doing research with ai tools like grok and google on disclaimers.

In re: ANONYMOUS ONLINE  SPEAKERS, good 9th circuit case. turns out helzer went 2-1 at 9th circuit in 2024.

So the way to follow up with Helzer is for example, a letter, oh how about get bondi involved. ask senator banks to write to bondi.

also, write to defendant in helzer with new demand. 

or, prepare disciplinary complaint against alaska evildoers.

and the x.com case is a good one. kohls v bonta. 

write to justice department voting rights division. whatshername. not bondi, the one under her. Harmeet Dhillon

 

Updated One-Page Complaint Outline

IN THE MARION COUNTY SUPERIOR COURT STATE OF INDIANA

ROBBIN STEWART, Plaintiff,

v.

MARION COUNTY ELECTION BOARD (official capacity), and [NAMES OF INDIVIDUAL MEMBERS OF THE MARION COUNTY ELECTION BOARD] (personal capacity), Defendants.

Cause No.: [To be assigned]

COMPLAINT FOR DECLARATORY, INJUNCTIVE, AND MONETARY RELIEF (Constitutional Challenge to IC § 3-9-3-2.5)

1. Jurisdiction, Venue, and Relief Sought This Court has jurisdiction under IC 34-14-1-1 (Uniform Declaratory Judgment Act), Trial Rule 57, and general equitable powers. Venue is proper in Marion County as the location of Plaintiff’s residence, the location where the chilled speech occurred, and the seat of the Marion County Election Board. Plaintiff seeks a declaration that IC § 3-9-3-2.5 is unconstitutional under the Indiana Constitution and First Amendment, permanent injunctive relief barring its enforcement, and monetary damages for past and ongoing chilling effects on speech. (Plaintiff requests certification of this constitutional challenge to the Indiana Attorney General per IC 34-33.1-1-1 and Trial Rule 5.1, even though the AG is not named as a party.)
2. Parties Plaintiff Robbin Stewart is an Indiana resident, voter, and political speaker with a history of challenging compelled-disclaimer laws (Stewart v. Taylor, 953 F. Supp. 1047 (S.D. Ind. 1997); Majors v. Abell, 361 F.3d 949 (7th Cir. 2004)). Defendant Marion County Election Board (official capacity) investigates complaints and imposes civil penalties under IC § 3-14 for alleged violations of § 3-9-3-2.5 in Marion County. Defendants [NAMES OF INDIVIDUAL MEMBERS OF THE MARION COUNTY ELECTION BOARD] (personal capacity) are sued for their individual actions in threatening or chilling Plaintiff’s speech through enforcement of the statute.
3. Factual Allegations IC § 3-9-3-2.5 requires a compelled “paid for by” disclaimer on communications that clearly identify a candidate or solicit contributions, with limited exemptions. In 2024, Plaintiff created a sign reading: “Robbin Stewart for Township Board – Vote Tuesday.” This material clearly identified Plaintiff as a candidate but omitted the required disclaimer due to Plaintiff’s belief in the right to anonymous political speech. Plaintiff was chilled from distributing the sign due to credible fear of civil penalties and enforcement by the Marion County Election Board. Plaintiff intends to distribute similar candidate-identifying materials (including signs) without forced self-identification but remains chilled by the ongoing threat of enforcement.
4. Claim 1: Violation of Indiana Constitution Article 1, § 9 The statute imposes a material burden on core political speech by conditioning expression on government-mandated self-identification, exceeding the state’s police power to prevent “abuses” (Price v. State, 622 N.E.2d 954 (Ind. 1993)). Less restrictive alternatives exist.
5. Claim 2: Violation of Indiana Constitution Article 2, § 1 The disclaimer requirement creates unequal electoral access, intimidating independent speakers while favoring organized committees, violating free and equal elections.
6. Claim 3: Violation of First Amendment (Supplemental) The statute is content-based under Reed v. Town of Gilbert, 576 U.S. 155 (2015), and compels speech under 303 Creative LLC v. Elenis, 600 U.S. 570 (2023). Majors v. Abell is no longer persuasive authority.
7. Actual Controversy, Ripeness, and Damages An actual controversy exists: Plaintiff created the 2024 sign but was chilled from distributing it due to enforcement threat; ongoing intent to speak without disclaimer creates credible chilling. Past and continuing burdens warrant compensatory damages.

WHEREFORE, Plaintiff prays the Court: a. Declare IC § 3-9-3-2.5 unconstitutional; b. Permanently enjoin Defendants from enforcing it; c. Award compensatory damages against Defendants in their personal capacities for chilled speech; d. Award costs and other just relief.

Respectfully submitted,

/s/ Robbin Stewart Robbin Stewart, Pro Se [Your Address] Indianapolis, IN [ZIP] [Phone] [Email] Date: [Insert Date]

Quick Filing Notes

• Personal capacity claims allow for damages (official capacity is injunctive/declaratory only). You’ll need to name the individual board members (check marioncounty.in.gov or call the clerk for current names).
• AG certification is still required (court will handle notice to AG even if not a party).
• Service: Serve the Marion County Election Board and named individuals (sheriff or certified mail).

This version is still short and focused. If you want to add more detail on the chilling (e.g., specific fear of reprisal) or refine the personal-capacity language, let me know. Otherwise, you're ready to format/print and file. Good luck! 😊

 STATE OF INDIANA

ROBBIN STEWART, Plaintiff,

v.

INDIANA ATTORNEY GENERAL ROB BONTA (in official capacity), and INDIANA ELECTION DIVISION (or relevant state election officials), Defendants.

Cause No.: [To be assigned]

COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF (Notice of Constitutional Challenge to Statute)

1. Jurisdiction and Venue This Court has jurisdiction under IC 34-14-1-1 (Uniform Declaratory Judgment Act) and Trial Rule 57. Venue is proper in Marion County as the state capital and location of the Indiana Election Division. Plaintiff seeks declaratory relief concerning the validity of IC § 3-9-3-2.5 and injunctive relief to prevent its enforcement.
2. Parties Plaintiff Robbin Stewart is an Indiana resident and voter/candidate with a history of political speech challenges (see Stewart v. Taylor, 953 F. Supp. 1047 (S.D. Ind. 1997); Majors v. Abell, 361 F.3d 949 (7th Cir. 2004)). Plaintiff intends to engage in anonymous or low-profile candidate-related political expression but is chilled by the statute. Defendant Indiana Attorney General (official capacity) enforces state laws. Defendant Indiana Election Division oversees election compliance. (Pursuant to IC 34-33.1-1-1 and Trial Rule 5.1, Plaintiff requests the Court certify this challenge to the Attorney General for intervention.)
3. Factual Allegations (Keep brief—1-2 sentences) IC § 3-9-3-2.5 requires a compelled "paid for by" disclaimer on communications clearly identifying a candidate or soliciting contributions, with limited exemptions. Plaintiff wishes to distribute candidate-related materials (e.g., signs/flyers) without forced self-identification but fears civil penalties or chilled speech.
4. Claim 1: Violation of Indiana Constitution Article 1, § 9 The statute imposes a material burden on core political speech (a fundamental value) by conditioning expression on self-identification, exceeding the state's police power to prevent "abuses" (Price v. State, 622 N.E.2d 954 (Ind. 1993)). Less restrictive alternatives exist (e.g., libel laws).
5. Claim 2: Violation of Indiana Constitution Article 2, § 1 The disclaimer creates unequal electoral access, intimidating independent/lone speakers while favoring organized committees, undermining free and equal elections.
6. Claim 3: Violation of First Amendment (Alternative/Supplemental) The statute is content-based (triggers on message content) under Reed v. Town of Gilbert, 576 U.S. 155 (2015), and compels speech under 303 Creative LLC v. Elenis, 600 U.S. 570 (2023). Majors v. Abell (upholding it) is no longer persuasive authority.
7. Actual Controversy and Ripeness There is an actual, justiciable controversy: Plaintiff's intended speech is chilled by credible enforcement threat.

WHEREFORE, Plaintiff prays the Court: a. Declare IC § 3-9-3-2.5 unconstitutional under the Indiana Constitution (and First Amendment); b. Enjoin Defendants from enforcing it; c. Award costs and any other relief just and proper.

Respectfully submitted,

/s/ Robbin Stewart Robbin Stewart, Pro Se [Your Address] Indianapolis, IN [ZIP] [Phone] [Email] Date: [Today]

Quick Filing Tips

• File pro se (no lawyer required initially).
• Attach civil cover sheet if required (check Marion County clerk).
• Pay filing fee (~$150–200; request waiver if low-income via affidavit).
• Serve summons/complaint on AG and Election Division (certified mail or sheriff).
• Immediately after filing, request certification to AG per IC 34-33.1-1-1 (court must do this for constitutional challenges).
• Consider filing a separate Motion for Preliminary Injunction if you want quick relief.

This keeps it short, focused on state grounds (to avoid federal removal/preemption), and highlights the unresolved Price question. Tweak facts/claims as needed. Once filed, it puts the issue before the court and may attract attention from IFS or others.

If you want me to expand any section or adjust for specifics (e.g., add standing details), let me know! Good luck—this is a strong start. 😊

 Restraining Order Outline (One-Page Format)

IN THE MARION COUNTY SUPERIOR COURT STATE OF INDIANA

ROBBIN STEWART, Plaintiff,

v.

MARION COUNTY ELECTION BOARD (official capacity), and [NAMES OF INDIVIDUAL MEMBERS OF THE MARION COUNTY ELECTION BOARD] (personal capacity), Defendants.

Cause No.: [To be assigned or insert if complaint already filed]

MOTION FOR TEMPORARY RESTRAINING ORDER (Pursuant to Indiana Trial Rule 65)

Plaintiff Robbin Stewart, pro se, respectfully moves the Court for a temporary restraining order (TRO) enjoining Defendants from enforcing IC § 3-9-3-2.5 pending resolution of this action. In support, Plaintiff states:

1. Jurisdiction and Standard This Court has jurisdiction under Trial Rule 65 and IC 34-14-1-1. A TRO may issue without notice if immediate and irreparable injury will result before Defendants can be heard (Trial Rule 65(B)(1)). Plaintiff certifies: [If seeking ex parte: No notice given because enforcement threat is immediate and notice could cause further chilling; efforts to notify were [describe any, or state none due to urgency]. Reasons notice not required: risk of self-censorship before hearing.]
2. Irreparable Injury Plaintiff created a 2024 sign reading: “Robbin Stewart for Township Board – Vote Tuesday.” This candidate-identifying material requires a compelled “paid for by” disclaimer under IC § 3-9-3-2.5. Plaintiff was chilled from distributing the sign due to credible fear of civil penalties (up to $1,000 per violation) by the Marion County Election Board. Ongoing chilling prevents anonymous/low-profile political speech, causing irreparable harm to core First Amendment and Indiana constitutional rights (loss of expression is not compensable by damages alone; see Elrod v. Burns, 427 U.S. 347 (1976) for chilling effect presumption).
3. Likelihood of Success on the Merits Plaintiff is likely to prevail:
   • Under Indiana Constitution Article 1, § 9, the statute imposes a material burden on core political speech without justification under the police power (Price v. State, 622 N.E.2d 954 (Ind. 1993)—unresolved for this statute).
   • Under Article 2, § 1, it creates unequal elections by intimidating independents.
   • Under the First Amendment, the disclaimer is content-based (Reed v. Town of Gilbert, 576 U.S. 155 (2015)) and compels speech (303 Creative LLC v. Elenis, 600 U.S. 570 (2023)). Majors v. Abell (361 F.3d 949 (7th Cir. 2004)) is undermined by these cases; Easterbrook, J., dubitante, correctly doubted its validity.
4. Balance of Equities and Public Interest No harm to Defendants from pausing enforcement (statute remains intact pending merits). Public interest strongly favors protecting anonymous political speech (McIntyre v. Ohio Elections Comm'n, 514 U.S. 334 (1995); Talley v. California, 362 U.S. 60 (1960)). Equities tip heavily to Plaintiff.
5. Bond Plaintiff requests waiver of bond or minimal bond (no monetary harm to Defendants from non-enforcement).

WHEREFORE, Plaintiff prays the Court: a. Issue a TRO without notice (or after expedited hearing) enjoining Defendants from enforcing IC § 3-9-3-2.5 against Plaintiff’s candidate-identifying materials; b. Set an expedited hearing on preliminary injunction; c. Grant such other relief as just.

Respectfully submitted,

/s/ Robbin Stewart Robbin Stewart, Pro Se [Your Address] Indianapolis, IN [ZIP] [Phone] [Email] Date: [Insert Date]

Certificate of Service I certify that on [date], I served this motion on Defendants via [method: certified mail, hand delivery, or e-file if available] at [their addresses].

/s/ Robbin Stewart

Filing Tips    

• Attach: Affidavit (your sworn statement detailing the sign creation, chilling effect, intent to speak, fear of penalties).
• Proposed Order: Attach a separate one-page proposed TRO (court can sign it quickly).
• If ex parte (no notice): Emphasize urgency in affidavit—chilling is immediate/ongoing.
• File with clerk; request hearing ASAP (

AFFIDAVIT

IN THE MARION COUNTY SUPERIOR COURT STATE OF INDIANA

ROBBIN STEWART, Plaintiff,

v.

MARION COUNTY ELECTION BOARD (official capacity), and [NAMES OF INDIVIDUAL MEMBERS OF THE MARION COUNTY ELECTION BOARD] (personal capacity), Defendants.

Cause No.: [To be assigned or insert if already filed]

AFFIDAVIT OF ROBBIN STEWART IN SUPPORT OF MOTION FOR TEMPORARY RESTRAINING ORDER

I, Robbin Stewart, being duly sworn, state under penalty of perjury as follows:

1. I am the Plaintiff in this action, over the age of 18, of sound mind, and competent to make this affidavit. I have personal knowledge of the facts stated herein.
2. I am a resident of Marion County, Indiana, and have a long history of engaging in political speech, including as a candidate and advocate. I previously successfully challenged Indiana's predecessor anonymous campaign literature ban in Stewart v. Taylor, 953 F. Supp. 1047 (S.D. Ind. 1997), and participated in the challenge to the current statute in Majors v. Abell, 361 F.3d 949 (7th Cir. 2004).
3. In 2024, I created a political sign that read: “Robbin Stewart for Township Board – Vote Tuesday.” The sign clearly identified me as a candidate for the Township Board and urged people to vote on election day.
4. Indiana Code § 3-9-3-2.5 requires that any communication clearly identifying a candidate include a conspicuous “paid for by” disclaimer stating the name and address of the person or committee responsible. My sign did not include such a disclaimer because I believe I have a constitutional right to engage in anonymous or self-identifying-free political speech.
5. I was chilled from distributing or displaying the sign publicly due to credible fear of enforcement action by the Marion County Election Board. Specifically, I feared civil penalties of up to $1,000 per violation, as authorized under Indiana election law for non-compliance with disclaimer requirements.
6. This chilling effect continues to this day. I intend to create and distribute similar candidate-identifying political signs, flyers, or other materials in the future (including during upcoming election cycles) without including the compelled disclaimer, but I refrain from doing so because of the ongoing threat of investigation, penalties, or other enforcement by the Marion County Election Board.
7. The compelled disclaimer requirement forces me to speak words I do not wish to speak (“paid for by Robbin Stewart” or similar), shifts focus from my political message to my identity, and exposes me to potential reprisal, harassment, or other negative consequences that anonymity would avoid.
8. I believe IC § 3-9-3-2.5 is unconstitutional under the Indiana Constitution (Article 1, § 9 – material burden on core political speech; Article 2, § 1 – unequal elections) and the First Amendment (content-based restriction under Reed v. Town of Gilbert, 576 U.S. 155 (2015); compelled speech under 303 Creative LLC v. Elenis, 600 U.S. 570 (2023)).
9. If the Court does not grant a temporary restraining order, I will continue to be chilled from exercising my constitutional rights to anonymous political speech. This loss of expression constitutes irreparable harm that cannot be adequately compensated by money damages.
10. Granting the TRO will not harm Defendants or the public interest; it merely preserves the status quo while the Court resolves the constitutional questions.

FURTHER AFFIANT SAYETH NAUGHT.

I declare under penalty of perjury under the laws of the State of Indiana that the foregoing is true and correct.

Executed on [Date] at Indianapolis, Indiana.

/s/ Robbin Stewart Robbin Stewart, Affiant

Sworn to and subscribed before me this [Date] day of [Month], 2026.

/s/ [Notary Public] Notary Public My Commission Expires: __________

(If the court allows unsworn declarations under IC 33-43-2-1, you can replace the notary block with: “I affirm under penalties for perjury that the foregoing is true.” and sign.)

Quick Tips

• Attach this to your TRO motion (label it Exhibit A).
• Customize dates, sign it, and get it notarized (many banks, UPS stores, or county clerks offer notary services for a small fee).
• If you have photos of the sign or other evidence, mention them (“Attached as Exhibit B is a photograph of the sign”) and include them.
• File electronically if Marion County allows e-filing for pro se litigants, or in person at the clerk’s office.

This affidavit is factual, concise, and directly supports the TRO elements (irreparable harm, likelihood of success, etc.). If you want to add more details (e.g., specific fear of reprisal, past enforcement experience, or references to your prior cases), let me know and I’ll revise it. Ready for the proposed TRO order next? 😊

PROPOSED CONSENT DECREE

IN THE MARION COUNTY SUPERIOR COURT STATE OF INDIANA

ROBBIN STEWART, Plaintiff,

v.

MARION COUNTY ELECTION BOARD (official capacity), and [NAMES OF INDIVIDUAL MEMBERS OF THE MARION COUNTY ELECTION BOARD] (personal capacity), Defendants.

Cause No.: [To be assigned]

PROPOSED CONSENT DECREE

Plaintiff Robbin Stewart and Defendant Marion County Election Board (the "Parties") hereby consent to the entry of this Consent Decree to resolve the claims in the Complaint without further litigation. The Parties stipulate and agree as follows:

1. Recitals This action challenges the constitutionality of Indiana Code § 3-9-3-2.5 (the "Disclaimer Statute"), which requires compelled disclaimers on certain candidate-identifying political communications. Plaintiff alleges violations of the Indiana Constitution (Article 1, § 9 and Article 2, § 1) and the First Amendment. Defendants deny liability but agree to this resolution to avoid the costs and uncertainties of litigation. This Consent Decree is not an admission of wrongdoing by any Party.
2. Jurisdiction and Venue The Court has jurisdiction under IC 34-14-1-1 (Uniform Declaratory Judgment Act) and Trial Rule 57. Venue is proper in Marion County.
3. Declaratory Relief The Court declares that IC § 3-9-3-2.5 is unconstitutional on its face and as applied to Plaintiff's intended anonymous or low-profile political speech under:
   • Indiana Constitution Article 1, § 9 (material burden on core political speech exceeding police power to prevent abuses, per Price v. State, 622 N.E.2d 954 (Ind. 1993));
   • Indiana Constitution Article 2, § 1 (undermining free and equal elections by chilling independent speakers); and
   • First Amendment (content-based restriction under Reed v. Town of Gilbert, 576 U.S. 155 (2015); compelled speech under 303 Creative LLC v. Elenis, 600 U.S. 570 (2023)).
4. Injunctive Relief Defendants are permanently enjoined from enforcing IC § 3-9-3-2.5 against Plaintiff or any person distributing candidate-identifying political communications (e.g., signs, flyers) without a compelled "paid for by" disclaimer in Marion County. This injunction applies to any future enforcement actions, investigations, or penalties based on non-compliance with the Disclaimer Statute for such speech.
5. Damages and Costs In settlement of Plaintiff's claims for compensatory damages related to chilled speech and threatened penalties, Defendants agree to pay Plaintiff [insert amount, e.g., $X] within 30 days of entry. Plaintiff waives further monetary claims. Each Party bears its own costs and attorney fees.
6. Retention of Jurisdiction The Court retains jurisdiction to enforce this Consent Decree, resolve disputes arising from it, and modify it upon motion and good cause shown.
7. No Admission of Liability This Consent Decree resolves disputed claims without admission of liability or wrongdoing by Defendants.
8. Binding Effect This Consent Decree binds the Parties, their successors, and agents. It is effective upon entry by the Court.

The Parties respectfully request the Court approve and enter this Proposed Consent Decree.

Respectfully submitted,

/s/ Robbin Stewart Robbin Stewart, Pro Se [Your Address] Indianapolis, IN [ZIP] [Phone] [Email] Date: [Insert Date]

[If defendant agrees: Signature block for Defendant's counsel or authorized representative]

APPROVED AND ENTERED this ___ day of __________, 2026.

---

Judge, Marion County Superior Court

Quick Tips for Use

• If no agreement yet: File this as "Plaintiff's Proposed Consent Decree" with a short motion asking the court to approve it or set a hearing (attach to your complaint/TRO).
• If defendant engages: Negotiate terms (e.g., add severability, no attorneys' fees, or narrow the injunction to your speech only).
• Filing: Submit as a separate document after the complaint; request AG certification if not already done.
• Customization: Adjust damages (if any), injunction scope, or add "no further enforcement against similar anonymous speech" if broader relief is desired.

This provides a clear path to final resolution if settlement happens. If you want variations (e.g., no damages, broader injunction, or joint motion language), let me know! 😊

Your Name Your Address Indianapolis, IN [ZIP Code] [Your Phone] [Your Email] [Date]

Marion County Election Board 200 E. Washington Street, Room W-144 Indianapolis, IN 46204

Attn: Board Chair / Legal Counsel / Nolita Stewart (Chair)

Re: Proposed Settlement or Mediation of Constitutional Challenge to IC § 3-9-3-2.5 (Robbin Stewart v. Marion County Election Board, forthcoming Marion County Superior Court action)

Dear Members of the Marion County Election Board and Counsel:

I am writing to propose a prompt and amicable resolution to the constitutional issues raised by Indiana Code § 3-9-3-2.5, the compelled “paid for by” disclaimer statute for candidate-identifying political communications.

As you may be aware, I have a history of successfully challenging similar compelled-disclaimer requirements (Stewart v. Taylor, 953 F. Supp. 1047 (S.D. Ind. 1997)) and participated in the challenge to the current statute (Majors v. Abell, 361 F.3d 949 (7th Cir. 2004)). In 2024, I created a political sign reading “Robbin Stewart for Township Board – Vote Tuesday,” but I was chilled from distributing it due to the statute’s requirement of a forced disclaimer, which I believe violates my rights to anonymous political speech.

I intend to file a pro se complaint in Marion County Superior Court seeking:

• Declaratory judgment that IC § 3-9-3-2.5 is unconstitutional under Indiana Constitution Article 1, § 9 (material burden on core political speech, Price v. State, 622 N.E.2d 954 (Ind. 1993)) and Article 2, § 1 (free and equal elections);
• Permanent injunctive relief barring enforcement against anonymous or low-profile candidate-identifying materials;
• Compensatory damages for chilled speech; and
• A temporary restraining order to prevent immediate enforcement threats.

Recent U.S. Supreme Court developments (Reed v. Town of Gilbert, 576 U.S. 155 (2015); 303 Creative LLC v. Elenis, 600 U.S. 570 (2023)) have undermined the 7th Circuit’s prior upholding in Majors, and Judge Easterbrook’s dubitante opinion in that case correctly anticipated these shifts. The statute’s compelled self-identification requirement is vulnerable on both state and federal grounds, and no Indiana court has ever applied Price v. State to this provision.

To avoid the time, expense, and uncertainty of litigation for all parties, I propose the following resolution options:

1. Direct Settlement Negotiations I am open to negotiating a consent decree or stipulated judgment that includes:

   • A declaration that the statute is unconstitutional as applied to anonymous candidate-identifying political speech (or a narrower scope if preferred);
   • A permanent injunction preventing enforcement against my speech (or similar anonymous materials in Marion County);
   • Nominal or modest compensatory damages (e.g., $5,000–$10,000) for past chilling effects;
   • Each party to bear its own costs.

   Please respond within 21 days to discuss terms or schedule a meeting/call.

2. Court-Ordered Mediation If direct talks are not feasible, I will request the Court refer the case to mediation under Indiana ADR Rule 2.7 and Marion County Local Rule LR49-ADR2-209 (mandatory for jury trials, encouraged otherwise). Mediation is an efficient way to explore resolution without full discovery or trial. I am willing to participate in good faith and suggest a court-appointed mediator from the Marion County ADR roster.

I believe a negotiated resolution serves the public interest by clarifying the statute’s constitutionality without prolonged litigation. Please contact me at [your phone] or [your email] to discuss next steps. I look forward to your response by [insert date 21 days from sending].

Thank you for your attention.

Sincerely,

Robbin Stewart

cc: Indiana Attorney General (via certified copy for notice under IC 34-33.1-1-1, if filing follows)

Quick Tips for Sending

• Send via certified mail with return receipt (proof of delivery) and email if you can find an address (e.g., elections@indy.gov from public sources).
• Attach or enclose your draft complaint/TRO/affidavit to show seriousness.
• Keep records of all communications.
• If they respond positively, propose a call or in-person meeting.
• If no response, proceed with filing and then file the mediation motion as planned.

This letter positions you as reasonable while signaling strength. If you'd like a shorter version, more aggressive tone, or adjustments (e.g., no damages mention), let me know! Good luck—this could prompt a quick settlement. 😊

=

American Target Advertising v. Giani (199 F.3d 1241, 10th Cir. 1999) — Upheld some disclosure but noted Talley's anonymity protections limit compelled ID in political mailings.

Chandler v. City of Arvada (292 F.3d 1236, 10th Cir. 2002) — Struck down a Colorado municipal ordinance banning anonymous political signs; directly followed Talley, emphasizing anonymity's role in allowing unpopular views without fear.

White v. Lee (227 F.3d 1214, 9th Cir. 2000) — Protected anonymous speech in ballot-measure contexts, citing Talley for the historical importance of unsigned political pamphlets.

Doe v. Cahill (884 A.2d 451, Del. 2005) — While about online anonymity in defamation, cited Talley extensively for the First Amendment right to anonymous political speech, requiring heightened 

 $550 citizens gas

$100 alisha/ walmart? downtown somewhere?

1. fix tire. try to make it downtown tonight? is this wednesday? trash out?

Blue v. State ex rel. Brown, 188 N.E. 583 (Ind. 1934)

• A foundational election law case.
• The court addressed whether election procedures violated Article 2, Section 1.
• It involved challenges to election laws based on the requirement that elections be free and equal.

2. Morris v. Powell, 125 Ind. 281 (Ind. 1891)

=

State v. $2,435 in U.S. Currency right to jury trial re forfeiture.

=

The phrase "a man's home is his castle" originates from English common law (notably referenced in Semayne's Case in 1604 and later popularized by Sir Edward Coke), emphasizing the sanctity of one's home and the right to defend it against unlawful intrusion.

The phrase "a man's home is his castle" is a correct statement of Indiana law. For example it was used by the Indiana Supreme Court about whether breaking into a cabin was first degree burglary.

Such attempted immunity extended to a man's dwelling or mansion house has been said to be attributable to the early common-law principle that a man's home is his castle. The jealousy with which the law guarded against any infringement of this ancient right of peaceful habitation is best illustrated by the severe penalties which at common law were assessed against a person convicted of burglary, 

Smart v. State 244 Ind. 69 (1963) 190 N.E.2d 650.

 This was an ok way for a lawyer to write to another lawyer in a letter to notify their client not to trespass. Subsequently Chip Jefferson trespassed onto the property in an ex parte discussion about how to resolve the case. 

By 

The expression a man's home is his castle is an analogy and metaphor, in which one concept, a castle, stands in for another, a home. The disputed references further in the letter continued this castle metaphor. Being "armed and dangerous" stands in for another. having a series of legal arguments, such as

lack of jurisdiction, demand for jury trial, dispute over the burden sta of proof, dispute over the constitutionality of the court, Timbs 8th Amendment excessive fines defense, ADA, RLUPIA claims, prior unresolved counterclaims, state and federal taking claims, as well as  as the ethical counterparts of these legal claims. 

Section 11 of article I states .
Section 11. The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable search or seizure, shall not be violated; and no warrant shall issue, but upon probable cause, supported by oath or affirmation, and particularly describing the place to be searched, and the person or thing to be seized.

Protection of the home, including its curtilage, is a core value under section 11. Brown v State, for example, protected the rights of a man living in his car, noting that the state constitution can go beyond the protections of the fourth amendment. see Gershoffer v State. 

I have had a long concern about my property rights and privacy rights under the indiana's constitution being violated by Marion County, especially Health and Hospital (HH).

For example  in Stewart v Taylor Marion County election officials took my campaign sign. They paid $7000 to settle the case. When I have disputes, I seek to use the legal process to resolve my concerns. 

Before moving to E. Washington Street I lived on Temple Street. My roommate there, Joell Palmer, had been one of the two plaintiffs in Indianapolis v. Edmond, 531 U.S. 32 (2000), which found that Palmer's 4th Amendment rights had been violated by a drug roadblock. 

In Crawford v Marion County Election Board, Palmer and I were part of an amicus to SCOTUS arguing that voter ID violates privacy. 

These are examples of when I felt my rights were being violated and chose to use the legal process.

My letter should be taken in that context. 

Similarly the term peril is no true threat.

" I will maintain the confidence and preserve inviolate the secrets of my client at every peril to myself".

TABLE OF CONTENTS

QUESTION PRESENTED .................................................................................... i

SUMMARY OF THE ARGUMENT .................................................................... 1

STATEMENT OF THE CASE AND FACTS ..................................................... 3

ARGUMENT ....................................................................................................... 5

I. INDIANA CODE § 3-9-3-2.5 VIOLATES THE FIRST AMENDMENT TO THE UNITED STATES CONSTITUTION AS AN UNCONSTITUTIONAL COMPULSION OF SPEECh

The Statute Imposes a Content-Based Restriction Subject to Strict Scrutiny Under Reed v. Town of Gilbert. ....................................................... The State’s "Informational Interest" Does Not Justify Burdens on Core Political Speech Under McIntyre v. Ohio Elections Commission. ............ 8

C. Forced Disclaimers Constitute Unconstitutional Compelled Speech Under 303 Creative LLC and NIFLA v. Becerra. ..................... 10


II. THE DISCLAIMER REQUIREMENT IMPOSES AN UNCONSTITUTIONAL "MATERIAL BURDEN" ON CORE POLITICAL VALUES UNDER ARTICLE 1, SECTION 9 OF THE INDIANA CONSTITUTION.

A. Political Expression Concerning Candidate Robbin Stewart is a "Core Constitutional Value" Under the Price v. State Framework. .................... 12
B. Mandating Identification as a Condition of Speech is a Material Burden That Exceeds the State’s Police Power to Prevent "Abuses." .................. 14

III. THE STATUTE VIOLATES THE MANDATE OF ARTICLE 2, SECTION 1 OF THE INDIANA CONSTITUTION THAT ALL ELECTIONS SHALL BE "FREE AND EQUAL."

A. The Disclaimer Requirement Acts as a "Constraining Influence" That Intimidates the Independent, Lone Speaker. ............................................... 16
B. By Imposing Institutional Burdens on Private Individuals, the State Creates an Unequal Electoral Playing Field. ................................................ 18

IV. THE CONSTITUTIONAL PROTECTIONS FOR THE SPEECH AT ISSUE ARE "CLEARLY ESTABLISHED," FORECLOSING THE DEFENSE OF QUALIFIED IMMUNITY. ................................................................................. 20
CONCLUSION .................................................................................................... 22
WORD COUNT CERTIFICATE ....................................................................... 23
CERTIFICATE OF SERVICE .......................................................................... 24
Final Recommendation:
When you file this in Indiana, make sure to emphasize that the Indiana Constitution (Section II and III above) provides an independent basis for relief. If the judge is hesitant to challenge federal campaign finance trends, they can still rule in your favor solely on the Price v. S
tate "

working with google on a stewart v stewart brief.

 

Here is the Table of Authorities with the specific citations you need to finalize the Stewart brief. These are formatted for a standard legal filing.

Table of Authorities 

U.S. Supreme Court Cases

• 303 Creative LLC v. Elenis, 600 U.S. 570 (2023) (Establishing that the government may not compel a speaker to alter their message or co-opt their expression).
• Americans for Prosperity Foundation v. Bonta, 141 S. Ct. 2373 (2021) (Clarifying that "exacting scrutiny" requires narrow tailoring even when the state claims an administrative or informational interest).
• McIntyre v. Ohio Elections Commission, 514 U.S. 334 (1995) (Holding that the right to anonymous political speech is a core First Amendment protection and rejecting the "informed electorate" defense for individual speakers).
• Meyer v. Grant, 486 U.S. 414 (1988) (Defining "core political speech" as being at its "zenith" and subject to the highest level of protection).
• NIFLA v. Becerra, 585 U.S. 755 (2018) (Ruling that content-based compulsions are "presumptively unconstitutional" and must survive strict scrutiny).
• Reed v. Town of Gilbert, 576 U.S. 155 (2015) (Establishing the "read the sign" test: if a law applies because of the topic discussed, it is content-based and subject to strict scrutiny).

 Upon being admitted to practice law in the state of Indiana, each applicant shall take and subscribe to the following oath or affirmation:

“I do solemnly swear or affirm that: I will support the Constitution of the United States and the Constitution of the State of Indiana; I will maintain the respect due to courts of justice and judicial officers; I will not counsel or maintain any action, proceeding, or defense which shall appear to me to be unjust, but this obligation shall not prevent me from defending a person charged with crime in any case; I will employ for the purpose of maintaining the causes confided to me, such means only as are consistent with truth, and never seek to mislead the court or jury by any artifice or false statement of fact or law; I will maintain the confidence and preserve inviolate the secrets of my client at every peril to myself; I will abstain from offensive personality and advance no fact prejudicial to the honor or reputation of a party or witness, unless required by the justice of the cause with which I am charged; I will not encourage either the commencement or the continuance of any action or proceeding from any motive of passion or interest; I will never reject, from any consideration personal to myself, the cause of the defenseless, the oppressed or those who cannot afford adequate legal assistance; so help me God.”

Upon being admitted to practice law in the state of Indiana, each applicant shall take and subscribe to the following oath or affirmation:

“I do solemnly swear or affirm that: I will support the Constitution of the United States and the Constitution of the State of Indiana; I will maintain the respect due to courts of justice and judicial officers; I will not counsel or maintain any action, proceeding, or defense which shall appear to me to be unjust, but this obligation shall not prevent me from defending a person charged with crime in any case; I will employ for the purpose of maintaining the causes confided to me, such means only as are consistent with truth, and never seek to mislead the court or jury by any artifice or false statement of fact or law; I will maintain the confidence and preserve inviolate the secrets of my client at every peril to myself; I will abstain from offensive personality and advance no fact prejudicial to the honor or reputation of a party or witness, unless required by the justice of the cause with which I am charged; I will not encourage either the commencement or the continuance of any action or proceeding from any motive of passion or interest; I will never reject, from any consideration personal to myself, the cause of the defenseless, the oppressed or those who cannot afford adequate legal assistance; so help me God

Upon being admitted to practice law in the state of Indiana, each applicant shall take and subscribe to the following oath or affirmation:

“I do solemnly swear or affirm that: I will support the Constitution of the United States 

and the Constitution of the State of Indiana;

so we're going to spend about a half hour talking about the state constitution, and walk through it point by point.  

 I will maintain the respect due to courts of justice and judicial officers; 

I will not counsel or maintain any action, proceeding, or defense which shall appear to me to be unjust, but this obligation shall not prevent me from defending a person charged with crime in any case;

was it just to (list the 19 reasons)

what is the appearance of impropriety?

the lawsuit that you filed against me, did  that have the name of katherine sweeny bell on it?

have you read stewart v taylor? 

do you understand that bell is engaged in the same behavbior as taylor was? and that taylor's behavior was found to be unconstitutional?

are you familiar with the case of rebecca majors v iec?

or williamson v iec?

now, in my letter to you i said that 

i could come after you in ways you wouldn't be expecting.

marion county health and hospital is marion county, right?

so you and the election board, same team right? same taxpayers pay you? are you in some sort of professional association with the election board or their lawyers? 

if they were conspiring to violate my rights, would you be part of that conspiracy as well, or are you completely separate? could there be an appearance of impropriety, if people think, well you work for marion county, and its marion county that would let him vote, won't give him a press pass, threatened him with arrest, tortured him in custody.

in the letter, i said i could come after you with character assasination. and here we are. my goal here today is is to show probable cause that you and perhaps some of your coworkers, should be investigated by this disciplinary commission.

so here are a few of the allegations:

1 denial of right to trial by jury

2 denial of right to elected judge

3 timbs excessive ,fine

4 less likely - interference w right to counsel

5 was it ethical to oppose appointed counsel, if she did?

6 rudely failed to talk to me first before lawsuit

7 did not tell me about first pretrial  conference

8 might not have read the files of the history of the county's litigation against me. had you read the files before you got the letter? duty of competence 

8 were you aware of the crossclaims against the previous attorney?

8 can you describe procedurally what happened to those crossclaims? 

9 is it possible that those are still live claims lurking in this case, that perhaps you renew with the new filing agains tme?

10 so in the letter where i talk, as one lawyer negotiating with another, about being armed and dangerous. in context, is it possible that i was alluding to filing crossclaims against you?

have you ever been sued? how'd that go? was it fun? were you the prevailing party each time? 

11 tell the rabbi story 

he said its not my job to decide if you were unethical. it's my job to spot the issue, report it, and let them decide.

in law school i had a friend mark carnes. his was to sytudy was to treat life like a law school exam, spotting issues, discussing rules, analyzing situations. so my goal here is issue spotting.

i'm going to talk about my concerns about your ethics, both before and after the letter. 

but i couldn't just file a complaint against you. i'm not usually a karen. 

what i could do instead was let you report me, so now i'm cross examining a hostile witness. does that let me ask leading questions?

in my world, being a narc is dangerous. 

when i called 911 on mighty dennis washington , that put michelle's life at risk. he said he would kill her.

or rather she said he said that, i wasn't there. she said he attacked her. 

my friend vegas is dead. he was helping me clean up the back yard. but he got shot dead. gary was with him. gary was a neighbor and had worked for me one day, helping me remove the burned garage.

is it more likely than not that i was alluding to filing crossclaims

rather than stocking up on bazookas, drones,?

here we are at the disciplinary commiussion. is it possible that i was alluding to was getting you up before the disciplinary commission, rather than planning to come at you with bazookas and drones and rockets and tanks, when I talked about being armed and dangerous?

are you a professional? was your witness a professional? 

what is her profession? did she tske an oath of any kind? while under oath,       did she deny having taken an oath to support the state constitution? has she received training in the indiana constitution? has she received any training on the bill of rights of the federal constitution? are you responsible inb any way for her training or supervision? training and supervision ? 

has he been trained on what her responsibilities under the rules of professional responsibility? 

is she paid with tax dollars? is there a contract that says we give her a paycheck, and she works here, but she has to agree to uphold the sttrae constitution.

and if she's been cashing that paycheck but n ot upholding the state constitution, would that be fraud?

would that be a breach of contract? could she be ordered to disgorge any pay she has received while not folling the constitution, as she either promised, or should have been required to promise? 

when chip jefferson entered my curtilage without a warrant. he was trespassing. you were an accessory. he physically invaded my property. i sent you a letter i should not have sent. it was rude, and could be misconstrued. but you sent an african american male to trespass onto my property. while ther e he attempted to negotiate the case. my lawyer was not present. this may have been an improper ex parte contact. 

what are your procedures for dealing with possible ex parte situations? 

if, that's if, there had been an ex parte violation, could that trigger the doctrine of fruit of the poisonous tree? 

the doctrine of unclean hands?

are here any other circumstances in th8isi case that might suggest or require an unclean hands analytsis?

are you familar with the facts of timbs?

are you familiar with the time they took 5 volvos from me?

that was before timbs. how would you apply timbs if that happened now? 

are your inspectors trained in timbs? do you have any procedures in place to ensure that remedies are proportional and not excessive fines? 

are you familiar with the institute for justice?

what can you tell us about it? * is heartland inst still a thing?

if a person is fined but is denied a requested jury trial, is their fine excessive? 

how much is 420 x 69? what is the capital or north dakota?

where'd you go to undergrad? what was your major? 

under what circumstances can a lawyer be named in a  crossclaim? 

what is mutual assured destruction? 

what's your favoriute book?

what is asymetrical warfare?

what is lawfare?

what is asymetrical lawfare?

in this case, you filed a case against me without discussing it with me first. was that a good idea? would you it the same way next time? are you going to sue any more lawyers without letting them know about it first?

what actual notice did you give me of the first conference? 

is it possible that i didnt know about it? did you make sure i knew about it and had actual notice?

is that important from a due course of law perspective? 

in your understanding, what does due course of law require? 

i think we both agree we have a duty of civility to each other.

does a lawyer who is suing another lawyer have any duty of civility to tell the lawyer so they know about it? 

did you pay the filinjg fee?

do you know how notice was provided? was that the best available method?

was it the minimum legally required, at best? could you have done more?

would you do it again the same way?

now, say someone get s a ticket, how do they go about requesting a jury trial?

how do they go about getting an administrative hearing?

if they want an administrative hearing, how many times do they have to ask for it?

do you understand the allegation that you  proceeded against me without jurisdiction?

would that be consistent with your oath as an attorney?

is it rude for one attorney to sue another while lacking jurisduction?

would that implicate the duty of civility?

could that create an appearance of impropriety?

how many have i got so far?

what is replacement theory?

do you recognize the possibility of appearance of impropriety

turning now to the indiana constitution, what is article I?

would it refresh your memory if i hand you a copy?

do i have any rights under section 1?

what is the inspiration for this section?

does the declaration have the force of law?

does section 1 incorporate the ideas and values of the declaration into indiana law?

1 does he have a first amendment right to petition the government for redress of greivamces?

does he hav3e a grievance against youy?

was his letter a petition?  did it assert a right of privacy?

in the first invasion, workers removed a sign that read Robbin Stewart for Township Board Vote Tuesday. is that text protected speech?

as a matter of indiana law?

when they removed it, did that  infringe on my right to free speech or press?

i've heard that currently i'm the only one in indiana with a continuing clean order against them. is that true?

so at least statistically there's a case the fine is more excessive here than usual?

how does the excerssive fine analysis differ under the state and federal constitiutions?

what do you train your inspectors about thius?

\

2 do i have a right to bear arms?

do i have a right to be dangerous?

do you agree with heller, mcdonald, and bruen?

my being armed and dangerous is not an overt threat to you. if you were to claim that it was, that would infringe on my right to bear arms, both constitutions.

you read at a college level, correct? you can recognize a methaphor or a simile, right? when you reead my letter which said i am armed and dangerous, did you understand that i was not being literal, but was employing a metaphor?

how long ago was the metaphor invented? and you dont have the hang of it yet?

did this case involve men with guns invading my lawn? on at least three occasions?

does that involve or invoke any of the values of the third amendment?

are your staff ttrained to observe and follow the third amendment? 

did you conspire with tom to violate my rights under 42 usc 1983?

in addition to any federal constitution or laws, is there anything in the in diana constitution that could protect a car or trailer parked in he yard? 

did this case involve my person, places, papers or effects?

did the court order  adequately specify the things to be seized?

was there adequate notice to justin, michelle, dusty? 

is it enough to notify    the actual legal landowner, but not tenants in possession or people with an equitable interest? is that consistent with section 12 or amendment 14?

should a lawyer do better than  the minimum?

what are some of the ways you could have done better here?

how does the 5th amendment apply to this case?

what is the current status of taking cases at the supreme court?

 

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5

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 I will employ for the purpose of maintaining the causes confided to me, such means only as are consistent with truth, and never seek to mislead the court or jury by any artifice or false statement of fact or law;

 I will maintain the confidence and preserve inviolate the secrets of my client at every peril to myself; I will abstain from offensive personality and advance no fact prejudicial to the honor or reputation of a party or witness, unless required by the justice of the cause with which I am charged; I will not encourage either the commencement or the continuance of any action or proceeding from any motive of passion or interest; I will never reject, from any consideration personal to myself, the cause of the defenseless, the oppressed or those who cannot afford adequate legal assistance; so help me God.”.”