LGBTQIA+ Pride Proclamation lawsuit plaintiff Sara Bloomberg, through lawyer Rook Ringer, has knocked St. Johns County Commission Chairman JEREMIAH RAY BLOCKER's arguments into a cocked hat. Three cheers!
Once again, our bigoted County has been shown lacking in compassion or respect for human rights.
The snooty 120 year old MARKS GRAY corporate law firm and partners SUSAN ERDELYI, frequent defender of civil rights violations, show themselves to be lacking in both legal and moral reasoning. Why would any law student want to work there as a law clerk or attorney?
In a footnote, attorney Ringer says, "during the Civil Rights Era, any advocation for equal rights for African Americans was often similarly derided as 'Far Left' or even 'Communist'. Unfortunately, the Defendants are repeating the sins of the past."
The madness and meanness of St. Johns County's anti-LGBTQIA+ bigotry belong in the dustbins of history, along with racist Sheriff L.O. Davis.
Here is the plaintiff's response to the otiose arguments of St. Johns County, which Rev. Dr. Martin Luther King, Jr. once called "the most lawless place in America":
Case 3:21-cv-00575-TJC-JRK Document 19 Filed 08/30/21 Page 1 of 16 PageID 765
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
JACKSONVILLE DIVISION
SARA BLOOMBERG, Plaintiff,
v.
JEREMIAH RAY BLOCKER, in his personal and professional capacity as the chair of St. Johns County Board of County Commissioners, and as Commissioner for District 4; and the ST. JOHNS COUNTY BOARD OF COUNTY COMMISSIONERS;
Defendants.
Case No.: 3:21-cv-00575-TJC-JRK Timothy J. Corrigan, Judge
James R. Klindt, Magistrate Judge
COMES NOW the Plaintiff, SARA BLOOMBERG (hereinafter, the “Plaintiff’), by and through the undersigned counsel, and hereby responds to the Defendants’ Motion to Dismiss First Amended Complaint (ECF 13) [Dkt. #18] (hereinafter, the “Motion to Dismiss”), filed by the Defendants, JEREMIAH RAY BLOCKER (hereinafter, “Chairman Blocker”), in his personal and professional capacity as Chair of the St. Johns County Board of County Commissioners, and the ST. JOHNS COUNTY BOARD OF COUNTY COMMISSIONERS (hereinafter, the “Board”), (hereinafter collectively, the “Defendants”) and states the following:
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MEMORANDUM OF LAW I. Standard of Review.
The threshold for surviving a motion to dismiss for failure to state a claim under Fed.R.Civ.P. 12(b)(6) is a low one. Quality Foods de Centro Am., S.A. v. Latin Am. Agribusiness Dev. Corp., S.A., et al., 711 F.2d 989, 995 (11th Cir.1983). A plaintiff must plead only enough facts to state a claim to relief that is plausible on its face. Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (abrogating the “no set of facts” standard for evaluating a motion to dismiss established in Conley v. Gibson, 355 U.S. 41, 45–46, (1957)). Once a claim has been stated adequately, it may be supported by showing any set of facts consistent with the allegations in the complaint. Id. (citing Sanjuan v. American Board of Psychiatry and Neurology, Inc., 40 F.3d 247, 251 (7th Cir.1994)). In evaluating the sufficiency of a complaint in light of a motion to dismiss, the well pleaded facts must be accepted as true and construed in the light most favorable to the plaintiff. Quality Foods, 711 F.2d at 994–95.
Because of the liberal pleading requirements of the Federal Rules, rarely will a motion to dismiss for failure to state a claim be granted. Quality Foods, 711 F.2d at 995. Indeed, such a motion should not be granted “unless it appears beyond doubt that the plaintiff can prove no set of facts in support of his claim which would entitle him to relief.” Id. (quoting Conley, 355 U.S. at 45–46, 78 S.Ct. at 102; accord McLain v. Real Estate Board of New Orleans, Inc., 444 U.S. 232, 246 (1980); Dussouy v. Gulf Coast Investment Corp., 660 F.2d 594, 602 (5th Cir.1981); Quinonez v. Nat'l Ass'n of
Sec. Dealers, Inc., 540 F.2d 824, 826-827 (5th Cir. 1976). Furthermore, a claim has Page 2 of 16
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facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged. Ashcroft v.Iqbal, 556 U.S. 662, 678 (2009).
II. Argument.
A. The Plaintiff has article III standing.
Once again, the Defendants initially resort to raising what are generally referred
to as “strawman arguments”. See, Consalvo v. State, 697 So.2d 805, 814–15 (Fla. 1996) (explaining that a strawman argument is one where one party creates an issue not raised by the opposing party then proceeds to knock it down) (cited in Middleton v. State, 220 So. 3d 1152, 1177 (Fla. 2017)). Here, the strawman argument is the idea that the Plaintiff is attempting to argue that they are entitled to set the Board’s agenda, or that they are entitled to force the Board to approve certain resolutions.
And sure, the Defendants do a decent job of attacking that argument, even though it is not an argument raised by the Plaintiff. To the contrary, this case is essentially about two things, really: (1) can the Defendants shut out all requests for resolutions with respect to the LGBTQ community, solely because they address the LGBTQ community; and (2) did the Defendants violate the law by making those decisions outside of the proper Sunshine Law provisions?
Here, as argued previously, if the Defendants were to have a policy of denying agenda placement on the basis of religion (i.e., allowing pro-Catholic agenda items while denying pro-Protestant, Jewish, etc., groups), this Court would easily recognize
these as unlawful content restrictions under the Constitution. Yet here, the decision to Page 3 of 16
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deny agenda placement of the LGBTQ Pride Proclamation is undoubtedly due to Chairman Blocker’s anti-LGBTQ religious beliefs. As noted in the Amended Complaint, Chairman Blocker has allowed “controversial” proclamations when they were supported by controversial right-wing, anti-LGBTQ organizations.
Essentially, the strawman argument fails, but the Defendants are not content to limit such strawman arguments to this section.
B. Count I properly alleges a First Amendment violation.
Once again, the strawman argument rears its ugly head. The Defendants arge that the issue is not about a “citizen’s right to free speech”, but rather that this action is asking “for a court to order a government to speak”. [Motion to Dismiss, Dkt. #18, p. 11]. As has been stressed numerous times, both before this Court and in the pleadings, this case is not as simple as that, and no amount of strawman arguments by the Defendants can force the issues to miraculously change into ones that are more easily ‘knocked down’ by the Defendants.
Here, the best manner of approaching this issue is by comparing it to that of the enforcement of Title VII of the Civil Rights Act (hereinafter, the “Civil Rights Act”). The Civil Rights Act did not say that an employer would be forced to hire African American people applicants. Rather, the issue was that such an employer could not deny those applicants on the basis that they were African American. Here, it is not even in dispute that the Defendants had an unwritten but binding policy of refusing to grant any proclamation deemed “too far left” or “controversial”, as was admitted by
the Defendants’ submission of an Affidavit by Michael Ryan, the St. Johns County Page 4 of 16
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Assistant Director of Public Affairs in the Office of the County Administrator. [Dkt. #10-4, p. 3].1
Similarly, if St. Johns County had a policy of not hiring Jewish people, and a Jewish person found out and filed a civil rights complaint, that would not be about that Jewish person “forcing” the County to hire her but would instead be directed to the issue of a blanket denial of all potential Jewish employees.
Here, the issue is that the Defendants have decided that anything dealing positively with the LGBTQ community is somehow “Far Left” and “controversial”. However, just as Title VII of the Civil Rights Act prohibits discrimination against the hiring of African Americans, the United States Supreme Court has held that it also applies to the LGBTQ community, based upon the definition of “on the basis of sex”:
Because discrimination on the basis of homosexuality or transgender status requires an employer to intentionally treat individual employees differently because of their sex, an employer who intentionally penalizes an employee for being homosexual or transgender also violates Title VII. There is no escaping the role intent plays: Just as sex is necessarily a but-for cause when an employer discriminates against homosexual or transgender employees, an employer who discriminates on these grounds inescapably intends to rely on sex in its decisionmaking.
Bostock v. Clayton County, Georgia, --- U.S. ---, 140 S. Ct. 1731, 1734 (2020). This Court has also found similarly, in reference to Title IX, and specifically with
1 It should also be noted that during the Civil Rights Era, any advocation for equal rights for African Americans was often similarly derided as “Far Left” or even “Communist”. Unfortunately, the Defendants are repeating the sins of the past.
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respect to St. Johns County. Adams by & through Kasper v. Sch. Bd. of St. Johns County, Florida, 318 F. Supp. 3d 1293, 1326 (M.D. Fla. 2018), aff'd sub nom. Adams by & through Kasper v. Sch. Bd. of St. Johns County, 968 F.3d 1286 (11th Cir. 2020), opinion vacated and superseded sub nom. Adams v. Sch. Bd. of St. Johns County, Florida, 3 F.4th 1299 (11th Cir. 2021), and aff'd sub nom. Adams v. Sch. Bd. of St. Johns County, Florida, 3 F.4th 1299 (11th Cir. 2021).
Here, again, the Defendants want to misrepresent this case as being about “government speech”, but it is about nothing of the sort.
C. Count II properly alleges an Equal Protection claim.
Once again, the Defendants rely upon their absurd strawman argument. Here, they argue that this is about “forcing” the Defendants to put the LGBTQ Proclamation on the agenda, but again, their analysis is predicated on a complete misunderstanding of civil rights law.
For example, going back to the Title VII analogy, if the Plaintiff were to apply for a job with a County division where the Defendants made hiring decisions, and the Defendants were to deny the Plaintiff employment because it viewed hiring a member of the LGBTQ community to be “controversial”, there were not even be any argument that Defendants could make that would withstand the Bostock decision’s ruling. Were the Plaintiff to then file a lawsuit about them being improperly denied consideration for employment, it would not really be a lawsuit about “forcing” the Defendants to hire them. This is really not that difficult to understand, but the Defendants are quite
committed to their strawman argument.
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Furthermore, the Plaintiff properly alleges an Equal Protection claim because it is not even in dispute that the reason that the LGBTQ Proclamation was denied was because of the Defendants’ contention that anything related to the LGBTQ community is “Far Left” and “controversial” as noted previously herein. In fact, the LGBTQ Proclamation is quite tame and not controversial at all...unless someone is opposed to the equal rights of members of the LGBTQ community. And just as racism, Anti-Semitism, sexism, and other bigotries cannot form the basis for a government policy, the Defendants’ policy here runs afoul of the United States Constitution, as well as the Bostock decision and the many decisions that have flowed therefrom.
Finally, at the end of the Defendants’ Section “C”, the following statement appears:
The Constitution provides for equal protection of the law, not superior rights to individuals who fall in a protected categories. Here Plaintiff seeks rights superior to all other citizens, namely a declaration from the Court that Plaintiff has the right to require the Board to place on its agenda Plaintiff’s proposed proclamation for purposes of a discussion and vote. As no law or procedure grants this right to others, Plaintiff’s equal protection claim should be dismissed with prejudice.
This idea that LGBTQ people are seeking “superior rights” by demanding equal treatment, is patently offensive. If this were said about someone on the basis of race, religion, or any other protected class, the Defendants would likely be sanctioned for it. Such commentary has no place in the practice of law.
D. Count III properly alleges a violation of Fla. Stat. § 286.011 (Florida Sunshine Law).
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While this is thankfully the first argument put forth by the Defendants that does not rely upon the strawman argument, it also fails because the citations presented do not apply to the instant case.
For example, the Defendants have included two Exhibits, both of which consist of informal Attorney General opinions. Exhibit 1 is a 2007 informal opinion stating that notes that it is not a violation of the Sunshine Law to require a written request to remove items from a consent agenda. [Dkt. #18-1]. Exhibit 2 is a 2003 informal opinion with respect to the calling of a special meeting. [Dkt. #18-2].
Notably, both exhibits contain the following text:
"Every step in the decision-making process, including the decision itself, is a necessary preliminary to formal action. It follows that each such step constitutes an ‘official act,’ an indispensable requisite to 'formal action,' within the meaning of the act."
[Dkt. #18-1, p. 1; Dkt #18-2, p. 1].
In addition, both exhibits also contain admonitions that are quite similar to one another, and are quite relevant to this case:
However, the members of the county commission must be mindful of the law and careful not to discuss substantive issues which may come before the council in their consideration of whether to withdraw a subject from the consent agenda.
[Dkt. #18-1, p. 2].
The members must, however, be mindful not to discuss substantive issues which may come before the council in their consideration of whether a special meeting is necessary.
[Dkt. #18-2, p. 2].
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Here, the issue of whether to refuse to place the LGBTQ Proclamation on the agenda is clearly a substantive issue. There was a decision made that labeled it “Far Left” and/or “controversial”. That decision violated the U.S. Constitution and was most certainly a substantive issue, and there was some kind of discussion.
Additionally, there is a difference between a “consent agenda” and a “regular agenda”, and the informal opinion dealing with consent agendas notes that such agenda items are “for routine matters that ‘are typically non-controversial and do not deviate from past Board direction or policy.’” [Dkt. #18-1, p. 1].
One thing is indisputable, a decision was made that the LGBTQ Proclamation was “controversial” and/or “Far Left”. There is no record of that decision, which constitutes a substantive issue, and is a violation of the U.S. Constitution. The Sunshine Law has no purpose if a Far-Right chairman can secretly decide to refuse agenda items because they deal with the LGBTQ community. Similarly, the Sunshine Law has no purpose if there is an unwritten rule declaring that anything dealing with the LGBTQ community is “controversial” or “Far Left”. No matter which way this Court views it, the citizens of this State have the right to know the details of this decision, who and how many people were involved in that decision, and upon what basis that decision was made. That is the very heart of the Sunshine Law.
Furthermore, it is not simply the final decision that is subject to the Sunshine Law. The Florida Attorney General explains in the 2021 Sunshine Manual as follows:
It is the how and the why officials decided to so act which interests the public, not merely the final decision. As the court recognized in Times Publishing Company v. Williams, 222 So. 2d
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470, 473 (Fla. 2d DCA 1969), disapproved in part on other grounds, Neu v. Miami Herald Publishing Company, 462 So. 2d 821 (Fla. 1985):
Every thought, as well as every affirmative act, of a public official as it relates to and is within the scope of his official duties, is a matter of public concern; and it is the entire decision-making process that the legislature intended to affect by the enactment of the statute before us.
Office of the Attorney General, “Government-in-the-Sunshine Manual”, 2021 Edition, Vol. 43, p. 25, (emphasis added) retrieved June 10, 2021 from <https://myfloridalegal.com/webfiles.nsf/WF/MNOS- B9QQ79/$file/SunshineManual.pdf>.
The Florida Attorney General further states therein:
The courts have recognized that the Sunshine Law should be construed so as to frustrate all evasive devices. City of Miami Beach v. Berns, 245 So. 2d 38 (Fla. 1971); Blackford v. School Board of Orange County, 375 So. 2d 578 (Fla. 5th DCA 1979); Wolfson v. State, 344 So. 2d 611 (Fla. 2d DCA 1977). As the Florida Supreme Court stated in Canney v. Board of Public Instruction of Alachua County, 278 So. 2d 260, 264 (Fla. 1973):
Various boards and agencies have obviously attempted to read exceptions into the Government in the Sunshine Law which do not exist. Even though their intentions may be sincere, such boards and agencies should not be allowed to circumvent the plain provisions of the statute. The benefit to the public far outweighs the inconvenience of the board or agency. If the board or agency feels aggrieved, then the remedy lies in the halls of the Legislature and not in efforts to circumvent the plain provisions of the statute by devious ways in the hope that the judiciary will read some exception into the law.
Office of the Attorney General, supra, p. 50. Page 10 of 16
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While the Defendants may wish to keep that knowledge secret, the Florida Sunshine Law says that it cannot be. They are acting in an unlawful and discriminatory fashion which offends the U.S. Constitution, and allowing them to do so in secret is not the public policy of Florida, or the intent of the Florida Sunshine Law.
E. Count IV properly alleges a violation of Fla. Stat. § 286.0114 and Article I, § 24 of the Florida Constitution.
Here, the Defendants rely upon their other common refrain, that of the general public comment at the end of the meeting. However, as they admit, Art. I, Section 24 of the Florida Constitution provides that meeting “at which official acts are to be taken or at which public business of such body is to be transacted or discussed, shall be open and noticed to the public”. [Dkt. 18, p. 21]. While in some instances the decisions of what is or is not to be included on an agenda might not qualify as an official act or public business, clearly the issue of the denial of the LGBTQ Proclamation is of greater public importance and scrutiny than the average agenda item, given the Defendants’ prejudicial behavior.
Furthermore, the idea that compliance with § 286.0114 (3)(b) applies is ludicrous. The plain wording of that section applies to the approval of minutes and ceremonial proclamations and does not authorize the blanket refusal of any proclamation dealing with the LGBTQ community from even consideration by the full Board, as was done here.
F. The claims against Chairman Blocker should not be dismissed. Page 11 of 16
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The claims against Chairman Blocker are well-pleaded, and the Defendants’ claims to the contrary are simply vague and conclusory statements themselves. While a suit against the governmental entity and the official in his official capacity can be the same as a suit against the entity itself, the Plaintiff would argue that this case presents the exception to that rule, given the fact that Chairman Blocker has abused his position, and the fact that the full extent of this abuse of power will only become known through discovery, thanks to the Defendants’ failure to properly conduct their actions in the “Sunshine”.
Furthermore, the Defendants fail to address the fact that they are sued both for damages and declaratory relief, and that federal courts can enjoin state officers acting in their official capacity with respect to future actions. See, ex., Russell v. Dunston, 896 F.2d 664, 668 (2d Cir.), cert. denied, 498 U.S. 813, 111 S.Ct. 50, 112 L.Ed.2d 26 (1990); Reid v. Streit, 697 Fed. Appx. 968, 971 (11th Cir. 2017) (injunctive relief not subject to Eleventh Amendment if “forward-looking”).
As to the allegations against Chairman Blocker in his personal capacity, they are again well-pleaded, as the Plaintiff has alleged that Chairman Blocker’s personal beliefs regarding “the fair and equal protection of LGBTQ Americans and their rights” and the extent of his prejudicial and anti-American belief system’s influence upon the Board is significant and has been alleged properly, whether his actions are condoned by the Board or ultra vires. [Amended Complaint, Dkt. #13, paragraphs 26-27]. In addition, “to establish personal liability in a § 1983 action, it is enough to show that
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the official, acting under color of state law, caused the deprivation of a federal right.” Kentucky v. Graham, 473 U.S. 159, 166 (1985).
Furthermore, an objectively reasonable board member would know that it is well-settled that discrimination against LGBTQ individuals is prohibited, and that Chairman Blocker’s abuse of his position as chairman of the Board violates the United States Constitution.
G. The Amended Complaint is not a “shotgun” pleading.
Unfortunately, the trend among defendants in the Eleventh Circuit these days is to always allege that every complaint is a “shotgun pleading”, without really giving any good explanation as to why such would be the case, and where the Defendants’ arguments fail when compared to their own case-law.
For example, the Defendants’ claim that this is proved by the Amended Complaint alleging the same twenty-nine introductory factual paragraphs into each count betrays a misunderstanding of the case-law cited, as there is nothing about re- alleging introductory facts that creates a “shotgun pleading”. In the Defendants’ case- law, it describes the most common type of such a pleading as follows:
The most common type—by a long shot—is a complaint containing multiple counts where each count adopts the allegations of all preceding counts, causing each successive count to carry all that came before and the last count to be a combination of the entire complaint.
Weiland v. Palm Beach County Sheriff's Office, 792 F.3d 1313, 1321 (11th Cir. 2015). As seen above, where a complaint just re-alleges all of the preceding paragraphs
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and counts, it can be a “shotgun pleading”, but the Amended Complaint does no such thing.
Secondly, the Defendants argue that addressing the Defendants collectively within the Amended Complaint does not differentiate between them and, “leads to confusion”. [Motion to Dismiss, Dkt. #18, p. 25]. However, given the fact that Chairman Blocker is himself a member and the chairman of the Board, and therefore a decision-maker with respect to the Board’s decisions, the idea that the Defendants cannot determine which allegations of fact apply to which claims for relief is simply not realistic.
Furthermore, given the secrecy and lack of transparency that the Defendants’ failure to adhere to basic Sunshine Law provisions, it is impossible at this pre-discovery period to determine where Chairman Blocker’s personal influence ends or extends. Essentially, the decisions were made in the Board’s name, but the Plaintiff will only be able to determine through discovery the full extent of Chairman Blocker’s prejudicial decision-making and abuse of authority. As such, the counts as they are alleged are perfectly adequate, and hardly “confusing”.
III. Conclusion.
By its own secrecy and subterfuge, the Defendants have inadvertently conceded that their denial to even consider the LGBTQ Proclamation lacks merit, and they know that it cannot be explained publicly in any way that does not offend the U.S. Constitution, so they refuse to discuss it, even in the Motion to Dismiss. “As Justice
Brandeis correctly observed, ‘sunlight is the most powerful of all disinfectants,’” New Page 14 of 16
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York Times Co. v. Sullivan, 376 U.S. 254, 305 (1964) (Goldberg, J., concurring), citing Freund, The Supreme Court of the United States (1949), p. 61. Furthermore, Justice Brandeis also wrote, when "government becomes a lawbreaker," it promotes disrespect for the law, and anarchy. Olmstead v. United States, 277 U.S. 438, 485 (1928) (dissenting), overruled in part by Berger v. State of N.Y., 388 U.S. 41 (1967), overruled in part by Katz v. United States, 389 U.S. 347 (1967).
In fact, the Motion to Dismiss contains a few arguments, but none of them have any merit, as most of them are tilting at windmills of imaginary strawman arguments that were never made. This action is important, and if this Court were to grant the Defendants’ Motion to Dismiss, it would signal that any amount of prejudicial decisions by a governmental entity in Florida could escape public scrutiny in the manner in which the Defendants have employed.
WHEREFORE, for all of the reasons stated above, Plaintiffs respectfully ask this Court to deny the Defendants’ Motion to Dismiss, and for all other relief as this Court deems necessary in the interests of justice.
Dated:
August 30, 2021
Respectfully Submitted,
ROOK ELIZABETH RINGER, ESQ. Florida Bar No. 1015698
LENTO LAW GROUP, P.A.
222 San Marco Ave., Ste. C
St. Augustine, FL 32084 904.602.9400 (Office)
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904.299.5400 (Fax)
reringer@lentolawgroup.com
Attorney for Plaintiff
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been e- filed and has been served by CM/ECF to counsel for the Defendants, Susan S. Erdelyi, Esq., Marks Gray, P.A., 1200 Riverplace Blvd., Suite 800, Jacksonville, Florida 32207, serdelyi@marksgray.com, jmcduffie@marksgray.com, on this 30th day of August 2021.
Dated: August 30, 2021
ROOK ELIZABETH RINGER, ESQ. LENTO LAW GROUP, P.A.
Attorney for Plaintiff
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