IN THE SUPERIOR COURT OF THE STATE OF RIDGEWAY
ADAM STRATTON, individually and in his
official capacity as Attorney General,
Plaintiff,
v.
LargeTitanic2, individually and in his official
capacity as President of the Senate of the
State of Ridgeway,
Defendant.
Case No. RSC-CV-4876
FIRST AMENDED COMPLAINT
Related: No. DCE-2026-0101
CORRECTION OF THE RECORD
Paragraph 9 of the original petition stated that the Defendant declared the Plaintiff in
contempt alone, from the chair, and that no vote of the Senate was taken. That was wrong. A
motion to hold the Plaintiff in contempt was put to the Senate and voted on, and a later motion to
reconsider it was voted down. The Senate’s published voting record is set out below. The Plaintiff
withdraws paragraph 9 of the original petition, Part A.1 of its argument, and every statement in it
that rested on the absence of a vote. This amended complaint replaces the original in full.
The Court has ruled that the request for an injunction against enforcement of the contempt
order is moot in light of the Senate’s passage of R12-20. The Plaintiff does not re-urge that request,
and he relies on no order that is not on the record of this Court. What remains is this. The Plaintiff
was arrested and booked on a charge under R.C.C. § 1.06; the Court found no probable cause for
that arrest in No. DCE-2026-0101; and the arrest and the record of it are still there. A challenge to
an arrest “shall not be held moot on the basis that the person was released from prison.” 7 R. Stat.
§ 133.001. The Plaintiff asks the Court to declare that the contempt was never validly voted, to
clear the record, and to award damages against the officer who announced a failed motion as
carried and ordered the arrest.
PARTIES AND JURISDICTION
1. The Plaintiff, Adam Stratton, is the Attorney General of the State of Ridgeway. Const.
art. IV, § V. He brings this action in both capacities. He sues individually because the arrest
took his own liberty, and the damages claims are his alone. On the claim for declaratory
relief he also sues as Attorney General, because the Senate held him in contempt while it
was questioning him, as Attorney General, about acts of his office, and the order punishes
the officer for the answers.
2. The Defendant, LargeTitanic2, is the President of the Senate. Const. art. III, § VI. He is not
a Senator and has no vote unless the Senate is tied. Id.; Standing Rules of the Ridgeway
State Senate (3d ed.) (“Senate Rules”), Rule VII(5). He is sued individually on Counts I and
II. On Counts III and IV he is named in his official capacity, as 7 R. Stat. §§ 121.404(b) and
122.004 direct, with any damages on Count III payable in his individual capacity. The
Plaintiff does not sue any Senator for a vote.
3. The Superior Court is “a court of law and equity” with original jurisdiction over all
misdemeanors under the Criminal Code, all civil claims, and any controversy not assigned
elsewhere, and it is empowered to hear expungements and to provide the writ of habeas
corpus. 3 R. Stat. §§ 131.001, 131.004(a), (c), (e); Const. art. V, § IV.
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4. Sovereign immunity does not bar these claims. Counts I and II run against the Defendant
individually. Count III is authorized against a public servant by 7 R. Stat. § 121.404. Count
IV rests on 7 R. Stat. § 122.101, which subjects any government “order” that “impedes on
an individual’s rights, immunities, or privileges secured by state statute or the constitution”
to “injunctive relief reversing any harm done” and so expressly creates liability against the
government. 7 R. Stat. § 122.002. The Plaintiff also invokes the writ of habeas corpus,
which is not mooted by release. 7 R. Stat. §§ 133.001, 133.004.
5. The Solicitor General defends this proceeding, 7 R. Stat. § 122.005, and serves at the
pleasure of the Attorney General, 2 R. Stat. § 122.002. The Plaintiff will give the Solicitor
General no direction concerning the defense of this proceeding and will take no action
against any officer of the Department of Justice on account of it. For the same reason the
mediation step in 2 R. Stat. § 123.001 cannot be performed: the Plaintiff cannot arbitrate
his own claim, and passing the duty to his own deputy under 2 R. Stat. § 121.107 cures
nothing. The habeas ground is outside § 123.001 in any case, because the writ may be
sought “at any time.” 7 R. Stat. § 133.001.
FACTS
6. On September 16, 2026, the Senate was in session at the State Capitol with the Defendant
presiding. The Plaintiff appeared before it as Attorney General, and Senators questioned
him about acts taken in that office. See Senate Rule X(4) (government officials may be
invited to the chamber to answer Senators’ questions).
7. In the course of that questioning, a motion was put “to hold adamstratton in contempt of the
Senate for obstruction of proceedings.” The conduct complained of was the Plaintiff’s
answers and remarks during the questioning, which were called outlandish.
8. Five Senators were present. The Senate’s published record of the vote is: eothyu, aye; mp5,
aye; c4j2y, abstain; aspenfun, abstain; north, abstain. Two Senators voted for contempt.
Three did not.
9. The Defendant treated the motion as carried. A motion to reconsider was then put and
failed, two to three: eothyu and north, aye; mp5, c4j2y, and aspenfun, nay. No second vote
on contempt was taken.
10. The Senate never afforded the Plaintiff time to answer the contempt or to speak on it.
Before the votes he was given no statement of the charge, no opportunity to respond, and no
opportunity to be heard by counsel.
11. The Senate made no finding that the Plaintiff blocked, halted, or prevented the session from
proceeding, and no finding that he acted purposely, knowingly, or recklessly.
12. No written order of the Senate was issued. No warrant was issued. The Senate did not direct
its Sergeant-at-Arms to take the Plaintiff into custody.
13. The Defendant instructed smashcans, an officer of the Ridgeway State Police, to take the
Plaintiff into custody. The officer arrested and booked him at the Capitol on a charge under
R.C.C. § 1.06. His sworn statement of probable cause reads in full: “On 09/16/2026, I was
instructed by the president of the Senate to take this subject into custody for obstructing the
Senate proceedings. I booked the suspect at the booking room within the cap.”
14. At 8:01 PM, the Court reviewed the officer’s sworn statement and found no probable cause.
The Plaintiff was released at 8:06 PM.
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WHY THE CONTEMPT AND THE ARREST WERE UNLAWFUL
A. The contempt motion failed under the Senate’s own rules.
The Senate may hold a person in contempt only “by a two-thirds (⅔) vote.” Senate Rule
V(3). Its rules say what that number is: “Five (5) Senators shall be considered two-thirds of the
Senate as a whole.” Senate Rule VII(2). The Senate has seven seats. Senate Rule IV(3)(b). Two
Senators voted aye. Two is not five, it is not two-thirds of the seven seats, and it is not two-thirds of
the five Senators in the room. A majority of the Senators present declined to vote for contempt.
The Defendant may argue that abstentions drop out, so that two ayes and no nays is a
unanimous vote. The rules do not read that way. Where the Senate meant two-thirds of those
“present and voting,” it said so, in the rule immediately before this one. Senate Rule V(2). Rule
V(3) does not use those words, and Rule VII(2) supplies the number. A rule that lets the Senate put
a person in jail should not be read to let two of seven Senators do it while the rest sit silent. The
Defendant, who is named on the cover of the Standing Rules as their reviser, announced as carried
a motion that his own rules say failed, and then ordered the arrest.
The failed motion to reconsider changes nothing. It left the first vote where it was, at two.
B. Making statements is not obstructing a session.
R.C.C. § 1.06 reaches two things: failing to appear on a lawful subpoena or writ of
command, and “obstruct[ing] any session of the whole or partial Senate.” The motion used the
word “obstruction,” but the conduct was statements that were called outlandish. That is a judgment
about what was said, and putting the statutory word in a motion does not turn speech into
obstruction. For contempt of court, the Legislature wrote an offense covering “disorderly,
contemptuous, or insolent behavior” and any “noise, or other disturbance directly tending to
interrupt the proceedings of the court.” R.C.C. § 1.08. It put none of that in § 1.06. The Senate
sitting as a tribunal is bound by the statute the Senate sitting as a legislature enacted. Its own rules
say so: the Senate may hold a person in contempt only where it acts “under statutory authority.”
Senate Rule V(3). The statute is § 1.06, and “contemptuous behaviour” is not its test.
Section 1.06 also requires that the obstruction be “without lawful justification.” The
Plaintiff was speaking because the Senate was questioning him. Answering the questions of the
body that put them is lawful justification for speaking, whatever the body thinks of the answers.
The Supreme Court of the United States reached the same result where the whole House
had voted. In Marshall v. Gordon, 243 U.S. 521 (1917), a United States Attorney facing an
impeachment inquiry sent the investigating subcommittee’s chairman a letter the House found
defamatory and insulting. The House adopted a resolution holding him in contempt and had him
arrested. The Court ordered him discharged on habeas corpus: the contempt power exists to remove
obstructions to the body’s work, and it does not reach a statement because the body is affronted by
it. See also Anderson v. Dunn, 19 U.S. (6 Wheat.) 204, 231 (1821) (“the least possible power
adequate to the end proposed”). The Senate could have had the Plaintiff shown out. Const. art. II,
§ VI. That is the remedy its own rules provide for a disorderly non-member: the Sergeant-at-Arms
may “remove or eject” him. Senate Rule II(3)(c). Imprisonment added only punishment.
A contrary reading would collide with the right to freedom of speech “concerning the
transactions of government.” Const. art. I, § IX; U.S. Const. amend. I; see Bond v. Floyd, 385
U.S. 116 (1966) (state legislature violated the First Amendment by excluding a member-elect
because of his statements on public questions). And no person is guilty of an offense without
culpability as to “each material element,” which the Senate did not find. 6 R. Stat. §§ 121.002,
121.003.
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C. The Plaintiff received no notice and no hearing.
Contempt of Senate is a criminal offense punished by imprisonment. The Constitution
guarantees the accused the right “to be heard by oneself and by counsel” and “to demand the cause
and nature of the accusation,” and provides that no person can “be justly deprived of liberty, except
by the laws of the land, or the judgment of the person’s peers.” Const. art. I, § VI. A correct vote is
not a hearing. In Groppi v. Leslie, 404 U.S. 496 (1972), a state assembly adopted a contempt
resolution against a non-member by vote of the body, without notice or an opportunity to respond,
and the Court held that the resolution denied due process. Groppi involved a resolution passed two
days after the event, and the Court did not decide whether a legislature may act summarily in the
moment to stop a disturbance. But stopping a disturbance requires only removal. It does not require
a criminal judgment and a jail term without a word from the accused.
The Senate’s own rules show what it considers fair when less is at stake. A Member facing
censure is given up to five minutes “to make their case.” Senate Rule IX(1). A Member facing
expulsion is given notice by the Secretary and five minutes to speak in his defense. Senate Rule
IX(3)(a). Those Members risk a mark on a file or a seat. The Plaintiff risked jail, and the Senate
never afforded him time to answer the contempt or to speak on it.
D. The order was not carried out the way the Senate’s rules or the law require.
When the Senate holds a person in contempt, its rules let it “direct the Sergeant-at-Arms to
take them into custody.” Senate Rule V(3). That did not happen. The Defendant instructed a Major
of the State Police, and the Major’s sworn statement names that instruction, and nothing else, as the
reason for the arrest. The rules also require that when the accused is brought before a judge for a
probable cause hearing, the court be told “whether a vote was held” and which Members voted in
favor. Senate Rule V(3)(b). The affidavit told the Court neither. Had it complied, the Court would
have been told that two Senators voted aye. The Court found no probable cause on it.
A contempt charge may be held only “upon order of the Senate.” S.B. 002, § 403(a)(i). Two
Senators voted aye, and the Senate issued no order an officer could execute or a court could read.
The arrest was made without a warrant. An officer may arrest without a warrant for a misdemeanor
only when it is committed in his presence, or when “[a] warrant for the arrest has been issued.”
6 R. Stat. § 131.006(a), (d); see 9 R. Stat. § 223.002 (State Police may arrest without warrant a
person who violates the law “in the presence of a state trooper”). A vote of the Senate is not a
warrant, and warrants issue on oath or affirmation. Const. art. I, § VIII.
E. The Senate may question the Attorney General. It may not jail him for his answers.
The Attorney General is a constitutional officer elected by the voters of the State. Const.
art. IV, §§ V, VI. The departments of government are “separate and distinct, so that neither
exercise the powers properly belonging to the others.” Const. art. II, § V. The Constitution gives
the Senate its remedies against an executive officer whose conduct or answers it disapproves: it
may question him, it may legislate, and it may order an impeachment by two-thirds of its members,
to be tried by the Supreme Court. Const. art. VI, §§ III, IV, V. Summary imprisonment by the
questioning body is not among them. If the Senate can jail an executive officer for answers it finds
outlandish, no officer can answer it candidly, and the questioning the rules provide for becomes a
trap.
F. Article I, Section X does not bar review.
Article I, Section X protects “[t]he freedom of deliberation, speech, and debate, in the
Legislature.” The Plaintiff does not sue any Senator and seeks nothing on account of any vote. The
Defendant is not a member of the Legislature, and instructing a police officer to arrest a person is
not deliberation, speech, or debate. The Plaintiff asks the Court to decide whether his imprisonment
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was lawful, which courts have done since Kilbourn v. Thompson, 103 U.S. 168 (1881) (members
who voted for a contempt resolution were immune, but the resolution was void and its execution
actionable). See also Powell v. McCormack, 395 U.S. 486 (1969). The Legislature placed this
misdemeanor within this Court’s jurisdiction, 3 R. Stat. § 131.004(a), and the Constitution gives
this Court the writ of habeas corpus with no exception for prisoners of the Senate. Const. art. V,
§ IV. Decisions of the Supreme Court of the United States are cited as persuasive authority and, on
the First and Fourteenth Amendments, as controlling.
COUNT I — FALSE IMPRISONMENT (7 R. Stat. § 121.003)
15. The Plaintiff repeats the paragraphs above. A person who, “without legal authority or
justification, restrains or restricts a person’s movement within an area” commits false
imprisonment. 7 R. Stat. § 121.003. The Defendant restrained the Plaintiff by instructing a
police officer to take him into custody, and the officer’s sworn statement names that
instruction as the reason for the arrest. The Defendant had no legal authority to give it: the
contempt motion had not carried, the Senate had not directed its Sergeant-at-Arms to act,
and no warrant existed.
COUNT II — DEPRIVATION OF RIGHTS UNDER COLOR OF LAW (7 R. Stat.
§ 121.403)
16. The Plaintiff repeats the paragraphs above. Acting under color of his office and of R.C.C.
§ 1.06, the Defendant caused the Plaintiff to be deprived of his liberty without the process
that Article I, Section VI and the Fourteenth Amendment require, and as punishment for
speech protected by Article I, Section IX and the First Amendment. He is liable “in an
action at law, suit in equity, or other proper proceeding for redress.” 7 R. Stat. § 121.403.
COUNT III — OFFICIAL MISCONDUCT (7 R. Stat. § 121.404)
17. The Plaintiff repeats the paragraphs above. The Defendant is a public servant. Announcing
the contempt motion as carried and ordering the Plaintiff’s arrest were acts relating to his
office and an unauthorized exercise of his official functions. The Defendant knew they
were unauthorized. He was in the chair and took the vote himself: two ayes and three
abstentions. He is named on the cover of the Standing Rules as their reviser, and those rules
require a two-thirds vote for contempt, fix two-thirds at five Senators, and provide that
custody is taken by the Sergeant-at-Arms at the Senate’s direction. Senate Rules V(3),
VII(2). His acts caused the Plaintiff concrete injury. 7 R. Stat. § 121.404(a).
COUNT IV — CIVIL RIGHTS (7 R. Stat. § 122.101)
18. The Plaintiff repeats the paragraphs above. The contempt declaration and the arrest
instruction are each an “order” that “impedes on an individual’s rights, immunities, or
privileges secured by state statute or the constitution.” The Plaintiff suffered concrete, non-
hypothetical harm from them: he was arrested, booked, and jailed. He is entitled to
“injunctive relief reversing any harm done,” which here means clearing the record.
7 R. Stat. § 122.101.
RELIEF REQUESTED
The Plaintiff respectfully requests that the Court:
(a) declare that the contempt motion of September 16, 2026, did not carry under Senate Rules
V(3) and VII(2) and that the Plaintiff’s arrest under it was without lawful authority;
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(b) on Count I, award punitive damages against the Defendant individually in an amount the
Court determines, not to exceed $6,000.00, 7 R. Stat. § 121.003;
(c) on Count II, award damages against the Defendant individually in an amount the Court
determines, 7 R. Stat. § 121.403;
(d) on Count III, award compensatory damages as proven and punitive damages in an amount
the Court determines, not to exceed $10,000.00, payable by the Defendant in his individual
capacity, 7 R. Stat. § 121.404;
(e) on Count IV, order any arrest or offense record arising from the contempt, including No.
DCE-2026-0101, expunged, 7 R. Stat. § 122.101; Const. art. V, § IV;
(f) award the Plaintiff his court costs, 7 R. Stat. § 132.203; and
(g) grant such further relief as the Court deems just and proper.
Respectfully submitted this ____ day of September, 2026.
/s/ Adam Stratton
ADAM STRATTON
Plaintiff, individually and as Attorney General
VERIFICATION
I, Adam Stratton, affirm under the pains and penalties of perjury that the facts stated in
paragraphs 1 through 14 of this amended complaint are true.
/s/ Adam Stratton
ADAM STRATTON
Plaintiff
CERTIFICATE OF SERVICE
I certify that on September ____, 2026, this amended complaint was filed with the Clerk of
the Superior Court and a copy was served by electronic means upon the Defendant, LargeTitanic2,
and upon the Solicitor General. 7 R. Stat. §§ 131.103, 131.106, 133.003.
/s/ Adam Stratton
ADAM STRATTON
Plaintiff
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