v. Case #: 1:24-cv-01215-JDB-jay
CITY OF HENDERSON POLICE DEPARTMENT. Defendant.
MOTION TO AMEND COMPLAINT
Plaintiff Joshua Haltom, by and through this Amended Complaint, pursuant to Federal Rule of Civil Procedure 15, hereby moves to amends his original complaint to more clearly state his claims against the Defendant, City of Henderson Police Department, and to provide additional factual allegations as required by applicable law and procedure.
I. PARTIES
Plaintiff JOSHUA HALTOM (also identified as Josiah), is an individual residing at 603 North Avenue, Henderson, TN 38340. Plaintiff is associated with Haltom Family Ministries of Henderson, TN. He identifies as a Certified Clergy and Ambassador for the Temple of Light & Life. Plaintiff states he is a Minister for the Temple of Light & Life and declares himself a legal living, breathing man operating under Divine Law and Will of God.
Defendant CITY OF HENDERSON POLICE DEPARTMENT is a municipal entity located in Henderson, Tennessee, and is the law enforcement agency responsible for policing within the City of Henderson, Tennessee. The case against the City of Henderson Tennessee Police Department was initiated in the Tennessee Western District Court on October 2, 2024.
II. JURISDICTION AND VENUE
This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. § 1331 (federal question jurisdiction) as this action arises under the Constitution and laws of the United States, specifically 42 U.S.C. § 1983. This Court also has jurisdiction pursuant to 28 U.S.C. § 1343, which grants district courts jurisdiction over civil rights actions.
Venue is proper in the Western District of Tennessee, Eastern Division, pursuant to 28 U.S.C. § 1391(b), as the events giving rise to the claims occurred within this judicial district, and the Defendant is located within this district.
III. FACTUAL ALLEGATIONS
Plaintiff claims authority derived from Universal Law, Common Law, and the divinely inspired Word of God, asserting non-commercial jurisdiction to assert his rights and remedies in this Court. He asserts his authority through the Universal Law, the Common Law of the land, evidenced through the divinely inspired Word of God.
Plaintiff provides notice of claims, supported by identification and evidence of law, including a declaration of inherent rights as a sentient being under Divine authority and common law.
On or about April 19, 2024, Plaintiff Joshua Haltom was subjected to an alleged unlawful traffic stop by officers of the Defendant, City of Henderson Police Department. This incident is cited as the flashpoint from which the broader legal claims emanate. A “Formal Demand for Relief and Damages Arising from Unlawful Traffic Stop and Civil Rights Violations on April 19, 2024” was filed on March 13, 2025. Also, it a third-previously annamed passenger, Jesse Lee Hess, was also witness to the alleged violations as a passenger in the vehicle with th Plaintiff that day.
During this unlawful traffic stop, and in subsequent interactions, Defendant, through its agents and officers, engaged in actions constituting coercion, extortion, and intimidation. These actions were carried out under the guise of color of law, aggressively violating Plaintiff’s rights.
These actions have led to the continued deprivation of Plaintiff’s rights as guaranteed by the Constitution of the United States, particularly his rights contained within the First Amendment. The First Amendment pertains to freedom of expression and religious liberties.
The Defendant’s actions appear to be part of a covert, for-profit scheme utilizing contrived devices in sleight of hand to undermine and manipulate the established lawful rights of individuals, including Plaintiff, thereby infringing upon Constitutionally protected freedoms. This alleged “engineered hurt” speaks to actions that may intentionally or systematically inflict harm, eroding trust and the social fabric essential for a healthy community. The call to “expose fraud” resonates with the imperative to challenge deceptions, misuses of authority, or betrayals of public trust.
Plaintiff has provided collected evidence against the Defendant probing deprivation of rights under color of law, including but not limited to: a “Judicial Conduct Letter”, “Traffic Court Observance” (x2), “Safety and Homeland Security” document, “The One People’s Public Trust” document, “Courtesy Notice”, “Call to Honorable Leadership”, “Email Cover”, “Affidavit Regarding proof of cause”, and a request to use “Video and media evidence”. This “collected evidence” was submitted on November 25, 2024.
Plaintiff emphasizes that the term “sovereign citizen” is a recognized misnomer and oxymoron under prevailing law. Its continued use by Defense Counsel is legally and factually inaccurate. Despite prior admonishments by the Court against using this derogatory and legally prejudicial term during proceedings in municipal courts in June-August 2020, where COL violation warnings were given for the multiple use of the aggressive phrase, “WE DO NOT CARE OF YOUR ID,” the Defense has persisted in employing this misleading and inflammatory label. This term improperly prejudices the Plaintiff, risks tainting proceedings, and violates principles of equity and justice.
Plaintiff’s position is rooted in theological and philosophical truths, as sovereignty, in ultimate terms, is ascribed solely to divine authority, not private individuals. This perspective is further detailed in Plaintiff’s filing titled “Structural Violence and Divine Law as ‘Eternal Evidence’ Under the Constitution,” filed on March 20, 2025.
The alleged unlawful traffic stop on April 19, 2024, is viewed by Plaintiff not as an isolated error but as a manifestation symptomatic of deeper, perhaps “engineered,” deficiencies or “fraudulent” practices within the system. This perspective transforms the lawsuit into a vehicle to “expose” these larger concerns.
The Defendant’s actions, and the alleged systemic issues, constitute an abuse of authority that shatters the public’s expectation that law enforcement will wield its power justly and lawfully, revealing a potential “fraud” in the implicit contract between the citizenry and its protectors.
IV. CLAIMS FOR RELIEF
COUNT I: Deprivation of Rights Under Color of Law (42 U.S.C. § 1983 – First Amendment)
Plaintiff incorporates by reference all preceding paragraphs as if fully set forth herein.
Defendant, acting under color of state law, deprived Plaintiff of his rights, privileges, and immunities secured by the First Amendment to the United States Constitution, specifically his freedom of expression and religious liberties, as well as those rights guaranteed by the Religious Freedom Restoration Act. The Religious Freedom Restoration Act is referenced in the Plaintiff’s identification card.
The unlawful traffic stop from August 2021 – April 19, 2024, to name a few, and the subsequent acts of coercion, extortion, and intimidation by Defendant’s officers, coupled with the continued improper use of derogatory terminology, constitute a direct infringement upon Plaintiff’s constitutionally protected rights and free exercise of beliefs.
These actions were taken by Defendant’s officers while acting in their official capacity and under the authority of the City of Henderson Police Department.
As a direct and proximate result of Defendant’s actions, Plaintiff has suffered and continues to suffer damages.
COUNT II: Municipal Liability (Monell Claim) Under 42 U.S.C. § 1983
Plaintiff incorporates by reference all preceding paragraphs as if fully set forth herein.
Defendant City of Henderson Police Department, officer’s Cox, Holloway, Heathcock, Davis, and the entire CHPD is, in fact, a municipal entity, is liable for the constitutional violations committed by its officers because these violations were a result of an official policy, custom, or practice, or a persistent and widespread practice tantamount to a custom, rather than isolated individual acts.
Specifically, Plaintiff alleges that the “for-profit scheme utilizing contrived devices” and the pattern of “engineered hurt” and “fraudulent practices” within the Defendant’s operations demonstrate a systemic issue beyond individual officer misconduct. This includes the alleged tolerance or encouragement of actions constituting coercion, extortion, and intimidation under color of law, and the failure to prevent the improper use of derogatory terminology despite prior warnings.
Plaintiff further alleges that the observations from “Traffic Court Observance” and the other submitted evidence will demonstrate a pattern of misconduct, inadequate training, flawed accountability mechanisms, or a departmental culture that tolerates or encourages overreach, which directly led to the deprivation of Plaintiff’s rights.
The specific incident of April 19, 2024, is not an isolated anomaly but is symptomatic of deeper, perhaps “engineered,” deficiencies or “fraudulent” practices, particularly with concern within the Defendant’s corrupted systems, what Plaintiff observes as thereby forming the basis for municipal liability under Monell v. Department of Social Services, 436 U.S. 658 (1978).
As a direct and proximate result of Defendant’s unconstitutional policies, customs, or practices, Plaintiff has suffered and continues to suffer both injustices and damages.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff Joshua Haltom respectfully prays that this Honorable Court:
a.) Order to overrule the ongoing color of law deprivation of his rights. b.) Recognize the necessity of reaffirming the freedom of expression under the First Amendment and the religious liberties assured under the Religious Freedom Restoration Act. c.) Allow proceedings that align with true justice and the restoration of his rights as protected by both the Constitution and Universal Law. d.) Call upon the advocacy of the Religious Liberty Task Force to ensure that the truth of this matter is upheld in the spirit of justice and equity. e.) Award Plaintiff full redress and damages according to the laws of the land and the principles established by Divine authority. f.) Grant such other and further relief as this Court deems just and proper.
By signing and presenting this document, we are certifying that it is not being presented for any improper purpose, that the claims are warranted by existing law or by a nonfrivolous argument for changing the law, and that the factual contentions have evidentiary support or will likely have evidentiary support after a reasonable opportunity for discovery.
Respectfully submitted,
Joshua Haltom (Josiah), pro se litigant ———- Henderson, TN [38340]
Email: haltom.family2020@gmail.com
Date: May 22, 2025
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