THE STATE OF RIDGEWAY
RIDGEWAY SUPERIOR COURT
Activated113,
Plaintiff,
v.
Canyoudrown, Patrol Officer in the
Palmer Police Department, in his
quasi-official capacity.
Defendant.
Case No. RSC-CV-3038
Presiding: Hon. Koala4Life
CIVIL COMPLAINT
Plaintiff Activated113 (“Plaintiff”), by and through his undersigned counsel,
hereby brings this action against Defendant Canyoudrown (“Defendant”) in his
individual and official capacity and to substantiate his action alleges the following:
STATEMENT OF FACTS
1. On or about the 11th of June, 2024, Plaintiff was standing roughly in the
middle of a marked crosswalk near the RNG Recruitment Center in Palmer,
Ridgeway County, State of Ridgeway.
2. While standing on the marked crosswalk, Defendant, in his police vehicle,
which reads “PALMER POLICE” on the side, completes a right turn onto
the road near the RNG Recruitment Center.
3. Defendant parks his police vehicle and begins walking towards Plaintiff.
4. Another car completes a right turn, onto the same road Defendant turned
into, demonstrating that vehicles had the ability to complete their turn
despite the Plaintiff’s presence.
5. Defendant approached Plaintiff, and Plaintiff returned to the sidewalk to
speak with Defendant.
6. Defendant pulled out his citation book and cited Plaintiff with Obstruction of
Traffic, a citation which stipulates six-hundred-and-fifty dollars ($650).
7. Obstruction of Traffic, as defined by Title 7, Subtitle 23 of the Ridgeway
State Vehicle Code is; “The act of intentionally preventing motor vehicles
from passing freely along a roadway, entering and exiting a roadway, or
hindering the regular flow of traffic. This includes obstruction of entrance
and exit points for both private and public property”.
8. Defendant is a certified peace officer by the Law Enforcement Training
Center (“LETC”) and has completed comprehensive training and education
there. Defendant
9. The LETC and/or, the Palmer Police Department, as part of their training
curriculums include education and/or training on the requirements for a
citation to be issued.
10. Plaintiff’s actions did not constitute the actions required to be cited for
Obstruction of Traffic, and Defendant knew he had no proper legal cause to
issue the citation to the Plaintiff.
11. Plaintiff, as a result of this citation, faced monetary loss.
VENUE
12. 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...”
13. Venue is proper as the actions occurred within Ridgeway County, which is a
county located in the State of Ridgeway.
PARTIES
14. Plaintiff Activated113, is a citizen and resident of the State of Ridgeway
15. Defendant canyoudrown, is a citizen and resident of the State of Ridgeway
and a Patrol Officer with the Palmer Police Department.
FIRST CAUSE OF ACTION
1 R. Stat § 3114
Official Misconduct
Against Defendant canyoudrown
16. Plaintiff incorporates the allegations within all prior paragraphs as if they
were fully set wherein.
17. Whereas, State law protects citizens from being victims of Official
Misconduct;
18.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.”
19. Defendant, exercising his official functions in an unauthorized manner,
fined Plaintiff for a crime he did not commit. Defendant was fully aware that
his actions were unauthorized due to his LETC certification.
20. 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 to be calculated at trial;
B. Plaintiff requests three-thousand dollars ($3000) in punitive damage;.
C. For declaratory judgment that Defendant’s conduct was unauthorized
and exceeded the scope of their authority.
D. For such other, or further, or different legal and equitable relief the
Court may deem necessary.
CENTER FOR INDIVIDUAL RIGHTS
/s/________________________
Rummy, Esq.
Ridgeway Bar No.28110
Counsel of Record
Advocate,
Center for Individual Rights
