases,
emergency vehicles use the opposite side of the road to continue on their way. And,
like here, when an emergency vehicle utilizes a clear side of the road to respond to
an emergency, traffic law still applies to other motorists, and they must yield.
The language of Traffic Code 7.02—in conjunction with the language of laws
in pari materia—confirms that even in rare cases when a police officer has to jump
the curb and utilize the wrong side of the road, motorists must yield if he is utilizing
his lights and sirens.1 If you strike the officer’s vehicle as a result of failing to yield
to him, your driving is reckless for two reasons—first, Traffic Code 7.02 makes it a
crime to recklessly strike a vehicle; second, failing to yield to an emergency vehicle
is punishable under Traffic Code 7.12. Either way it is analyzed, a police car, fire
truck, and ambulance are all vehicles within the meaning of Traffic Code 7.02. Thus,
1 “Odd or unexpected consequences aren’t enough” to apply the absurdity doctrine and rewrite a
statute. Scalia & Garner, Reading Law: The Interpretation of Legal Texts 234 (2012).
the Legislature’s plain purpose is reflected in the language—motorists are criminally
liable when they strike a vehicle—emergency or not—because of their recklessness.
CONCLUSION
The plain language of Traffic Code 7.02 unequivocally discards the necessity
of applying the absurdity doctrine here; indeed, the traffic code is clear in its intended
function. For the reasons listed above, this Court should deny habeas corpus.
Dated: May 7, 2024.
Palmer, Ridgeway.
Respectfully submitted,
/s/ S. Stickza
Stickza
Solicitor General
Ridgeway Department of Justice
1 County Annex
Palmer, Ridgeway 33368
Counsel for Defendant
