THE STATE OF RIDGEWAY
RIDGEWAY SUPERIOR COURT
SMARTABITY1, an individual,
Plaintiff,
-against-
RAINQG, in his official capacity as a lieutenant
of the Ridgeway County Sheriff's Office, and
the STATE OF RIDGEWAY.
Defendant.
RSC-CV-####
COMPLAINT
Presiding Judge: Hon. N/A
Plaintiff smartabity1, hereby files this complaint to commence the above-titled civil
action. It is alleged as follows:
PARTIES
1. Defendant rainqg is a resident of the State of Ridgeway. He is a lieutenant of the
Ridgeway County Sheriff's Office. He has held his peace officer certification from the
Law Enforcement Training Center since 2021-04-22.
2. The State of Ridgeway, which is a defendant of this civil action, is the state where this
civil action takes place.
3. Plaintiff smartabity1 is a resident of the State of Ridgeway. He has held his peace officer
certification from LETC since 2026-06-21.
JURISDICTION AND VENUE
4. This court, which is the Superior Court of the State of Ridgeway, shall "shall exercise
original jurisdiction for all civil and criminal cases or controversies under the rules as set
by the Supreme Court", Rid. Const., Art. Ⅴ, § Ⅳ, and it shall have original jurisdiction
over, among other things, "any controversy not otherwise falling within the jurisdiction of
the Supreme Court, Administrative Court, or Magistrate Court as set forth by law". See
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generally The Judiciary Act of 2026 § 302, S.B. 002, 11th Sen. (2026); 3 R. Stat. §
131.104(a–e). As the controversy is actionable here, jurisidiction is proper.
5. This court is the proper venue because civil actions shall only take place in the county
where the controversy occurs. See 7 R. Stat. §§ 131.001–131.003. Since this takes place
within the County of Ridgeway, a county of the State of Ridgeway pursuant to 9 R. Stat.
§ 321.001, venue is proper.
STATEMENT OF FACTS
6. On September 18th, UnitedGPT, the undersheriff of the Ridgeway County Sheriff's
Office, announced that the Ridgeway County Sheriff's Office was hiring. See Exh. 1,
infra. Invoking 4 Rid. Stat. § 122.105, the selection criteria was the following: (a) Prior
law-enforcement experience, including experience with another recognized
law-enforcement agency; (b) Prior supervisory or command experience, when relevant to
the position sought; (c) Demonstrated knowledge of law-enforcement procedures or
applicable state law; (d) Training and certifications relevant to the position; (e)
Demonstrated competency in written and verbal communication; (f) Demonstrated ability
to exercise sound judgment and discretion in circumstances relevant to the position; (g)
Demonstrated knowledge of constitutional principles and lawful law-enforcement
practices, where relevant to the position; (h) Prior disciplinary or performance history, to
the extent relevant to determining an applicant's suitability for appointment; (i)
Demonstrated leadership, professionalism, and integrity; (j) Other bona fide occupational
qualifications or merit-related factors reasonably necessary to fulfill the operational needs
of the Sheriff’s Office.
7. Plaintiff applied to the Ridgeway Sheriff's Office.
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8. When his application was read by RCSO Sgt. AjxGPT, he said, "Great application all
around with solid detail in every question. Will make a great deputy in the RCSO and
excited to train you."
9. Then, his application was screened by RCSO Lt. and Defendant rainqg, who is the chief
detective of the Criminal Investigations Division. The screening of applications is an
"in-depth background check of the applicant conducted by the Criminal Investigations
Division." Exh. 3, infra.
10. Defendant failed Plaintiff's screening. Defendant simply put a note over Plaintiff's cell,
which cited 4 Rid. Stat. § 122.402(h). Exh. 2, infra. The screening failed his application
as a whole. Ibid.
11. Plaintiff went to Undersheriff UnitedGPT to ask why his application was denied. Exh. 4.
He was directed to the FOIA officer of the Ridgeway County Sheriff's Office, who was
RCSO Lt. dev_Typ.
12. After Plaintiff made his FOIA request, he asked dev_Typ, who simply ignored him. Exh.
5.
EVIDENCE
EXHIBITS
# PREVIEW + URL DESCRIPTION
1. Undersheriff UnitedGPT's announcement of RCSO applications.
Taken by Plaintiff's attorney.
URL leads to the message itself.
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2. A screenshot of the RCSO application tracker taken by Plaintiff's
attorney. Timestamp on the bottom right translates to
2026-10-08T20:22:00-05:00.
3. The database of the Ridgeway County Sheriff's Office, which
includes the spreadsheet where applications are tracked.
Because the database contains rules of the Ridgeway County
Sheriff's Office, it is self-authenticating under Rid. Rule Evid.
902(3)(2).
4. A video of the conversation between Plaintiff and Undersheriff
UnitedGPT. Taken by Plaintiff.
Under Rid. Rule Evid. 902(4)(2), this exhibit is
self-authenticating.
5 The conversation between Plaintiff and dev_Typ, who is the FOIA
officer of the Ridgeway County Sheriff's Office. Taken by
Plaintiff.
Under Rid. Rule Evid. 902(4)(2), this exhibit is
self-authenticating.
TORTS
#1: Deprivation of Rights under Color of Law (7 Rid. Stat. § 121.403)
Tortfeasor: Defendant rainqg
13. When the screening of Plaintiff was failed by Defendant rainqg, see supra, at p. 3, ¶ 10,
he was acting under 4 Rid. Stat. § 122.401 and was therefore the acting authority: he was
acting under color of law.
14. Further, Plaintiff has the statutory rights to, inter alia, "a clear and defined reason for
their denial from the civil service, where such is applicable," 4 Rid. Stat. § 123.501(c),
and to "request information pertaining to the reason for their denial." Id., at § 123.501(d).
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By plainly citing a statute and nothing more, see supra, at p. #, ¶ 10, Defendant deprived
Plaintiff of his 4 Rid. Stat. § 123.501(c) right. As a result of the denial, Plaintiff's
application was failed.
15. Therefore, there is a cause of action for the tort of Deprivation of Rights under Color of
Law, of which Defendant rainqg is the tortfeasor.
#2: Civil Rights (7 Rid. Stat. § 122.101)
Tortfeasor: the State of Ridgeway
16. The Ridgeway County Sheriff's Office, which is "an agency of the County of Ridgeway,"
9 Rid. Stat. § 331.001, forbids its appointing authorities from complying with 4 Rid. Stat.
§ 123.501(c). See Exhs. 3 (application tracker orders applicants to not "DM Detectives
with questions regarding [their] background check."), 4 (Undersheriff UnitedGPT
conferring the aforementioned policy).
17. Because of this policy, Plaintiff was denied his right to a clear and defined reason for his
background check's failure and subsequent application denial.
18. As the County of Ridgeway is a politicial subdivision of the State of Ridgeway, and in
compliance with equitable priniciples applicable to the aforementioned tort, the State of
Ridgeway itself is, by extension, the malfeasor.
19. Therefore, there is a cause of action for the tort of Civil Rights, of which the State of
Ridgeway is the tortfeasor.
PRAYER FOR RELIEF
Plaintiff is entitled to and requests the following:
1. $### in punitive damages from Defendant rainqg in his individual capacity pursuant to 7
Rid. Stat. § 121.404;
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2. thereunder, an injunction enjoining Defendant rainqg to give Plaintiff a clear and defined
denial;
3. under 7 Rid. Stat. § 121.401, an injunction enjoining the State of Ridgeway from enacting
any policy of the Ridgeway County Sheriff's Office where appointing authorities shall not
give clear and defined reasons for denials from the civil service, see 4 Rid. Stat. §
123.501(c), supra; and
4. any other relief that this Court deems proper. See Rid. Rule Civ. Proc. 8(1) ("Relief in the
alternative or of several different types may be demanded.")
Respectfully submitted,
———————————————
/s/ smartabity1
Plaintiff of the above-titled civil action;
———————————————
/s/ thr33six8
Filer of this document and Attorney of
Plaintiff/Client smartabity1;
Licensed Attorney in the State of Ridgeway
since July 23rd, 2026 (R.S.B. License
#19302).
Timezone UTC–05:00.
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