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Sunshine Crew Problems / A Message / Moving Steel

Every journey has its conclusion, and Tach’s chapter ends here.

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Awesome company, the best one in the server so far. Their roleplay can't be beaten.

Eastside Hustler Crips - Funeral Event (HIP Smokey)

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the boys are going strong

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What you're witnessing here are some of the greatest roleplayers to ever step foot on this server, taking one final trip down memory lane. Pay close attention, this is how it's done. Consider this your last chance to learn from the best.

Home-made / Your Local Weed Dealer

One love

IN THE SUPERIOR COURT OF THE STATE OF SAN ANDREAS RE: MENDOZA v. LOS SANTOS POLICE DEPARTMENT, et al. RENEWED RESPONSE IN OPPOSITION TO PETITION FOR DECLARATORY RELIEF ------------------------------------- Jurisdiction and Procedural Impropriety: Redundant Filing Against Non-Involved Parties: As in the original motion, the plaintiff erroneously names the Los Santos Sheriff's Department (LSSD) and San Andreas Department of Corrections and Rehabilitation (SADCR), although there is no connection with the incident and both these agencies. Declaratory relief necessitates a "justiciable controversy" between specific parties (Maryland Cas. Co. v. Pacific Coal & Oil Co., 312 U.S. 270). They were not represented by any officers, exercised no jurisdiction over the place of the supposed conduct, and had no administrative authority over Officer Love. Such insistence upon inclusion is judicial waste and intentional misdirection. The Video Evidence and it's Contextual Clarification: Officer Love's Conduct Was Lawful and Proportionate: The video confirms Officer Love told Ms. Mendoza to "move to the other side of the street" and included the words: "Or you could join them." This language, even forceful in its rhetoric, was followed by no prior physical action, detention, or escalation, and Mendoza did move accordingly without protest. There had been no constitutional violation. The police may direct people to move in the public interest or to prevent obstruction to justice, even in a place of public resort, according to Colten v. Kentucky, 407 U.S. 104 (1972). No detention, arrest, or deprivation of liberty took place. The encounter ended peacefully, undermining allegations of coercion or violations of rights. Recording in Public; First Amendment Not Absolute: Time, Place, and Manner Restrictions Apply: Glik v. Cunniffe (1st Cir. 2011) recognized the right to record police in public, but continued to remark that the right is "not without limits" and needs to be balanced against public safety and scene control. Officer Love's directive was content-neutral, meant for clearing the active arrest scene, not suppressing Mendoza's speech. As per Ward v. Rock Against Racism, 491 U.S. 781 (1989): "Even in a public forum, the government may impose reasonable restrictions on the time, place, or manner of protected speech." The instruction was brief, peaceful, and reasonable, consistent with safety procedure. Declaratory Relief – No Continuing Threat, Not Standing: No Live Case or Controversy: Declaratory relief under 28 U.S. Code § 2201 or state equivalents needs a continuing or threatened future legal injury. Mendoza: Was not arrested Was not charged Faces no ongoing harm or police interference The case lacks the immediacy or stakes required for declaratory judgment. Courts decline jurisdiction in such abstract disputes (Steffel v. Thompson, 415 U.S. 452). Mendoza has not demonstrated a legitimate threat of future enforcement action against her recording activity. The Court Cannot Legislate: There are no grounds for expansive judicial rulemaking: The plaintiff asks the court to set general policies on the behaviour of all law enforcement agencies towards civilian recorders. This is not a judicial but a legislative role. Courts decide individual violations, not policy guidelines. This request is vague, poses separation of powers conflict, and invites uneven enforcement across jurisdictions. The Accident Video Footage, Internal Affairs Report Becomes Obsolete, Not Evidence of Misconduct: New Video Overrides Earlier IA Finding, But Doesn't Create Misconduct: Yes, the video establishes the incident did indeed happen, which upholds against the earlier conclusion by the LSPD Internal Affairs that it "didn't occur." However: This doesn't retroactively constitute constitutional wrongdoing. The IA misreport can be an example of administrative failure, and not of legal fault. Courts do not issue declaratory relief based on bureaucratic incompetence alone (Ashwander v. TVA, 297 U.S. 288) The video creates a situation that an incident did indeed take place, not that Mendoza's rights were being violated. IN CONCLUSION: The plaintiff pleads no constitutional violation, no threat of continuation, and no fact basis for declaratory relief. The new video shows no unlawful activity on the part of Officer Love and instead confirms again that Mendoza's rights were not infringed upon. The defense respectfully requests the petition be denied in its entirety, with prejudice as to all non-involved law enforcement agencies. ---------------------- Respectfully submitted, Alexander Cornelius Braithwaite IV Office of the District Attorney | County of Los Santos State of San Andreas April 07th, 2025

Special Interests I Special Interests II Special Interests III

Gloria Mendoza v. The Los Santos Police Department, The Los Santos Sheriff's Department, The San Andreas Department of Corrections, and any other law enforcement agency within the State of San Andreas. Case Number: YY-XNNN Prepared by: Juan Tzompaxtle CIVIL CASE BRIEF FOR PLAINTIFF _______________________________________________ JURISDICTION AND APPLICABILITY OF DECLARATORY JUDGMENT: 1. The Federal Rules of Civil Procedure Rule 57 establishes the right for a Title III court to issue a declaratory judgment in the face of an actual case or controversy. to The “controversy” must necessarily be “of a justiciable nature, thus excluding an advisory decree upon a hypothetical state of facts.” Ashwander v. Tenn. Valley Auth., 297 U.S. 288, 325, (1936). The case presented is not hypothetical, Ms. Mendoza's right to film was cut short by a threat of a law enforcement officer thus depriving her of her constitutional rights. Although Ms. Mendoza was not arrested, that does not prohibit her from asserting a claim under 42 U.S.C. § 1983. The fact that Officer Love used his position to move Ms. Mendoza away from a scene that she had a legal right to observe and record, and for however short a period of time she was unable to record the scene when relocated prevented her from freely exercising her rights is not "hypothetical" in nature. Rather, those two acts give rise to a claim. This court is in a position to clarify the legality of video recording and audio recording law enforcement officers in public. However, even if the court finds that the unconstitutional threat and actions of a law enforcement officer does not establish a claim because the case is "moot," the court is permitted under Article III, Section 2, to hear the case because it is capable of repetition, yet evading review. Further, declaratory judgment is appropriate because "[a declaratory judgment] [. . .] which declares the rights of the parties or expresses the opinion of the court on a question of law, without ordering anything to be done, or requiring that an actual wrong, giving rise to a cause of action for damages, should have been committed or suffered." Stanley H. Mervis, Declaratory Judgments in Virginia, 1 Wm. & Mary Rev. Va. L. 32 (1950), https://scholarship.law.wm.edu/wmrval/vol1/iss2/2. (persuasive authority.) ARGUMENT: 1. The First Amendment to the United States Constitution protects the rights of citizens to assemble, protect the freedom of press, and protects citizens from unreasonable searches and seizures. The Courts of these United States have long concerned themselves with attempts by the government to chill the rights of citizens through intimidation. The law enforcement agencies within the State of San Andreas have taken advantage of the lack of precedent established by this Court on the topic of "obstruction of justice" when law enforcement officers are faced with a member of the public recording them. 2. On March 25th, 2025, Ms. Mendoza, was lawfully driving on a public roadway to the Idlewood Gas Station. During this drive, she lawfully parked her vehicle, dismounted the vehicle, and proceeded to a public sidewalk where she noticed a large crowd of people being detained. Ms. Mendoza decided to record the interaction, and states she was at minimum fifty feet from the scene, when a uniformed law enforcement officer, Officer Love approached her and asked what she was doing. Ms. Mendoza informed Officer Love that she was watching and filming. Officer Love requested that Ms. Mendoza leave the scene. Ms. Mendoza stated that she was over fifty feet from the incident, Officer Love persisted and threatened Ms. Mendoza stating if she did not leave "she would join them" (referring to the detained individuals). The threat is a violation of 42 U.S.C. 1983 a threat under the color of law, that for a period of time required Ms. Mendoza to move from a lawful position, and deprived her of her right to record in public the actions of law enforcement officers, giving rise to this request. The threat of arrest (or detention) is sufficient to establish a claim and controversy for declaratory relief. The facts of this case do not differ substantially from Steffel v. Thompson, 415 U.S.C. 452 (1974). In that case, a law enforcement officer threatened a Vietnam protestor with arrest when "petitioner and others were engaged in the distribution of handbills, which criticized American involvement in Vietnam, upon the exterior sidewalk of a large shopping center." Id. "Warned that they would be arrested if they continued to handbill, the group departed. However, petitioner and a friend returned 2 days later, and police again threatened them with arrest. Fearful of this prospect, petitioner left, while his companion, who remained, was arrested and charged with violation of the statute." Id. "The district court dismissed the claims of petitioner and others because it could find no active - and hence, no justiciable - controversy between the parties. Abandoning the action for injunctive relief, petitioner appealed the district court's denial of declaratory relief to the Court of Appeals for the Fifth Circuit, which affirmed, holding that to obtain declaratory relief from the threat of state prosecution petitioner was required to demonstrate irreparable injury resulting from bad faith harassment by the state." The Supreme Court of the United States reversed, holding: 1) that since petitioner faced a genuine threat of enforcement of a state criminal statute, the case presented an actual "controversy" as required by Article III of the Constitution; 2) that since no state prosecution was pending, declaratory relief was not precluded regardless of the propriety of injunctive relief; and 3) that it was irrelevant to the grant of declaratory relief whether the statute was attacked as being invalid upon its face or as applied." Steffel. Similar to Steffel, Ms. Mendoza faced a threat under the color of law. The charge of "obstruction of justice" has long been used to prevent the free exercise under the First Amendment. The role of the court is to determine the law drafted by the legislative branch, signed by the executive branch. In previous filing the state attacked the authority of this court to interpret and establish a test, or rule the practices of law enforcement agencies as unlawful. The facts presented in this case are unique to Ms. Mendoza but identify a larger need for the court to intervene and protect the rights of the citizens bestowed upon them by the Constitution. 3. The Supreme Court has held that public sidewalks, even those surrounding the Supreme Court building are a "Traditional Public Forum" See generally United States v. Grace, 461 U.S. 171 (1983). A traditional public forum receives the highest level of scrutiny when analyzing the governments action, the deference being given to the citizen. See Ward v. Rock Against Racism, 491 U.S. 781 (1989). 4. The First Circuit has clearly established that videotaping police carrying out their duties in public is constitutional in Gilk v. Cunnife, 655 F.3d 78 (1st Cir. 2011). "The First Amendment issue here is, as the parties frame it, fairly narrow: is there a constitutionally protected right to videotape police carrying out their duties in public? Basic First Amendment principles, along with case law from this and other circuits, answer that question unambiguously in the affirmative." Id. The right of a citizen to film their government and dissiminate that information is clearly affirmed throughout the opinion in Glik. The filming of government officials engaged in their duties in a public place, including police officers performing their responsibilities, fits comfortably within these principles. Gathering information about government officials in a form that can readily be disseminated to others serves a cardinal First Amendment interest in protecting and promoting “the free discussion of governmental affairs.” Mills v. Alabama, 384 U.S. 214, 218 (1966). Moreover, as the Court has noted, “[f]reedom of expression has particular significance with respect to government because it is here that the state has a special incentive to repress opposition and often wields a more effective power of suppression.’ “ First Nat'l Bank, 435 U.S. at 777 n. 11 (alteration in original) (quoting Thomas Emerson, Toward a General Theory of the First Amendment 9 (1966)). This is particularly true of law enforcement officials, who are granted substantial discretion that may be misused to deprive individuals of their liberties. Cf. Gentile v. State Bar of Nev., 501 U.S. 1030, 1035–36 (1991) (observing that “[t]he public has an interest in [the] responsible exercise” of the discretion granted police and prosecutors). Ensuring the public's right to gather information about their officials not only aids in the uncovering of abuses, see id. at 1034–35 (recognizing a core First Amendment interest in “the dissemination of information relating to alleged governmental misconduct”), but also may have a salutary effect on the functioning of government more generally, see Press–Enter. Co. v. Superior Court, 478 U.S. 1, 8 (1986) (noting that “many governmental processes operate best under public scrutiny”). 5. The law enforcement agencies of San Andreas have long ran wild with the idea that any citizen, videotaping any law enforcement officer, at anytime, can be detained or arrested. This has chilled the First Amendment, has prevented news outlets both official and unofficial from flourishing in the City of Los Santos -- and has resulted in the wrongful detention, or diminishment in the free exercise of the First Amendment -- for far too long. 6. This declaratory judgment comes after the Los Santos Police Department's Internal Affairs Group has determined that "the incident [of which Ms. Mendoza retained me] did not occur." This declaratory relief seeks to enjoin the law enforcement agencies throughout the furthest jurisdiction of this court from ever depriving citizens of their constitutional rights when recording law enforcement officers. 7. This declaratory judgment will resolve the controversy of this case, and establish a precedent allowing Ms. Mendoza, and other citizens, if any law enforcement officer chooses to act in a manner inconsistent with the federal precedent, and order of this court. 8. The plaintiff's prayer is that this court to impose a defined test for determining "obstruction" -- by defining a proximity, if one is appropriate at all, consistent with federal precedent -- of which a citizen can exercise their First Amendment rights in public by videotaping and audio recording without fear of unlawful arrest or detainment, and to adopt the First Circuit opinion that violating this test -- if the court deems one appropriate -- is grounds for defeating sovereign immunity claims against the law enforcement officer and agency. Exhibits 1. Video recording of the distance of Ms. Mendoza from the scene (( click the link for the album of the recording )). (( https://imgur.com/a/m5M1MMP )) 2. Response from the LSPD who found "the event did not occur." Witness List No witnesses are required or requested. _______________________________________________ Certification. The undersigned swears or affirms, under penalty of perjury, that the information contained herein is truthful to the best of his knowledge. Sworn this 6th day of April, 2025 by: /s/ Juan Tzompaxtle Juan Tzompaxtle

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