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UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF FLORIDA
JACKSONVILLE DIVISION

SARA BLOOMBERG,

Plaintiff, Case No.: _________________

v.

JEREMIAH RAY BLOCKER, in his

personal and professional capacity as the
chair of St. Johns County Board of
County Commissioners, and as
Commissioner for District 4; and the ST.
JOHNS COUNTY BOARD OF
COUNTY COMMISSIONERS;

Defendants.

COMPLAINT FOR DECLARATORY JUDGMENT

INJUNCTIVE AND OTHER RELIEF

Plaintiff, SARA BLOOMBERG (hereinafter, the “Plaintiff’), by and through

the undersigned counsel and pursuant to 42 U.S.C. § 1983, the United States

Constitution, the Florida Constitution, and the Florida Government in the Sunshine

Law, Florida Statutes §§ 286.011 and 286.0114, sues Defendants, JEREMIAH RAY

BLOCKER, in his personal and professional capacity as Chair of the St. Johns County

Board of County Commissioners, and the ST. JOHNS COUNTY BOARD OF

COUNTY COMMISSIONERS, (hereinafter collectively, the “Defendants”), and

alleges:

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1. This action is brought to enforce federal and Florida state laws regarding

the Plaintiff’s rights and seeks declaratory and injunctive relief arising from the refusal

to allow the discussion of an agenda item in regards to the Lesbian, Gay, Bisexual,

Transgender, and Queer (hereinafter, “LGBTQ”) community (hereinafter, the

“LGBTQ community”) arising from a meeting on May 4, 2021 of the St. Johns

County Board of County Commissioners and Chairman Jeremiah Ray Blocker’s

unlawful violations of federal and Florida state law with respect thereof.

2. Plaintiff’s claims for relief are predicated, in part, on the First and

Fourteenth Amendments to the United States Constitution, 42 U.S.C. § 1983, and 42

U.S.C. § 1988, which authorizes injunctive relief and the award of attorneys’ fees and

costs to a prevailing plaintiff in actions brought pursuant to 42 U.S.C. 1983.

3. Plaintiffs also seek declaratory relief pursuant to 28 U.S.C. §§ 2201 and

2202. Plaintiffs seek preliminary and permanent injunctive relief pursuant to Rule 65,

Federal Rules of Civil Procedure.

4. This action is also brought to enforce Article I, Sections 2, 4, and 24, and

Article III, Section 4 of the Florida Constitution, as well as Florida’s Government in

the Sunshine Law, §§ 286.011 and 286.0114, Florida Statutes (hereinafter, the

“Sunshine Law”).

VENUE AND JURISDICTION

5. This Court has jurisdiction pursuant to 42 U.S.C. § 12101 et. seq. because

the instant case arises under federal law, specifically under 42 U.S.C. § 1983, and under

the First and Fourteenth Amendments to the United States Constitution.

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6. Also, this Court has subject matter jurisdiction pursuant to 28 C.S.C. §

1331 for civil actions arising under the laws of the United States; and for actions under

laws providing for the protection of civil rights as per 28 U.S.C. § 1343.

7. On this matter, the Court has supplemental jurisdiction over claims based

in Florida State Law as stated in 28 U.S.C. § 1367.

8. Venue is proper pursuant to 28 U.S.C. § 1391 (b)(2) as the Middle District

of Florida is the judicial district in which a substantial portion of the events or

omissions giving rise to the claims alleged herein occurred.

PARTIES

9. At all times material hereto, Plaintiff Sara Bloomberg was and is a citizen

of this St. Johns County who has standing to bring this action.

10. Defendant Jeremiah Ray Blocker (hereinafter, “Chairman Blocker” or

the “Chair”) was at all times material the Chair of the St. Johns County Board of

County Commissioners, as well as Commissioner for District 4.

11. Defendant St. Johns County Board of County Commissioners

(hereinafter, the “Board”) was at all times material the governing board of St. Johns

County, Florida.

FACTS COMMON TO ALL COUNTS

12. On or about March 8, 2021, the Plaintiff emailed St. Johns County

Commissioner Henry Dean regarding a proclamation celebrating, among other things,

celebrating LGTBQ civil rights progress and the contributions of LGBTQ individuals

to the St. Johns County community (hereinafter, the “LGBTQ Pride Proclamation”).
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13. About 30 minutes later Commissioner Henry Dean replied indicating his

support for the proposed proclamation and indicated that he would be broaching the

Chair and Administrator for the proclamation to be placed on the agenda for

consideration before the St. Johns County Board of County Commissioners.

14. Around the 28th of April 2021, the Plaintiff received a phone call from

the County stating that Chairman Blocker felt that the proclamation was too

“controversial” and “left leaning”, and that the proclamation would not come before

the Board for consideration.

15. Chairman Blocker holds beliefs antithetical to the fair and equal

protection of LGBTQ Americans and their rights and seeks to impose these beliefs

upon St. Johns County residents through his personal power as Chairman of the Board

of County Commissioners.

16. Further attempts by other individuals to convince Chairman Blocker to

at least discuss or bring the measure to a vote have been met with silence.

COUNT I: FREEDOM OF SPEECH

42 U.S.C. § 1983; First and Fourteenth Amendments of the United States
Constitution; and
Article I, Section 4 of the Florida Constitution

17. Plaintiff incorporates herein by reference paragraphs 1 through 17 above

as if fully set forth herein.

18. By refusing to even publicly hear or put to a vote the Plaintiff’s request

for the LGBTQ Pride Proclamation, and by specifically describing the reasoning

behind this decision was content-based (i.e., “controversial” and “left-leaning”) the

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Defendants, acting under color of state law, have deprived the Plaintiff of the rights to

freedom of speech in violation of the First Amendment to the United States

Constitution as incorporated by the Fourteenth Amendment, 42 U.S.C. § 1983, and

Article I, Section 4 of the Florida Constitution.

WHEREFORE, Plaintiff demands the following relief:

(1) A declaratory judgment that the Defendants violated the First and

Fourteenth Amendments of the United States Constitution, and Article

I, Section 4 of the Florida Constitution, by refusing to hear or allow a

public vote on the LGBTQ Pride Proclamation, based upon the content

and Chairman Blocker’s personal animus towards the LGBTQ

Community;

(2) Preliminary and permanent injunctions ordering Defendants to

immediately hold a public hearing on the issue of the LGBTQ Pride

Proclamation;

(3) Nominal monetary relief;

(4) An award of attorney’s fees and costs pursuant to 42 U.S.C. § 1988; and

(5) Such other relief as this Court deems just and proper.

COUNT II: EQUAL PROTECTION

42 U.S.C. § 1983; Fourteenth Amendment
of the United States Constitution; and
Article I, Section 2 of the Florida Constitution

19. Plaintiff incorporates herein by reference paragraphs 1 through 17 above

as if fully set forth herein.

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20. By refusing to even publicly hear or put to a vote the Plaintiff’s request

for the LGBTQ Pride Proclamation, and by specifically describing the reasoning

behind this decision was content-based (i.e., “controversial” and “left-leaning”) the

Defendants, acting under color of state law, have treated the Plaintiff differently from

all other similarly situated individuals or organizations because the Plaintiff is a

member of the LGBTQ Community and because Chairman Blocker disagrees with

the message and content of a pro-LGBTQ proclamation.

21. Notably, the United States Supreme Court, in Bostock v. Clayton

County, Georgia, 140 S. Ct. 1731 (2020), concluded that discrimination against the

LGBTQ Community is discrimination on the basis of sex. See also, Adams by &

through Kasper v. Sch. Bd. of St. Johns County, 968 F.3d 1286, 1310 (11th Cir. 2020).

WHEREFORE, Plaintiff demands the following relief:

(1) A declaratory judgment that the Defendants violated the Fourteenth

Amendment of the United States Constitution, and Article I, Section 2

of the Florida Constitution, by refusing to hear or allow a public vote on

the LGBTQ Pride Proclamation solely due to the fact that it was being

sought by and on behalf of the LGBTQ Community;

(2) Preliminary and permanent injunctions ordering Defendants to

immediately hold a public hearing on the issue of the LGBTQ Pride

Proclamation;

(3) Nominal monetary relief;

(4) An award of attorney’s fees and costs pursuant to 42 U.S.C. § 1988; and
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(5) Such other relief as this Court deems just and proper.

COUNT III: SUNSHINE LAW

Florida Statute § 286.011;
Article I, Section 24 and Article III, Section 4
of the Florida Constitution

22. Plaintiff incorporates herein by reference paragraphs 1 through 17 above

as if fully set forth herein.

23. The Florida State Constitution requires that all meetings at which public

business is to be transacted or discussed be open and noticed to the public, requiring,

where official acts are to be taken or at which public business of such body is to be

transacted or discussed, them to be open and noticed as provided in Article III, Section

4(6). Art. I, § 24(b), Fla. Const.

24. Furthermore, the Florida legislature has further implemented this

mandate through the Sunshine Law, which broadly requires all formal municipal

action to be taken at a public meeting, as follows:

All meetings of any board or commission of any state agency or

authority or of any agency or authority of any county, municipal
corporation, or political subdivision, except as otherwise provided
in the Constitution, including meetings with or attended by any
person elected to such board or commission, but who has not yet
taken office, at which official acts are to be taken are declared to
be public meetings open to the public at all times, and no
resolution, rule, or formal action shall be considered binding
except as taken or made at such meeting. The board or
commission must provide reasonable notice of all such meetings.

Fla. Stat. § 286.011(1).

25. The purpose of the Sunshine Law is the protection of the public’s right to

be present and to be heard during all phases of enactments by governmental boards

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and commissions, School Bd. 0f Duval Cty. v. Florida Publishing C0., 670 So.2d 99,

101 (Fla. lst DCA 1996), and “to prevent at non-public meetings the crystallization of

secret decisions to a point just short of ceremonial acceptance.” See, Monroe County v.

Pigeon Key Historical Park, Inc., 647 So.2d 857, 860 (Fla. 3d DCA 1994) (quoting, Town

0f Palm Beach v. Gradison, 296 So.2d 473 (F1a.1974)).

26. The Sunshine Law was enacted in the public interest to protect the public

from "closed door" politics. In addition, it should be construed so as to frustrate all

evasive devices. Board 0f Public Instr. Of Broward C0. v. Doran, 224 So.2d 693, 699

(Fla. 1969).

27. In Herrin v. City of Deltona, 121 So. 3d 1094, 1097 (Fla. 5th DCA 2013),

the court acknowledged the enactment of section 286.0114, Florida Statutes, stating

that the statute "specifically provides, with limited exceptions, that the public be

allowed a reasonable opportunity to be heard on a proposition before a board or

commission.”

28. The Office of the Florida Attorney general has even given very specific

guidance on this subject, stating:

Given that the Government in the Sunshine Law applies to all

meetings of a board or commission at which official acts are to be
taken, it would be advisable to adhere to the mandates of section
286.0114, Florida Statutes, when a board or commission is taking
official action on a proposition regardless of the formality of the
meeting.

2014 WL 4100151, at *2 (Fla.A.G. Apr. 25, 2014) (internal citations omitted).

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29. By making a decision to deny or even publicly hear or put to a vote the

Plaintiff’s request for the LGBTQ Pride Proclamation, the Defendants, acting under

color of state law, violated Florida Statute § 286.011(1), having made that decision

outside of any public meetings.

30. Furthermore, by communicating this decision through a phone call and

deliberately avoiding any “paper trail” of this unlawful decision, whether by transcript,

video recording, or minutes, the Defendants, acting under color of state law, violated

Florida Statute § 286.011(2), by failing to keep proper public records of official

decisions.

WHEREFORE, Plaintiff demands the following relief:

(1) A declaratory judgment that the Defendants violated Florida Statute §

286.011, and Article I, Section 24 and Article III, Section 4 of the Florida

Constitution by privately refusing to hear or allow a public vote on the

LGBTQ Pride Proclamation, by communicating this refusal privately

and without any public record or transcript;

(2) Preliminary and permanent injunctions ordering Defendants to

immediately hold a public hearing on the issue of the LGBTQ Pride

Proclamation, and enjoining the Defendants from further violations of

the Sunshine Law;

(3) Nominal monetary relief;

(4) An award of attorney’s fees and costs pursuant to § 286.011(4), Florida

Statutes; and
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(5) Such other relief as this Court deems just and proper.

COUNT IV: SUNSHINE LAW

Florida Statute § 286.0114; and Article I, Section 24
of the Florida Constitution

31. Plaintiff incorporates herein by reference paragraphs 1 through 17 and 24

through 29 above as if fully set forth herein.

32. Plaintiff seeks a declaration that the Defendants violated Art. I, § 24(b)

of the Florida Constitution and Florida Statute § 286.0114, by removing the proposed

proclamation from the Board agenda and refusing to allow members of the public, or

even other commissioners to discuss or vote on it.

33. Plaintiff seeks declaratory and injunctive relief to address the Defendants’

violation of Florida Statutes § 286.0114, which required the Committee to afford

members of the public a reasonable opportunity to be heard on the LGBTQ Pride

Proclamation before taking action on same.

34. Section 286.0114(2) requires that “[m]embers of the public shall be given

a reasonable opportunity to be heard on a proposition before a board or commission.”

WHEREFORE, Plaintiff demands the following relief:

(1) A declaratory judgment that the Defendants violated Florida Statute §

286.0114, and Article I, Section 24 of the Florida Constitution by

privately refusing the public a reasonable opportunity to be heard on the

issue of the LGBTQ Pride Proclamation;

(2) Preliminary and permanent injunctions ordering Defendants to

immediately hold a public hearing on the issue of the LGBTQ Pride

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Proclamation, and enjoining the Defendants from further violations of

the Sunshine Law;

(3) Nominal monetary relief;

(4) An award of attorney’s fees and costs pursuant to § 286.0114(7)(a),

Florida Statutes; and

(5) Such other relief as this Court deems just and proper.

COUNT V: VIOLATION OF ST. JOHNS COUNTY

BOARD OF COMMISSIONERS RULES
Rule 4.303

35. Plaintiff incorporates herein by reference paragraphs 1 through 17 above

as if fully set forth herein.

36. The Rules and Policies of the St. Johns County Board of County

Commissioners (Hereinafter, the “Rules”) vests governmental and legislative

authority of the county in the Board, consisting of a Chair, Vice-Chair and three

Commissioners.

37. The Rules provide for the chair to set a proposed agenda and provides

other policy mechanisms by which other commissioners can propose and add agenda

items with a majority vote of the Board.

38. According to Rule 4.303 of the Board’s Board Rules and Policies:

Changes to the Regular Agenda may be proposed by any

Commissioner, the County Administrator or the County
Attorney. Changes to the Regular Agenda must be approved by
majority vote.

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39. Essentially, if a commissioner wishes to have an item on the agenda, the

Board should take a vote and a majority vote in favor would add the proposed item to

the current meeting agenda.

40. While the Court should never usurp the discretionary decisions of elected

officials, it is certainly within the Court’s power to compel the Board to follow its own

ordinances and adopted procedures. This is especially true when a decision

purportedly within the scope of that discretionary authority violates or potentially runs

contrary to existing law.

41. Upon determining that the Defendants violated this section, the Court

should assess reasonable attorneys’ fees against the Defendants.

WHEREFORE, Plaintiff demands the following relief:

(1) A declaratory judgment that the Defendants violated Rule 4.303 of the

Board’s Board Rules and Policies by privately refusing to hear or allow a

public vote on the LGBTQ Pride Proclamation;

(2) Preliminary and permanent injunctions ordering Defendants to

immediately hold a public hearing on the issue of the LGBTQ Pride

Proclamation, compelling the Defendants to take an official vote as

prescribed by its bylaws where the majority passage would result in the

debate, public comment, and a vote on potential adoption, and enjoining

the Defendants from further violations of the Sunshine Law;

(3) Nominal monetary relief;

(4) An award of attorney’s fees and costs; and

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(5) Such other relief as this Court deems just and proper.

JURY DEMAND

Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff demands

trial by jury on all triable matters of the instant case.

Respectfully Submitted,

Dated: June 3, 2021

ROOK ELIZABETH RINGER, ESQ.
Florida Bar No. 1015698
LENTO LAW GROUP, P.A.
222 San Marco Ave., Ste. C
St. Augustine, FL 32084
904.602.9400 (Office)
904.299.5400 (Fax)
reringer@lentolawgroup.com
Attorney for Plaintiff

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JS 44 (Rev. 04/21) Document
CIVIL COVER1-1 SHEET
Filed 06/03/21 Page 1 of 1 PageID 14
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS
JEREMIAH RAY BLOCKER, ST. JOHNS COUNTY BOARD
SARA BLOOMBERG
OF COUNTY COMMISSIONERS
(b) County of Residence of First Listed Plaintiff St. Johns County of Residence of First Listed Defendant St. Johns
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)

Rook Elizabeth Ringer, Esq.

222 San Marco Ave., Ste. "C", St. Augustine, FL 32084
II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
1 U.S. Government 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4
of Business In This State

2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a 3 3 Foreign Nation 6 6

Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act
120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 376 Qui Tam (31 USC
130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 3729(a))
140 Negotiable Instrument Liability 367 Health Care/ INTELLECTUAL 400 State Reapportionment
150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 410 Antitrust
& Enforcement of Judgment Slander Personal Injury 820 Copyrights 430 Banks and Banking
151 Medicare Act 330 Federal Employers’ Product Liability 830 Patent 450 Commerce
152 Recovery of Defaulted Liability 368 Asbestos Personal 835 Patent - Abbreviated 460 Deportation
Student Loans 340 Marine Injury Product New Drug Application 470 Racketeer Influenced and
(Excludes Veterans) 345 Marine Product Liability 840 Trademark Corrupt Organizations
153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR 880 Defend Trade Secrets 480 Consumer Credit
of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud 710 Fair Labor Standards Act of 2016 (15 USC 1681 or 1692)
160 Stockholders’ Suits 355 Motor Vehicle 371 Truth in Lending Act 485 Telephone Consumer
190 Other Contract Product Liability 380 Other Personal 720 Labor/Management SOCIAL SECURITY Protection Act
195 Contract Product Liability 360 Other Personal Property Damage Relations 861 HIA (1395ff) 490 Cable/Sat TV
196 Franchise Injury 385 Property Damage 740 Railway Labor Act 862 Black Lung (923) 850 Securities/Commodities/
362 Personal Injury - Product Liability 751 Family and Medical 863 DIWC/DIWW (405(g)) Exchange
Medical Malpractice Leave Act 864 SSID Title XVI 890 Other Statutory Actions
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 790 Other Labor Litigation 865 RSI (405(g)) 891 Agricultural Acts
210 Land Condemnation 440 Other Civil Rights Habeas Corpus: 791 Employee Retirement 893 Environmental Matters
220 Foreclosure 441 Voting 463 Alien Detainee Income Security Act FEDERAL TAX SUITS 895 Freedom of Information
230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 870 Taxes (U.S. Plaintiff Act
240 Torts to Land 443 Housing/ Sentence or Defendant) 896 Arbitration
245 Tort Product Liability Accommodations 530 General 871 IRS—Third Party 899 Administrative Procedure
290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION 26 USC 7609 Act/Review or Appeal of
Employment Other: 462 Naturalization Application Agency Decision
446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration 950 Constitutionality of
Other 550 Civil Rights Actions State Statutes
448 Education 555 Prison Condition
560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
1 Original 2 Removed from 3 Remanded from 4 Reinstated or 5 Transferred from 6 Multidistrict 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
42 U.S.C. § 1983
VI. CAUSE OF ACTION Brief description of cause:
Denial of rights under First and Fourteenth Amendments, refusal to place LGBT proclamation on agenda
VII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND: Yes No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
Jun 3, 2021
FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE