IN THE SUPERIOR COURT OF THE
STATE OF RIDGEWAY
THEUNKNOWNSAVAGX,
Plaintiff,
v,
SHADOWCULTURE, in their official capacity
as a Corporal of the Ridgeway County Sheriff’s
Office,
GOODBUGGATTI, in their official capacity as
a Senior State Trooper of the Ridgeway State
Police,
Defendant.
DEFENDANT’S MOTION TO DISMISS
THE COMPLAINT
Hon. EffortlessBrit
Docket Number: RSC-CV-3946
The Defendant’s, Corporal ShadowCulture and Trooper goodbugggatti, through the
Department of Justice, respectfully move this Honorable Court to dismiss Plaintiff’s complaint
for failure to state a claim upon which relief may be granted, pursuant to Rule 12(1)(5) of the
Ridgeway Rules of Civil Procedure.
FACTUAL BACKGROUND
1. Plaintiff alleges that on July 25, 2026, he was recorded planning on obtaining a police
officer’s “smg” (submachine gun) Compl. ¶ 6.
2. Plaintiff alleges he then sent photographs depicting firearms and other equipment stored
within his personal vehicle. Those communications were allegedly shared with multiple
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peace officers, including a Palmer Police Department officer, a Ridgeway County
Sheriff’s Office deputy, and Trooper goodbugggatti. Compl. ¶ 11-16.
3. Law enforcement thereafter sought a search warrant to search Plaintiff’s vehicles, which
was issued and carried out. Plaintiff alleges that Corporal ShadowCulture conducted the
search.
4. Plaintiff alleges that he was not given a copy of the search warrant or a receipt. Compl. ¶
23.
5. The Complaint does not allege that Plaintiff was denied access to the warrant itself.
In-fact, Plaintiff already had the warrant and receipt.
6. The Complaint further does not allege that the officer's failure to personally
‘hand-deliver’ a warrant and receipt to Plaintiff caused the seizure of any property.
Rather, the seizure resulted from the execution of a search warrant, which uncovered the
very same illegal items which Plaintiff had taunted in officer’s direct-messages.
7. Plaintiff nevertheless claims he has suffered injury, and asserts four causes of action:
a. Two counts of Official Misconduct under 7 R. Stat. § 121.404; and,
b. Two counts of Deprivation of Rights under Color of Law under 7 R. Stat. §
121.403.
8. Plaintiff seeks $10,000 in punitive damages from each Defendant and an injunction
preventing each Defendant from enforcing the law for fourteen days.
LEGAL STANDARD
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9. Although a complaint is generally accepted as true, a court need not accept legal
conclusions or conclusory recitations of a tort’s definition, especially when considering a
motion to dismiss for that very reason.
10. A complaint must contain sufficient factual matter in order to state a claim. See Bell
Atlantic Corp. v. Twombly, 550 U.S. 544 (2007). Indeed, the Ridgeway Supreme Court
better defined as to what they consider is a sufficient complaint. In xLaZerify v.
StudsPerSecond, the Supreme Court explained that “a claim has facial plausibility when
the plaintiff pleads factual content that allows the court to draw the reasonable inference
that the defendant is liable for the misconduct.”
11. In particular, the Supreme Court held that the plaintiff in xLaZerify v. StudsPerSecond did
not satisfy that standard, partially because the complaint “did not adequately combine the
factual allegations with the legal conclusions that address all parts of the tort in question.”
12. Indeed, this is exactly inline with what Ashcroft v. Iqbal holds, which is that courts are
not required to accept legal conclusions which are couched as factual allegations, because
it does not allow the court to draw the reasonable inference for liability. See Ashcroft v.
Iqbal, 556 U.S. 662 (2009).
13. This principle applies where the plaintiff alleges a violation of civil rights. Under these
standards, the plaintiff must identify the right which was allegedly violated, and plead
facts (not legal conclusions) in order to establish that the defendant's conduct actually
caused the deprivation. See West v. Atkins, 487 U.S. 42, 48 (1988); Rizzo v. Goode, 423
U.S. 362 (1976).
14.
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ARGUMENT
I. PLAINTIFF’S OFFICIAL-MISCONDUCT CLAIMS FAIL BECAUSE HE HAS
NOT PLEADED CONCRETE INJURY CAUSED BY THE ALLEGED
MISCONDUCT
15. Under the tort which Plaintiff alleges twice, 7 R. Stat. § 121.404 requires that a plaintiff
“prove that the official misconduct from that individual caused concrete injury to
himself”. Here, the complaint does not attempt to prove concrete injury.
16. The part facts-part legal conclusions section from the Complaint establishes at most, that
Plaintiff was not hand-delivered a copy of the warrant and receipt directly from the
executing officer. The Complaint does not even attempt to show how this caused injury,
but instead simply asserts “therefore, there is a cause of action.” That is not concrete
injury, that is just storytelling.
17. In-fact, Plaintiff never alleged he couldn’t obtain the warrant, because in-fact, Plaintiff
already has the warrant and receipt. See Compl. ¶ Page 5 and 61
18. Indeed, the search warrant and associated receipt are available through the Courts’s
public record system. In-fact, Plaintiff proved he knew that by sharing with the Court
multiple warrants and receipts he took from the website.
19. Nonetheless, Plaintiff still alleges that “defendant did refrain from giving Plaintiff a copy
of the search warrant”. Compl. ¶ 3 (of counts one and two). Plaintiff is essentially
pleading that he was deprived of a public record available to him.
1 Yes, despite claiming Plaintiff was never given the search warrants and receipts, Plaintiff has provided those search
warrants and receipts…but still sues nonetheless.
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20. Therefore, Plaintiff cannot possibly establish concrete injury, which is required to sue for
official misconduct.
The Seizure of Plaintiff’s Illegal Firearms Is Not an Injury Caused by Allegedly Failing
to Hand-Deliver a Warrant
21. Plaintiff may argue that the seizure of his firearms, as a result of the search warrant,
constitutes a concrete injury. It is important to note that Plaintiff has not actually pleaded
this in the Complaint, but the Defendant’s will address it is as a precaution.
22. The argument would fail because even the Plaintiff alleges that the firearms were
unlawfully possessed. Compl. ¶ 12 (admitting to having possessed illegal firearms and
government equipment).
23. If an officer executes a search warrant, discovers and seizes contraband pursuant to that
warrant, any subsequent failing to provide a copy of the warrant does not cause the
seizure. The seizure has already been authorized by a judge.
24. Thus, Plaintiff cannot possibly complain that because the officer allegedly failed to
hand-deliver the copy and receipt, the seizure itself was unlawful and caused him
concrete injury. Thus, the torts of official misconduct cannot survive the principals
outlined in Iqbal, Ashcroft, and xLaZerify.
Plaintiff’s Access to the Warrant and Receipt Through the Public Court Records Website
Defeats Any Plausible Allegation of Injury
25. Plaintiff alleges that he was never personally provided a copy of the warrant. Compl. ¶¶
22-23.
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26. Assuming this to be true, Plaintiff nonetheless still had access to the search warrant, and
even proved this by sharing them in their Complaint.
27. Assessing the law, 6 R. Stat. § 131.014 requires that peace officers “ensure that a copy of
the warrant and inventory is left with the owner of the searched premises.” However, this
statute does not explicitly state how the police should leave a copy. The Ridgeway Court
website provides everyone with access to every single warrant and receipt in the State.
According to the website: “Once law enforcement executes a warrant and files a return of
service, the warrant and return become public record and appear in the register…”
28. Defendant’s contend that when they uploaded an inventory to the website, and made the
record public, they satisfied the requirement under 6 R. Stat. § 131.014, because this
record was publicly available to the Plaintiff, and Plaintiff knew about it.
29. Because Plaintiff had access immediately, just like everyone else, they cannot possibly
have been deprived of any constitutional right which they allege in their Complaint.
30. And because the Defendant’s followed the law, and satisfied 6 R. Stat. § 131.014, they
could not have possibly caused any concrete injury to Plaintiff, which they allege in their
Complaint.
II. 6 R. STAT. § 131.014 DOES NOT ACTUALLY GUARANTEE PLAINTIFF ANY
RIGHT
31. Plaintiff brings two counts of deprivation of rights under color of law, and claims that
their right which was violated is afforded to them under 6 R. Stat. § 131.014.
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32. Defendant’s contend that 6 R. Stat. § 131.014 does not afford Plaintiff any rights,
specifically because the language makes 6 R. Stat. § 131.014 a duty, and places that duty
on any peace officer enforcing a search warrant.
33. That is not to say any State statute is not a right, which can be deprived. The legislators
do use specific language to clearly indicate what statute is a right. For example, a fugitive
from justice “may seek relief from fugitive status as a matter of right…” 6 R. Stat. §
131.506, or that a judge must “grant an order of delinquency as a matter of right…” 7 R.
Stat. § 132.105.
34. Clearly, the legislators use the word “as a matter of right” in order to establish a state
statute as a right. In 6 R. Stat. § 131.014, they do not, and therefore, Plaintiff cannot
possibly have been deprived of a right he had never had in the first place.
III. PLAINTIFF’S REQUEST TO SUSPEND DEFENDANT’S IS FRIVIOLOUS AND
UNSUPPORTED
35. Plaintiff seeks that each Defendant pay him $10,000 of their personal money, and for the
Court to suspend their ability to enforce the law for five days.
36. Defendant’s recognize that 7 R. Stat. § 121.404 does carry the power of injunctive relief.
Defendant’s therefore do not contest that injunctive relief is categorically unavailable.
37. The problem however, is that the reason why Plaintiff seeks an injunction. Defendant’s
assert that the reason for an injunction must be for the purposes of repairing the injury.
See 7 R. Stat. § 121.404(c) (when the Solicitor General refuses to defend in an official
misconduct suit, they shall provide injunctive relief that repairs the injury caused).
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38. Here, Defendant’s argue that Plaintiff is using the power of an injunction for frivolous
reasons, and not to actually repair the injury. The injury they allege in the misconduct
charge is not giving Plaintiff the warrant.
39. Suspending two proactive, and dedicated police officers for 5 days does not repair the
alleged injury. In-fact, any alleged injury here was automatically repaired when the
warrant and return became part of public records.
40. Defendant’s contend that this requested relief is frivolous because the Complaint does not
establish why a 5 day suspension would remedy any alleged injuries.
41. Indeed, the Plaintiff explains he seeks to suspend these officers “for committing the tort
of deprivation of rights under color of law”. The tort also carries a $10,000 punitive
damage, which Plaintiff does not seek.
42. Defendant’s point here is that Plaintiff frivolously has chosen the powerful injunction for
punitive reasons, despite there being punitive damages. Their only justification for this is
because they allegedly violated the tort. An injunction suspending officers is irrelevant
and unnecessary because there is no imminent threat, and honestly nothing to prevent.
CONCLUSION
43. Plaintiff’s Complaint comes close to accusations of frivolous, given it complains about
not being given a copy of a warrant, but also showing that they have it. It also attacks two
proactive police officers, and tries to suspend them without reason. It is not tailored to
any continuing injury, but rather is frivolously used as a form of punishment and
retaliation.
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44. For these reasons, Defendant’s respectfully request that this Court dismiss the Complaint
in its entirety.
Date: August 9, 2026
Respectfully submitted,
Counsel for the Defendant’s
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