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

[zLost]

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. RylandW be re-instated as Representative instead of bigpappa140.
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).
5. $10,965 in legal fees as I am charging RylandW 20% of the case value for representation.

Spoiler: EXHIBIT A

Copy of Untitled spreadsheet

docs.google.com

yellow color meaning the vote that is chosen to be allocated for surplus

voting times of voter 37 (above) and voter 41 (below)

Spoiler: EXHIBIT B

January 2025 - House Election Investigation

docs.google.com

Spoiler: Exhibit C

Spoiler: EXHIBIT D

Spoiler: EXHIBIT E

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)

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

Spoiler: WITNESS LIST

TheReal42Person
xEndeavour
lcn

Spoiler: PROOF OF REPRESENTATION + LEGAL FEES

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

 

[zLost]

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

 

[Matthew100x]

Writ of Summons

@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.

​

 

[Alexander P. Love]

Commonwealth is present your honor.

 

[Matthew100x]

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.

 

[Babysoga4real]

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?

 

[Alexander P. Love]

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.

 

[zLost]

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

 

[Matthew100x]

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.

 

[Matthew100x]

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.

 

[Matthew100x]

My apologies @zLost. You are obviously free to post as the plaintiff's attorney.

 

[Alexander P. Love]

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.

 

[Matthew100x]

Granted.

 

[Alexander P. Love]

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.

 

[Alexander P. Love]

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.

 

[Alexander P. Love]

The defense has amended dispute five due to a copy paste error.

 

[Matthew100x]

Does the plaintiff also want to do Summary Judgment?

 

[zLost]

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.

 

[Alexander P. Love]

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.

 

[zLost]

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).

 

[Alexander P. Love]

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.