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IN THE SUPERIOR COURT OF RIDGEWAY
ZONED_ JJ,
Petitioner,
v.
O_RANGEGAMING,
Respondent.
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Civil Claim No. RSC-CV-3395
BR IE F I N OP P O SIT IO N
Respondent O_RANGEGAMING, by and through the Solicitor General of Ridgeway, hereby
files a brief in opposition to the Petitioner’s Writ of Habeas Corpus pursuant to 1 R. Stat. § 2211.
STA NDA R D O F REV I EW
In reviewing a petition for habeas corpus, a court of competent jurisdiction “shall either
grant or deny review of the petition based on its merits.” 1 R. Stat. § 2211. Accordingly, “[t]he
Court may...deny or grant a petition...” Id. If habeas corpus is issued, courts will next determine
“whether the police were lawfully entitled to make [the] arrest.” In re Zachcasisbeast, 1 R. Supp., at
12 (2022). That is, if the police officer “had probable cause that a crime was committed.” Id. If the
arrest was unlawful, “the inquiry ends there; the record must be removed.” Id. But if the arrest was
lawful, the next question is whether the applicant is “actually innocent of the charge or charges for
which they were arrested.” Id. The arrest here is lawful, and there is no present need to debate the
scope of “Obstruction of Justice”—it is clear enough.
ARGUM E NT
I. OB ST RU C T IO N O F JUST I C E RE FE R S TO TH E PR EVE NT I O N O F ANY
OF FI C IA L FRO M DO I N G HIS JO B , NO T JU ST CO U RT PRO C E E DI N G S.
Petitioner was arrested for Obstruction of Justice after he swerved his car in front of a police
car engaged in a pursuit. The elements of that statute require an individual to “interfere[e] with the
process of justice and hinder[] any county official or law enforcement officer from performing their
duties.” Rid. Crim. C. § 2.07. He challenges that arrest on the grounds of vagueness. In his view,
the statute is unclear about what constitutes a “process of justice.” Id. Applying the plain meaning
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rule, the petitioner contends that the obstruction of justice statute only criminalizes conduct that
interferes with “[activities] relating to a judicial process.” Pet. at ¶ 12. That contention is wrong.
When statutory language is straightforward, “interpretation has no business getting
metaphysical.” Lexecon Inc. v. Milberg Weiss Bershad Hynes Lerach, 523 U.S. 26, 37 (1998). That is
why “plain, obvious, and rational [language]...is always to be preferred to any curious, narrow,
hidden [language].” Im_Thunder v. Nephral, 3 Rid. ___ (2024). If the language is clear, the inquiry
“ends there...” Hughes Aircraft Co. v. Jacobson, 525 U.S. 432, 438 (1999). The petitioner’s
interpretation is as metaphysical as it gets. Instead of constructing the statute with its actual terms,
he relies on unconvincing common law interpretations to define a statute. But “[j]udges do not
make legislative policies.” Bradley v. United States, 410 U.S. 605, 613 (1973). Nor should they.
Indeed, their review stops short of making the law but extends to declaring. See Fowler v. Lindsey,
3 U.S. 411, 414 (1799) (“[It] is the duty of judges to declare, and not to make the law.”).
Across the Republic, an obstruction of justice statute has never carried the meaning that the
petitioner assigns it today. East of the Rio Grande, obstruction of justice is defined as “intentionally
prevent[ing] or obstruct[ing] a person he knows is a peace officer…” Tex. Pen. C. 8, 38(38.03). In
New York, obstruction is the act of “obstruct[ing]…or pervert[ing] the administration of law or
other governmental function or prevents or attempts to prevent a public servant from performing
an official function, by means of…physical force or interference.” New York Penal Law § 195.05.
These are just two examples—among others—that parallel Ridgeway’s obstruction of justice
statute. Plainly applied, the statute clearly works to prevent a person from obstructing—or
inadvertently preventing—a public officer from performing some ministerial duty—from serving
“justice.” Especially in law enforcement officers.
CO NC LUSIO N
For the foregoing reasons, this Court should deny the petitioner’s writ of habeas corpus.
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Dated: August 9, 2024
Palmer, Ridgeway.
Respectfully submitted,
/s/ S. Stickza
Stickza
Solicitor General
Ridgeway Department of Justice
1 County Annex
Palmer, Ridgeway 33368
