IN THE SUPERIOR COURT OF THE
STATE OF RIDGEWAY
MANMAN2380,
Petitioner,
v,
INTERNAL AFFAIRS DIVISION, PALMER
POLICE DEPARTMENT,
Respondent.
RESPONDENT’S MOTION TO DISMISS
Docket Number: RSC-CV-5214
The Respondent, the Palmer Police Department, by and through the Department of
Justice, respectfully moves this Court to dismiss the administrative claim against them for lack of
jurisdiction. Administrative claims in Ridgeway are strictly for adverse employment decisions,
not to complain that an internal affairs team did not accept Petitioner's case.
INTRODUCTION
1. Petitioner brings an administrative claim, claiming that Petitioner had fled from the
police, and while being pursued, force was used against them.
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RESPONDENT’S MOTION TO DISMISS
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2. In their claim, Petitioner complains that the Palmer Police Department rejected
Petitioner's misconduct report, and this makes it “invalid, arbitrary, and strictly
prohibited.”1
3. Petitioner therefore believes it is appropriate to file and administrative claim, and ask the
Court to issue an extreme amount of relief, including:
a. Forcing the Respondent to sustain Petitioner's complaint;
b. Declaring that Respondent acted arbitrary and did not observe the law, despite
conducting a review, and explaining the reasons with law;
c. Forcing the Respondent to give Petitioner all of their internal communications;
d. To forever stay any vehicle license suspension, despite the fact that doesn’t exist
in Ridgeway.
4. For the reasons set forth below, the Petitioner inappropriately misuses an administrative
claim, which is generally for employed persons to fight against an employment action
taken against them, not for members of the public to complain their misconduct reports
aren’t sustained.
ARGUMENT
A. THIS COURT DOES NOT HAVE JURISDICTION
5. An administrative claim is to claim one of two things:
a. An adverse employment action was arbitrary; or
1 Even though Petitioner acknowledges that the Respondent conducted a review, it is still somehow
arbitrary (arguing Respondent did so randomly, but also confirming Respondent investigated the
complaint).
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RESPONDENT’S MOTION TO DISMISS
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b. An employment action was made without due observe of State law
6. An “adverse employment action” is for things such as suspensions, demotions, etc. When
a police agency does not sustain a misconduct report, that’s not an adverse employment
action. In-fact, it’s beneficial because that means someone keeps their job!
7. However, Petitioner is challenging the fact the Respondent didn’t accept this complaint,
and despite providing reasons why, claims this was random, and without due observance
of the law.
8. Because this case doesn’t involve adverse employment action, but instead deals with
whether or not the Respondent conducted their investigation within the law, an
administrative claim is improper, and therefore, this Court lacks jurisdiction.
9. The Court should dismiss the claim, and instruct Petitioner to file in the appropriate
manner.
B. PETITIONER LIES ABOUT WHAT RELIEF HE IS ENTITLED TO
10. Petitioner seeks an impressive amount of relief from this Court, including impossible or
outright illegal relief. In almost every single request, Petitioner lies about why he is
entitled to that relief, citing State law that doesn’t even apply to him.
11. Firstly, Petitioner seeks to have the Court force Respondent to sustain his complaint, and
cites 3 R. Stat. § 141.102(b) as the authority. However, 3 R. Stat. § 141.102(b) states:
“An administrative court judge shall grant or reject the punitive action sought by the civil
service agency.”
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RESPONDENT’S MOTION TO DISMISS
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12. No where, does this statute give the Court the authority to force an agency to accept a
complaint, just because Petitioner ask’s for it. Accordingly, this Court lacks the authority
to issue such relief, especially where Petitioner lies about what a statute grants.
13. Secondly, Petitioner wants “immediate, unredacted access to all internal communications,
statements, and raw video materials…” Is this guy stupid or something?
14. Petitioner says that the Court can issue this relief under 2 R. Stat. § 511.101(b), but that
statute is for State Auditors. Petitioner isn’t a State Auditor.
15. Essentially, Petitioner is saying “even though im not a State Auditor, I too should get
access to sensitive government information!”
16. Once again, Petitioner is lying about 2 R. Stat. § 511.101 actually affords him. The Court
cannot give relief here.
C. SERVICE WAS INSUFFICIENT
17. Petitoner’s attorney, who organized the service, has a history of improper and insufficient
summons. See thr33six8 v. AlbertWellesley, et. al (where the Court found the same
attorney had improperly conducted summons, by, inter alia, not furnishing proof).
18. Under Rid. R. Civ. P. 4.2, Petitioner is required to demonstrate proof of service. “Proof is
made by filing a return through the electronic filing system.”
19. However, Petitioner has not demonstrated Respondent has been served, because they
have not followed the rules.
20. Although failure to make proof is not a dispositive issue (See Rid. R. Civ. P. 4.2(7)), the
Court can order proof be made.
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RESPONDENT’S MOTION TO DISMISS
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21. So, although Petitoner’s failure to file does not warrant dismissal solely based on that, the
Court should recognize Petitoner’s incompetence when it comes to understanding the
rules. They have incorrectly filed an administrative claim, when it should have been a
civil claim (which has very different rules and procedures), and has not filed the
appropriate returns.
CONCLUSION
22. This Court should dismiss the administrative claim against the Palmer Police Department
because this is the incorrect legal avenue for someone to challenge the issues at hand.
23. Petitioner is not a PPD employee who had adverse action taken against him, which would
warrant an administrative claim. Instead, they are a citizen who isn’t happy that the IA
unit did not accept his complaint.
24. Because the Rules very clearly state that an administrative claim does not apply here, the
Court should dismiss this case, and allow Petitoner to file properly next time.
Date: September 15, 2026
Respectfully submitted,
Detachment_Result
[Detachment_Result] State Bar No.
11103
Counsel for the Defendants
Deputy Attorney General
Ridgeway Department of Justice
Annex Building, Palmer City
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RESPONDENT’S MOTION TO DISMISS
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