Steven J. Stringfellow v. Texas Department of Public Safety

ACCEPTED 15-24-00024-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 15-24-00024-CV 2/14/2025 5:09 AM CHRISTOPHER A. PRINE ____________________________________________________________________________________________________________________________________________________________________ CLERK 15th Civil Court of Appeals FILED IN 15th COURT OF APPEALS Texas AUSTIN, TEXAS ____________________________________________________________________________________________________________________________________________________________________ 2/14/2025 5:09:47 AM Steven J Stringfellow Texas Department CHRISTOPHER of Public Safety A. PRINE 10160 Hwy 242 Assistant Attorney General John Sydow Clerk Ste 800-4117 Law Enforcement Division ~v~ Conroe, TX 77385-4379 PO Box 12548 (713) 570-6738 Austin, TX 78711-2548 [email protected] (512) 463-2080 [email protected] ____________________________________________________________________________________________________________________________________________________________________

Motion of Frivolous Claim ____________________________________________________________________________________________________________________________________________________________________

1. Motion of frivolous claim is hereby filed with the Court under Chapter 105 Texas Civil Practice and Remedies Code. 2. The counterclaim of the state agency in question which this motion deems frivolous would be the Appellee's claim that sovereign immunity may allow this case to be dismissed in their favor.

3. The Appellee's claim of sovereign immunity is frivolous due to the fact that federal law under the FTCA law enforcement proviso in 28 USC 2680(h) holds law enforcement accountable for certain intentional torts committed against civilians, and with that having been well-proven in this case by the Appellant; furthermore, the state allows for relief to be granted for unintentional torts as well, and with this cause possessing elements of both in an escalating manner, indicating that the malfeasance was moreso intentional at its root, though still would not necessarily exclude unintentional elements.

4. Sovereign immunity is a legitimate claim under the Article III precedent law, though the Court should bear in mind that that precedent law of course would be for civil sovereign immunity, with government sovereign immunity being only one side and with the other side being civilian sovereign immunity--meaning that such constitution may apply to the caveat in either direction depending upon the sovereignty, with it well understood that citizens of this Nation's governmental structure are moreso sovereign their government ceteris paribus, actually being it, and so the only time that government may normally supersede itself is when recession's extenuation for secession prevails, which may only occur under recession's clause towards refederation higher against itself, being derived from the Second Paragraph of The Declaration of Independence by the 10th and 14th Amendments.

5. Obvious it should be that failure to hold someone accountable for undue actions would constitute a type of hypocrisy absent humor at the least and time at most, with civil rule favoring plaintiffs, and so officials who have more responsibility should be scrutinized moreso though also given a type of immunity for torts committed within the scope of office while exercising due care as it were. When that privilege is abused though there should be extra damages awarded to those affected duly, though when we factor in the need to secede from recession in order to exact refederation higher, judgment may indeed perceive those afflicted by such normally unlawful action as being deserving of it to a certain degree simply due to the caveat...for if a citizen were not in caveat for secession also being in a recession, the law may view such an individual as having been recessive moreso primarily due to the paramount being of the people at any and every rate, and so federal theory would requite civil policy to sway in favor of government in those cases with it being unspoken that such action should A. tend to align the proper caveat of secession towards the greater net constitution and B. be able to be sued over at a later date for relief anyway...and with it also understood that civil policy may shelter the official actor at that time too under recession's clause the same.

6. Claim that a public in recession would deserve such unlawful action by the state may apply to those citizens not in caveat as outlined, though also may apply to those within because the constitution would imply that civilians personally injured by government who were within caveat who technically would not be at normal fault then could seek relief and be granted compensation, thereby supporting the caveat just the same, when "deserving" would take on an even more constitutional meaning associated with humor in net. In fact, when recession becomes federal when total debt eclipses half of total assets, government may take the offensive and actively seek to injure any and all citizen parties that it normally can so that the public may begin to be culled with respect to the caveat at large, with it being implied that the courts would have seeded caveat enough during the initial stateful phase of recession and so able to further separate sovereign from unsovereign by inuring those in caveat through heightened relief from the courts.

7. Such regard makes much more sense when we regard the evidence in this case, for there would be no better explanation for the highly unprofessional actions of these state employees for albeit intentionally and negligently injuring an otherwise law abiding citizen from an upstanding background no less, which would be a tarnish upon reputation in general otherwise. Though when we factor in the advanced social technological apparatus in federal government that is secession's keel, such actions may actually be interpreted as a type of behavior to be associated with perhaps one of the most keen and advanced psychosocial traits one could officially possess, giving the state the impetus to uphold more through relief being granted.

8. As such, the Appellee's counterclaim of government sovereign immunity would be frivolous against the Appellant's claim of civil sovereign immunity superseding.

9. Appellant also states that if the action is dismissed or judgment is awarded to the party, the party intends to submit a motion to the court to recover fees, expenses, and reasonable attorney's fees.

I, Plaintiff Steven J Stringfellow, hereby certify that all of the foregoing is true and correct under penalty of law.

Statefully Submitted,

02/14/2024 ___________________________________________ Dated: ______________

Steven J Stringfellow 10160 Hwy 242 Ste 800-4117 Conroe, TX 77385-4379 [email protected]

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Certificate of Service _____________________________

I certify that a copy hereof has been furnished towards: Law Enforcement Defense Division Office of the Attorney General P.O. Box 12548 Austin, Texas 78711-2548 (512) 463-2080 / Fax (512) 370-9994 [email protected]

Return service to: Steven J Stringfellow 10160 Hwy 242 Ste 800-4117 Conroe, TX 77385-4379 (713) 570-6738 [email protected]

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Envelope ID: 97377423 Filing Code Description: Motion - Exempt Filing Description: Motion of Frivolous Claim Status as of 2/14/2025 7:08 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Rebecca Kaluhiokalani [email protected] 2/14/2025 5:09:47 AM SENT Gloriana Ojeda [email protected] 2/14/2025 5:09:47 AM SENT John Sydow 24127980 [email protected] 2/14/2025 5:09:47 AM SENT Steven Stringfellow [email protected] 2/14/2025 5:09:47 AM SENT