IN THE SUPERIOR COURT OF RIDGEWAY FOR RIDGEWAY COUNTY
ARTHUR_CHEN
Plaintiff;
-v-
LARGETITANIC2, in his official capacity as
President of the Senate; and
NISICULT, in his official capacity as Deputy
Sheriff and Sergeant-at-Arms of the State Senate
Defendant.
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Case No.: ______________________________
COMPLAINT FOR DECLATORY AND INJUNCTIVE RELIEF
I. INTRODUCTION
Petitioner Arthur Chen, a member of the press, petitions this Court for an emergency writ of
habeas corpus ordering his immediate release. On [date], Petitioner was arrested at the direction
of Respondent LargeTitanic2, President of the Senate, and taken into custody by Respondent
Nisicult, Deputy Sheriff and Sergeant-at-Arms of the State Senate, on a charge of Contempt of
Senate under RCC § 1.06.
Petitioner has never received a probable cause hearing. No neutral judicial officer has ever
reviewed whether the charge is supported by facts. The arrest arose from Petitioner's lawful
newsgathering. This detention violates due process and the freedom of the press, and it must end
immediately.
II. PARTIES
1. Petitioner Arthur Chen is a member of the media working as reporter for the Alder
Group
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2. Respondent LargeTitanic2 is the President of the Senate and is sued in his official
capacity. Upon information and belief, Respondent LargeTitanic2 ordered and directed
Petitioner's arrest.
3. Respondent Nisicult is a Deputy Sheriff and the Sergeant-at-Arms of the State Senate
and is sued in his official capacity. Respondent Nisicult carried out Petitioner's arrest.
IIII. STATEMENT OF FACTS
1. On Sep 24, 2026, Petitioner was present at State Capitol to report on the senate session.
2. Petition was wearing a press vest and holding a camera.
3. Respondent Nisicult arrested Petitioner at the direction of Respondent LargeTitanic2 and
charged him with Contempt of Senate under RCC § 1.06.
4. Petitioner was never brought before a judge or magistrate for a probable cause
determination despite requesting one.
IV. GROUNDS FOR RELIEF
Ground One: Detention Without a Prompt Judicial Determination of Probable Cause
Violates Due Process
A person arrested without a warrant is entitled to a prompt judicial determination of probable
cause as a condition of continued detention. Gerstein v. Pugh, 420 U.S. 103 (1975). A
determination made more than 48 hours after arrest is presumptively unreasonable, and the
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government must then prove an emergency or extraordinary circumstance justifying the delay.
County of Riverside v. McLaughlin, 500 U.S. 44 (1991).
Petitioner has received no probable cause determination at all. A legislative officer's belief that
contempt occurred is not a substitute for review by a neutral judicial officer. Continued detention
is therefore unlawful.
Ground Two: The Facts Do Not Satisfy the Elements of RCC § 1.06
RCC § 1.06 applies only to a person who, "without lawful justification, fails to appear after being
issued any lawful senatorial subpoena, writ of command, or who obstructs any session of the
whole or partial Senate."
The first prong cannot apply because Petitioner was never issued any subpoena or writ of
command. The second prong requires actual obstruction, meaning conduct that stopped, delayed,
or interfered with a Senate session. Petitioner's [observing / recording / reporting] did none of
those things. Presence and documentation are not obstruction.
The statute also excuses conduct undertaken with "lawful justification." Constitutionally
protected newsgathering is lawful justification. Because neither prong is met, no probable cause
exists.
Ground Three: The Arrest Violates Petitioner's Freedom of the Press
The First Amendment protects the freedom of the press, and newsgathering receives
constitutional protection. Branzburg v. Hayes, 408 U.S. 665, 681 (1972). Public access to
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information about government proceedings lies at the core of that protection. Richmond
Newspapers, Inc. v. Virginia, 448 U.S. 555 (1980). Arresting a journalist for reporting on the
Senate, without actual disruption, punishes protected activity and chills the press. An arrest
motivated by retaliation for protected activity raises serious constitutional concerns. See Nieves v.
Bartlett, 587 U.S. 391 (2019).
Ground Four (Alternative): RCC § 1.06 Is Unconstitutionally Vague and Overbroad as
Applied
A criminal statute violates due process if it fails to give fair notice of what is prohibited or invites
arbitrary enforcement. Kolender v. Lawson, 461 U.S. 352 (1983). The undefined term
"obstructs," applied to a journalist who caused no disruption, gives Senate officers unchecked
discretion to arrest reporters whose coverage they dislike.
VI. IRREPARABLE HARM AND NEED FOR IMMEDIATE RELIEF
The loss of First Amendment freedoms, even for minimal periods of time, unquestionably
constitutes irreparable injury. Elrod v. Burns, 427 U.S. 347, 373 (1976). Petitioner's liberty is
being restrained right now without any judicial review. There is no adequate alternative remedy
because no probable cause hearing has been held or scheduled. Delay would render relief
meaningless.
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VII. PRAYER FOR RELIEF
Petitioner respectfully requests that this Court, on an emergency basis:
1. Immediately issue a writ of habeas corpus, or an order to show cause, directing
Respondents LargeTitanic2 and Nisicult to produce Petitioner before the Court and
justify his detention within [24] hours;
2. Order Petitioner's immediate release from custody;
3. In the alternative, order an immediate probable cause hearing within [24] hours;
4. Dismiss the charge under RCC § 1.06 for lack of probable cause;
5. Enjoin Respondents from re-arresting Petitioner on the same facts while this matter is
pending; and
6. Grant any further relief the Court deems just and proper.
VIII. VERIFICATION
I, Arthur Chen, declare under penalty of perjury that the facts stated in this petition are true and
correct to the best of my knowledge.
Respectfully submitted,
/s/
Arthur_Chen
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