Ridgeway Unified Courts

JUDICIAL COUNCIL OF RIDGEWAY

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THE STATE OF RIDGEWAY RIDGEWAY SUPERIOR COURT UN91570135 (formerly known as nyyple), Plaintiff, v. Tactical_Joe, Corporal in the Palmer Police Department, in his quasi-official capacity. Defendant. Case No. RSC-CV-3000 CIVIL COMPLAINT Presiding Judge: AlexJCabot Plaintiff UN91570135, formerly known as nyyple, (“Plaintiff”), by and through her undersigned counselors, hereby brings this action against Defendant Tactical_Joe (“Defendant”) in his individual and official capacity and to substantiate her action alleges the following: STATEMENT OF FACTS 1. On or about 2nd June 2024, Plaintiff was crossing a road at or near Sterling Heights, Ridgeway County after paying bail for a prior arrest. 2. While Plaintiff crossed the road, Defendant swerved around Plaintiff while having activated emergency lights and siren prior. 3. Defendant, after crashing his police vehicle, then turned his police vehicle around and crashed it into a fence near the Plaintiff. 4. Defendant proceeded to exit his vehicle, taking out his Conducted Electrical Weapon (CEW) - albeit Plaintiff showed no threat toward Defendant - and aimed it at Plaintiff. 5. Plaintiff was then handcuffed, and thereby detained on scene. 6. Defendant then forcibly placed Plaintiff in the back of his police vehicle which display the words “PALMER POLICE”. 7. Defendant then stated “What the hell are you doing” followed by “Yield to an LEO dude” and “I’m in a purs”. 8. Defendant failed to state reasonable grounds to make the detainment, as failure to yield to a law enforcement officer is not an arrestable offense. 9. Plaintiff was detained without legal cause. 10. Plaintiff did not have any warrants at the time of the detainment nor a BOLO (Be On the Look Out) order. 11. Defendant did not arrest the Plaintiff as Plaintiff committed no arrestable offense. 12. Defendant is certified as a peace officer by the Law Enforcement Training Institute (“LETC”) and has completed comprehensive training and education there. 13. The LETC, as part of its curriculum, includes education and/or training on the requirement of probable cause or reasonable suspicion to detain an individual. 14. Defendant did not have probable cause or reasonable suspicion to detain Plaintiff, and Defendant knew he had no probable cause or reasonable suspicion to lawfully detain Plaintiff. VENUE 15. This Court has original jurisdiction over this Complaint under Article V, Section IV of the Ridgeway Constitution; “There shall be a superior court which shall exercise original jurisdiction for all civil and criminal cases…” 16.Venue is proper as the tortious actions occurred within Ridgeway County, which is a county located in the State of Ridgeway. PARTIES 17. Plaintiff UN91570135, formerly known as nyyple, is a citizen and resident of the State of Ridgeway. 18. Defendant Tactical_Joe is a citizen and resident of the State of Ridgeway and a Corporal with the Palmer Police Department. FIRST CAUSE OF ACTION 1 R. Stat § 3104 False Imprisonment Against Defendant Tactical_Joe 19. Plaintiff incorporates the allegations within all prior paragraphs within this Complaint as if they were fully set wherein. 20. Whereas, the Ridgeway Constitution protects citizens against deprivation of liberty without due process, stating “...nor can any person be justly deprived of liberty…” Rid. Const. Art. I, Sec VI. 21. Whereas, false imprisonment is defined in 1 R. Stat § 3104 as “without legal authority or justification, restrains or restricts a person's movement within an area”. Defendant, “without legal authority or justification” “restrain[ed]” the Plaintiff’s “movement within an area”, and thus falsely imprisoned her. 22. Plaintiff is entitled to compensatory and punitive relief. SECOND CAUSE OF ACTION 1 R. Stat § 3114 Official Misconduct Against Defendant Tactical_Joe 23. Plaintiff incorporates the allegations within all prior paragraphs within this Complaint as if they were fully set wherein. 24.Whereas, Official Misconduct is defined in 1 R. Stat § 3104 as “Any individual who is a public servant and commits an act relating to his office but 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; or refrains from performing a duty which is imposed upon him by law or is clearly inherent in the nature of his office.” 25.See paragraph 20. 26. Defendant detained Plaintiff without probable cause or reasonable suspicion of committing any crime and thus violated Plaintiff’s rights to liberty protected by the Ridgeway Constitution by falsely imprisoning her. Defendant’s actions were unauthorized, and Defendant was aware of this due to his educational background in the LETC. 27. Plaintiff is entitled to punitive, compensatory and injunctive relief. PRAYERS FOR RELIEF WHEREFORE, the Plaintiff prays for judgment against Defendant as follows– A. For awardment of compensatory damages; B. For awardment of punitive damages amounting to six-thousand-five-hundred dollars ($6500); C. For declaratory judgment that Defendant’s conduct was unauthorized and exceeded the scope of their authority. D. For a declaration affirming that Defendant’s actions were unauthorized under law, and department policy. E. For such other, or further, or different legal and equitable relief the Court may deem necessary. CENTER FOR INDIVIDUAL RIGHTS /s/______________________ Singhski, Esq. Ridgeway Bar No.25100 Counsel of Record President, Center for Individual Rights T: (505) 503-4455 E: [email protected] D: singhski /s/___________________ ChiefAuror, Esq. Ridgeway Bar No. 28101 Co-Counsel Center for Individual Rights

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