UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. ____ Civ. Judge _______
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THOMAS JOHNSON; DERRICK ANDRE THOMAS;
ERIC ROBINSON; OMALI YESHITELA; ADAM
HERNANDEZ; KATHRYN WILLIAMS-CARPENTER;
JAU'DOHN HICKS; and JOHN HANES in their own COMPLAINT - CLASS ACTION
right and as representatives of all ex-felon citizens of
Florida,
Plaintiffs,
v.
JEB BUSH, Governor of Florida; KATHERINE
HARRIS, Secretary of State of Florida; ROBERT
BUTTERWORTH, ROBERT MILLIGAN, WILLIAM
NELSON, ROBERT CRAWFORD, and THOMAS
GALLAGHER in their roles as members of the Clemency
Board of Florida; BEVERLY HILL, Alachua County
Election Supervisor, JANE CARROLL, Broward County
Election Supervisor, PAM IORIO, Hillsborough County
Election Supervisor, DAVID C. LEAHY, Miami-Dade
County Election Supervisor, WILLIAM COWLES,
Orange County Election Supervisor, and DEBORAH
CLARK, Pinellas County Election Supervisor, in their
official capacities and as representatives of all county
supervisors of election in Florida,
Defendants.
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PRELIMINARY STATEMENT
1. This action is brought by Plaintiffs on behalf of all Florida citizens who
have been convicted of felonies and fully completed the periods of incarceration and/or
1
supervision to which they were sentenced ("ex-felons"), but nonetheless remain ineligible to
SNIPPETS:
THOMAS JOHNSON; DERRICK ANDRE THOMAS; ERIC ROBINSON; OMALI YESHITELA; ADAM HERNANDEZ; KATHRYN
JEB BUSH, Governor of Florida;
Secretary of State of Florida; ROBERT
NELSON, ROBERT CRAWFORD, and THOMAS GALLAGHER in their roles as members of the Clemency Board
Election Supervisor, JANE CARROLL, Broward County
Election Supervisor, PAM IORIO, Hillsborough County
CLARK, Pinellas County Election Supervisor, in their official capacities and as
This action is brought by Plaintiffs on behalf of all Florida citizens who
register or vote because a felony conviction results in permanent disenfranchisement under
The permanent disenfranchisement of felons in Florida was
ex-felons disenfranchised under these provisions
represented approximately 15% of the African-American male voting age population in Florida.
the right to vote, many ex-felons are denied restoration or are not eligible for restoration
provisions violate the First, Fourteenth, Fifteenth and Twenty-Fourth Amendments of the United
States Constitution, Sections 2 and 10 of the Voting Rights Act of 1965, codified at 42 U.S.C.
released in November 1992 without any period of supervision.
and has not had his rights restored, JOHNSON is ineligible to register and vote under Florida
In 1990, THOMAS was convicted of two felonies, one under federal law and one
ROBINSON applied for restoration of his civil rights in September 1999.
YESHITELA lives with his wife and two sons.
Plaintiff KATHRYN WILLIAMS-CARPENTER is a 44 year old African-American female who lives in
The Plaintiff class includes all ex-felons in Florida,
persons who have completed the periods of incarceration and/or supervision to which they were
the prohibition in Florida's laws on voting by convicted felons who have not had their civil
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