by Sondra Wilson. 1/31/2025. Updated 7/22/2026

Wilson v. Reliable Street Inc., et al. (Case No. LACV053674) is the civil-rights case that ultimately derailed my campaign and kept me off Iowa’s 2026 gubernatorial ballot. I requested an extension of the ballot-access deadline, but that request was denied. I am now appealing that decision in Wilson v. Pate, which you can follow here.

Wilson v. Reliable Street was filed in December 2023 to clear my name from false allegations and modified documents that were lodged into government records, in retaliation for my filing a discrimination complaint. The following two articles provide the background necessary to understand the present status of the case.

Article #1: Liberty and Justice for All? — This article provides the full background of the dispute: what happened before the lawsuit, why I filed a discrimination complaint, what was placed into the civil-rights record, and why I ultimately concluded that filing suit was necessary. It also examines how Iowa’s civil-rights process can harm the very people it is supposed to protect.

Article #2: Iowa's Broken Judiciary — This article provides the an unabridged procedural timeline of what happened after I filed suit, including the major filings, rulings, and procedural obstacles that led to the present stage of the case. It explains why I added an abuse of process claim and how procedural traps, harmful precedent, and an unaccountable court system can compound injustice rather than correct it.

This article begins where that fuller timeline leaves off. It focuses on the case’s current posture: the defendants’ argument that statements submitted to civil-rights investigators are absolutely privileged—even when allegedly false, altered, or deliberately misleading—and the court’s acceptance of that argument. That ruling has now placed this case, and potentially other Iowa civil-rights cases, at a critical turning point.

Current Status: A Condensed Filing Timeline

Note: Actual court filings are linked throughout this article, followed by their docket numbers—for example, “D0001” and “D0002.” This condensed timeline highlights the major filings and rulings necessary to understand the case’s current posture. For the complete procedural history leading to this point, see Iowa’s Broken Judiciary, linked above.

Dec. 5, 2023 — Original Petition Filed (D0001)

This initial petition commenced the action under Iowa’s notice-pleading standard. It identified the underlying events, the defendants allegedly involved, the principal injuries claimed, and the relief sought. Iowa Rule of Civil Procedure 1.403(1) requires a “short and plain statement of the claim” showing an entitlement to relief; it does not require the initial petition to contain every supporting fact, item of evidence, or fully developed legal theory.

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Feb. 29., 2024 — Defendants' Motion for a More Speicific Statement

Feb.–March 2024 — Defendants Challenge the Original Petition; Plaintiff Seeks Leave to Amend

The defendants responded to the original petition with motions seeking dismissal for failure to state a claim or, alternatively, an order requiring the petition to be recast or made more specific. They argued, among other things, that the petition did not clearly identify which claims applied to which defendants or plead sufficient facts supporting each cause of action.

In response, I resisted dismissal and sought permission to amend the petition. I explained that the amended pleading would provide more specific statements, clarify the claims challenged by the defendants, and reorganize the allegations into a more formal structure.

(Defendants’ motion to dismiss, recast, and require a more specific statement, [docket number]; Plaintiff’s resistance and motion to amend, [docket number].)

June 17, 2024 — I filed (Plaintiff's amended petition, D0020)

Dec. 26, 2025 — Judge Doyle set the trial date for August 4, 2026 (see order setting trial, D0074).

Mar. 2, 2026 — (see first set of discovery requests, D0091)

Apr. 26, 2026 — Defendants filed a motion for summary judgment, arguing that my libel claim should be dismissed immediately, and that there should be no trial. They argued that their statements to the Iowa Civil Rights Commission were protected by "absolute privilege" because the ICRC is a quasi‑judicial tribunal. , stating, “[Absolute privilege] applies regardless of whether the statement was false… or made with ill will.” They further argue that the ICRC is a quasi‑judicial tribunal, writing in the same filing that “The ICRC satisfies every criterion for a judicial proceeding… [and] is the hallmark of a quasi‑judicial proceeding.” Because of this, they insist that my discovery requests are irrelevant. As they put it: “No discovery… could change the legal character of the Iowa Civil Rights Commission proceeding.” (see motion for summary judgment, D0089).

The one defamation claim that moved forward should be dismissed immediately and without trial. In their Resistance, they again requested the court to grant the Motion for Summary Judgment they filed in April (D0089. 4/6/26) . The reasoning they gave is that they contend that their statements to the Iowa Civil Rights Commission were protected by "absolute privilege" even if knowingly false, stating, “[Absolute privilege] applies regardless of whether the statement was false… or made with ill will.” They further argue that the ICRC is a quasi‑judicial tribunal, writing in the same filing that “The ICRC satisfies every criterion for a judicial proceeding… [and] is the hallmark of a quasi‑judicial proceeding.” Because of this, they insist that my discovery requests are irrelevant. As they put it: “No discovery… could change the legal character of the Iowa Civil Rights Commission proceeding.”

June 24, 2026 — (see second set of discovery requests, D0107)

1.) Denied my motion for leave to amend (D0110) — In Iowa civil cases, a Motion for Leave to Amend is a request asking the judge for permission to change a pleading, such as a complaint, petition, or answer. Under Iowa law, "leave to amend... shall be freely given when justice so requires"

Exhibit A — Correspondence and Filings Before the Iowa Civil Rights Commission (ICRC)

Exhibit B — Open Mic and Flier Agreements and Related Communications

Exhibit C — Garden and Prairie Agreements and Related Communications

Exhibit D — Allegations of Stalking and Harassment: Statements v. Contemporaneous Communications

Exhibit E — Allegations Concerning Defendant Martinez and Contextual Communications

Exhibit F — Statement by Defendant Esker and Contradictory Prior Communications

Exhibit G — Litigation Conduct and Continuing Damages (2023-2026)

2.) Granted Defendants' motion for summary judgment (D0111) —

Although I was in the nearly finished drafting a memorandum which cited several cases I believe will prevent this case from setting a devastating and wholly unjust precedent,

However, I requested the trial to be set to a later date (D0107, 6/24/26) because:

1. Defendants have refused to comply with discovery requests. Evidence that is essential toward proving my allegations is being withheld by the defendants. I filed a Motion to Compel Discovery (D0091, 4/14/26). In other words, I am requesting the court to order the defendants to comply with my pretrial discovery requests. This is discussed in detail below.

2. On June 15, I filed a Motion for Leave to Amend and Revised Second Amended Petition (D0102, D0100). A motion for leave to amend is a formal request that the court allows you to amend your petition due to some improvement or clarification that makes it a more accurate, well-pled filing. If the court grants my motion, the Revised Second Amended Petition will become the operative pleading. Currently, the Amended Petition (D0020, 10/4/24) is the operative pleading, however, as noted by Judge Currie when she dismissed all of my claims except for defamation (10/4/24, D0036),

Sondra referenced several exhibits [that] are apparently saved in a Google Doc folder. The Court does not have access to the exhibits and does not consider them in addressing the motion to dismiss. See Rucker v. Taylor, 828 N.W.2d 595, 598 (Iowa 2013) (“[D]istrict courts generally do not consider facts outside the pleadings in evaluating a motion to dismiss.”).

I believe that several of my claims would not have been dismissed, had the court been able to view these exhibits. Also, after the ruling a legal professional indicated that my Amended Petition was not well-pleaded, and that if it were formatted as a more standard pleading, several of my claims would have likely moved forward. That is why I requested the court to allow the Revised Second Amended Pleading to become the operative pleadings (current petition recognized by the court as active). Right now they consider my previous petition "operative". Pursuant to Iowa Rule of Civil Procedure 1.402, courts grant these motions "freely... when justice so requires." I argue that justice requires the court to grant leave to amend.

My Motion for Leave to Amend, Revised Second Amended Petition, and Exhibits A-G are presented here, and then the defendants' arguments against allowing this case to move to trial are presented below.

We are currently awaiting a ruling on whether the court will grant leave to amend, or if instead they will side with the defendants, and grant summary judgment. That is explained below. Click the blue titles to view the filings.

Before we unpack the defendants' arguments about why this case should be dismissed immediately (without trial), let's clarify some backstory to help bring all this into context.

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Why the Iowa Civil Rights Commission is Central to This Case

In 2022, I filed a discrimination complaint with the Iowa Civil Rights Commission, the state agency responsible for receiving and reviewing civil-rights complaints. The defendants responded to that complaint by submitting statements and documents about me to the Commission.

I allege that those statements contained false, severely damaging accusations against me that are now lodged into government records. The primary reason i filed this lawsuit back in December 2023 was to prove those accusations are false, which I believe the above exhibits can prove.

Additionally, I allege that several or all of the defendants knew that materials they submitted alongside those statements were altered and/or presented in a misleading way in order to trick the ICRC investigator, while simultaneously creating political leverage over me.

The discovery requests I filed

central legal question now is whether the defendants can be held accountable for what they submitted—or whether everything they submitted is completely immune from liability because it was sent during a civil-rights proceeding.

Defendants' Arguments

Defendants filed a Resistance (D0104, 6/15/26), urging the court to deny my Motion for Leave to Amend, and arguing that:

1. My Amended Petition that was largely dismissed (except for one of my libel claims) ought to remain the operative pleadings,

The defendants are asking the court to prevent my revised claims from moving forward and to dismiss the one remaining defamation claim without a trial.

In their Defendants’ Resistance to Plaintiff’s Renewed Motion to Amend (D0104, June 15, 2026), they ask the court to deny my renewed request to amend the petition. They also ask the court to grant their pending motion for summary judgment, enter judgment in their favor on the remaining defamation claim, and dismiss the case entirely.

Their central argument appears in their Defendants’ Statement of Material Facts and Memorandum of Authorities in Support of Summary Judgment (D0090, April 6, 2026). They contend that statements submitted to the Iowa Civil Rights Commission are protected by absolute privilege because the Commission’s process qualifies as a judicial or quasi-judicial proceeding.

Absolute privilege is a legal protection that can prevent a person from recovering damages for statements made during certain official proceedings, even when those statements are alleged to be false or malicious. The defendants state:

“The absolute privilege is distinct from the qualified or conditional privilege: it applies regardless of whether the statement was false, regardless of whether it was made with ill will, and regardless of whether it caused serious harm.”

— Defendants’ Statement of Material Facts and Memorandum of Authorities in Support of Summary Judgment (D0090, April 6, 2026), p. 5.

The defendants argue that the Iowa Civil Rights Commission functions like a court for purposes of this doctrine. They write:

“The ICRC satisfies every criterion for a judicial proceeding.”

They further state that the Commission’s investigative and adjudicative structure is “the hallmark of a quasi-judicial proceeding.”

— Defendants’ Statement of Material Facts and Memorandum of Authorities in Support of Summary Judgment (D0090, April 6, 2026), p. 6.

Based on that argument, the defendants contend that the truth or falsity of their submissions—and their reasons for making them—would not affect the outcome. They state:

“The dispositive feature of the absolute privilege is that it bars recovery even if the plaintiff can prove the statements were false, made with actual malice, and caused serious harm.”

They therefore ask the court to grant summary judgment before further discovery takes place.

— Defendants’ Statement of Material Facts and Memorandum of Authorities in Support of Summary Judgment (D0090, April 6, 2026), p. 8.

The defendants repeat this position in their Defendants’ Reply in Support of Motion for Summary Judgment and Resistance to Motion to Compel (D0093, April 27, 2026). They argue that discovery into the authorship, drafting history, metadata, accuracy, or selective compilation of the documents would make no legal difference because, in their view, the privilege applies to the submissions automatically if the Commission proceeding was quasi-judicial.

They state:

“No discovery, no amendment of the pleading, and no characterization of Defendants’ internal document-preparation process can change the legal character of the Iowa Civil Rights Commission proceeding in which those statements were made.”

— Defendants’ Reply in Support of Motion for Summary Judgment and Resistance to Motion to Compel (D0093, April 27, 2026), p. 2.

And later:

“It does not turn on whether the submission was accurate or selectively compiled—the privilege protects inaccurate and even malicious statements in quasi-judicial proceedings.”

— Defendants’ Reply in Support of Motion for Summary Judgment and Resistance to Motion to Compel (D0093, April 27, 2026), p. 4.

Defendants’ Statement of Material Facts and Memorandum in Support (D0090),

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To make sense of all this, we need to back the story up, and explain how things got to this point. Why don't the defendants want to share discovery?

This Case Could Destroy Civil Rights Protections in Iowa

summary-judgment argument is that statements submitted during an Iowa Civil Rights Commission investigation are protected by absolute privilege, even when the person making the statements allegedly knew they were false.

They argue that this presents a question of law rather than fact. For that reason, they contend that the court does not need to determine:

1. Who actually wrote or edited the disputed documents.
2. Whether drafts or earlier versions exist.
3. Whether the documents were altered.
4. Whether relevant information was deliberately omitted.
5. What communications occurred while the documents were being prepared.

The defendants also argue that my discovery requests are irrelevant, burdensome, and harassing. In their Reply in Support of Summary Judgment and Resistance to Motion to Compel (D0094, 4/27/26), they state that no discovery concerning their internal document-preparation process could change whether their statements are legally privileged.

The defendants argue that the court should deny my Renewed Motion for Leave to Amend, and that my my previous Amended Petition (D0020, 6/17/24).

They contend that my Revised Second Amended Petition improperly attempts to revive claims the court dismissed in 2024. They therefore ask the court to:

Deny leave to amend.
Grant their Motion for Summary Judgment (D0089, 4/6/26).
Dismiss the entire case.

My Rebuttal

I contend that the court should not grant summary judgment before I have been allowed to obtain evidence directly relevant to the disputed documents.

My Motion to Compel (D0091, 4/14/26) asks the defendants to produce basic information concerning the preparation of the documents submitted to the Iowa Civil Rights Commission, including:

The identity of each person who wrote or edited the documents.
Drafts and earlier versions.
Native electronic files.
Metadata and revision histories.
Communications concerning the preparation and submission of the documents.

These requests are not based on speculation. The documents contain disputed statements, disputed chronology, apparent omissions, and information attributed to multiple defendants. The requested evidence may show who created the statements, how they changed, and whether the final submissions accurately reflected the underlying information.

The defendants are asking the court to rule that their statements are absolutely protected while simultaneously refusing to produce evidence showing how those statements were created.

I contend that this would allow a person responding to a civil-rights investigation to submit false or misleading information, prevent the opposing party from examining how it was produced, and then avoid accountability merely because the information was submitted to a government agency.

That is the dangerous precedent at the center of this case.

My Argument

The Four Petitions That Have Been Filed

Original Petition

Amended Petition

Second Amended Petition

Revised Second Amended Petition

Motion for Leave to Amend, Revised Amended Petition, and Exhibits A-G

(Proposed filings — not yet accepted by the Court)

What These Filings Are In January 2026, I filed a Second Amended Petition along with a Motion for Leave to Amend. The Court denied that request on April 22, 2026, ruling that the filing was too long, contained defects, and did not comply with Iowa’s pleading rules. The Court also clarified that the June 17, 2024 Amended Petition remains the operative pleading, and that all claims except written defamation (Libel II) remain dismissed with prejudice.

On June 25, 2026, I filed a Revised Second Amended Petition together with a Renewed Motion for Leave to Amend (D0102, D0100). This new filing was created specifically to cure the defects the Court identified in April.

What the Revised Petition Does The Revised Second Amended Petition:

- reorganizes the factual record chronologically,
- shortens the pleading from 115 pages to ~62,
- removes unverified citations,
- consolidates overlapping claims,
- incorporates Exhibits A–G directly into the factual narrative, and
- clarifies claims based on conduct occurring after the original petition was filed.

It presents a clearer, evidence‑supported account of the agreements, communications, administrative proceedings, and alleged misrepresentations from 2021–2026.

Why Amendment Is Being Requested The Court dismissed most of my claims in October 2024 because the exhibits referenced in my Amended Petition were not before the Court. The Revised Second Amended Petition corrects that problem by presenting the full factual record in an organized, properly supported format.

Under Iowa R. Civ. P. 1.402(4), courts “freely” grant leave to amend when justice requires. I contend that justice requires allowing the revised petition to become operative so the Court can evaluate the claims on a complete record rather than on the incomplete pleading filed in 2024.

Why These Filings Matter This entry helps readers understand:

- What was filed: a motion + a reorganized petition.
- Why it was filed: to correct defects and present the full factual record.
- What happened: the January version was denied; the June version was filed to comply with the Court’s instructions.
- What is pending: the Court must decide whether to accept the revised petition or, as Defendants request, deny amendment and instead grant summary judgment.

Operative Petition

Read: Plaintiff’s Reply Brief in Support of Renewed Motion for Leave to File Revised Second Amended Petition
Read: Plaintiff’s Reply in Support of Renewed Motion for Leave to File Revised Second Amended Petition

Although the court dismissed all but one of my claims in October 2024 (D0036, 10/4/24), I firmly disagree that claims ought to have been dismissed, and was prevented from being able to file a timely motion to reconsider following the court's ruling. Here's what happened: after the court's ruling, the defendants' counsel urged me to enter into settlement conferences. I agreed on the condition that deadlines for me to be able to respond to the Judge Currie's order would be extended. Defendants agreed, and we filed a joint motion requesting this (D0037, 10/9/24).

Following unsuccessful settlement conferences I am not supposed to discuss because the court considers them confidential, on December 2, 2025 Judge Currie extended deadlines to begin running on December 23 (D0041).

If the court accepts the argument Defendants have recently presented to the court, this case will set a dangerous precedent for all protected classes under the Iowa Civil Rights Act. This article presents my understanding of where the the case currently stands, what led up to this situation, and

It would allow

case could establish a dangerous precedent for civil-rights complainants in Iowa. The defendants argue that statements and materials submitted to the Iowa Civil Rights Commission are absolutely protected from liability, while also opposing discovery into how the disputed materials were created, edited, arranged, and submitted.

If the court accepts that position, respondents could potentially use false or manipulated materials to shape a civil-rights record, defeat a complaint, and then prevent meaningful scrutiny of what occurred.

The outcome will also profoundly affect my safety, financial stability, reputation, public work, and future. I am representing myself because I have been unable to find or afford counsel. I am urgently seeking an attorney or experienced legal professional who can represent me, provide limited-scope assistance, consult, review filings, or help with discovery and appellate strategy.

Anyone who may be able to assist or provide a qualified referral may contact me at Sondra.Wilson7777@gmail.com.

This article explains the live dispute in Wilson v. Reliable Street Inc., et al. Trial is currently scheduled for August 4, 2026. I have asked the court to continue the trial, extend discovery, and resolve the pending discovery (D0107) dispute because the defendants have not produced materials I requested that bear directly on key facts in the case.

This article presents my firsthand testimony, court filings, documents and communications in my possession which the court has not yet, and may or may not choose to accept, and my sincere understanding of what occurred, and where the case stands now. Some of the materials presented here have been filed with the court. Others were submitted as part of my proposed Revised Second Amended Petition (D0101) and accompanying exhibits, which the court has not yet accepted as the operative pleading. Additional materials I have requested through discovery have not been produced.

It is therefore possible that some of the evidence published in this article will never be formally admitted into evidence or considered by the court. If the court accepts the defendants’ position that the remaining claim should be dismissed as absolutely privileged before discovery is completed, the defendants may never be required to produce the drafts, native files, metadata, revision history, and communications that I believe would confirm key parts of this account.

This article is not written as a neutral report by an outside journalist. It is my firsthand testimony, supported by the documents currently available to me and presented so readers can examine them directly. The defendants dispute many of the facts described here, and the court has not entered a final judgment determining the truth of the parties’ competing accounts.

Several of my claims were previously dismissed. I believe they were wrongly dismissed before the court considered the complete exhibit-supported account, and I intend to seek appellate review if necessary. My renewed request to amend remains pending, so the court may never accept or rule on several of the claims and exhibits discussed in this article.

I cannot predict how the court will rule. I have encountered procedural barriers, highly technical rules, and legal doctrines that, in my experience, have repeatedly prevented the case from reaching the full facts of what happened. A court ruling may ultimately turn on pleading requirements, privilege, procedure, or other legal doctrines rather than a determination that the events described here did or did not occur.

That is one reason I am publishing the supporting materials directly. Regardless of which evidence the court ultimately accepts, readers can examine the available communications, filings, timelines, and exhibits and reach their own conclusions.

I believe many Iowans will agree that ordinary people should not lose access to justice because they cannot afford an attorney, cannot obtain evidence controlled by the opposing party, or fail to navigate rules so complex that the underlying facts are never meaningfully heard.

Dangerous precedent — The defendants have put forth a dangerous argument which, if the court accepts, would create a dangerous precedent. Thus, this case is bigger than me, and I suspect many other Iowans will want to know about it, and make sure that this case is not lost as a result of my inexperience. I need help, and thus far have been been unable to find (or afford) counsel. If anyone can help, please contact me at Sondra.Wilson7777@gmail.com.

Personal Safety — Defendants have already requested the court to assign their attorney's fees to me. If the court sides with the defendants' arguments and assigns approximately four years of attorney's fees to me, I would be required to pay tens of thousands of dollars to a group of people who used me for labor that I was not paid for, discriminated against me under false pretenses, and harmed my reputation, then lodged false, severely damaging accusations against me into government records. Although the Iowa Civil Rights Act explicitly prohibits retaliation, it doesn't define what the defendants did as retaliation within the Iowa Code, therefore the court might not interpret it that way. Regardless, if

The case Wilson v. Reliable Street Inc., et al. asks a dangerous question for civil rights in Iowa:

Can businesses submit false statements, misleading narratives, or altered documents to a civil‑rights investigator — have those materials shape official government records — and then avoid accountability by claiming those submissions are absolutely protected?

That is the issue now before the Iowa District Court for Story County.

Note: This article explains the live court dispute. For the longer article, which tells the backstory on how this case reached this point, read:

How Iowa's Civil Rights Process Harms The People It Was Designed to Protect:
An exposé on the Iowa Office of Civil Rights, Broken Judiciary, and What's Really Going on with the Reliable/Lockwood Case

How the case reached this point

How the case reached this point

I filed this lawsuit after the Iowa Civil Rights Commission ("ICRC") administratively closed my complaint and chose not to investigate. Their decision not to investigate was largely based upon their investigator's reliable upon statements and documents the defendants in this case submitted to them.

Although these documents were withheld from me by the ICRC from 2022 until late 2023, after being granted access to them I learned that:

Several respondents submitted statements they knew to be false and extremely damaging to my reptuation

These statements were bolstered, and made to appear true, because defendants submitted screenshots of texts messages between myself and some of the defendants, in such a manner that deliberately presented them out of order, or out-of-context, and place

Such st, these statements were bolstered, and made to appear true, based upon out-of-context statements screenshotted from conversations, and place out-of-order, after defendants submitted false statements, misleading narratives, and materially altered documents — designed to make those narratives appear true — to the ICRC investigator. The court has not adjudicated the facts I am about to share, and it is possible that the court will rule in a way that is unjust. I have already experienced that in this case, so am am not certain the court will rule justly in its final order.

Regardless of how the court rules, I intend to lay the evidence below so that readers can examine it themselves. I intend to show past rulings the court has made that, frankly, were unjust, and not in alignment with the law.

The original court ruling did not examine the full exhibit-supported record. Earlier in the case, the court noted that although I referenced exhibits, they were not attached in a way the court could review. As a result, the court ruled on the defendants’ motion to dismiss without seeing the communications, timelines, agreements, exclusions, agency submissions, and factual context now organized in my Revised Second Amended Petition.

All claims except one defamation claim were dismissed with prejudice. I intended to ask the court to reconsider that ruling. But after settlement conferences and repeated filings from the defendants, the deadlines became impossible to manage while I was attending Iowa State University full time and preparing for finals.

I asked the court to continue the case until after the semester. The defendants opposed that request, and the deadline was set immediately before finals. I never had a meaningful opportunity to file the motion to reconsider and ultimately had to drop two classes.

That procedural history matters because the defendants now argue that the earlier dismissal should permanently narrow the case, even though the court has still never examined the full exhibit-supported record.

My position is straightforward: the dismissed claims should not have been dismissed without the court seeing the evidence. My Revised Second Amended Petition now places that record before the court in organized form, with more than one hundred exhibits showing communications, timelines, agreements, exclusions, agency submissions, and factual context that were not previously examined.

The court has not yet accepted that Revised Second Amended Petition. My Motion for Leave to Amend is still pending. That means the underlying facts and exhibits have not yet been fully examined.

Meanwhile, the defendants are asking the court to keep the case narrowed to the single remaining defamation claim — and then dismiss that claim too.

Read: Defendants’
Read: Defendants’ Motion for Summary Judgment
Read: Defendants’ Statement of Facts and Memorandum in Support of Summary Judgment

I have also asked the court to resolve the pending motion for leave to amend before summary judgment, compel discovery, continue trial, and extend discovery so the case is not decided before the disputed documents and communications are produced.

Read: Plaintiff’s Resistance to Summary Judgment and Motion to Compel Discovery

The defendants oppose that discovery. They argue that absolute privilege makes the disputed facts irrelevant. In effect, they are asking the court to decide the case before I receive the drafts, metadata, native files, revision history, and communications that could show how the June 28, 2022 submission was created, edited, arranged, and used.

Read: Defendants’ Reply in Support of Summary Judgment and Resistance to Motion to Compel

That is the danger at the center of this case: if respondents can submit false or manipulated materials to a civil-rights agency, shape the government record, defeat the complaint, and then block discovery by claiming absolute privilege, civil-rights complainants are placed in a trap the law was never meant to create.

What the defendants argue

The defendants are not simply arguing that I am wrong. They argue that the court should end the last remaining claim before discovery because the statements they submitted to the Iowa Civil Rights Commission are protected by “absolute litigation privilege.”

In plain language: They claim that the statements and materials they submitted to the Civil Rights Commission — even if false, harmful, misleading, or damaging — cannot support a defamation claim.

They argue the privilege applies to judicial and “quasi‑judicial” proceedings, and that an Iowa Civil Rights Commission investigation qualifies. Under their theory, the privilege applies even if the statements were inaccurate, malicious, or damaging.

They also oppose my Motion to Compel Discovery. They are resisting production of draft versions, native files, metadata, revision history, and communications about preparing the June 28, 2022 submission.

So their position is not only that the case should be dismissed. Their position is that I should not receive the discovery needed to show how the disputed materials were created, edited, arranged, submitted, and used.

Why absolute privilege requires a closer, context-specific look

There is an important reason the defendants’ absolute-privilege argument should not automatically end this case.

In my reply brief, I cited Mills v. Denny, 245 Iowa 584, 588–89, 63 N.W.2d 222, 224–25 (1954), an Iowa Supreme Court case explaining that whether privilege is absolute or qualified depends on the occasion and circumstances involved. In other words, privilege should not be applied mechanically simply because a statement was connected to an official proceeding. The context matters.

That matters here because the defendants are not merely asking for protection for ordinary participation in a civil-rights investigation. They are asking the court to apply absolute privilege even where I allege that respondents created or relied on a false factual record, selectively compiled or altered documents, reversed chronology, omitted contrary communications, and caused the civil-rights agency to rely on a distorted record.

My argument is that this goes beyond protecting candid participation in an administrative process. It would turn a doctrine meant to protect truth-seeking into a shield for alleged corruption of the truth-seeking process itself.

I am not asking the court to punish someone simply for responding to an Iowa Civil Rights Commission complaint. I am asking the court to recognize that absolute privilege should not become categorical immunity for allegedly false, altered, misleading, selectively excerpted, or chronologically distorted submissions that defeat a civil-rights complaint before the complainant ever receives a fair chance to challenge the record.

Civil-rights law is supposed to protect people who report discrimination and retaliation. That protection becomes hollow if respondents can lodge false statements, misleading narratives, or altered documents into government records — and then claim those materials are absolutely immune from accountability.

That creates an implicit threat against every civil-rights complainant:

File a complaint, and the people you complained about may be able to place damaging accusations about you into official records — accusations that shape the investigation, deny you remedies, follow you into future proceedings, harm your reputation, and remain shielded from accountability because they were submitted inside the civil-rights process.

The Iowa Civil Rights Act was not designed to create an immunity zone where respondents can allegedly manipulate the administrative record, cause the complainant to lose civil-rights remedies, and then avoid discovery because the manipulation occurred inside the civil-rights process.

The Revised Second Amended Petition alleges that these materials were incorporated into administrative and judicial records, contributed to the denial of administrative remedies, harmed my reputation, and continue to create future risk because those records remain capable of being cited, relied upon, repeated, or republished.

So the issue is not simply whether I disagree with what the defendants said.

The issue is whether civil-rights respondents can use the government complaint process itself to distort the record, defeat the complaint, and then avoid discovery by invoking absolute privilege.

Why discovery matters

Discovery is the part of a lawsuit where parties must turn over documents, drafts, metadata, communications, and sworn answers. It is how courts determine what actually happened instead of relying only on one side’s description of events.

In this case, discovery matters because the dispute is not only about what the defendants said. It is also about how the documents and statements were prepared, edited, arranged, and submitted.

I filed a Motion to Compel Discovery because the defendants have refused to produce key materials, including:

draft versions
native files
metadata
revision history
communications about the June 28 submission

These materials could show who created the documents, how they were edited, whether communications were rearranged, whether screenshots or written materials were altered or selectively excerpted, and whether the final submission accurately reflected the underlying communications.

The defendants argue discovery is irrelevant because, in their view, the only question is whether the Civil Rights Commission process was “quasi‑judicial.” Under their theory, even deliberately false or manipulated submissions would be absolutely privileged.

That is why this case is so dangerous.

If the court accepts that argument before discovery, then the people accused of shaping the government record through false or manipulated materials may never have to produce the drafts, metadata, communications, or revision history that could show what happened.

Why this case matters beyond me

Civil-rights agencies exist to investigate discrimination and retaliation complaints and protect the public from unlawful discrimination. But if respondents can submit false or manipulated materials, have those materials shape official records, and then claim total immunity, the process becomes dangerous for the very people it was created to protect.

This spring — while finishing a full‑time semester and running an independent campaign for Governor of Iowa — I compiled and filed a Revised Second Amended Petition with more than one hundred exhibits. These exhibits show the communications, timelines, agreements, exclusions, agency submissions, and factual context that the court has never fully examined.

I am representing myself because I have not been able to obtain civil‑rights counsel. I am doing my best as a pro se litigant to keep my mouth above water in a case I cannot afford to lose — not only because of the continuing harm to my own reputation, safety, campaign, and future, but because of what this ruling could mean for minorities and civil‑rights complainants across Iowa.

The defendants argue that all claims except one were already dismissed with prejudice, and that the remaining libel claim should now be dismissed on summary judgment.

Summary judgment allows a court to end a claim without trial if there is no genuine factual dispute. But here, the missing facts concern the very documents and communications discovery is supposed to uncover.

The core question

So the question before the court is not only about me.

Will Iowa courts apply privilege in a careful, context-specific way that protects honest participation in civil-rights proceedings while allowing discovery into allegedly false, misleading, or altered submissions — or will respondents be able to shield those submissions from scrutiny by invoking absolute privilege?

If the defendants’ argument is accepted broadly, it could create a dangerous precedent: civil‑rights complainants could be harmed by official records shaped by manipulated materials, while the people who submitted those materials claim they cannot be held liable because the deception occurred inside the civil‑rights process.

This case urgently needs attention from civil‑rights lawyers, defamation lawyers, legal scholars, journalists, and Iowans who care about whether civil‑rights investigations can still be trusted.

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To understand how Iowa’s civil-rights process failed before this lawsuit became necessary, read:

Iowa Is Failing the People Civil Rights Law Was Meant to Protect.

References

Ballantine’s Law Dictionary Legal Assistant Edition
by Jack Ballantine (James Arthur 1871-1949). Doctored by Jack G. Handler, J.D. © 1994 Delmar by Thomson Learning. ISBN 0-8273-4874-6.

[1]: Motion for Summary Judgment, Black’s Law Dictionary 1842 (10th ed. 2014) (defining a motion for summary judgment as “[a] request that the court enter judgment without a trial because there is no genuine issue of material fact to be decided by a fact-finder—that is, because the evidence is legally insufficient to support a verdict in the nonmovant’s favor”).

[1]: See Discovery Abuse, Black’s Law Dictionary [page number] (10th ed. 2014) (defining discovery abuse as “[t]he failure to respond adequately to proper discovery requests”).

Additional Reliable/Lockwood Case Materials: Current Procedural Posture

The following documents provide additional context for where the Reliable/Lockwood case currently stands. Trial is presently scheduled for August 4, 2026, but multiple issues remain pending, including Defendants’ motion for summary judgment, my motion to compel discovery, my renewed request to file the Revised Second Amended Petition, and my request to continue trial and extend discovery.

I am including these materials because they show why the case remains active, why discovery matters, and why the litigation continued to impose major burdens during the ballot-access period.

Defendants’ Motion for Summary Judgment
Link to PDF: https://wildwillpower.org/wp-content/uploads/2026/06/4-6-26-DEF-Mot-for-Summary-Judgment-2.pdf
Defendants ask the court to enter summary judgment on the remaining libel claim, arguing that statements submitted to the Iowa Civil Rights Commission are protected by litigation privilege and that the claim should be dismissed as a matter of law.

Defendants’ Statement of Material Facts and Memorandum in Support of Summary Judgment
Link to PDF: https://wildwillpower.org/wp-content/uploads/2026/06/4-6-26-DEF-Facts-in-Support-of-Summary-Judgment.pdf
This filing sets out Defendants’ factual and legal arguments in support of summary judgment, including their position that the ICRC submissions were privileged, true, conditionally privileged, and not capable of supporting damages.

Plaintiff’s Resistance to Summary Judgment, Motion to Compel Discovery, and Motion to Clarify Operative Pleading
Link to PDF: https://wildwillpower.org/wp-content/uploads/2026/06/4-14-Mot-to-Compel.pdf
In this filing, I opposed summary judgment, asked the court to compel discovery, and requested clarification of the operative pleading. I argued that Defendants were seeking summary judgment while withholding discovery concerning authorship, alteration, metadata, communications, chronology, transmission, truth or falsity, republication, damages, and privilege.

Defendants’ Reply in Support of Summary Judgment and Resistance to Motion to Compel
Link to PDF: https://wildwillpower.org/wp-content/uploads/2026/06/4-27-26-Reply-in-Support-of-MSJ-and-Resistance-to-Compel.pdf
Defendants responded that further discovery was unnecessary because, in their view, the privilege issue is a legal question and the alleged publication occurred within the ICRC proceeding. They also resisted my motion to compel and argued that additional discovery would not change the legal character of the ICRC submissions.

Plaintiff’s Reply and Reply Brief in Support of Renewed Motion for Leave to File Revised Second Amended Petition
Link to Reply: https://wildwillpower.org/wp-content/uploads/2026/06/Plaintiffs-Reply-to-Resistance-to-Mot-to-Leave-to-Amend.pdf
Link to Reply Brief: https://wildwillpower.org/wp-content/uploads/2026/06/Plaintiffs-Reply-Brief-to-Resistance-to-Mot-to-Leave-to-Amend.pdf
These filings respond to Defendants’ resistance to my renewed request to file the Revised Second Amended Petition. I argued that the revised pleading was shorter, reorganized, exhibit-supported, responsive to the court’s April 22 order, and necessary to place the factual record before the court in a usable form before summary judgment or trial.

Plaintiff’s Motion to Continue Trial, Extend Discovery, Defer Summary Judgment, and Request Status Conference
Link to PDF: https://wildwillpower.org/wp-content/uploads/2026/06/Plaintiffs-Mot-to-Continue-Trial-and-Extend-Discovery.pdf
This filing asks the court to continue the August 4, 2026 trial date, extend discovery and pretrial deadlines, defer summary judgment until discovery is completed, and hold a status conference or enter a revised scheduling order. I argued that the case is not trial-ready while discovery, summary judgment, the operative pleading, and the motion to compel remain unresolved.

Wilson v. Reliable Street, et al.