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FROM: Jeffrey D. Dean Sr.

XXXXX Florida


On August 8, 2019 a wrongful arrest was perpetrated against J. Dean Sr on his own property at
XXXXXXXXXXXXXXXXXX Avenue by two officers of the Dixie County Sheriff Department.
Fourth Amendment rights violations were perpretrated by the officers against both Jeffrey D. Dean Sr
and Jeffrey D. Dean Junior. Jeffrey D. Dean Jr. was denied his 5th Amendment rights, as well as his
right, as a disabled American to have a guardian with him during questioning by law enforcement.
(Exhibit A) Further, the officers on the scene engaged in clear intimidation and coercion, abuse of
power, and threats of reprisal in order to trample the rights of the residents at this property. Both
officers showed indifference to the laws they were sworn to uphold and blatant disregard for the basic
human dignity of an honorable retiree of the United States Military who, at one time possessed two of
our nation's highest security clearances and was awarded the Meritorious Service medal 3 times as well
as other honors, not the least of which is a Presidential Citation. J Dean Sr was then wrongfully
imprisoned for 2 days.

1. Officer A. Martin made 3 written statements accusing Jeffrey Jr of making threats against the
college." They are as follows: (Exhibit B)

a. Paragraph 2 "...I need to speak to his son, Jeffrey Dean Jr (white male DOB: 02/19/01) in
refrence to threats he made towards the school.”

b. Paragraph 2: "...I again asked him to speak to his son about the threats he made towards the

c. Paragraph 2: "...I advised J. Dean Jr. that I was there to find out about the threats made to the

d. Officer A. Martin used language that left no doubt that he was proceeding under the
assumption that the son was guilty of threats made against the school in order to increase the
severity of J. Dean Sr.'s supposed "interference."
e. Officer A. Martin indicated that he did not even possess (and or had not seen) the
“evidence” for these threats, and that so called “evidence” was in the hands and
jurisdiction of “another agency” in Levy County (Exhibit C Data Disk- Video HDV_0004
Timestamp 1:50) and that his probable cause was the Levy County request to interrogate J
Dean Jr. Because it was Dixie County jurisdiction (even though supposedly the threats took
place in Levy County). Levy County sent Dixie County in order to circumvent their
requirement to obtain a warrant to enter another County to investigate, a clear indication that
they had no real probable cause and could not satisfy the legal requirements of said warrant.

f. The following facts (attached to this complaint Exhibits D, E, F, G) show that, had officer A.
Martin bothered to actually investigate the claims of these supposed threats, by merely calling
the College, he would have discovered that the College never alleged J. Dean Jr. made any
threats to the school at all, never alleged Jeffrey made any comments about “a shotgun” at the
school, and certainly the school never alleged that Jeffrey Jr. Threatened to "shoot up the
school” as A. Martin repeatedly claimed to both Jeffrey Dean Sr and Jeffrey Dean Jr. (See
Exhibits D and Exhibit G page 2 of 5 Paragraph Entitled “Background” for a list of the 3
behavioral complaints the school had regarding Jeffrey Jr.)

g. Had Levy County wanted to ask J Dean Jr. About these allegations all they needed to do was
call the Deans (their phone number is on record with the College) and J. Dean Sr would have
brought him to Levy County to be interviewed. Instead, they sent Dixie County, (because they
lacked probable cause to obtain a warrant to bring Jeffrey Junior in for questioning themselves.
Dixie County, lacking Jurisdiction to investigate an alleged crime committed in Levy County,
nevertheless, went to the Dean residence and made accusations with no evidence and no real
probable cuase, being they lacked legal standing to charge a crime that was allegedly committed
in Levy County. who showed up on the property making allegations and demanding to know
“why” J. Dean Jr made these threats (as if it was well established fact that he made them).

h. A. Martin should have known that on 16 October 2018 another officer of Dixie County
Sheriff had already been sent- also erroneously- about "non direct" threats regarding a shot gun,
but this turned out to be a complete misunderstanding according to the Provost at the College.
(See Exhibit F -OCR Complaint filed by J. Dean Sr. Paragraph “allegation number 2”)

i. A disiciplinary hearing was held in November 2018 in which all the the disciplinary issues
the school had with J. Dean Jr. were clearly outlined. (Exhibit E). Nowhere does the school
allege that J. Dean Jr. ever made threats to "shoot up the school” in this hearing or at any other
time before or since. Jeffrey Jr was allowed to enter the college month after month to test for
his Diploma without any incidents.
(See Exhibits D and Exhibit G page 2 of 5 Paragraph Entitled “Background” for a list of
the 3 behavioral complaints the school had regarding Jeffrey Jr.)

j. Jeffrey Jr. was reinstated to the college as a result of the hearings, (Exhibit E Decision
Letter) he opted to attend classes online and went to the school by appointment to take his
tests. Jeffrey did this for about 4 months and finally graduated, obtaining his HS Diploma
without further incident. (Exhibit H)
k. By August 8, 2019, the date of this "so called" investigation into threats against the school, it
had been 10 months since Jeffrey had stepped foot in a classroom on the College Campus, and
during his nearly 1 year at the college he was never accused of threatening to "shoot up the
school." Not by the School, and not by the Dixie County officer sent to J. Dean Sr.'s home on
16 October 2018.

2. Officer A. Martin claimed on initial contact with Jeffrey Dean Sr that he had “credible reports that
Jeffrey Dean threatened to “shoot up the school” something that to my knowledge no one has ever
alleged and which has no basis in any fact whatsoever within the record or coming from the school
itself. The officer, instead of calling the school and actually investigating, banged on the front door of
J. Dean Sr and demanded to know WHY the threats were made (not if or when the threats may have
been made). Mistaking Mr. J. Dean Sr as the target of his “investigation” he made an accusation that
he had “been down to the College” and “threatened to shoot up the school” demanding to know why he
would do such a thing.

3. In the arrest report of J. Dean Sr, Officer A. Martin omitted key facts in order to deceive the court:

a. Paragraph 2. "...J. Dean Sr that he was the only Jeffrey Dean that I needed to speak to."

b. This statement omits the fact that Jeffrey Dean Jr., though he be legally an adult, is diagnosed
with High Spectrum Autism (a fact of which the record will easily show Dixie County Sheriff
Department is keenly aware). Indeed, the officer seemed to have justified his interrogating of
J. Dean Jr by telling the charge officer who took custody of J. Dean Sr (at the county jail) that
Jeffrey Jr “didn't look disabled” to him.
SEE EXHIBIT A an example of diagnoses.

4. Officer A. Martin committed a violation of the Americans with Disabilites act by not only insisting
on interrogating a disabled American without the consent or cooperation of his guardian, but when the
officer was told that Jeffrey Jr. is "disabled" the officer presumed himself to be qualified to diagnose
Jeffrey Jr. as not being disabled by saying "he doesn't look disabled to me." A. Martin made this same
statement in front of his supervisor at the Dixie County Jail, while taking J. Dean Sr into custody.
Jeffrey Jr expressed his desire to go back in the house and was told that he was being “detained” in his
own front yard and that he had to answer their questions, even without an attorney. Clear violations of
the 5th Amendment. (Exhibit C- Data Disk- Video HDV-0002 time stamp 2:50)

5. Officer A. Martin committed inumerable violations of the 4th Amendment when, without LEGAL
probable cause to do so the officer insisted upon staying on the property after he had been asked to
leave and had been requested that he obtain a warrant that would lay out his probable cause for being
there. There was no legal reason for the officer to remain, since (by his own admission) he was only
there to interrogate Jeffrey Dean Jr. and the officer had already been told by Jeffrey Junior's legal
guardian that he could not interrogate the younger man without an attorney present. Thus, Jeffrey D.
Dean Jr. was denied his right to an attorney during questioning as well as being denied his right as a
Disabled American to have his guardian present during interrogation. A. Martin's claim in his arrest
report of Mr. J. Dean Sr that he was there to do a “wellness” check on J. Dean Jr. Because of threats
that were supposedly made 10 months earlier is completely preposterous in the extreme. The officers
told J. Dean Jr that he was “being detained for questioning” (Exhibit C- Data Disk- Video HDV_0002
time stamp 0: 13) and then was told he could not refuse to answer the questions and could not go back
in the house (Exhibit C- Data Disk- Video HDV_0002 time stamp 3: 13)
6. The officer made the following statements which can easily be shown to be false using video tape
made by Jeffrey Dean Senior and Junior. The officer claims in the report (Exhibit B) repeatedly that J.
Dean Sr followed him “into the yard." This making it appear that J. Dean Sr was somehow physically
impeding his investigation (and possibly acting in a threatening manner). Video tape will show that,
during this part of the event, J. Dean Sr never left the confines of his domicile while video taping. (J.
Dean Sr remained in the screened in rec room which is attached to the home, has a door that locks and
is clearly a part of the domicile under the law). (Exhibit C- Data Disk- All 3 Videos). During the
entire event spanning over all 3 videos Mr. J. Dean Sr only left the confines of the screened recreation
room once for less than 30 seconds (Exhibit C- DATA DISK- Video HDV_0002 time stamp 4: 39)
and again when the officer called Mr. Dean Sr to step out of the house so that he could arrest him.

7. A. Martin violated the 5th Amendment to the Constitution by insisting that Jeffrey Dean Jr. had to
answer his questions and he could not remain silent, when Jeffrey said he could go in the house now
the second officer told him “no you can't.” (Exhibit C- Data Disk Video HDV_0002 time stamp

8. Officer A. Martin violated the rights of Jeffrey Dean Jr. by ordering Jeffrey Dean Sr to "shut his
mouth" or the officer would "arrest him (J. Dean Sr) for obstruction. " Even though J. Dean Sr was
only advising his son of his rights under the 5th Amendment as any good guardian would do under the
circumstances where police show up at the door making wild eyed accusations based purely on fantasy
and false accusation. Officer A. Martin commited gross abuse of his power at this point, making
threats and intimidation in an attempt to coerce J. Dean Sr into allowing him to question J. Dean Jr.
against the objections of J. Dean Sr (Junior's legal guardian). This is also a clear violation of The
Americans with Disabilities act.

9. The Dixie County Sheriff office dispatch illegaly deemed that J. Dean Sr had no right to call 911 on
two abusive officers, who were not acting within the bounds of the law and who were acting in an
agressive manner, (grabbing at their tasers constantly) and who were intimidating and coercing with no
real probable cause and without even vetting the information they had concerning a supposed threat.
The dispatch also violated the 5th Amendment by ordering J. Dean Senior to "cooperate with the
officers" who were attempting to quesion J. Dean Jr. in violation of the 5th Amendment and who were
on the property against their will in clear violation of the 4th Amendment.

a. The DOJ Ferguson Report (U.S. V. Ferguson) found that it is abuse for police to charge an
employer with "misuse of 911" for objecting to their detaining of one of their employees and then
calling 911 when the officer persisted.

b. In The Argument Brief filed by the ACLU Supreme Court case 17-1174 Nieves V. Bartlett the
incident cited in the Ferguson report was listed as an example of when illegal arrests are made for
speech officers do not like.

c. The SCOTUS ruled in favor of the argument saying:

“(d) Because States today permit warrantless misdemeanor arrests for minor criminal offenses
in a wide range of situations—whereas such arrests were privileged only in limited
circumstances when §1983 was adopted—a narrow qualification is warranted for
circumstances where officers have probable cause to make arrests, but typically exercise their
discretion not to do so. An unyielding requirement to show the absence of probable cause in
such cases could pose “a risk that some police officers may exploit the arrest power as a means
of suppressing speech.” Lozman, 585pp U. S., at ___. Thus, the no-probable-cause requirement
should not apply when a plaintiff presents objective evidence that he was arrested when
otherwise similarly situated individuals not engaged in the same sort of protected speech had
not been. Cf. United States v. Armstrong, 517 U.S. 456, 465. Because this inquiry is objective,
the statements and motivations of the particular arresting officer are irrelevant at this stage.
After making the required showing, the plaintiff’s claim may proceed in the same manner as
claims where the plaintiff has met the threshold showing of the absence of probable cause.
Pp. 13–15.

d. The County is unable to show how they routinely arrest an individual for making a
single call to 911 in which the dispatch and the caller disagree as to whether this
constitututes a true emergency, and in which officers then subsequently arrest for “misuse
of 911.” It is clear the officers simply sought to make an arrest because they did not like
the speech of J. Dean sr because he was accusing them of violating his rights and
protesting their being on his property without a warrant and questioning the validity of
their probable cause claim. (Exhibits J, K, L)

e. Florida Statutes for misuse of 911 require multiple calls to 911 in order to constitute abuse.
Further, the Dixie County website in the FAQ section tells residents to “call 911 if they are in

10. Officer A. Martin assumed "guilt before innocence" as seen by the Officer's statement in the arrest
report where he states 3 times that Jeffrey Dean Jr. "made threats." when no such threats were ever
made. He was not "investigating" but had rather made up his mind that the threats had been made and
was simply demanding to know why they were made instead of determining if they had actually been
made, which could have simply been accomplished without interrogating J. Dean Jr but instead by
simply calling the college and asking if such threats had actually been made.

11. Officer A. Martin made false statements implying that J. Dean Sr had made another 911 call. The
second officer on the scene also accused Mr. Dean of this as well (Exhibit C- Data Disk- Video
HDV_0002 time stamp 2:12). Phone records, however will show that the second call was made to the
7 digit number of the Sheriff's office found in the contact pages of the Dixie County Sheriff Web site.
The officer deliberately used the word "again" in the report (Exhibit B) regarding this call so he could
deceptively create the impression that after being told not to use 911 emergency number for the call J.
Dean Sr did it "again." This deception was made to attempt to justify a felony charge of misuse of 911
(charges reduced to misdemeanor at first appearance).

12. Mr. Dean Sr is Disabled (See Exhibit M full VA Physician Medical examination) when he was
being arrested he reacted in pain to his arms being twisted behind his back. His son explained that he
was not resisting but that he had disabilities and was reacting to the pain. Still, he is being charged
with “resisting arrest without violence” for these movements. Any reasonable mind can view the video
of this arrest and see there was no resistence on the part of J. Dean Sr.
13. Mr. Dean was also concerned during the arrest that his son would be without any means of
financial support while he was incarcerated. (Exhibit C- Data Disk- Video HDV_0003 time stamp
2:22) J. Dean Jr. has no income and would be homeless in no time without his father's wallet, which
contains a debit card with full access to J. Dean Sr.'s military retirement funds. Jeffrey had full written
instructions in a drawer in the house on how to use this card to access the funds and how to pay the
bills in the absence of his father. Instead of asking J. Dean Sr or Jr. why it was so important for Jr. to
have the wallet, the officer paints this as "suspicious" and an "act of nonviolent resistence." As can be
seen in the video, A. Martin, who was apparently now suspicious as to why J. Dean Sr wanted his son
to take his wallet, committed a clear violation of the 4th Amendment by ordering Jeffrey Dean Jr. to
"search for the wallet" in the house and "bring the wallet to me." The officer was committing an illegal
search using a proxy in order to find out what was in the wallet. Illegal search and seizure. The officer
did not merely ask Jeffrey Jr. to bring him his father's I.D. but asked him to bring the officer the entire
wallet and give it to him. (Exhibit C-Data Disk Video HDV_0004 time stamp 2:38)

14. Both officers on the scene showed reckless disregard for the rights both accused under the law.
They continually grabbed at their tasers, at one point a taser was brought out and pointed at J. Dean Sr
unnecessarily. (Exhibit C- Data Disk- Video HDV_0003 2:24) This constitutes excessive force. The
officer used excessive force closing the handcuffs, nearly breaking the left wrist of J. Dean Sr. Tasers
are not to be brought out on someone fleeing or resisting arrest, but only in the case that they are a
danger to themselves or others, displaying violent or otherwise similarly irrational behavior. Under all
state and Federal guidelines a taser cannot be brought out in a case of non violent resistance which is
what the officer inevitably charged the defendant. It can be clearly seen in the video that Mr. Dean was
already subdued by handcuffs when the officer brought out the taser. In a 2016 case involving the
death of a mentally ill man, a federal appeals court held that a taser “may only be deployed when a
police officer is confronted with an exigency that creates an immediate safety risk and that is
reasonably likely to be cured by using the taser.” The man in the case had wrapped his arms around a
post and wasn't a continuing threat to safety, but officers stunned him five times. (The court, however,
found that the officers were entitled to qualified immunity (discussed below) because the law on this
kind of taser use wasn't clearly established at the time.) (Estate of Armstrong ex rel. Armstrong v. Vill.
of Pinehurst, --- F.3d ---- (4th Cir. 2016).)

Courts routinely consider the following factors in determining the reasonableness of the force officers
• the severity of the arrestee’s crime
• whether the suspect constitutes a current threat to officers or others, and
• whether the suspect physically resists arrest or tries to escape.

15. After placing Mr. J. Dean Sr into his car, Officer A. Martin told J. Dean Sr that "I am charging you
with obstruction because you came back out of the house with a camera." Thus, further demonstrating
his contempt for the rights of citizens to film the police, even on their own property.
16. Once arriving at the jail, J. Dean Sr was almost unconscious from the pain in his wrist and from his
shoulders being wrenched together so tightly in a rearward motion. J. Dean Sr is documented with
severe arthritis in the hips, joints and knees, and has a permanent spinal injury from his time in the Air
Force, for which he collects two disability checks. The video clearly shows Jeffrey Jr. informing the
officer about these disabilities during the arrest and explaining to them that his father was “moving
around” because of the pain (and that he was not resisting). Nevertheless A. Martin pretended not to
know about these disabilities when they arrived at the jailhouse and told the supervising officer that he
had "no idea" why Mr. Dean was nearly unconscious and that he was faking and charged Mr. Dean Sr
with resisting arrest. (Exhibit I- Data Disk, Video HDV_0003 time stamp 2:44 and Exhibit M full
Veterans Administration medical diagnosis of Dean Sr disabilities)