IN THE SUPERIOR COURT OF RIDGEWAY FOR RIDGEWAY COUNTY
ARTHUR_CHEN;
Plaintiff ;
v.
STATE OF RIDGEWAY;
Defendant.
Case No. ___________________________
COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF
COMES NOW, Plaintiff Arthur_Chen, a judge of the State of Ridgeway holding senior
status, brings this Complaint against Defendant the State of Ridgeway and alleges as follows:
PARTIES
1. Plaintiff ARTHUR_CHEN (hereinafter “Plaintiff” or “Mr. Chen”) is a citizen of the
United States and resident of the State of Ridgeway. Plaintiff Arthur_Chen is a duly
appointed judge of the State of Ridgeway who lawfully holds senior status under 3 R.
Stat. § 122.107.
2. Defendant STATE OF RIDGEWAY (hereinafter “State” or “Defendant”) is one of many
state governments which constitute the United States of America, responsible, under
Article I, Section IV of the State Constitution, for the “common benefit . . . of the
people.”
JURISDICTION AND VENUE
3. Pursuant to Article V, Section IV of the Constitution of the State of Ridgeway, this
Honorable Court is vested with the jurisdiction over this matter as a civil dispute.
4. Venue is proper as the incident giving rise to the present litigation occurred within the
geographical bounds of Palmer, a municipality situated within Ridgeway County, and
thus subject to the jurisdiction and laws of the State of Ridgeway.
FACTUAL ALLEGATIONS
5. Under 3 R. Stat. § 122.107, a senior-status judge maintains that status by satisfying any
one of three alternatives: (a) actively managing a caseload one-fourth (1/4) that of an
active judge; (b) actively assisting in judicial duties, including case management,
settlement conferences, grand jury supervision, or other assignments; or (c) being on a
leave of absence with good cause.
6. The three alternatives in § 122.107 are joined by "or." Satisfying any single alternative is
sufficient to maintain senior status.
7. Plaintiff has at all relevant times managed a caseload far exceeding one-fourth that of an
active judge. Plaintiff has in fact carried out the full range of judicial duties of the court,
satisfying both § 122.107(a) and § 122.107(b).
8. Before October 1, 2026, 3 R. Stat. § 122.106 contained procedural requirements
governing the revocation of senior status including a referral by the Chief Judge of the
Superior Court, an office Mr. Chen used to hold.
9. On October 1, 2026, Bill S12-54, the “Judicial Appointment Revocation Amendment Act
of 2026,” was introduced in the Senate. Its stated purpose is to strip “unnecessary
revocation requirements” from § 122.106 and replace them with a bare majority vote of
the Senate.
10. On October 3, 2026, only two days after S12-54 was introduced, Resolution R12-24 was
introduced to "immediately revoke" the senior status of Plaintiff, identified by name.
11. R12-24 rests on two recitals: that Plaintiff "failed to uphold the duties and requirements"
of senior status, and that Plaintiff "admitted to committing multiple crimes." R12-24
identifies no duty Plaintiff failed to perform, no caseload figure, no crime, no charge, and
no evidence.
12. Plaintiff received no notice of any charge, no opportunity to be heard, no hearing, and no
opportunity to present evidence or confront any evidence against him before R12-24 was
introduced or acted upon.
13. Plaintiff has not been convicted of any crime.
FIRST CAUSE OF ACTION
Unlawful Removal
14. Plaintiff incorporates paragraphs 1 through 13.
15. The amended statute does not reach Plaintiff. Even if S12-54 is in force, amended §
122.106 permits revocation only when a judge "has failed to fulfill the duties and
requirements of senior status." Those requirements are defined by § 122.107, which
S12-54 does not change.
16. Plaintiff satisfies § 122.107(a) and § 122.107(b). Because the alternatives are disjunctive,
satisfying either one alone forecloses revocation. The statutory precondition for
revocation is absent, and the Senate acted beyond its statutory power.
17. Alleged crimes are not a ground for revocation. Neither § 122.106 (as amended) nor §
122.107 lists alleged criminal conduct as a basis for revoking senior status. Allegations of
judicial misconduct or crime belong to impeachment, judicial discipline, or criminal
prosecution, each with its own safeguards. The Senate cannot use a senior-status
revocation to bypass them.
SECOND CAUSE OF ACTION
Deprivation Without Due Process of Law
18. Plaintiff incorporates paragraphs above.
19. The Fourteenth Amendment to the United States Constitution forbid the State to deprive
any person of property or liberty without due process of law.
20. Senior status is conferred by statute and may be lost only on specified conditions. That
legitimate claim of entitlement, together with the office, compensation, and duties
attached to it, is a protected property interest. Board of Regents v. Roth, 408 U.S. 564
(1972). Branding Plaintiff a criminal in an official act of the Senate also injures his
reputation and standing in his profession, a protected liberty interest. Wisconsin v.
Constantineau, 400 U.S. 433 (1971).
21. Before depriving a person of a protected interest, the State must give notice of the
charges, an explanation of the evidence, and a meaningful opportunity to respond.
Cleveland Board of Education v. Loudermill, 470 U.S. 532 (1985). Plaintiff received
none of these.
22. The Mathews factors favor Plaintiff. Under Mathews v. Eldridge, 424 U.S. 319 (1976),
Plaintiff's interest is substantial; the risk of error is extreme, because R12-24 states no
facts and the record shows Plaintiff exceeds every requirement; and the burden of giving
notice and a hearing is minimal.
23. A process that allows a bare majority to remove a named judge "immediately," on
unexplained recitals, without notice or hearing, violates due process on its face and as
applied to Plaintiff.
WHEREFORE, Plaintiff Arthur_Chen respectfully requests that this Honorable Court:
A. Declare that Plaintiff satisfies the requirements for maintaining senior status under 3 R.
Stat. § 122.107 and is not subject to revocation under 3 R. Stat. § 122.106;
B. Declare that Resolution R12-24 is unlawful, exceeds the Senate’s statutory authority, and
violates Plaintiff’s right to due process of law under the Fourteenth Amendment to the
United States Constitution;
C. Declare Resolution R12-24 null and void and of no legal effect as applied to Plaintiff;
D. Enter a preliminary and permanent injunction prohibiting Defendant, its officers, agents,
employees, and all persons acting in concert with them from enforcing or giving effect to
Resolution R12-24 and from depriving Plaintiff of his senior status without lawful
authority and constitutionally adequate process;
E. Order the restoration of Plaintiff’s senior status and all rights and privileges attendant
thereto, to the extent they have been withdrawn pursuant to Resolution R12-24;
F. Award Plaintiff his costs of suit and such other relief as this Honorable Court deems just,
proper, and equitable.
Respectfully submitted,
ARTHUR_CHEN
