Affidavit & Writ of Certiorari – Haltom – US Courts

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1. PLAINTIFF’S MOTION TO STRIKE COLOR OF LAW VIOLATIONS AND FOR RELIEF
   IN SUPPORT OF CONSTITUTIONAL RIGHTS AND RELIGIOUS FREEDOM
   TO THE HONORABLE JUDGE THOMAS ANDERSON AND JUDGE JON YORK:

   COMES NOW Plaintiff, Joshua HALTOM (Josiah), sui juris and ordained clergy,
   respectfully submitting this Motion to Strike Violations of Constitutional Rights under
   Color of Law (18 U.S.C. § 242) and for Equitable Relief. Plaintiff seeks redress for
   unlawful coercion, deprivation of freedom to travel, and infringement of religious liberty,
   by Defendants at CHPD.

   I. INTRODUCTION
   Plaintiff, an ordained clergy member acting under lawful ecclesiastical authority, asserts
   violations of:
   1. First Amendment (Free Exercise Clause and Church-State Separation);
   2. Fourteenth Amendment (Due Process and Equal Protection);
   3. 42 U.S.C. § 1983 (Deprivation of Rights under Color of Law);
   4. Uniform Commercial Code (UCC) §1-305 (Remedies to be Liberally Administered),
   1-306 (Waiver or Renuncitation of Claim or Right After Breach, & 1-308 (Right to
   Reserve Rights Without Prejudice);
   5. International Law (Universal Declaration of Human Rights, Article 13: Freedom of
   Movement).
   Defendants, through threats, extortionate demands, and misuse of state authority, have
   unlawfully conditioned Plaintiff’s freedom to travel on his purchasing overpriced state
   products, violating Plaintiff’s constitutional and spiritual autonomy.

   II. FACTUAL BACKGROUND
   1. Plaintiff has repeatedly provided COL Violation Warnings, Courtesy Notices, and
   now to US Courts, has given several sworn Affidavits, plus a Writ of Certiorari, all
   of which, detail Defendants’ coercive tactics and agenda.
   2. Defendants refuse to engage in good faith, any communication other than
   aggression, instead will persistently demand monetary payments and product
   purchases under threat of legal intimidation and retaliation.
   3. Plaintiff holds a valid Clergy ID and operates under Common and Ecclesiastical
   law, which Defendants blatantly disregard, imposing public-sector commercial
   mandates on a private, religiously guided life.

   III. LEGAL ARGUMENT
   A. Color of Law Violations (18 U.S.C. § 242, 42 U.S.C. § 1983)
   Defendants’ threats and financial demands under guise of state authority constitute
   unlawful coercion. Monroe v. Pape (1961) holds state actors liable for constitutional
   deprivations.
   B. Freedom of Travel
   The right to travel is a fundamental liberty under the Constitution (Saenz v. Roe, 1999).
   Defendants’ conditioning of this right on monetary compliance is indefensible.
   C. First Amendment Violations
   1. Free Exercise Clause: Defendants’ demands interfere with Plaintiff’s religious
   mission. Sherbert v. Verner (1963) requires strict scrutiny for state actions
   burdening religion.
   2. Church-State Separation: Defendants’ intrusion into Plaintiff’s private, religious
   sphere violates the Establishment Clause (Everson v. Bd. of Educ., 1947).
   D. Equal Protection (14th Amendment)
   The State of Tennessee presently provides accommodations for disability/mental
   health IDs (Tennessee Code Title 33). Plaintiff’s Clergy ID, a private religious identifier,
   merits an equivalent deference in this case. Disparate treatments lack a rational, secular
   basis.
   E. UCC § 1-308 Reservation of Rights
   Plaintiff’s explicit non-consent to the Defendants’ commercial impositions preserves all
   lawful rights under UCC to exonerate the forced transactions, ones which anyone could
   recognize as actual examples of fraud against the living.

   IV. REQUESTED RELIEF
   1. Strike All Color of Law Violations by Defendants as unconstitutional.
   2. Injunction prohibiting Defendants from enforcing coercive financial demands or
   restricting Plaintiff’s freedom to travel.
   3. Compensatory Damages for emotional distress, financial harm, and violation of
   rights under 42 U.S.C. § 1983.
   4. Declaratory Judgment affirming Plaintiff’s Clergy ID as valid under Common and
   Ecclesiastical Law, free from threats of hierarchical government interference or
   aggression.

   V. CONCLUSION
   CHPD and the State’s overreach into Plaintiff’s private, religious domain and coercive
   commercial demands are anathema to constitutional order. Plaintiff respectfully urges
   this Court to uphold the sacred divide between church and state, strike unlawful actions,
   and restore Plaintiff’s God-given and constitutional liberties. Plaintiff also will ask to be
   compensated 2.2 millions USD or the equal value of Pure Caimbrage Troy Silver.

   💭 Respectfully submitted, February 25, 2025 by
   -Joshua HALTOM (Josiah), sui juris
   Plaintiff, Pro Se

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