IN THE ADMINISTRATIVE COURT OF THE STATE OF RIDGEWAY
SEJECHRILLE,
Petitioner,
v. Case No. ______________
PALMER POLICE DEPARTMENT,
Respondent.
_______________________________________/
ADMINISTRATIVE CLAIM
Petitioner SejeChrille, by and through undersigned counsel, and pursuant to 3 R. Stat. §§
141.006 and 141.101, respectfully submits this Administrative Claim against Respondent Palmer
Police Department ("PPD" or "the Department"), and in support states as follows:
I. JURISDICTION AND VENUE
1. This is an Administrative Claim asserting that an adverse employment action taken
against Petitioner was arbitrary and issued without due observance of state statute,
within the meaning of 3 R. Stat. § 141.101.
2. This Court holds original and exclusive jurisdiction over this matter pursuant to 3 R.
Stat. § 141.006 (jurisdiction over administrative procedures arising from an adverse
personnel action against a civil service employee) and 3 R. Stat. § 141.007
(jurisdiction over matters involving the internal policy or rules of a civil service
agency). Jurisdiction that would otherwise lie with the Superior Court under 3 R. Stat.
§ 131.004(c) is expressly excluded from that grant by 3 R. Stat. § 131.004(e) where,
as here, the controversy falls within this Court's jurisdiction.
3. Respondent Palmer Police Department is a "Primary Civil Service Agency" within
the meaning of 4 R. Stat. § 111.002(c). Petitioner was, at all relevant times, an
"Employee" lawfully occupying a position within the civil service within the meaning
of 4 R. Stat. § 111.009.
4. To the extent Respondent may assert sovereign or governmental immunity under 7 R.
Stat. § 122.002, that immunity does not bar this action. Titles III and IV of the
Ridgeway Code of Statutes expressly create civil-service employment rights and a
dedicated judicial remedy against civil service agencies for adverse personnel actions,
including the right to a pre-disciplinary hearing (4 R. Stat. § 124.301), the right to be
free from arbitrary discipline (4 R. Stat. §§ 123.401–123.402), and this Court's
original jurisdiction to hear such claims (3 R. Stat. §§ 141.006–141.007). This
statutory scheme constitutes an express, later-established creation of liability against
the government within the meaning of 7 R. Stat. § 122.002, and sovereign immunity
accordingly does not apply.
II. PARTIES
5. Petitioner SejeChrille was, until his involuntary discharge on September 13, 2026,
employed by Respondent as a Patrol Officer, having completed the Palmer Police
Academy and the probationary period required to attain that rank.
6. Respondent Palmer Police Department is an agency of the City of Palmer and a
Primary Civil Service Agency as defined above, headed by its Chief of Police.
III. STATEMENT OF FACTS
7. At all relevant times, Petitioner held the rank of Patrol Officer and was additionally
pursuing certification as a trainee within Respondent's Traffic Enforcement Division
("TED"), a specialized assignment distinct from his general employment with
Respondent.
8. Petitioner had not, at any relevant time, completed TED's classroom, practical, or
examination requirements, and his TED certification status was recorded as
"Pending."
9. Petitioner did not appear on TED's roster and was not authorized to go on duty, or
patrol, on behalf of TED.
10. On August 27, 2026, between approximately 2:37 a.m. and 2:49 a.m., Respondent,
through Captain ab_bae, issued three recorded warnings against Petitioner in
immediate succession, each for an alleged "Failure to meet activity requirements"
during the weeks of August 2–9, August 10–16, and August 16–23, 2026,
respectively.
11. None of the three warnings was issued contemporaneously with the week to which it
related; all three were issued in a single bulk action, more than three weeks after the
earliest violation alleged.
12. Later that same day, Petitioner separately raised this deficiency with Captain ab_bae
and with Lieutenant KeenPack's designee, duckyyy445.
13. Captain ab_bae responded, in relevant part: "this is also the first time I'm hearing of
this. Was not aware that there were people in TED that had not yet completed traffic
school," and further stated "yes, there was a backlog of warnings across patrol and
traffic that were waiting to be issued," and "I can always remove them."
14. duckyyy445 responded, in relevant part: "Yea so abby sent a strike from last week
and one for this week at once so I see your point that you didn't know," and further
represented that he would "speak with c4 and figure something out to remove a strike
that way you dont get the termination."
15. On August 28, 2026, notwithstanding the foregoing, Respondent placed Petitioner in
a suspended status "until exit search is complete."
16. On September 2, 2026, duckyyy445 informed Petitioner, without further explanation,
that "we had agreed the administrative actions would stay."
17. Petitioner completed the required exit search on or about September 5, 2026.
18. At no point between August 27, 2026, and September 13, 2026, was Petitioner
afforded a pre-disciplinary hearing, notice of a right to such a hearing, or any other
opportunity to respond to the charges against him prior to separation.
19. On September 13, 2026, Respondent issued a Department Action stating that
Petitioner "has been generally discharged," citing "Involuntary General Discharge; 3
Warnings."
20. Respondent did not, prior to September 13, 2026, initiate or demonstrate cause for
Petitioner's discharge before this Court or any administrative tribunal.
IV. CLAIMS FOR RELIEF
COUNT I — Discharge Without Required Pre-Disciplinary Hearing and Without Prior
Proceeding Before This Court
21. Petitioner incorporates the foregoing paragraphs as though fully set forth herein.
22. As a regular-status civil service employee, Petitioner held a property interest in his
continued employment and could not lawfully be disciplined or discharged except for
just cause and in accordance with due process. 4 R. Stat. § 121.207.
23. 4 R. Stat. § 124.301 entitles a regular-status employee to a pre-disciplinary,
non-investigative hearing before the appointing authority prior to the filing of any
administrative hearing for involuntary separation.
24. Respondent's own governing procedure independently confirms this obligation,
providing that an officer is entitled to a pre-disciplinary hearing — including notice of
the rules and statutes considered, presentation of evidence, witness statements, and an
informal opportunity to respond — unless affirmatively waived by the officer, and
that Respondent "shall be required to initiate an administrative claim and demonstrate
before the Administrative Court that such officer qualified for a general discharge,
prior to separating such employee." PPD SOP § 501.8(b)–(c).
25. This Court's jurisdiction independently extends to Respondent's underlying policy. 3
R. Stat. § 141.007 grants this Court original jurisdiction over all matters involving the
internal policy or rules of a civil service agency. PPD SOP § 501.3(c), which instructs
automatic discharge upon a third recorded warning without provision for the
individualized hearing and prior court proceeding required by 4 R. Stat. §§ 124.301
and 124.304(c), is accordingly reviewable and should be declared inconsistent with
state statute as applied to Petitioner.
26. Petitioner was afforded neither a pre-disciplinary hearing nor notice of any right to
one, did not waive that right, and Respondent did not initiate or prevail on any
proceeding before this Court prior to discharging him.
27. Petitioner's discharge was therefore issued without due observance of state statute and
of Respondent's own governing procedure, and is void.
COUNT II — Arbitrary and Factually Erroneous Administrative Demerits
28. Petitioner incorporates the foregoing paragraphs as though fully set forth herein.
29. An administrative demerit is reviewable where there is clear and present factual error
in its issuance, or where it was plainly and clearly arbitrary. 4 R. Stat. § 123.302(a).
30. Arbitrary punishment includes punishment with no factual backing and punishment
that takes no accounting for mitigating factors, circumstances, or liabilities, and no
appointing authority may issue arbitrary punishment. 4 R. Stat. §§ 123.401, 123.402.
31. The three administrative demerits underlying Petitioner's discharge held him to an
activity requirement he was structurally incapable of satisfying, as he was not
TED-certified, not on TED's roster, and not authorized to patrol on TED's behalf.
32. The issuing Captain has admitted she was unaware Petitioner was uncertified at the
time the demerits issued and that a "backlog" of similarly delayed warnings existed;
the reviewing Lieutenant's designee has admitted Petitioner had no means of knowing
of the deficiency before all three demerits were issued simultaneously.
33. The three demerits were accordingly issued in clear and present factual error and
were plainly and clearly arbitrary, and cannot lawfully support Petitioner's discharge.
COUNT III — Involuntary General Discharge Issued Without a Bona Fide Misconduct or
Personnel Investigation
34. Petitioner incorporates the foregoing paragraphs as though fully set forth herein.
35. An involuntary general discharge shall issue only where the findings of a bona fide
misconduct or personnel investigation indicate that the employee engaged in
wrongdoing in the form of negligence or recklessness. 4 R. Stat. § 124.304(c).
36. On information and belief, Petitioner's discharge followed automatically and
mechanically from the accumulation of three recorded warnings, pursuant to
Respondent's internal policy that "[u]pon receiving the third recorded warning, the
Professional Standards Division is instructed to involuntarily discharge the
employee," PPD SOP § 501.3(c), rather than from any independent bona fide
investigation or findings particular to Petitioner.
37. Petitioner's discharge accordingly fails to satisfy the statutory prerequisites for an
involuntary general discharge.
V. PRAYER FOR RELIEF
WHEREFORE, Petitioner respectfully requests that this Court:
(a). declare that Petitioner's discharge was arbitrary and issued without due observance of
state statute, and is therefore void;
(b). order Petitioner reinstated to the position of Patrol Officer with the Palmer Police
Department, with all attendant rank, privileges, and standing;
(c). order the expungement of the three recorded warnings dated August 27, 2026, from
Petitioner's personnel record;
(d). declare PPD SOP § 501.3(c) inconsistent with 4 R. Stat. §§ 124.301 and 124.304(c)
to the extent it authorizes discharge without the individualized hearing and prior court
proceeding those provisions require;
(e). award Petitioner his recoverable court costs pursuant to 7 R. Stat. § 132.203; and
(f). grant such other and further relief as this Court deems just and proper.
Respectfully submitted,
_______________________________
/s/ NPCWAR
Counsel for Petitioner
Bar No. 17132
_______________________________
/s/ SejeChrille
Petitioner
