Motion for Leave, Supplemental Complaint, and Memorandum of Law

Supplemental Complaint

After more than a month after Plaintiffs filed a Federal Civil Rights lawsuit against four Wake County Family Court Judges—including Judge Brian Ratledge and Judge Julie Bell—now, due to their failure to recuse themselves and take appropriate action, Plaintiffs Davis and Webster have submitted a Motion for Leave and a Supplemental Complaint. These new violations have increased the total counts from 15 to 17.

 

Why It Matters

  • Stopping Violation Escalation: Plaintiffs Davis and Webster in their new supplementary pleading have brought in new constitutional violations, which focus specifically on The Honorable Brian Ratledge and The Honorable Julie Bell’s refusal to recuse themselves. This is not merely dealing with past violations but with their continued actions which further violate the plaintiffs’ rights to due process.
  • Preventing Further Harm: This is designed to clearly make the federal court aware of what is happening to stop it from going any further than it already has. The plaintiffs hope to avoid a situation where the parties involved continue to be subjected to the procedural biases they have already encountered.
  • Establishing Accountability: The motion for leave and the supplemental complaint and memorandum of law aim to address actions by these court officers and make them accountable for what they’ve done, to help prevent further breaches of the legal process.
  • Strengthening A Case for Injunctive Relief: By formally documenting the judges’ continued participation despite the conflict of interest, i.e., the supplemental complaint, the Plaintiffs strengthen the basis of all their requests for injunctive relief. It provides the federal court a reason to get involved to help ensure these judges recuse themselves to protect the plaintiffs’ constitutional rights now and moving forward.
  • Setting up Another Lawsuit: The supplemental complaint enlarges the complaint by bringing the new claims up to 17.