STATE OF RIDGEWAY
COUNTY OF RIDGEWAY
IN THE SUPERIOR COURT OF
THE STATE OF RIDGEWAY
Yaahz,
Plaintiff(s),
v.
ab_bae, in their quasi-official capacity
as Sergeant in the Palmer Police
Department
Defendant(s).
Case Number: RSC-CV-3089
Presiding: Hon. Koala4Life
CIVIL COMPLAINT
PLAINTIFF, Yaahz, by and through the undersigned counsel, alleges the following:
JURISDICTION & VENUE
1. The court has jurisdiction to hear “all civil and criminal cases or controversies.”
Ridgeway State Constitution Article V, Section IV.
2. Venue is proper as the tortious actions alleged herein took place in Ridgeway County,
Ridgeway.
PARTIES
3. Yaahz (“Plaintiff”) is a resident of Ridgeway County. He is also a citizen of the State of
Ridgeway—his place of business and personal home address is unknown; but it is
understood that he resides within the applicable jurisdiction as hereinafter referenced and
applied in this case.
4. ab_bae (“Defendant”) is a resident of Ridgeway County. She is also a citizen of the State
of Ridgeway—her personal home address is unknown; but it is understood that she
resides within the applicable jurisdiction as hereinafter referenced and applied in this
case. She is a Police Officer in the Palmer Police Department.
FACTS
5. On June 10th, 2024, The Plaintiff, Yaahz, was legally in his house within the Oakland
Community.
6. Defendant, ab_bae, while on duty as a Palmer Police Officer, acting under the color of
state law, approached Plaintiff's house with several other officers without any probable or
reasonable suspicion that the plaintiff had committed a crime.
7. While the Plaintiff was in his residence, he noticed Law Enforcement was outside.
8. While the plaintiff's car sat outside and had no ties to any criminal activity his vehicle
was searched by the defendant.
9. As the plaintiff had opened the garage to his house the defendant, without reason, shot the
plaintiff when he was unarmed with her taser.
LAW OFFICES OF CLARKE, FEELINGS & ASSOCIATES, LLP.
- 1 -
FIRST CAUSE OF ACTION
Official Misconduct - 1 R. STAT. § 3114
10. Plaintiff repeats and realleges the allegations contained in Paragraphs 1-8 as if fully set
forth herein.
11. “Any individual who is a public servant and commits an act relating to his office but
constitutes an unauthorized exercise of his official functions, knowing that such act is
unauthorized ... shall be liable for compensatory damages; injunctive reliefs restraining
the individual from performing a certain action, or orders instructing the individual to
perform a certain action; and punitive damages up to six thousand dollars ($6,000).” 1
R.S. § 3114
12. The defendant had no legal probable cause in her official capacity to search the plaintiff's
car while it was parked on his property.
13. The defendant willingly searched the vehicle without the plaintiff's prior consent, which
is a 4th amendment violation.
14. The defendant willingly tased the plaintiff having no probable cause or fact that the
plaintiff had, has, or was committing a criminal offense.
15. The defendant then held the plaintiff in detainment without any reasonable or probable
cause present against the plaintiff.
16. "Police may search a vehicle incident to a recent occupant's arrest only if the arrestee is
within reaching distance of the passenger compartment at the time of the search or it is
reasonable to believe the vehicle contains evidence of the offense of arrest." (Arizona v.
Gant, 556 U.S. 332, 351 (2009)).
17. The plaintiff was nowhere near his vehicle or in reach of the vehicle when the defendant
searched the vehicle.
RELIEF
WHEREFORE, Plaintiff requests the court to grant relief to redress the injury as follows:
a. For punitive damages of $6,000 (six-thousand)
b. For punitive damages in an amount sufficient to punish and deter Defendant
from engaging in similar misconduct in the future
c. For such other and further relief as the Court deems just and proper
June 25, 2024 Respectfully submitted,
Br1452232
Counsel of Record
Clarke, Feelings & Associates, LLP.
Junior Associate
R. Bar. No. 16103
Attorney for Plaintiff
LAW OFFICES OF CLARKE, FEELINGS & ASSOCIATES, LLP.
- 2 -
STATE OF RIDGEWAY
COUNTY OF RIDGEWAY
IN THE SUPERIOR COURT OF
THE STATE OF RIDGEWAY
Yaahz,
Plaintiff(s),
v.
ab_bae, in their quasi-official capacity
as Sergeant in the Palmer Police
Department
Defendant(s).
Case Number: RSC-CV-3089
Presiding: Hon. Koala4Life
INITIAL DISCLOSURE
INITIAL DISCLOSURE
PLAINTIFF, Yaahz, by and through the undersigned counsel, submits this document in the
above-entitled matter, pursuant to Rid. Civ. P. 19 and Fed. R. Civ. P. 25.
INITIAL DISCOVERY
Plaintiff submits the following articles as initial discovery as to the tortious claims listed within
the civil complaint, pursuant to Rid. Civ. P. 19:
a. Exhibit A
b. Exhibit B
June 25, 2024 Respectfully submitted,
Br1452232
Counsel of Record
Clarke, Feelings & Associates, LLP.
Junior Associate
R. Bar. No. 16103
Attorney for Plaintiff
LAW OFFICES OF CLARKE, FEELINGS & ASSOCIATES, LLP.
- 3 -
