Lawsuit: Adjourned RylandW v. The Commonwealth of Redmont [2025] SCR 4

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Case Filing


IN THE SUPREME COURT OF THE COMMONWEALTH OF REDMONT
CIVIL ACTION


RylandW (Represented by zLost)
Plaintiff

v.

The Commonwealth of Redmont
Defendant

COMPLAINT
The Plaintiff complains against the Defendant as follows:

The Plaintiff has unfairly been removed from their position as Representative due to the Department of State randomly changing their voting system regarding surplus votes when recounting votes for the House of Representatives January 2025 election.

I. PARTIES
1. RylandW
2. The Commonwealth of Redmont

II. FACTS
1. On January 11th, Secretary of State TheReal42Person announced the results of the January Congressional Elections, in which surplus votes were allocated using the Last Parcel voting system, as we can see from the voting sheet in Exhibit A.
2. On January 17th 2025, the Patriotic Coalition of Redmont filed a case against the Commonwealth of Redmont (link).
3. On February 11th 2025, the Commonwealth responded to the case, stating that Representatives RylandW and zLost were unlawfully elected, and bigpappa140 and McBrittle147 should've been elected instead.
4. The recount done by Electoral Officer lcn used an entirely different system regarding allocation of surplus votes, where instead of the vote of the surplus voter who voted last having their preference allocated, it instead allocates the vote of the surplus voter who voted earliest (Exhibit B).
5. On February 14th 2025, the Supreme Court delivered a verdict ordering Representative RylandW and zLost to be removed from their position, and for these seats to be replaced by McBrittle147 and bigpappa140.

III. CLAIMS FOR RELIEF
1. There are two voters very important in this lawsuit, they are Voter 37 and Voter 41 in the original voting sheet, and in the second sheet, they are Voter 50 and Voter 100 (they are the same people, however have been numbered differently in both sheets. for ease of communication, they will be referred to by the number they are given in the original sheet.). Voter 37 was the last voter who voted for 2theo, and their 2nd preference was RylandW. Voter 41 was the earliest voter who voted for 2theo, and their 2nd preference was bigpappa140.
2. These two votes decide whether RylandW or bigpappa140 are eliminated or win the election, as both bigpappa140 and RylandW received the same amount of first preference votes. Assuming that last parcel is used for surplus allocation, Voter 37's vote is allocated from the surplus, which means that RylandW's vote count goes from 5 to 6. Both bigpappa140 and RylandW would survive the rounds until round 5, where all those who have 5 votes are eliminated, due to which bigpappa140 is eliminated, and RylandW moves onto the next round. In round 6, since only 11 candidates are left and there are to be 11 people to be elected, RylandW wins. However, if the system used by Electoral Officer lcn is used instead, Voter 41's vote is allocated from the surplus, RylandW's vote count would stay at 5, and they would be eliminated instead of bigpappa140 in round 5. This would mean that bigpappa140 would win the election, instead of RylandW. This is why it's very important what method of surplus allocation is used.
3. In the voting sheet we see used for the January 2025 House of Representatives election, the Last Parcel method (also referred to as the Hare-Clark method) for distribution of surplus votes is used. Meanwhile, in the recount done by Electoral Officer lcn, they use an entirely different system which (to the knowledge of the Plaintiff) is not used anywhere else in the world. What Electoral Officer lcn has done is re-number the voters according to the time they voted at from last to earliest, and then distributed the surplus vote of the voter that voted earliest. This method was not used by the DoS during the January 2025 House of Representatives election. Therefore RylandW's votes were in fact not miscounted, and the DoJ misled the court into believing that they had been.
4. Electoral Officer lcn has used an entirely different voting system than the actual one used in the January 2025 House of Representatives election, and then disregarded the results of the January 2025 House of Representatives election as invalid, in terms of RylandW's seat.
5. The law alleges that Last Parcel method is to be used, as the Electoral Act (link) states:
(3) Surplus Votes. If a candidate receives more votes than needed to meet the threshold, the surplus votes are transferred to the next preference on the voters' ballots.

Surplus is defined by the Oxford Languages Dictionary as:
an amount of something left over when requirements have been met

The votes that have been submitted last are the ones that have been left over, as the earliest votes are a part of the requirement that needs to be met to be elected. This has been the interpretation that the DoS has followed, as indirectly stated by the Secretary of State at the time TheReal42Person and directly stated by the author of the STV system in the Electoral Act xEndeavour (Exhibit C). This is further supported by the fact that Last Parcel was used in the original voting sheet for the January 2025 House of Representatives election.

IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:
1. A recount of the election to be done using the Gregory system.
2. $5,000 in punitive damages as Electoral Officer lcn has shown complete negligence (Exhibit D).
3. $10,000 in consequential damages due to Loss of Enjoyment in Redmont, as they have been abruptly removed as Representative, possibly for the remainder of his term depending on how long this case takes.
4. $5,000 in legal fees

1739618534457.png
yellow color meaning the vote that is chosen to be allocated for surplus
1739618593650.png
voting times of voter 37 (above) and voter 41 (below)
1739619075133.png
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1739619159540.png
RylandW has earnt 1 month 19d 20h 55m 39s aka 1196.93 hours of playtime since he joined the server 634 days ago (on May 23 2023)

1739619342539.png

1196.93h/634 days = 1.89 hours per day
In-game wages are paid in 15 minute intervals, 1.89 hours is 113.4 minutes, which consists of:
113.4/15 = 7.56 15 minute intervals.

Representatives earn $65 per 15 minutes, as stated in the Economic Standards Act (link). There were supposed to be 21 days left in RylandW's term (14th February 2025 --> 7th March 2025), so RylandW would've earnt the following through their wage:
7.56x65x21 = $9828
TheReal42Person
xEndeavour
lcn
1739620310350.png

By making this submission, I agree I understand the penalties of lying in court and the fact that I am subject to perjury should I knowingly make a false statement in court.

DATED: This 15th day of February 2025

 

Attachments

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Note: I have amended the witness list to add lcn as a witness.
 

Writ of Summons


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@Freeze_Line is required to appear before the Supreme Court in the case of RylandW v. The Commonwealth of Redmont [2025] SCR 4.

Failure to appear within 72 hours of this summons will result in a default judgement based on the known facts of the case.

Both parties should make themselves aware of the Court Rules and Procedures, including the option of an in-game trial should both parties request one.

 
Commonwealth is present your honor.
 
Thank you for the prompt response to this matter. The defendant has 72 hours to post their answer to complaint. Kindly inform us if you need any extension for this case.
 
Thank you for the prompt response to this matter. The defendant has 72 hours to post their answer to complaint. Kindly inform us if you need any extension for this case.

Your Honor,
I wish to file a Brief to the Court.
Do I have permission?
 
Your Honor,
I wish to file a Brief to the Court.
Do I have permission?

Objection


Breach of Procedure

This spectator deleted his previous request and reposted it. He is disrupting these proceedings and I urge the Court to hold him in contempt and strike his request.

 

Objection


Breach of Procedure

This spectator deleted his previous request and reposted it. He is disrupting these proceedings and I urge the Court to hold him in contempt and strike his request.

IN THE SUPREME COURT OF THE COMMONWEALTH OF REDMONT
RESPONSE TO OBJECTION

Let him cook 🔥
 
Your Honor,
I wish to file a Brief to the Court.
Do I have permission?
Why do you want to file a brief?

IN THE SUPREME COURT OF THE COMMONWEALTH OF REDMONT
RESPONSE TO OBJECTION

Let him cook 🔥
Kindly refrain from posting in a court case that you're not involved in unless you are submitting an amicus brief. This is a warning, doing this again will result in a contempt of court charge.
 

Objection


Breach of Procedure

This spectator deleted his previous request and reposted it. He is disrupting these proceedings and I urge the Court to hold him in contempt and strike his request.

Overruled. Two justices of this court agree that members of the public are allowed to request to post an amicus brief.
 
Thank you for the prompt response to this matter. The defendant has 72 hours to post their answer to complaint. Kindly inform us if you need any extension for this case.
Defense requests a 24 hour extension your honor, just got back from a family trip.
 

Answer to Complaint


IN THE FEDERAL COURT OF THE COMMONWEALTH OF REDMONT
ANSWER TO COMPLAINT

RylandW
Plaintiff

v.

The Commonwealth of Redmont
Defendant

I. ANSWER TO COMPLAINT
1. The defense AFFIRMS that "On January 11th, Secretary of State TheReal42Person announced the results of the January Congressional Elections" but DISPUTES that the system used was "the Last Parcel System" as that is not what the system is legally called.
2. The defense AFFIRMS that "On January 17th 2025, the Patriotic Coalition of Redmont filed a case against the Commonwealth of Redmont."
3. The defense AFFIRMS that "On February 11th 2025, the Commonwealth responded to the case, stating that Representatives RylandW and zLost were unlawfully elected, and bigpappa140 and McBrittle147 should've been elected instead."
4. The defense DOES NOT AFFIRM that "The recount done by Electoral Officer lcn used an entirely different system regarding allocation of surplus votes, where instead of the vote of the surplus voter who voted last having their preference allocated, it instead allocates the vote of the surplus voter who voted earliest."
5. The defense AFFIRMS that "On February 14th 2025, the Supreme Court delivered a verdict ordering Representative RylandW and zLost to be removed from their position, and for these seats to be replaced by McBrittle147 and bigpappa140."

II. DEFENSES
1. The Commonwealth contends that there is no specificity in the law on which voters to transfer versus which to "consume". The method of counting votes prescribed by the Constitution is inherently unfair, but we have to follow it as it is the supreme law of the land. On one hand, counting it the way the plaintiff desires makes it so the voters who vote later have more power in the election. The opposite is true for counting the votes backwards, as the plaintiff alleges was done. The Constitution gives no instructions as to what order the votes are to be counted in. The only fair way to have votes counted is for a different interpretation on the law.
2. "Surplus Votes. If a candidate receives more votes than needed to meet the threshold, the surplus votes are transferred to the next preference on the voters' ballots." The key issue is defining who the surplus voters are. There is nothing that says the surplus voters can't be all voters simultaneously. A popular method of transferring surplus votes is called the Gregory Method. It essentially takes a proportional fraction of each ballot and moves it, rather than arbitrarily moving whole voter ballots over unequally.
3. The Constitution establishes two key rights: "The right to vote in elections and referendums" and "Every citizen is equal before and under the law and has the right to equal protection and equal benefit of the law without unfair discrimination and, in particular, without unfair discrimination based on political belief or social status." By the logic of these two rights, every citizen is entitled not only to vote, but to have a vote that is equal in status to any other citizen's vote, especially since voting is a form of "political belief", explicitly covered under the equality right. We can now infer that ALL votes should be subject to equality where possible. As covered previously, a traditional "last parcel" method of voting produces vote inequality based on time, of all things. Some people live in different time zones, so this is systemically unfair. Luckily, as I laid out in defense item two, there is an interpretation of "surplus votes" that solves all the concerns of both the plaintiff and the defense.
4. I therefore would like the Court to rule in favor of neither party, implement the gregory method of counting surplus votes to maintain equality, and order a recount of the election under that system to see what the true Congressional composition should be.


By making this submission, I agree I understand the penalties of lying in court and the fact that I am subject to perjury should I knowingly make a false statement in court.

DATED: This 19th day of February, 2025.

 
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The defense agrees to summary judgment under the following terms:
1. The plaintiff modifies fact one to be accurate, as I outlined in my refutation.
2. The plaintiff modifies fact four to be more objective to what actually happened (less slant).
3. The plaintiff modifies the prayers for relief to the following:

IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:
1. RylandW be re-instated as Representative instead of bigpappa140. A mandatory recount be held under an equitable surplus allocation method, namely the "Gregory Method" which allocates proportions / fractions of ballots rather than whole ballots. Surplus votes are counted up, then all people who vote for the winning candidate have a fraction of their second choice moved according to the ratio between the surplus vote and the total vote count for that winning candidate.
2. $20,000 in punitive damages as Electoral Officer lcn has shown complete negligence (Exhibit D).
3. $25,000 in consequential damages due to Loss of Enjoyment in Redmont, as they have been abruptly removed as Representative, possibly for the remainder of his term depending on how long this case takes.
4. $9,828 in compensatory damages due to RylandW not being able to earn his wage as Representative as he has been removed (calculations given in Exhibit E).
2. $10,965 $5,000 in legal fees as I am charging RylandW 20% of the case value for representation.
 
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The defense has amended dispute five due to a copy paste error.
 
Does the plaintiff also want to do Summary Judgment?
 
The Plaintiff declines summary judgement as RylandW would've won whether Gregory or Last Parcel was used, therefore the point still stands that the DoS misled the courts to remove RylandW's position.
 
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The Plaintiff declines summary judgement as RylandW would've won whether Gregory or Last Parcel was used, therefore the point still stands that the DoS misled the courts to remove RylandW's position.
The summary judgment compromise allows Ryland to win his seat again. I’ll even throw in $10,000 in loss of enjoyment.
 
The Plaintiff will accept summary judgement if $5,000 extra is added on top for punitive damages, for a total of $20,000 in damages ($5,000 punitive, $10,000 loss of enjoyment, $5,000 legal fees).
 
The Plaintiff will accept summary judgement if $5,000 extra is added on top for punitive damages, for a total of $20,000 in damages ($5,000 punitive, $10,000 loss of enjoyment, $5,000 legal fees).
Defense accepts.
 
If both parties are okay with it, can we move the case to discovery so you can both amend your complaint and answer so this court can properly understand what is being asked of it in a summary judgment?
 
If both parties are okay with it, can we move the case to discovery so you can both amend your complaint and answer so this court can properly understand what is being asked of it in a summary judgment?
The defense is fine with that
 
Yes, Your Honor.
 
We're moving to discovery for 72 hours and then to summary judgment. Please make amendments to your complaint and answer.
 
The Plaintiff wishes to amend their prayers for relief as follows:

IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:
1. RylandW be re-instated as Representative instead of bigpappa140. A recount of the election to be done using the Gregory system.
2. $20,000 $5,000 in punitive damages as Electoral Officer lcn has shown complete negligence (Exhibit D).
3. $25,000 $10,000 in consequential damages due to Loss of Enjoyment in Redmont, as they have been abruptly removed as Representative, possibly for the remainder of his term depending on how long this case takes.
4. $9,828 in compensatory damages due to RylandW not being able to earn his wage as Representative as he has been removed (calculations given in Exhibit E).
5.
4. $10,965 $5,000 in legal fees as I am charging RylandW 20% of the case value for representation.
 
The Plaintiff wishes to amend their prayers for relief as follows:

IV. PRAYER FOR RELIEF
The Plaintiff seeks the following from the Defendant:
1. RylandW be re-instated as Representative instead of bigpappa140. A recount of the election to be done using the Gregory system.
2. $20,000 $5,000 in punitive damages as Electoral Officer lcn has shown complete negligence (Exhibit D).
3. $25,000 $10,000 in consequential damages due to Loss of Enjoyment in Redmont, as they have been abruptly removed as Representative, possibly for the remainder of his term depending on how long this case takes.
4. $9,828 in compensatory damages due to RylandW not being able to earn his wage as Representative as he has been removed (calculations given in Exhibit E).
5.
4. $10,965 $5,000 in legal fees as I am charging RylandW 20% of the case value for representation.
Granted, please amend.
 
The defense would like to end discovery early.
 
The Plaintiff concurs.
 
Your Honor, I apologize for my intrusion but I ask that this case be handled as soon as possible, due to the upcoming general elections.
 

Verdict


IN THE SUPREME COURT OF THE COMMONWEALTH OF REDMONT
VERDICT


RylandW v. The Commonwealth of Redmont [2025] SCR 4

I. PLAINTIFF'S POSITION
1. The plaintiff was originally declared elected in the January 2025 House of Representatives election under the Last Parcel voting system (Hare-Clark method).
2. A lawsuit was later filed by the Patriotic Coalition of Redmont, claiming the election results were incorrect. (see Lawsuit: Adjourned - SCR 1 [2025] The Patriotic Coalition of Redmont v. The Commonwealth of Redmont). As a result of the verdict of that lawsuit, the plaintiff lost their position as a member of the House of Representatives.
3. The second vote count used to re-tally the election was done using an unknown methodology. The plaintiff argues that under Last Parcel, as well as under Gregory, that they would still have won the election.
4. Plaintiff initially argues for the main methodology for counting votes to be Last Parcel, but for the purposes of summary judgment, also agrees with the Gregory Method.

II. DEFENDANT'S POSITION
1. The government agrees that the election happened, a lawsuit was filed, and the Supreme Court ruled to remove RylandW.
2. They disagree that a "different system" was used in the recount and argue that the law does not specify which ballots should be counted as surplus. They dispute that the Last Parcel System was used.
3. That neither party should win, a recount should be done with the Gregory Method, and a new recount using Gregort should be done to determine the correct election results.

III. THE COURT OPINION

The court has struggled with this opinion over the last few weeks since the request for motion for summary judgment was made. Typically, the process of a motion for summary judgment is quick, the facts are agreed upon so it is just a matter of the court’s interpretation of the law. Given that the parties seem to agree on what the law is, this would seem to lend itself to being a quick and easy decision for the court, right? Unfortunately not.

To begin with, the Supreme Court does not believe it has a right to dictate to the Department of State which voting method it used. The Department of State has the power of “Facilitation of Federal elections.” (see 30(a)(1)(g), Government - Constitution, in-line with 4(1)(g) Redundant - Department Reform Act which edited the Act of Congress - Executive Standards Act, soon to be replaced by upcoming constitutional changes seen here: Act of Congress - Commonwealth of Redmont Constitution Act and https://www.democracycraft.net/threads/executive-standards-amendment-act.24777/. (It should be noted that this power remains unchanged in the new constitution)). Judicial Officers have a duty to interpret and defend the constitution (see Lawsuit: Adjourned - hugebob23456 v. The Commonwealth of Redmont [2022] FCR 6). When the constitution explicitly permits power to a secretary, the court does not have the power to override it (Lawsuit: Adjourned - Aladeen22 v. The Department of Justice [2021] FCR 84). It is therefore not within our discretion to tell the DOS how to facilitate the election. Facilitation definition, per the Oxford Languages dictionary, is “the action of facilitating something.” Per the Oxford Languages dictionary, facilitating is the present participle of facilitate. The definition of facilitate is “make (an action or process) easy or easier.” Accordingly, it is the Department of State’s power to make elections easier means that they have control over the voting preference used, thus we defer to them on these matters.

The court reasserts its right to review the results as the court of disputed returns. (see Act of Congress - Electoral Act, soon to be amended by https://www.democracycraft.net/threads/electoral-amendment-act.24881/ (it should be noted that this power remains unchanged)). We have invalidated election results before. (see Lawsuit: Adjourned - SCR 1 [2025] The Patriotic Coalition of Redmont v. The Commonwealth of Redmont, Lawsuit: Adjourned - Prodigium & Partners at Law v. Commonwealth of Redmont [2021] SCR 1). This decision does not impair or impact the Supreme Court’s ability to review election results. We merely defer the electoral voting method to the Department of State.

The court notes that within the upcoming constitutional changes that the voting method does change to the Gregory Method. (see 5(3)(a) https://www.democracycraft.net/threads/electoral-amendment-act.24881/). It reserves the right of the legislative branch to make proper changes to the system of government utilizing the proper constitutional amendment method.

Onto damages. On a balance of probabilities, it is more than likely that this recount method harmed the plaintiff. The plaintiff alleged that they “randomly chang[ed]” the method to counting votes. While originally alleging that the Last Parcel system was used, their prayer for relief argues for Gregory. The defendant only agreed on summary judgment for the Gregory system. The Court needs factual alignment to conduct a summary judgment. But we cannot decide that the Gregory system should be used and override the Department of State’s power. Therefore, we’re deciding whether or not an error occurred that was, on a balance of probabilities, more likely that harm occurred.

Public Statements made by LCN showed that they were mistaken in handling the vote counting method. The defendant Does not Affirm whether LCN used an entirely different system. This pleading seems to be an error.

The defense’s argument can be summed up as follows: “If it were an error, we should use the Gregory Method to find out.” The defendant initiated a motion for summary judgment on the basis of the complaint’s pleading. The defendant specifically agreed for a motion for summary judgment if the complaint were amended on the defendant’s terms. The plaintiff did so.

The defendant’s outright disputement of the Last Parcel System is dispositive (meaning it nulls an element) of a summary judgment. The defendant however, simply chose not to affirm the fact revolving around LCN. Given that the defendant initiated summary judgment, asked the complaint to be changed, did not object to the changes, and still motioned for summary judgment anyways seems to be a positive affirmation of this fact. However, let’s say it was not a positive affirmation. The lack of affirmation, given the circumstances, will not be treated as a disputed denial of fact but instead as a neutral view of the fact. The plaintiff positively affirmed that Electoral Officer lcn used an entirely different system, and, acting on that fact, the defendant decided to ask this court for a recount of the election. If this fact were truly disputed, why would this issue be at play for the court to decide on summary judgment? It is not, therefore, the court can move forward on this issue in a summary judgment.

It seems more than likely that LCN made a mistake and decided to use an irregular vote counting method in re-tallying the election. On a balance of probabilities, we find favor in the plaintiff. However, with the on-going election, we decline to restore him to his seat and instead offer additional monetary damages.

IV. DECISION
The Supreme Court rules in a 3-0 decision in favor of the plaintiff and grants a modified prayer for relief.

1. $35,000 dollars in punitive damages.
2. $10,000 dollars in consequential damages for loss of enjoyment.

The Supreme Court thanks all involved.

 
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