IN THE SUPERIOR COURT OF THE
STATE OF RIDGEWAY
STATE OF RIDGEWAY,
Plaintiff,
v,
ICITRUZX,
Defendant.
MOTION FOR PRETRIAL RELEASE ON
CONDITIONS
Hon. vonhagen123
Docket Number: RSC-CM-3357
1. The State of Ridgeway, by and through its counsel, hereby moves this Honorable Court to
impose conditions upon the Defendant that will ensure their appearance and the safety of
the community pursuant to Rid. R. Crim. P. 7.1(5).
INTRODUCTION
2. The defendant has been charged by a superseding Criminal Information with two counts
of voluntary manslaughter, contrary to R.C.C. § 3.04.
3. These charges arise as a result of multiple investigations, which found reasons to believe
that the Defendant had knowingly shot and killed two people while in a heat of passion.
More specifically, the Defendant, a peace officer at the time, had responded to the noise
of gunshots by spraying two unsuspecting victims in bullets, killing them both.
4. As a result, there is a presumption that weighs in favor of strict pretrial release with
conditions.
——————————————————————————————————————————————
MOTION FOR RELEASE ON CONDITIONS
- 1 -
5. The Court has the authority to impose a “condition or combination of conditions
sufficient to secure the defendant’s appearance and the safety of victims and witnesses.”
Rid. R. Crim. P. 7.1(6).
BACKGROUND
6. In July of 2026, the Palmer Police Department’s Professional Standards Division (“PSD”)
received a misconduct report, which accused the Defendant, a PPD officer, of violating
the department’s use of force policy by shooting and killing another officer and detainee.
7. PSD Investigators substantiated the claim, and conducted an investigation which
involved interviewing victims and the Defendant. Ultimately, PSD concluded that the
Defendant was responsible for the shooting, and forwarded the case to the Ridgeway
State Police (“RSP”) for criminal inquiry.
8. RSP investigators conducted their own investigation, and interviewed victims, witnesses,
and the Defendant. The RSP investigator concluded that the Defendant had committed
voluntary manslaughter.
9. Both investigations found that the Defendant was providing security to other officers
while they were carrying out a search warrant when gunshots were heard in the area. The
Defendant, who was standing on the roof, immediately pointed their firearm towards the
officer and detainee, and fired repeatedly. The gunfire struck the officer and detainee,
killing them.
ARGUMENT
——————————————————————————————————————————————
MOTION FOR RELEASE ON CONDITIONS
- 2 -
10. This Court retains inherent authority to impose reasonable conditions that are appropriate
in aid of its jurisdiction in accordance with principles of law. Chambers v. Nasco, Inc.,
501 U.S. 32 (1991).
11. Although State law does not have codified factors for this Court to consider when making
a decision on pretrial release, the State of Ridgeway moves this Court to consider the
federal factors under under 18 U.S.C. § 1342(g) to consider appropriate pretrial
conditions or detention, which comprises of (1) the nature of the circumstances of the
offense charged; (2) the weight of the evidence against the defendant; (3) the history and
characteristics of the defendant; and (4) the nature and seriousness of the danger to any
person or the community that would be posed by the defendant’s release.
12. In State of Ridgeway v. TheUnknownSavagx, the Court ruled on, and imposed release
conditions based on the government’s motion which applied 18 U.S.C. § 1342(g).
13. In United States v. Dominguez, the Court held that even where a defendant has offered
evidence to rebut the fourth circumstance, the presumption remains a factor in the court’s
analysis of 18 U.S.C. § 3142(g). United States v. Dominguez, 783 F.2d 702, 707 (7th Cir.
1983).
14. This Court should use its inherent common law authority by considering the factors of 18
U.S.C. § 3142(g) when it comes to determining the appropriate conditions of release for
the defendant because they are charged with felony possession and weapons offenses.
ANALYSIS
15. For the reasons that follow, the State submits that the defendant cannot rebut the
presumption in favor of conditions that are held in federal courts, and that there exists a
——————————————————————————————————————————————
MOTION FOR RELEASE ON CONDITIONS
- 3 -
combination of conditions that will reasonably assure the safety of the community and
defendant’s appearance, as required by Rid. R. Crim. P. 7.1(6).
A. The Nature and Circumstances of the Offenses Charged
16. As noted above, the Defendant is charged with two felony counts of voluntary
manslaughter. Although given the acts were limited and contained to only two victims,
the Defendant’s misuse of a firearm clearly demonstrates a hazard to others. Accordingly,
the Court should impose a condition which ensures the Defendant cannot harm others
while handling a firearm.
17. Thus, the nature and circumstances of the offenses weigh in favor of pretrial conditions.
B. The Weight of the Evidence Against the Defendant
18. The evidence against the Defendant is strong. Firstly, there is no question as to identity in
this case.
19. Secondly, the evidence has been put under immense analysis and scrutiny by both PSD
and RSP investigators, who assessed that the evidence to be credible, reliable, and
relevant. The evidence against the Defendant is clear, and shows every aspect of the
crime as alleged in the Information.
C. The Nature and Seriousness of the Danger to Any Person or the Community
20. The RSP and PSD investigations both noted the lack of care when the Defendant handled
a firearm. Their conduct caused two people to be shot and killed, because the Defendant
had recklessly begun shooting instead of relying on training.
21. So, although their conduct does not warrant extreme conditions, the facts do warrant
certain conditions to avoid any further reckless firearm usage.
——————————————————————————————————————————————
MOTION FOR RELEASE ON CONDITIONS
- 4 -
22. Thus, this factor weighs heavily in favor of setting strict pretrial conditions.
MOST APPROPRIATE CONDITIONS
23. Rid. R. Crim. P. 7.1(5) provides statutory conditions that this Court may impose.
Accordingly, the State believes that the following conditions under this statue would (1)
reasonably assure the defendant’s appearance; and (2) the safety of the community:
a. A requirement that the defendant remain a participant in the proceeding
communications, respond to the court there, and report any change of username to
the clerk within twenty-four (24) hours;
b. A requirement that the defendant not renounce residency in the State of Ridgeway
and not leave the State while the matter is pending;
c. An order that the defendant have no contact with the following:
i. FryIsPro;
ii. Patrickstarcheeks1; and,
iii. DannyDoesApprove
d. An order that the Defendant does not possess a firearm or other deadly weapon
while the matter is pending; and,
e. An order that the Defendant refrain from conduct of a kind charged in the
accusatory instrument.
——————————————————————————————————————————————
MOTION FOR RELEASE ON CONDITIONS
- 5 -
CONCLUSION
24. For all of the reasons set forth above, and other any reasons set forth at any hearing on
this issue, a consideration of the evidence in this case and applicable common-law factors
compel the conclusion that the defendant should be released with strict conditions.
25. WHEREFORE, the State respectfully requests that the Court grant its motion and impose
conditions of release on the defendant.
Date: October 1, 2026
Respectfully submitted,
——————————————————————————————————————————————
MOTION FOR RELEASE ON CONDITIONS
- 6 -
