(Case No. 1:24-cv-01215-JDB-jay)
Addressed To: The Honorable Mayor Terry Bell, City of Henderson, Tennessee
From: Ambassador Josiah Haltom, Plaintiff, pro se
Date: July 26, 2025
I. Introduction: A Formal Overture for Resolution and Righteous Judgment
This document constitutes a formal proposal for a principled settlement intervention in the matter of Haltom v. City of Henderson Police Department (CHPD), currently pending in the United States District Court for the Western District of Tennessee. It is submitted in good faith to you, Mayor Terry Bell, as the chief executive officer of the City of Henderson, who is vested with the ultimate responsibility for the conduct and integrity of its departments. This proposal is offered as a constructive alternative to protracted, costly, and potentially damaging litigation, an approach that aligns with the federal judiciary’s stated preference for alternative dispute resolution (ADR) to achieve just and efficient outcomes.
The intervention proposed herein is grounded in the highest principles of American law, invoking the solemn purpose articulated in the Preamble to the United States Constitution. The plaintiff’s action is a direct petition to “establish Justice, insure domestic Tranquility… and secure the Blessings of Liberty” for the people of Henderson. This proposal offers the City a clear and tangible path to reaffirm its own commitment to these foundational goals. The current litigation represents more than a mere dispute over damages; it is a “critical juncture” and a “prophetic” moment for the City of Henderson. It presents an opportunity to address deep-seated institutional issues and consciously choose a path of “redemption” and “transformation” over one of continued conflict, public mistrust, and escalating legal liability.
This proposal is therefore crafted not merely as a legal document for review by counsel, but as a direct appeal to you as a civic leader. By framing the issues within the context of the Constitution’s aspirational mandate, it elevates the conversation beyond the narrow confines of a lawsuit. It presents a leadership challenge: to demonstrate that Henderson is a city that actively pursues the Preamble’s promise of justice, or one that becomes mired in litigation over allegations of police misconduct. This framing establishes political and moral stakes that are more difficult to disregard than a standard legal demand. It reframes the narrative from one of a “frivolous litigant” to one of a citizen demanding the constitutional accountability to which every American is entitled.
II. The Factual and Legal Predicate for an Unconventional Intervention
A direct and unconventional intervention is warranted because the issues underlying this litigation are not isolated but appear to be systemic, and because the ordinary legal process is being obstructed by a pattern of evasion and bad-faith engagement.
A. A Documented Pattern of Institutional Dysfunction: The Testimony of a Former Chief
The plaintiff’s allegations of “structural violence” and a culture of impunity within the CHPD are not without precedent. They find powerful, independent, and high-level corroboration in the public testimony of former Henderson Police Chief Wilton Cleveland upon his resignation in June 2018. Chief Cleveland, a law enforcement professional with over 25 years of experience, resigned after only a year and a half, citing a deeply ingrained “good ole boy” mindset that actively resisted accountability and equal enforcement of the law.
His public statements from that time are critically relevant. He noted receiving significant push-back for attempting to end favoritism, describing the prevailing attitude as, “I shouldn’t get a ticket because I’m a good citizen, go get those guys” [News]. He further alleged that officers had lied to the Board of Aldermen and that he was ultimately pushed out for trying to implement basic professional standards, such as requiring officers to sign affidavits. Most alarmingly, Chief Cleveland concluded that the town’s problems were so severe that they required a federal investigation, confirming he had already spoken with the Federal Bureau of Investigation (FBI) [News].
This public record from a former chief of police serves as a secular, verifiable anchor for the plaintiff’s otherwise spiritual diagnosis of the CHPD’s institutional maladies. The “good ole boy” mindset Cleveland described is the observable, political manifestation of the “spiritual wickedness that seemingly influences [public] agendas” which the plaintiff has alleged from the outset. The events giving rise to
Haltom v. CHPD can thus be presented as the predictable and foreseeable outcome of the City’s failure to heed Chief Cleveland’s 2018 warning and purge the culture of impunity he identified. This history transforms the current case from an isolated incident into a symptom of a documented, unresolved institutional crisis about which the City’s leadership was formally and publicly warned.
B. The Unaddressed Question of Lawful Authority: Oaths of Office as a Constitutional Covenant
A central and repeatedly raised issue in this litigation has been the plaintiff’s demand for verification of the oaths of office for the CHPD personnel involved. This is not a trivial or procedural matter. The Tennessee Constitution, Article X, Section 1, and associated state laws (e.g., T.C.A. §§ 8-18-107, 8-18-109) mandate that every public official must take and file a subscribed oath to support the constitutions of Tennessee and the United States before their actions carry the force of law. This oath is the fundamental covenant between the official and the people, and it is the prerequisite for the lawful exercise of state power.
Despite the plaintiff’s formal notices on this matter, the defendant’s response filings have been completely silent on the issue, refusing to confirm or deny that the officers in question have met this basic constitutional requirement. This evasion is profoundly troubling. From the plaintiff’s jurisprudential framework, the oath is the “covenant that connects a public servant’s actions to the sovereign authority of God and the People”. An official acting without a verified oath has severed their connection to this source of legitimacy, rendering their actions
ultra vires—beyond the scope of lawful authority. As established in Norton v. Shelby County, 118 U.S. 425 (1886), an unconstitutional act “confers no rights; it imposes no duties; it affords no protection”. Therefore, any claim to qualified immunity by an official who cannot produce a valid oath of office is null and void. The City’s refusal to provide this simple, public-record verification raises a critical question that must be answered: Why does the defendant refuse to confirm the lawful authority of its own agents?
C. A Record of Bad-Faith Engagement and Procedural Obfuscation
The defendant’s refusal to address the substantive issue of oaths is part of a broader pattern of litigation tactics that the plaintiff contends are designed to obfuscate, misdirect, and prejudice the court. These actions stand in stark contrast to the duties of candor and good faith imposed by Federal Rule of Civil Procedure 11 and the due process principles articulated in
Brady v. Maryland. The defendant has, for instance, allegedly misrepresented filing deadlines to create a false narrative of untimeliness by the plaintiff. Most notably, the defense counsel has persisted in using the pejorative and legally inaccurate label “sovereign citizen” to describe the plaintiff, a tactic clearly intended to “improperly prejudice the Plaintiff before the Court” by associating him with stigmatized and legally frivolous rhetoric.
Furthermore, in a sworn declaration to the court, defense counsel stated that “Plaintiff has not served Defendants with the ’48 volumes of Zohar.’ Nor do Defendants know what Plaintiff is talking about”. This categorical denial directly contradicts the plaintiff’s multiple filings and notices regarding the gift of these books, including a formal letter to you, Mayor Bell. This creates a factual dispute that points to either a deliberate bad-faith denial in violation of FRCP 11 or a severe breakdown in communication within the City’s administration.
To provide a clear summary of this pattern for your review, the following table analyzes the defendant’s litigation conduct:
| Defendant’s Action or Omission | Plaintiff’s Filing Reference / Evidence | Implication Under Legal & Ethical Principles |
| Categorical denial of knowledge or receipt of the 48 Zohar volumes. | : “Nor do the Defendants know what Plaintiff is talking about.” | Contradicts multiple notices and filings from Plaintiff. Creates a factual dispute suggesting either bad-faith denial (violating FRCP 11) or gross incompetence in internal communications. |
| Refusal to address the substantive demand for verification of Oaths of Office. | (by omission). | Evasion of a foundational question of legal authority. Suggests an unwillingness to confirm the legitimacy of the very officers whose actions are being defended, violating the spirit of due process. |
| Dismissal of Plaintiff’s entire theological framework as “frivolous ecclesiastical rhetoric.” | . | Fails to engage with the substance of the claims, contrary to the principle in Ballard v. United States that courts cannot adjudicate the truth of sincere religious beliefs, but must address the claims they produce. |
| Persistent use of the prejudicial “sovereign citizen” label. | . | An attempt to “improperly prejudice the Plaintiff before the Court” and associate him with stigmatized rhetoric, a tactic that can be seen as harassment under FRCP 11. |
| Alleged misrepresentation of filing deadlines to claim untimeliness. | . | An attempt to “derail proceedings through misdirection” and win on procedural technicalities rather than the merits of a serious civil rights claim. |
This pattern of behavior demonstrates that the plaintiff’s call for direct mayoral intervention is not an arbitrary step but a necessary one, prompted by the defense counsel’s own obstructive conduct.
III. The Proposed Settlement Framework: A Choice Between Blessing and Condemnation
Given the preceding factual and legal predicate, this proposal outlines a unique but principled path toward resolution. It requires the City to make a foundational choice before any conventional settlement negotiations can proceed.
A. The Forum: A Meeting for Restorative Justice and Tikkun Olam
A formal request is hereby made for a settlement meeting to be attended by yourself, Mayor Terry Bell, the City Attorney, and the plaintiff, Ambassador Josiah Haltom. The purpose of this meeting is explicitly twofold:
- Legal Resolution: To negotiate a settlement of the civil rights claims filed under 42 U.S.C. § 1983, addressing the tangible harms alleged by the plaintiff.
- Spiritual Rectification: To engage in an act of Tikkun Olam, a concept from Jewish thought meaning “the repair of the world”. This process is intended to address the underlying “spiritual wickedness” and “structural violence” that the plaintiff contends are the root causes of this conflict. It is offered as a path to “foster introspection, wisdom, and a renewed commitment to the highest principles of service and integrity” within the CHPD, thereby “fixing what is broken” at a fundamental, spiritual level.
B. The Fulcrum of Resolution: The Disposition of the 48 Zohars
The settlement meeting will commence with the City of Henderson making a definitive, public choice regarding the 48 volumes of the Zohar previously gifted to the CHPD. These are not to be understood as mere “books,” but as “forcefields of blessing and protection,” a “living Ark against the floodwaters of injustice,” and potent tools for spiritual correction. The gift was conditional, predicated on the Kabbalistic principle that “A gift of light must be received with awe, or it becomes a weight upon the soul”. The City’s choice is the necessary first step before any further negotiation can occur.
- Option A: The Path of Awe and Reconciliation. The City of Henderson, through its Mayor, formally accepts the 48 Zohar volumes on behalf of the CHPD. This act would signify an agreement to receive them in the spirit they were offered: as “seeds of Tikkun Olam” and instruments to foster wisdom and justice. This acceptance will be interpreted by the plaintiff as an act of good faith, demonstrating an alignment with the “light of absolute certainty” and opening the door to a conventional and fair settlement discussion of the legal claims.
- Option B: The Path of Rejection and Revelation. The City of Henderson, through its Mayor, formally rejects the 48 Zohar volumes and arranges for their immediate return to the plaintiff. This act of rejection will be interpreted by the plaintiff as dispositive proof of his entire case. It will be treated as a public declaration that the City “choose[s] Pharaoh’s path over the covenant”. The plaintiff will then immediately move to enter this act of rejection into the court record as “eternal evidence” of the defendant’s bad faith and sacrilege, arguing it proves that the CHPD “loued darknesse rather then light, because their deedes were euill” (John 3:19, KJV).
C. The Plaintiff’s Standing as Ministerial Intervenor
It is anticipated that the defendant may attempt to dismiss this unconventional framework by continuing to mischaracterize the plaintiff as a “sovereign citizen” engaging in frivolous pseudo-legal tactics. This characterization is inaccurate and strategically flawed. The plaintiff’s actions are not rooted in a rejection of all law, but in an adherence to a higher, recognized body of ecclesiastical law that compels this intervention.
As an ordained clergy member, the plaintiff operates under the duties described in the Code of Canon Law. Specifically, Canon Law 287 provides the mandate for this action:
- Canon 287 §1: “Most especially, clerics are always to foster the peace and harmony based on justice which are to be observed among people”. This proposal is a direct attempt to fulfill that duty.
- Canon 287 §2: While clerics are generally not to have an active part in political matters, an exception exists where, in the judgment of competent ecclesiastical authority, “the protection of the rights of the Church or the promotion of the common good requires it”. The plaintiff asserts that the CHPD’s alleged pattern of constitutional violations constitutes a grave threat to the “common good,” thus compelling this active intervention under this specific canonical provision.
By grounding his actions in a recognized body of law, the plaintiff distinguishes himself from the common caricature of a sovereign citizen who invents a private legal system. He is not rejecting law; he is asserting that he is bound by a different and higher legal framework that mandates his pursuit of justice. This forces the defense into a more precarious position: to maintain their “frivolous” argument, they would have to implicitly challenge the legitimacy of Canon Law as a basis for personal conduct. This structured, text-based justification for the plaintiff’s actions lends credibility to his approach and makes it substantially more difficult for the City’s leadership to summarily dismiss.
IV. Conclusion: A Formal Demand for Clarity and a Call to Conscience
This proposal places a clear and powerful choice before the City of Henderson. One path leads toward reconciliation, repair, and a resolution that honors the principles of justice. The other path involves a public act of rejection that the plaintiff will argue is irrefutable proof of the City’s mal-intent, thereby solidifying his case in court.
To that end, this proposal concludes with two formal demands requiring a written response from the Office of the Mayor within 14 business days of receipt:
- A definitive answer regarding the proposed settlement framework: Will the City of Henderson agree to participate in a settlement meeting structured around the foundational choice concerning the disposition of the 48 Zohar volumes? A simple “yes” or “no” is requested.
- A substantive explanation for the ongoing refusal to provide verification of the oaths of office for all CHPD personnel relevant to the incidents giving rise to this litigation. Continued silence on this fundamental question of lawful authority will be construed as a tacit admission that no such valid oaths exist or can be produced.
This decision rests with you, Mayor Bell. It is a moment that extends beyond legal tactics and touches upon your solemn duties as the city’s leader. Recalling the warnings of your former Police Chief and the aspirational promise of our Constitution’s Preamble, this choice will be a defining statement about the character, integrity, and future of the City of Henderson. The consequences, both legal and spiritual, will follow from the path you select.
Respectfully Submitted,
/s/ Ambassador Josiah Haltom Plaintiff, pro se Haltom Family Ministries 603 North Avenue, Henderson, TN
