STATE OF RIDGEWAY
COUNTY OF RIDGEWAY
IN THE SUPERIOR COURT OF
THE STATE OF RIDGEWAY
BLOXWATCH_CD; VARKRUS,
Petitioner(s),
v.
PALMER POLICE DEPARTMENT, a
municipal-level law enforcement
agency,
Respondent(s).
Case Number: RSC-AD-2774
Presiding: Hon. jyoungbird
ADMINISTRATIVE CLAIM
ADMINISTRATIVE CLAIM
PLAINTIFF, BloxWatch_CD, and Varkrus, by and through the undersigned counsel,
seeking all available relief, in their complaint against the defendants, alleges the following:
INTRODUCTION
1. The Palmer Police Department has unlawfully denied the applications of eligible
applicants under the guise of failing their background checks, due to the “likelihood” that they
are alternate accounts.
2. This process—one which is shrouded in secrecy—has been used to deny the
applications of both BloxWatch_CD and Varkrus, and presumably many others throughout the
many employment cycles of the Palmer Police Department.
3. Undoubtedly, both individuals are well-respected tenants of this community. Of
course, despite their many difficulties in gaining employment into the Palmer Police Department,
they have both achieved many other certifications and careers—including those of which require
a successful background check.
4. It is clear that these are not mere mistakes, they are deliberate infringements on
the rights of qualified individuals. In fact, Commissioner_Jason, the Chief of the Palmer Police
Department, received a letter addressing the unfair hiring practices of the department. Despite
being sent a letter, the Palmer Police Department has failed—and ultimately cannot—provide a
reason which is in line with the employment laws in our state. No response or action has been
taken to address the concerns raised.
5. Unfortunately, this isn’t a new concept—departments and agencies alike have
long been sued over their unreasonable employment standards. Today, however, we seek
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injunctive and declaratory relief in order to repair the clear infringements of the rights of the
applicants.
JURISDICTION & VENUE
6. The administrative court has jurisdiction to hear “all civil claims involving
administrative action, or policy, or rules of a government agency.” 2 R. Stat. § 3305.
7. The administrative court has the jurisdiction to “review…prejudicial hiring
practice.” 2 R. Stat. § 3301.
8. The administrative court may grant “equitable remedy as necessary to ensure
proper enforcement of law.” 2 R. Stat. § 3307. Further, the administrative court may grant
“declaratory relief when necessary.” 2 R. Stat. § 3308.
9. Venue is proper as the tortious actions alleged herein took place in Ridgeway
County, Ridgeway.
PARTIES
10. BloxWatch_CD (“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.
11. Varkrus (“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.
12. Palmer Police Department (“Defendant”) (hereinafter the “Department”, “PPD”)
is a municipal-level law enforcement agency, responsible for, among other things, general patrol
duties and county hall protection. The Palmer Police Department is a “primary agency” as
defined by 2 R. Stat. § 3201. Defendant is sued under 2 R. Stat. § 3241.
FACTS
I. Employment Cycle
13. On or about March 31st, 2024, the Palmer Police Department opened employment
applications for a “non-competitive” hiring round, as defined by 2 R. Stat. § 3226.
14. On or about April 7th, 2024, the Palmer Police Department closed employment
applications.
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15. The Palmer Police Department employs an “application tracker” which is hosted
on Google Sheets.
16. Upon applying, all applicants are required to pass through three stages found on
the application tracker.
17. The first stage applicants must pass is the “primary screening” stage, which is a
“review of basic applicant requirements.”
18. The second stage is the “application review” stage, which is a “careful, full
review of [the] application and its contents.”
19. The third stage is the “background check” stage, which is conducted by the
Special Investigations Unit.
20. Of course, the fourth and final stage is the “final review” stage. Using data from
the previous stages, “the committee and department high command…take[s] a final look at
everything and vote[s] on whether to pass [or] fail the applicant.”
21. If an applicant fails their background check stage, they are, emphatically—in
capital, red, and underlined letters—directed to “NOT DM ANYONE REGARDING YOUR
BACKGROUND CHECK OUTCOME.”
II. BloxWatch_CD
22. On or about April 6th, 2024, Plaintiff BloxWatch_CD applied for employment in
the Palmer Police Department during their employment cycle, in a good-faith effort to expand his
opportunities, service his community, and earn an income.
23. Plaintiff BloxWatch_CD passed the “primary screening” stage.
24. Plaintiff BloxWatch_CD passed the “application review” stage, with Sergeant
zac2524 commenting that he “ha[s] a good understanding of law enforcement” and that “it would
be nice to see [him] return.”
25. On or about April 13th, 2024, Plaintiff BloxWatch_CD was denied the
opportunity to work at the Palmer Police Department having been denied employment due to his
background check being denied.
26. On or about the same day, the reason for the denial of the background check was
because of the “likelihood that the individual is an alternate account,” in accordance with 2 R.
Stat. § 3235, at ¶i.
27. The account of Plaintiff BloxWatch_CD was created on September 17th, 2017.
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28. Throughout his years on the platform, he has gained around 56 friends, 6
followers, and around 190 different badges. Further, he has joined around 40 groups and
favorited 11 games—undoubtedly, these are not the statistics of an alternate account.
29. Plaintiff BloxWatch_CD is not an alternate account.
30. Plaintiff BloxWatch_CD has his inventory open and viewable to the public. It was
open at the time that he applied, during the time in which the application was reviewed, and
remains open to this day.
31. Plaintiff BloxWatch_CD has no criminal records. He is not involved in a criminal
or terrorist organization. Further, he has never been convicted in a court of law.
32. Plaintiff BloxWatch_CD is a former Senator.
33. Plaintiff BloxWatch_CD has formerly been employed by the Palmer Police
Department as a Patrol Officer on two occasions, from May 28th, 2023 to August 11th, 2023;
and from September 27th, 2023 to February 1st, 2024. On all occasions, he was discharged
honorably.
34. Plaintiff BloxWatch_CD is currently employed by the Ridgeway Park Service as a
Park Ranger I.
35. Plaintiff BloxWatch_CD has a law enforcement certification granted by the Law
Enforcement Training Institute.
36. Plaintiff BloxWatch_CD has no moderation against him.1
37. Plaintiff BloxWatch_CD has never been extremely toxic or openly committed any
crime outside of the community, he strives to be the best and kindest that he can be.
38. In order to deny Plaintiff BloxWatch_CD for being an alternate account, there
must be a reasonable likelihood that he is indeed an alternate account.
39. Undoubtedly, the denial of the application of Plaintiff BloxWatch_CD prevents
him from advancing his career in the future as well as earning an income and servicing the
public.
40. The background check—and further, the application—of Plaintiff
BloxWatch_CD, was denied in a way inconsistent with the law.
1 “RidgewayWS | Moderation.” Ridgeway County, https://moderation.ridgewaycounty.org/lookup. Accessed 28 Apr.
2024.
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III. Varkrus
41. On or about April 2nd, 2024, Plaintiff Varkrus applied for employment in the
Palmer Police Department during their employment cycle, in a good-faith effort to expand his
opportunities, service his community, and earn an income.
42. Plaintiff Varkrus passed the “primary screening” stage.
43. Plaintiff Varkrus passed the “application review” stage, with Acting Sergeant
Xotlkz commenting that the application was good, stating that it was “not bad but not amazing
either,” but praising his “accurate” and “excellent knowledge” and further “wish[ing] [him] the
best of luck throughout the application process and the department overall.”
44. Similarly to Plaintiff BloxWatch_CD, on or about April 13th, 2024, Plaintiff
Varkrus, was denied the opportunity to work at the Palmer Police Department having been
denied employment due to his background check being denied.
45. On or about the same day, the reason for the denial of the background check was
because of the “likelihood that the individual is an alternate account,” in accordance with 2 R.
Stat. § 3235, at ¶i.
46. The account of Plaintiff Varkrus was created on September 7th, 2014.
47. Throughout his years on the platform, he has gained around 49 friends, multiple
different followers, and hundreds of different badges. Further, he has joined around 92 groups
and favorited 93 games—similarly to Plaintiff Varkrus, these are not the statistics of an alternate
account.
48. Plaintiff Varkrus is not an alternate account.
49. Plaintiff Varkrus has his inventory open and viewable to the public. It was open at
the time that he applied, during the time in which the application was reviewed, and remains
open to this day.
50. Plaintiff Varkrus has no criminal records. He is not involved in a criminal or
terrorist organization. Further, he has never been convicted in a court of law.
51. Plaintiff Varkrus was formerly employed by the Ridgeway National Guard as a
Sergeant. He was discharged honorably.
52. Plaintiff Varkrus was formerly employed by the Ridgeway County Sheriff's Office
as a Sheriff Deputy. He was discharged honorably.
53. Plaintiff Varkrus is currently employed by the Ridgeway Park Service as a Park
Ranger I.
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54. Plaintiff Varkrus has a law enforcement certification granted by the Law
Enforcement Training Institute.
55. Plaintiff Varkrus owns a sole-proprietorship organized and existing under the laws
of the State of Ridgeway, KWIK CASH. Additionally, he owns a plaza plot, sponsored by the
Department of State, for this business.
56. Plaintiff Varkrus has no moderation against him.2
57. Plaintiff Varkrus has never been extremely toxic or openly committed any crime
outside of the community, he strives to be the best and kindest that he can be.
58. In order to deny Plaintiff Varkrus for being an alternate account, there must be a
reasonable likelihood that he is indeed an alternate account.
59. Undoubtedly, the denial of the application of Plaintiff Varkrus prevents him from
advancing his career in the future as well as earning an income and servicing the public.
60. The background check—and further, the application—of Plaintiff Varkrus, was
denied in a way inconsistent with the law.
IV. Notice of Practices
61. On or about April 15th, 2024, the Chief of the Palmer Police Department,
Commissioner_Jason, was sent a letter regarding the inappropriate, unfair, and discriminatory
practices of the Palmer Police Department.3
62. Despite this, however, the Palmer Police Department, its affiliates, subsidiaries,
officers, agents, or other employees, made no response or action to address the concerns raised.
63. Naturally, without action, of course, we further sent a letter to the Office of the
Governor for adjudication, in accordance with 2 R. Stat. § 3229.4
64. Unfortunately, both of these letters yielded no results—for weeks, we have
received no response from the Palmer Police Department or Office of the Governor.
FIRST CAUSE OF ACTION
UNFAIR HIRING PRACTICES - 2 R. STAT. § 3241
65. All prior paragraphs within this complaint are incorporated as if they were fully
set forth herein.
4 https://drive.google.com/file/d/1obZRvP-sUpgSgFTF7cHBXAzcKLuEt9gA/view?usp=sharing
3 https://drive.google.com/file/d/1c_Ek1wuIHHXLtQTHo7eVDq3rX0sz1pTA/view?usp=sharing
2 “RidgewayWS | Moderation.” Ridgeway County, https://moderation.ridgewaycounty.org/lookup. Accessed 28 Apr.
2024.
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66. When an individual or entity “engage[s] in prejudicial or unfair hiring practices,”
they are breaking the law, and as such, a cause of action has been established. 2 R. Stat. § 3241.
67. A prejudicial or unfair hiring practice “is a hiring practice that does not conform
to what has been established by law.” 2 R. Stat. § 3240.
68. Of course, remedy in the administrative courts “is limited to systematic violations
of statutory procedure for hiring practices.” 2 R. Stat. § 3301, at ¶iii.
69. By denying two individuals under the guise of being an alternate account, when
they are clearly not, the Palmer Police Department has committed a systematic violation of
statutory procedure.
70. Indeed, all agencies are ordained to follow an “objective criteria” which remains
“static” and “non-subjective.” 2 R. Stat. § 3233. Of course, when this criteria is applied
harmoniously—as the framers and the legislators of the law intended—two different departments
and agencies alike cannot make separate determinations on the same individual—or in this case,
numerous different departments.
I. BloxWatch_CD
71. Plaintiff BloxWatch_CD had his background check denied due to the “likelihood
that [he] is an alternate account.”
72. In order to deny a background check due to the “likelihood that [an] individual is
an alternate account,” the factors which determine such suspicion must be “evaluated under
reasonableness.” 2 R. Stat. § 3235.
73. Despite this, however, the Palmer Police Department cannot substantiate—with
regards to reasonableness—its claim that Plaintiff BloxWatch_CD is indeed an alternate account.
74. Plaintiff BloxWatch_CD consistently demonstrates genuine user activity—he
actively engages and contributes to the community. Furthermore, he has successfully passed
several background checks—all of which were entitled to the same objective criteria that the
Palmer Police Department itself is ordained to follow. This in itself, of course, brings reasonable
doubt to any claim that Plaintiff BloxWatch_CD is an alternate account—and as such, the Palmer
Police Department has made a determination contrary to the law.
75. Plaintiff BloxWatch_CD has served this community as a Senator. Indeed, to first
even qualify for the Senate: the account of an individual must be 180 days old, a resident of the
state for 90 days, and have no felony records. Further, a prospective candidate must then rally at
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least ten supporters—who themselves must have an account of 180 days old, and be a resident of
the state for 90 days—prior to the actual election. Achieving this prized position does not bring
reasonableness to the claim that Plaintiff BloxWatch_CD is an alternate account, rather, it falters.
76. Plaintiff BloxWatch_CD currently works in the Ridgeway Park Service, a
“secondary agency” as defined under 2 R. Stat. § 3202. Of course, upon applying for
employment, all “applicants and new-hires” are subject to “background check[s].” 2 R. Stat. §
3234. In order to be employed, he would have had to pass his background check. To do so, of
course, he must be determined, by the Ridgeway Park Service, to not be an alternate account.
77. Indeed, to further substantiate our claims: Plaintiff BloxWatch_CD has been
employed by the Palmer Police Department on two occasions. Of course, Plaintiff
BloxWatch_CD went through his background check successfully on both of these occasions. To
say that Plaintiff BloxWatch_CD is now an alternate account, would be to contradict two other
determinations in the matter of two months.
78. Plaintiff BloxWatch_CD is not an alternate account, and a test of reasonable
assessment concludes that claim. The Palmer Police Department has made a determination
contrary to the law, and has therefore broken employment laws.
II. Varkrus
79. Much like Plaintiff BloxWatch_CD, Plaintiff Varkrus has had his background
check denied due to the “likelihood that [he] is an alternate account.”
80. Of course, when this suspicion arises, the factors which determine such suspicion
must be “evaluated under reasonableness.” 2 R. Stat. § 3235.
81. However, the Palmer Police Department is unable to substantiate its claims that
Plaintiff Varkrus is an alternate account.
82. Plaintiff Varkrus demonstrates that he is a genuine user—he actively engages and
contributes to this community: he has served as a Sergeant in the Ridgeway National Guard,
Sheriff Deputy in the Ridgeway County Sheriff's Office, and he is currently a Park Ranger I in
the Ridgeway Park Service. Additionally, he has a law enforcement certification granted by the
Law Enforcement Training Institute, and currently owns a plaza plot, sponsored by the Ridgeway
Department of State, on behalf of his registered business, KWIK CASH. He has successfully
passed all of his background checks prior to becoming a public servant—of course, all of these
background checks use and have used the same objective criteria that the Palmer Police
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Department is ordained by law to follow. This in itself, of course, brings reasonable doubt to any
claim that Plaintiff Varkrus is an alternate account—and as such, the Palmer Police Department
has made a determination contrary to the law.
83. Prior to receiving employment in a public agency, “applicants and new-hires” are
subject to a “background check.” 2 R. Stat. § 3234. This, of course, means that Plaintiff Varkrus
would have had to pass his background check—which uses the same objective criteria which the
Palmer Police Department is ordained to follow—each time he became employed in the
Ridgeway National Guard, Ridgeway County Sheriff's Office, and Ridgeway Parks Service.
84. Plaintiff Varkrus is not an alternate account, and a test of reasonable assessment
concludes that claim. The Palmer Police Department has made a determination contrary to the
law.
RELIEF
WHEREFORE, Plaintiff requests the court to grant relief to redress the injury as follows:
a. Declaratory relief declaring that Defendant denied the background check of Plaintiffs
contrary to the law and transgressed their legal rights;
b. Declaratory relief declaring that Defendant employs an unlawful procedure in conducting
background checks;
c. Injunctive relief ordering Defendant to comply with all statutory and legal obligations as
it relates to employment practices;
d. Injunctive relief restraining Defendant from engaging in the conduct complaint of herein;
e. Injunctive relief restraining Defendant from taking retaliatory action against Plaintiff for
prosecuting this action;
f. Granting Plaintiff such other further relief as the court finds just and proper.
May 1, 2024 Respectfully submitted,
Nicklaus_s
Counsel of Record
Clarke, Feelings & Associates, LLP.
Associate Attorney
R. Bar. No. 23102
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Attorney for Petitioner
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STATE OF RIDGEWAY
COUNTY OF RIDGEWAY
IN THE SUPERIOR COURT OF
THE STATE OF RIDGEWAY
BLOXWATCH_CD; VARKRUS,
Plaintiff(s),
v.
PALMER POLICE DEPARTMENT, a
municipal-level law enforcement
agency,
Defendant(s).
Case Number: RSC-CV-0000
Presiding: Hon.
INITIAL DISCLOSURE
INITIAL DISCLOSURE
PLAINTIFF, BloxWatch_CD, and Varkrus, by and through the undersigned counsel,
submits this document in the above-entitled matter, pursuant to Rid. Civ. P. 19.
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
c. Exhibit C
d. Exhibit D
e. Exhibit E
f. Exhibit F
g. Exhibit G
h. Exhibit H
May 1, 2024 Respectfully submitted,
Nicklaus_s
Counsel of Record
Clarke, Feelings & Associates, LLP.
Associate Attorney
R. Bar. No. 23102
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Attorney for Petitioner
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