THE STATE OF RIDGEWAY
IN THE SUPERIOR COURT FOR RIDGEWAY
takosull1
Plaintiff,
v.
Acenxrblx and Xotlkz, both individually,
Defendants.
Hon.
Case No.
COMPLAINT
I certify that there is no other pending or resolved civil action arising out of the same transaction
or occurrence alleged in this Complaint. I have read this Complaint and believe the statements
of fact contained in it to be true to the best of my information, knowledge, and belief.
PARTIES AND JURISDICTION
1. Plaintiff is an individual residing in the State of Ridgeway.
2. Defendant Trooper Acenxrblx was, at all relevant times, a sworn law-enforcement
officer of the Ridgeway State Police.
3. Defendant Trooper Acenxrblx is sued in his individual capacity for damages arising
from his personal conduct described in this Complaint.
4. Defendant Trooper Xotlkz was, at all relevant times, a sworn law-enforcement officer
of the Ridgeway State Police.
5. Defendant Trooper Xotlkz is sued in his individual capacity for damages arising from
his personal conduct described in this Complaint.
6. Jurisdiction and venue is proper per 3 R. Stat. § 131.104(c).
GENERAL ALLEGATIONS
7. On September 14, 2026, Plaintiff was operating a motor vehicle in Ridgeway.
8. Ridgeway State Police officers initiated enforcement action against Plaintiff and the
officers ultimately used a police maneuver to stop Plaintiff's vehicle.
11. Plaintiff does not challenge for purposes of this Complaint whether the initial vehicle
maneuver was subjectively reasonable.
12. After Plaintiff exited the vehicle, Plaintiff stood outside the vehicle.
13. Plaintiff was not physically resisting the officers.
14. Plaintiff was not attempting to flee.
15. Plaintiff was not threatening the officers or any other person.
16. Plaintiff was not attacking or attempting to attack any officer.
17. Plaintiff was not reaching for a weapon.
18. Plaintiff was not given a warning that a taser would be deployed immediately before
the first taser deployment.
19. Plaintiff was not given a command requiring him to move, surrender, or otherwise
comply immediately before the first taser deployment.
20. Defendant Trooper Acenxrblx nevertheless deployed a taser against Plaintiff.
21. The taser probes entered Plaintiff's body.
22. The first deployment caused Plaintiff to experience neuromuscular incapacitation.
23. The first deployment caused Plaintiff to fall to the ground.
24. After a few seconds, Plaintiff recovered sufficiently to stand back up.
25. Plaintiff moved only a very small amount and then again stood still.
26. Plaintiff continued not to resist, attack, threaten, flee, or reach for a weapon.
27. Plaintiff was not given a warning or command immediately before the second taser
deployment.
28. Defendant Trooper Xotlkz then deployed a taser against Plaintiff.
29. The second deployment again subjected Plaintiff to harmful electrical force and
neuromuscular incapacitation and caused additional physical injury.
30. Plaintiff was thereafter placed in handcuffs and taken into custody.
31. Plaintiff was booked for Reckless Driving under RVC § 3.01 and was not charged
with resisting arrest or a similar offense alleging physical resistance to the officers.
32. Plaintiff possesses personal recorded video footage depicting material portions of the
incident.
33. Plaintiff suffered puncture wounds from the taser probes and temporary
neuromuscular incapacitation.
34. Following the taser deployments, the Defendants did not provide Plaintiff an
ambulance or other medical assistance despite the use of force used. Plaintiff was instead taken
into custody and placed in a cell without receiving the required immediate medical treatment.
35. Plaintiff experienced physical pain and emotional distress as a result of the incident.
36. Plaintiff was subsequently incarcerated and suffered economic losses, including
reduced earnings or compensation.
37. Plaintiff filed an internal-affairs complaint concerning the officers' conduct.
38. The internal-affairs investigation resulted in an "exonerated" finding based upon the
agency's determination that the force was justified, though this is an admission that the alleged
facts did occur, as this only disputes the rationality of the force used from the foregoing facts.
39. Plaintiff disputes that determination and alleges that the evidence, including
Plaintiff's recorded footage which was provided to the agency, demonstrates that Plaintiff was
not resisting or presenting an immediate threat when the tasers were deployed.
40. Each Defendant personally participated in the conduct alleged against him and
personally caused or contributed to the injuries alleged in this Complaint.
COUNT 1
BATTERY – 7 R. Stat. § 121.002
41. Plaintiff incorporates foregoing paragraphs as if fully set forth herein
42. 7 R. Stat. § 121.002 provides that an individual who brings unconsented harmful or
offensive contact against another person commits battery and is liable for compensatory
damages and may be liable for punitive damages of up to $5,000.00.
43. Defendant Trooper Acenxrblx intentionally caused harmful or offensive physical
contact with Plaintiff by deploying a taser against him.
44. Plaintiff did not consent to the taser deployment.
45. Defendant Trooper Acenxrblx caused Plaintiff to suffer taser probe wounds,
neuromuscular incapacitation, a fall, physical pain, and other concrete injuries.
46. Defendant Trooper Xotlkz likewise intentionally caused harmful or offensive
physical contact with Plaintiff by deploying a taser against him.
47. Plaintiff did not consent to the second taser deployment.
48. Defendant Trooper Xotlkz caused Plaintiff to suffer additional taser-related physical
injury, neuromuscular incapacitation, physical pain, and other concrete injuries.
49. Each Defendant is liable for the compensatory damages caused by his own conduct.
50. Plaintiff seeks punitive damages against each Defendant in the maximum amount
permitted by 7 R. Stat. § 121.002.
COUNT 2
DEPRIVATION OF RIGHTS UNDER COLOR OF LAW – 7 R. Stat. § 121.403
51. Plaintiff incorporates foregoing paragraphs as if fully set forth herein
52. 7 R. Stat. § 121.403 provides a civil action for redress where a person acting under
color of statute, ordinance, regulation, custom, or usage subjects another person to deprivation
of rights, privileges, or immunities secured by the Constitution and laws.
53. Each Defendant was acting under color of state law as a Ridgeway State Police
officer.
54. Defendant Trooper Acenxrblx, by personally deploying a taser against Plaintiff
under the circumstances alleged above, subjected Plaintiff to a deprivation of rights secured by
the Constitution and laws of Ridgeway.
55. Defendant Trooper Xotlkz, by personally deploying a taser against Plaintiff under
the circumstances alleged above, likewise subjected Plaintiff to a deprivation of rights secured
by the Constitution and laws of Ridgeway.
56. Plaintiff alleges that the first deployment occurred while Plaintiff was standing
outside the vehicle, was not resisting, was not fleeing, was not threatening anyone, and had not
been given a warning or command immediately before the deployment.
57. Plaintiff alleges that the second deployment occurred after Plaintiff had already been
incapacitated, had stood back up, and again was not resisting, fleeing, threatening anyone, or
reaching for a weapon.
58. Each Defendant's conduct directly caused concrete injury to Plaintiff.
59. Plaintiff therefore seeks all redress available under 7 R. Stat. § 121.403.
COUNT 3
OFFICIAL MISCONDUCT – 7 R. Stat. § 121.404
60. Plaintiff incorporates foregoing paragraphs as if fully set forth herein
61. Each Defendant was a public servant within the meaning of 7 R. Stat. § 121.404.
62. Section 121.404 prohibits a public servant from knowingly making an unauthorized
exercise of official functions, or failing to perform a duty imposed by law or clearly inherent in
the nature of the office.
63. Defendant Trooper Acenxrblx exercised governmental authority by deploying a taser
against Plaintiff under circumstances in which Plaintiff was not resisting, fleeing, threatening
anyone, or presenting an immediate physical threat.
64. Defendant Trooper Xotlkz likewise exercised governmental authority by deploying a
taser against Plaintiff under circumstances in which Plaintiff was not resisting, fleeing,
threatening anyone, or presenting an immediate physical threat.
65. Each Defendant had the opportunity to observe Plaintiff's conduct immediately
before his respective taser deployment.
66. Plaintiff alleges that each Defendant knowingly exercised official authority in an
unauthorized manner under the circumstances alleged herein.
67. Each Defendant's conduct caused Plaintiff concrete injury, including physical
injuries, pain, emotional distress, and economic losses.
68. Pursuant to 7 R. Stat. § 121.404, Plaintiff seeks compensatory damages and punitive
damages of up to $10,000.00 against each Defendant.
COUNT IV
NEGLIGENCE – 7 R. Stat. § 121.301
69. Plaintiff incorporates foregoing paragraphs as if fully set forth herein
70. Each Defendant owed Plaintiff a duty of care in the exercise of law enforcement
authority and in the use of force against Plaintiff.
71. Each Defendant breached that duty by, among other things, deploying a taser against
Plaintiff under the circumstances alleged above and failing to obtain or provide the required
immediate medical response following the taser deployments.
72. Each Defendant's conduct caused Plaintiff physical injury, pain, emotional distress,
and economic loss.
73. Plaintiff therefore seeks compensatory damages and punitive damages up to the
maximum amount permitted by 7 R. Stat. § 121.301.
DAMAGES
74. As a direct and proximate result of Defendants' conduct, Plaintiff suffered actual and
compensable injuries and losses, including:
a. Physical injuries caused by Taser probe penetration;
b. Temporary neuromuscular incapacitation;
c. Physical pain and discomfort;
d. Emotional distress and mental anguish;
e. Economic losses associated with Plaintiff's incarceration and reduced
compensation;
f. Other consequential damages established through evidence;
g. Any additional damages established through discovery and trial.
h. Plaintiff's damages may continue to be established through employment,
incarceration, investigative, medical, and other records.
i. Plaintiff does not seek duplicate recovery for the same injury under multiple
causes of action and requests only the damages lawfully recoverable.
REQUESTED RELIEF
WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in Plaintiff's favor
and against Defendants, individually and according to each Defendant's respective conduct, and:
A. Award Plaintiff compensatory damages in an amount determined by the Court or trier
of fact;
B. Award Plaintiff punitive damages against Defendant Trooper Acenxrblx in the
maximum amount permitted by each applicable statute;
C. Award Plaintiff punitive damages against Defendant Trooper Xotlkz in the maximum
amount permitted by each applicable statute;
D. Award Plaintiff all redress available under 7 R. Stat. § 121.403;
E. Award Plaintiff all recoverable court costs and charges pursuant to 7 R. Stat. §
132.203;
F. Grant such other relief as the Court determines to be lawful and appropriate
Respectfully submitted, /s/ takosull1
