IN THE SUPERIOR COURT OF THE
STATE OF RIDGEWAY
Halo4isin
Plaintiff,
v,
Ridgeway Parks Service,
Defendant.
MOTION TO DISMISS
Hon. EffortlessBrit
Docket Number: RSC-CM-0750
DEFENDANT’S MOTION TO DISMISS AND MEMORANDUM IN SUPPORT
COMES NOW, Defendant, Ridgeway Parks Service (RPS), by and through its counsel, Assistant
Attorney General wynneboy2010, respectfully submits this that this Court under Rid. R. Civ. P. P.
7.1(2)(3) to dismiss the supplemental claims introduced via Plaintiff's recent filing. In support of this
motion, Defendant states with particularity the following grounds:
I. THE ORIGINAL CONTROVERSY IS MOOT AND THE COURT LACKS
JURISDICTION OVER POST-MANDATE AGENCY ACTIONS
On August 20, 2026, this Court issued a Partial Summary Judgment mandating that Defendant
re-evaluate Plaintiff’s application specifically regarding the background investigation stage, without
consideration of prior appealed warnings. Defendant fully complied with this mandate. As Plaintiff
admits in his own filings, this re-evaluation resulted in Plaintiff passing the Final Screening phase.
Because Defendant fully executed the Court’s directive, the original legal controversy is resolved and
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Opposition to Motion
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moot. The Court's jurisdiction over the original pleadings ended upon compliance. Plaintiff's current
grievances stem from a completely separate, subsequent administrative phase—the Final Outcome
character evaluation. Plaintiffs cannot unilaterally extend this Court’s jurisdiction over new,
post-mandate executive actions simply by filing supplemental discovery demands under a closed
docket number.
II. PLAINTIFF FATALLY BYPASSED MANDATORY PROCEDURAL PREREQUISITES
Even if Plaintiff’s new claims were ripe for review, his method of introducing them is fatally
defective. Under established rules of civil procedure, a party seeking to litigate events that occurred
after the original pleadings must first file a standalone Motion for Leave to Supplement the Pleadings.
Plaintiff bypassed this mandatory prerequisite. Instead of seeking the Court’s permission to introduce
new claims, Plaintiff filed sweeping demands for expedited discovery, document preservation, and
injunctive relief concerning a claim that has not yet been authorized to exist on this docket. As
Plaintiff himself recently lectured this Court regarding procedural rules, permission from the Court is
a prerequisite to filing, not an entitlement a party may exercise unilaterally. Plaintiff’s failure to
obtain leave before burdening the docket with post-judgment discovery demands renders his motion
procedurally void.
III. PLAINTIFF FAILS TO STATE A CLAIM UPON WHICH RELIEF CAN BE GRANTED
Should the Court look past the jurisdictional and procedural defects, Plaintiff’s supplemental motion
still fails on the merits. Plaintiff challenges a Final Outcome denial issued pursuant to 4 R. Stat. §
121.102(e) (character defects). Under 4 R. Stat. § 121.103, the appointing authority is expressly
granted the power to evaluate applications subjectively. It is a foundational principle of administrative
law that the judiciary does not possess the authority to usurp or second-guess the subjective hiring
and character evaluations of an executive agency. Because the statute explicitly shields the subjective
weighting of the Superintendent, Plaintiff has failed to state a claim upon which this Court can grant
relief.
IV. CONCLUSION AND PRAYER FOR RELIEF
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Opposition to Motion
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Plaintiff’s Supplemental Motion seeks unauthorized discovery for unapproved claims stemming from
a closed case. Permitting this motion to proceed would invite endless satellite litigation and violate
the separation of powers. WHEREFORE, Defendant respectfully requests that this Court:
1. DENY Plaintiff’s Supplemental Motion for Limited Discovery, Preservation, Protective
Relief, and Leave to Supplement in its entirety;
2. DISMISS Plaintiff's supplemental claims with prejudice;
3. DIRECT the Clerk to formally close this case; and
4. Grant such other and further relief as the Court deems just and proper.
Date: September 21st, 2026
Respectfully submitted,
/s/ Wynneboy2010
Assistant Attorney General
Major Crimes Division
Public Integrity Division
R. Bar No. 19204
1100 Lakeside Drive
Annex Building
Palmer Ridgeway 80013
Counsel for the Ridgeway Parks Service
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Opposition to Motion
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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing State's Opposition was electronically
served upon Plaintiff, Halo4asin, on this 21st day of September, 2026, through the court's automated
filing system.
Date: September 21st, 2026
Respectfully submitted,
/s/ Wynneboy2010
Assistant Attorney General
Major Crimes Division
Public Integrity Division
R. Bar No. 19204
1100 Lakeside Drive
Annex Building
Palmer Ridgeway 80013
Counsel for the Ridgeway Parks Service
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Opposition to Motion
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Opposition to Motion
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