IN THE SUPERIOR COURT OF THE
STATE OF RIDGEWAY
STATE OF RIDGEWAY,
Plaintiff,
v,
STORMCATSRULE,
Defendant.
STATE’S RESPONSE TO MOTION TO
SUPPRESS
Hon. EffortlessBrit
Docket Number: RSC-CM-5130
1. The State of Ridgeway, by and through its counsel, respectfully responds to Defendant’s
Motion to Suppress the evidence in this matter, made under Rid. R. Crim. P. 13.1.
INTRODUCTION
2. This case arises from a search warrant which was executed on the Defendant’s person,
vehicles, and property, which turned up an illegally possessed firearm, and multiple
military files.
3. Therefore, the issues are:
a. Whether the Court had ground(s) to issue the warrant; and,
b. Whether the police executed the warrant lawfully;
4. Defendant’s motion brings up two other issues, that is:
a. Whether the warrant satisfied the particularity requirement under Const. Art. 1 § 8
and 6 R. Stat. § 131.013; and,
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b. Whether the good-faith exception prevents suppression under United States v.
Leon, 468 U.S. 897 (1984).
5. For the reasons that follow, the State submits that (1) the Court had legal grounds to issue
the warrant; (2) the execution of the warrant was carried out within the law; and (3) that
the arguments made in Defendant’s motion fail as a matter of law.
ARGUMENT
I. THE WARRANT WAS ISSUED LAWFULLY, AND EXECUTED LAWFULLY
6. This Court signed the warrant, stating that the Judge found probable cause to believe that
evidence of Unlawful Possession of a Firearm, Contrary to R.C.C. § 2.29 would be found
in the place or person described. Thus, this clearly satisfies subsection (d) of 6 R. Stat. §
131.010.
7. The Court had probable cause, through the officer’s affidavit and evidence, that an illegal
firearm was possessed in violation of State firearm laws.
8. Accordingly, the Court had grounds to issue the warrant.
9. The evidence shows that the police carried out the search warrant within the law. They
searched only what the warrant stated could be searched, and filed an inventory receipt
immediately thereafter.
II. THE WARRANT SATISFIES 6 R. Stat. § 131.013 & CONST. ART. 1 § 8.
10. 6 R. Stat. § 131.013 requires that officers can only search “the property described in the
warrant or person named, for the property specified…”
11. Defendant argues that the warrant never specified to search a property, safe, vehicles, or
“parts of the vehicle”, and therefore is not specific enough.
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12. In fact, the warrant actually does specify all of these things. The warrant instructed
officers to search “all personal vehicles, persons, safes, and residences that are shown
through the Mobile Data Terminal”. The only conditions were to search for all illegal
firearms and ammunition, and seize any other illegal items found.
13. Defendant goes further to argue that the warrant failed to specify what residence, what
vehicle, what safe, what munitions, and their calibers.
14. This is reaching, and it's unnecessary. The warrant clearly instructed officers to search
residences only found in the Defendant’s MDT history (meaning, only residences owned
by them). Per game mechanics, a safe can only be placed in a residence, so Defendant’s
argument that it's unclear what safe fails, because it is restricted by game mechanics to
only one area.
III. DEFENDANT MISAPPLIES LEON
15. Defendant’s next argument is that the good-faith exception under Leon does not apply
because the wording of the warrant would make a reasonable officer assume its invalid.
16. However, Leon held that “The Fourth Amendment exclusionary rule should not be
applied so as to bar the use in the prosecution's case in chief of evidence obtained by
officers acting in reasonable reliance on a search warrant issued by a detached and neutral
magistrate but ultimately found to be invalid.”
17. More specifically, Defendant’s argument fails because Leon would only apply if the
Court was fooled into signing the warrant. Leon held that: “Suppression remains an
appropriate remedy if the magistrate or judge in issuing a warrant was misled by
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information in an affidavit that the affiant knew was false or would have known was false
except for his reckless disregard of the truth, or if the issuing magistrate wholly
abandoned his detached and neutral judicial role.”
18. Ultimately, Defendant’s argument with Leon does not apply here, because Defendant isn’t
attacking the grounds for a warrant, he’s attacking the wording of it. Leon only applies in
situations where the grounds (affidavit) were false, which isn’t the case here.
19. Had the officer knowingly made a false statement in the application, suppression would
have been appropriate, using Leon.
20. Accordingly, the warrant survives Leon, mostly because Defendant doesn’t actually claim
the affidavit was false.
21. On a side note, Leon also held that: “depending on the circumstances of the particular
case, a warrant may be so facially deficient -- i.e., in failing to particularize the place to
be searched or the things to be seized -- that the executing officers cannot reasonably
presume it to be valid." However, the warrant clearly identified the Defendant as the
person to be searched, and that only any residences under their MDT profile could be
searched. Any reasonable officer would have known this to be lawful, and within the
grounds for a search warrant.
RELEVANT CASE LAW
22. The State submits the following cases to the Court, which should guide its decision on the
suppression motion.
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Herring v. United States, 555 U.S. 135 (2009)
23. A defendant’s Fourth Amendment rights are not violated when police mistakes that lead
to unlawful searches are merely the result of isolated negligence, and not “systematic
error or reckless disregard of constitutional requirements.” Evidence obtained under these
circumstances are admissible, and not subject to the exclusionary rule.
V_iiIy v. New Haven County District Court, 4 M.S.C. 32 (2020)
24. Affirming that because this is a game, the particular requirement of the Fourth
Amendment that limits search warrants to individual, specific vehicles would “otherwise
be impossible to know if a person owns would be destructive to the nature and roleplay of
our game.”
25. This Clark case stated that the Fourth Amendment particularly requirement is satisfied
“once a location, whether it be broad or specific, and instructs law enforcement what to
seize.”
26. Defendant’s argument shouldn’t apply because this is a game, and the real-world
applications of a search warrant are far more different. A Ridgeway search warrant which
identifies who’s vehicles, and what to seize should be considered constitutional, because
it concedes with iiIy v. New Haven County District Court.
Heien v. North Carolina, 574 U.S. 54 (2014)
27. “The ultimate touchstone of the Fourth Amendment is ‘reasonableness’. Heien
recognizes that the Fourth Amendment allows for some mistakes, giving them “fair
leeway for enforcing the law in the community’s protection.” Brinegar v. United States,
338 U. S. 160, 176 (1949).
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28. Heien allows for Fourth Amendment mistakes, only if they were reasonable.
CONCLUSION
29. There is a clear intersection between real-world and Ridgeway when it comes to searches,
and this Court has an obligation to meet in the middle.
30. The warrant is legal, because it clearly directs officers to a person, places (vehicles and
homes), and the thing to be searched for (firearm).
31. The evidence should not be suppressed because it was gained lawfully.
32. Accordingly, the motion should be denied.
Date: August 26, 2026
Respectfully submitted,
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