Part Three of the Wilson v. Reliable Street Inc., et al. series —
Political Sabotage:
The Concealed ICRC File Revealed a Reinforcing False Narrative and Modified Evidence
the Trial Court Never Examined — and That I Am Asking to Have Heard

By Sondra Wilson | Updated September 7, 2026

New to this case? This article is Part Three of an eight-part series and serves as the evidentiary hub for the series. For the current appellate status, why the case matters statewide, and a roadmap to the complete series, begin with the Wilson v. Reliable Street Inc., et al. landing page.

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If you use an AI system to analyze or summarize this article, check the “Updated” date shown above and make sure the system is analyzing the current version of the page. Cached or previously indexed versions may contain older wording, incomplete sections, or material that has since been corrected or reorganized.

 

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This Article is the Keystone Article of the Entire Series

Although this is chronologically Part Three of the eight-part series, it also serves as the series' evidentiary hub.

The other installments explain how the dispute arose, how I tried to obtain help, what happened procedurally in court, why the evidence was never fully examined, and what rulings I am now challenging.

This article is where those threads return to the underlying record.

Exhibits A through F bring together the administrative submissions, contemporaneous communications, agreements, documentary comparisons, and contradictions underlying the claims discussed throughout the series. As this reconstruction has developed, I have also used each exhibit section to identify what the evidence shows, what claims it supports, what remains unknown without discovery, and what I am asking the appellate courts to reopen.

Later installments therefore link back here rather than repeatedly reproducing the same evidentiary record.

 

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Table of Contents

 

Recap — Where We Are in the Series

I. What Changed When I Finally Saw the Complete ICRC File

II. How to Read the Evidence

III. Before the Evidence: Why These Are Court Exhibits

IV. The Evidence: The ICRC Narrative Compared With the Contemporaneous Record

V. Why the Record Functioned as Political Leverage — Regardless of Ultimate Motive

VI. What I Filed — How the Claims Developed Across Four Petitions

VII. What the Claims Mean — and How the Evidence Supports Them

VIII. How Procedural Irregularities Prejudiced My Rights and Prevented the Evidence From Reaching Ordinary Discovery and Factual Adjudication

IX. The Rulings I Am Challenging — Legal Error, Procedural Irregularity, Prejudice, and Dismissal With Prejudice

X. What I Am Asking the Iowa Supreme Court to Do

XI. Where the Case Goes Next

 

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Recap — Where We Are in the Series

 

Political Sabotage begins with two facts established in the first two installments of this series.

First, the contemporaneous record reconstructed in Record Retaliation shows months of friendship, collaboration, project approval, affection, delegated responsibility, and ongoing communication before my sudden removal from Reliable Street and Lockwood Café on March 31, 2022.

The later ICRC's Preliminary Case Review portrayed that same period through allegations that I was obsessive, stalking, harassing, intrusive, racist, controlling, acting without permission, and unwilling to respect boundaries.

Second, Iowa's Civil-Rights Trap shows what happened when I tried to challenge those accusations. I appealed, sought the underlying evidence, searched extensively for counsel, pursued EEOC review, contacted the Ombudsman, approached law enforcement and prosecutors, and eventually entered Iowa’s formal tort-claim process. None of those routes resolved the underlying factual dispute, and for more than a year I still could not see the respondents’ complete submissions.

On October 11, 2023, that changed.

I finally received the complete ICRC file.

Only fifty-five days remained before the December 5 filing deadline.

For the first time, I could place the respondents’ actual statements and supporting materials beside the messages, project records, photographs, agreements, and other contemporaneous evidence I had preserved.

The comparison escalated the severity of the threat.

I found approved work characterized as unauthorized or intrusive; serious accusations that had never been communicated to me while the supposed misconduct was occurring; accounts from multiple people that reinforced one another; out-of-context material; and a submitted document whose added date and caption appeared to change the chronology of a communication with Willa Colville.

Some contradictions can be evaluated directly from the documents themselves. Other questions—particularly disputed authorship or modification history, private communications, transmission pathways, allocation of responsibility, the full scope of coordination, and motives not otherwise established by a participant's own firsthand communications—require discovery or factual adjudication.

Part One showed what happened. Part Two showed what happened when I tried to obtain help. Part Three shows what was actually inside the file.

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I. What Changed When I Finally Saw the Complete ICRC File

Before October 11, 2023, I knew that serious accusations had been made against me because the ICRC’s Preliminary Case Review summarized them. I knew many of those accusations were false because I had lived the events. What I did not know was exactly what each respondent had submitted, what documents had been supplied to support those statements, how the different accounts related to one another, or whether the agency’s summaries accurately reflected the underlying materials.

The complete file changed that.

For the first time, I could compare the respondents’ statements in their own words against the contemporaneous communications reconstructed in Record Retaliation.

What emerged was not a single disagreement about one incident.

I found multiple accounts reinforcing a common portrayal of me as obsessive, intrusive, harassing, racist, controlling, and unwilling to respect boundaries. I found activities that the contemporaneous record showed had been requested, approved, or encouraged later characterized as unauthorized or invasive. I found private messages used to support allegations that appeared materially different when placed back into their original context.

And most significantly, I found a document associated with the stalking-and-harassment allegations whose submitted presentation differed from the original communication in a way that changed its apparent chronology.

That document is Exhibit D-3.

The complete file therefore did more than provide additional detail. It allowed me to see, for the first time, how the narrative summarized by the ICRC had been constructed and supported.

Some of what I found can be evaluated by simply placing two documents beside one another. The available record supports substantial inferences about coordination and deceptive presentation, while discovery remains necessary to identify authorship, trace communications, allocate knowledge among participants, and determine the full scope of the conduct.

Those unresolved questions are among the reasons discovery became so important.

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II. How to Read the Evidence

This article does not treat every evidentiary question the same way.

Throughout the sections that follow, I distinguish among four categories:

What the documents themselves establish. Some conflicts can be evaluated directly by comparing dated messages, submissions, screenshots, photographs, or other records.

What I know firsthand. I participated in these relationships, conversations, projects, and events. Where I describe something I personally said, did, saw, or experienced, I identify it as firsthand testimony.

What I conclude from the comparison. In some places, I explain what the combined record leads me to conclude. Those conclusions should be distinguished from the underlying documents themselves.

What remains unresolved. Questions involving private motive, undisclosed conversations, disputed authorship or modification history, the full scope of coordination, allocation of responsibility, and what a participant knew about matters outside that person's own firsthand involvement may require discovery or factual adjudication. Where a person's own communications or conduct establish what that person necessarily knew about events in which they personally participated, I treat that separately.

That distinction is especially important in an article titled Political Sabotage. The evidence can establish that a damaging record existed, how particular materials were presented, and what political leverage that record could carry. The more difficult question of why particular people created, transmitted, or relied upon particular materials must be evaluated separately.

The complete exhibits are linked throughout. I quote or reproduce the portions necessary to understand the comparison, but readers who want the full evidentiary context can examine the underlying exhibit directly.

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III. Before the Evidence:
Why These Are Court Exhibits

The Record Was Not One Accusation — It Was a Reinforcing Narrative

 

What I found did not look like a series of spontaneous remarks made independently in the heat of the moment.

The submissions were prepared over time, involved multiple people, incorporated selected supporting materials, and converged around a common portrayal of me as obsessive, intrusive, harassing, racist, controlling, and unwilling to respect boundaries.

In at least one instance, supporting material itself was submitted with a changed date and added caption that reversed the apparent chronology of an underlying communication.

Whatever the ultimate explanation for who knew what and when, the record reflected preparation—not merely an impulsive accusation.

The reinforcing narrative strongly indicates coordinated preparation, but the evidence also suggests that different participants may have possessed different knowledge, performed different functions, and acted from different motives.

To evaluate those questions responsibly, the evidence has to come first.

The exhibits below were not created merely for this article. They were organized as court exhibits for Wilson v. Reliable Street Inc., et al.

In 2026, I attached these materials to proposed amended pleadings as I attempted to place the reconstructed evidentiary record before the district court. Those proposed pleadings did not become operative, the case did not proceed through the discovery process I was seeking, and the factual comparisons contained in these exhibits were not adjudicated on their merits.

That procedural history is examined later in this series, particularly in Part Seven: Dangerous Precedent. For purposes of this article, readers should understand why the PDFs themselves are written in comparatively neutral, court-oriented language: they were prepared as litigation exhibits, not as advocacy graphics for this website.

The analysis accompanying them here explains what I understood the comparisons to show, what conclusions I drew from them, and what questions I expected discovery to clarify before trial.

I am publishing them now because the evidence remains legally relevant. I am preparing the appellate record in a case in which I am asking that dismissed claims be reinstated and returned for further proceedings. If the case is remanded, questions involving authenticity, authorship, transmission, knowledge, motive, and coordination may still be developed through discovery and factual adjudication.

My appellate position is that these claims should not have been permanently dismissed with prejudice before the central factual disputes were developed. The district court did not adjudicate the authenticity and meaning of the documentary comparisons presented here, and discovery into disputed authorship, knowledge, transmission, intent, and coordination did not occur.

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IV. "Exhibit A": 
The Administrative Record — Read the Respondents' Statements in Full

 

 

Examine Exhibit A: Correspondence and Filings Related to the Iowa Civil Rights Commission's  Preliminary Investigation

Exhibit A is the control record for everything that follows.

Before separating individual allegations into Exhibits B through F, I wanted the respondents' principal accounts preserved unabridged and in their original context. Readers should not have to rely upon excerpts selected by me to decide whether I am characterizing those statements fairly.

Exhibit A therefore preserves the administrative sequence itself: my April 12 request for mediation, my April 22 discrimination complaint, Stewart's and Nissen's complete statements to the ICRC, the agency's administrative closure and Preliminary Case Review, my appeal, and the later right-to-sue correspondence. The exhibit was expressly organized to preserve the administrative record and document the origin and procedural handling of representations later repeated in court.

That matters because Exhibits B through F are not substitutes for the respondents' statements. They are tests of them.

Exhibit A lets readers first see what Stewart and Nissen actually said, without my breaking their accounts apart. The later exhibits then isolate particular factual assertions and place them beside the dated messages, project records, screenshots, agreements, and other contemporaneous evidence necessary to evaluate them.

Nissen's statement is especially important to that structure. Exhibit A preserves it in full specifically for “establishing chronology, providing evidentiary context, and ensuring full transparency,” while the later thematic exhibits place particular portions beside the underlying record.

The result is a sequence readers can independently audit: first, what was said to the ICRC; then, what the contemporaneous records show; then, how related allegations were repeated or reinforced by other participants.

And that sequence begins with Nissen.

 

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V. "Exhibit B":
The Narrative Begins With Nissen

Examine Exhibit B: The Open Mic and Flier Agreement That Was Reframed as Unsolicited and Intrusive

Before the later allegations of racism, harassment, stalking, and unwanted intrusion appear, the administrative record begins with something more ordinary: a sympathetic management narrative explaining why increasingly unwanted behavior supposedly had to be stopped.

Nissen wrote from the position of president of Reliable Street and described herself as someone who had welcomed me into the community, appreciated helping people, and gradually became concerned as my involvement supposedly became excessive, unauthorized, and invasive.

That framing matters because it gives the later accusations a plausible foundation. If the reader accepts that I had already begun inserting myself into activities without permission, then later allegations of obsession, boundary violations, harassment, and stalking become easier to believe.

But Exhibit B contains contemporaneous communications showing that the Open Mic and flier activity used to establish that premise had actually been requested, reviewed, corrected, approved, publicly used, delegated, and repeatedly praised by Nissen herself.

The Contemporaneous Record in One Timeline

Readers do not have to take that conclusion on faith. Exhibit B preserves the sequence chronologically:

• September 21, 2021 — Exhibit B-2: I offered to create a flier for the Open Mic. Nissen responded “Awesome!” and discussed showing me how to run the event in her absence.
• September 29–30 — Exhibits B-3 and B-4: I sent Nissen the draft flier and asked for feedback. She responded positively and specifically directed me to change the event name from “Lockwood Café” to “Reliable Street.”
• October 4 — Exhibit B-5: Reliable Street's official Facebook page publicly posted the promotional flier I created.
• October 12 — Exhibit B-10: Nissen thanked me for “continuously affirming that we're gonna make this amazing” and said “it's so nice to have another person who believes.”
• October 13 — Exhibits B-6 and B-7: Nissen requested an additional design feature—pull tabs—and approved the revised flier, saying “It looks great!” The finalized flier incorporated her requested changes.
• October 22 — Exhibit B-8: I told Nissen I had distributed the fliers around Ames and given some to students. She responded “Awesome!”
• February 8–9, 2022 — Exhibits B-11 and B-12: Nissen entrusted Colville and me with responsibility for the Open Mic in her absence, thanked us for “always being so amazing and helpful!!!”, and the next day responded positively to suggestions I made for improving the event.
• March 22–23 — Exhibit B-13: nine days before my exclusion, I apologized for leaving an Open Mic before cleanup was complete. Nissen replied with three heart emojis.

That chronology is difficult to reconcile with the later portrayal of the same activity as unsolicited intrusion.

Read in isolation, Nissen's account sounds plausible.

She describes herself as someone who welcomed me into the community and appreciated helping others, but whose openness supposedly had unintended consequences as I became increasingly intrusive:

That is why the chronology above matters. The contemporaneous messages are not merely inconsistent with an incidental detail. They contradict the factual premise that my Open Mic and flier participation developed without authorization.

The issue is not merely that Nissen was once friendly to me. The records show operational conduct: she gave instructions, reviewed drafts, required changes, approved the finished work, publicly used it through Reliable Street, acknowledged its distribution after the fact, delegated responsibility for the event to me, and continued thanking me for my involvement through March 2022.

Those are materially different facts from a situation in which a community member repeatedly inserted herself into an event despite a manager's silence, reluctance, or objection.

The point is not simply that Nissen was friendly toward me. The documented conduct was operational: she reviewed and revised the work, used it publicly, acknowledged its distribution, delegated event responsibility, and continued encouraging my involvement. Exhibit B therefore establishes the first important comparison in this article: activity later described as unsolicited intrusion had been openly discussed, approved, and used at the time.

 

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VI. "Exhibit C":
Nissen Reframed the Garden and Prairie Agreements
as Unauthorized and "Obsessive" Conduct

Exhibit C: The Garden and Prairie Agreements and the Record Later Used to Recast Them as Unwanted Conduct

Exhibit B showed a relatively simple example of the pattern: work on the Open Mic and promotional flier that had been discussed, approved, corrected, publicly used, and encouraged was later portrayed as unsolicited intrusion.

Exhibit C is where that pattern becomes much more consequential.

The garden and prairie projects involved months of labor, planning, expenditures, coordination with volunteers and students, project-management responsibilities, and communications with multiple people connected to Reliable Street and Lockwood Café. Exhibit C was assembled specifically to document those activities and compare them with Nissen's later ICRC account.

Exhibit C focuses on the Garden and Prairie projects themselves. Martinez's involvement and later complaints are addressed separately in Exhibit E. Esker was not documented as a participant in either project; how Esker later came to describe project finances, fundraising, and SHEPH is addressed in Exhibit F.

What Nissen Later told the ICRC

In her ICRC statement, Nissen described me as becoming an almost-daily presence who began finding increasingly “unsolicited projects and responsibilities.” She said I repeatedly approached or “cornered” her about the garden; that the prairie proposal had not been properly coordinated with the other participants; that I began performing work without permission; that I was “obsessive”; that I pushed for more control; that I “bulldozed” other people with my ideas; and that “everything [I] did was of [my] own accord.”

That portrayal matters because it extends the foundation begun in Exhibit B.

The narrative is no longer simply that I made a flier nobody asked for. It becomes a broader account in which I supposedly attached myself to the property, invented responsibilities, failed to coordinate with others, assumed control, spent money on my own initiative, and became obsessive about projects that were never really mine to manage.

Exhibit C allows that portrayal to be tested against the contemporaneous record.

The Garden Record in One Timeline

Readers can verify the Garden Agreement through the sub-exhibits themselves:

• September 21, 2021 — Exhibit C-2: the messages document that Stewart had already approached me about the garden. When I raised that with Nissen, Nissen approved my involvement and expressed interest in my participation.
• October 27 — Exhibit C-3: I asked Nissen for clarification concerning the garden blueprints. She supplied project-specific information and thanked me, documenting active coordination rather than an unsolicited project being performed independently.
• October 31 — Exhibit C-4: I asked permission before removing site markers. Nissen authorized me to remove them and confirmed that they belonged to her.
• Fall 2021 — Exhibit C-5: I gave Nissen a progress update and expressly offered to stop sending updates if they were unwelcome. She responded positively and expressed gratitude.
• January 20, 2022 — Exhibit C-6: Nissen told a third party that I was “taking the lead on the community garden this upcoming season.”
• February 18 — Exhibit C-7: Nissen stated that the SHEPH president and I were “in charge of the garden this year.”
• March 4 — Exhibit C-8: Lockwood Café co-owner Austin Stewart contacted me regarding the 50% café discount associated with the garden arrangement and expressed appreciation for my work.

Those records describe more than casual permission to perform isolated volunteer tasks. They document an arrangement that developed over months: Stewart initially approached me, Nissen approved my participation, I sought permission and project instructions from her, she represented to third parties that I was taking the lead, later confirmed that I and SHEPH's president were “in charge” for the year, and Lockwood Café was honoring the discount associated with my work.

That is materially different from the later assertion that “everything [I] did was of [my] own accord.”

The Prairie Project Shows the Same Pattern

The prairie was a related but distinct project.

Exhibit C preserves the proposal itself and the communications surrounding its review and implementation. Colville reviewed the Prairie Proposal and responded:

“It looks great.”

The proposal was then sent to Nissen. Later, after I told Colville that Nissen had approved it, Colville responded:

“Let me know what all I can help with”

and offered to assist with measurements.

That record matters because Nissen later told the ICRC that the prairie had not been discussed with the other participants, that I needed to be told repeatedly to coordinate with everyone, and that I became “obsessive” about the project.

Again, the conflict is not merely between two people's impressions of my personality. It concerns objectively verifiable acts of review, approval, communication, coordination, and performance.

SHEPH Was Not a Group I Was Ignoring — We Coordinated Directly

Nissen's account also portrayed me as failing to listen to other participants and acting as though the garden belonged to me.

But Exhibit C contains an entire section documenting my collaboration with SHEPH, including communications with its president, garden blueprints prepared by the students, subsequent project communications, and the SHEPH president's reaction after learning that I had been barred from the property.

That is significant because Nissen's later narrative invoked SHEPH as one of the groups whose existing plans I supposedly failed to respect. The contemporaneous record instead documents me communicating and working directly with the organization whose participation I was supposedly disregarding.

Poag’s reaction after my exclusion also matters. Exhibit C-15 preserves the immediate response of SHEPH President Emily Poag after she learned that I had been barred from the property. According to the exhibit, Poag stated that neither she nor other SHEPH leaders had felt uncomfortable with me and that my expertise had been appreciated.

That response does not establish what every volunteer privately thought. But it is difficult to reconcile with Nissen’s broad portrayal that I had been “bulldozing” the very group I was supposedly failing to listen to. The surrounding SHEPH record documents sustained coordination: the students prepared blueprints and selected plants, while I assisted with research, organization, planting guidance, and coordination among the participating groups.

The Financial Narrative Also Looks Different in the Contemporaneous Record

The same problem appears in the later characterization of spending.

Exhibit C separately preserves the rain-barrel coordination, my request for Reliable Street's address so garden-related products purchased with my own money could be delivered there, the joint prairie-seed contributions, and the March communications concerning a meeting to sort through finances. The exhibit records that Nissen supplied the property address for those purchases only about six weeks before the March 31 exclusion, and that Colville and I each contributed $100 toward prairie seed.

That does not mean every expenditure was necessarily governed by precisely the same terms. It does mean the financial history cannot fairly be reduced to a story in which I independently began spending money on projects nobody had authorized and then unexpectedly demanded reimbursement.

And this becomes especially important when Exhibit F is reached: Esker later spoke confidently about spending, reimbursement, fundraising, and SHEPH even though Exhibit C expressly documents that Esker was not involved in the Garden or Prairie projects.

That is one of the places where the separate branches of the record begin to connect.

The Evidence Supported More Than One Legal Theory

The legal significance of Exhibit C also developed as I became able to reconstruct the record more fully.

My June 2024 operative amended petition pleaded promissory estoppel concerning the Garden and Prairie Agreements. Defendants responded that the claims should be dismissed because I had described myself as a volunteer, arguing that there was no sufficiently clear promise, no substantial detriment, and no basis for equitable enforcement.

Judge Currie ultimately dismissed both promissory-estoppel claims with prejudice.

But the court's own order acknowledged several important facts. It recognized that the Garden Agreement involved a promised 50% Lockwood Café discount, and that Nissen had stated that the SHEPH president and I were “in charge” of the garden through the 2022 growing season.

Promissory Estoppel Was About Reliance — Not Simply Whether I Received Additional Pay

There is another problem with how I understand the promissory-estoppel ruling.

The court itself identified the four Iowa elements:

“(1) a clear and definite promise; (2) the promise was made with the promisor's clear understanding that the promisee was seeking an assurance upon which the promisee could rely and without which [s]he would not act; (3) the promisee acted to h[er] substantial detriment in reasonable reliance on the promise; and (4) injustice can be avoided only by enforcement of the promise.”

The order then expressly acknowledged:

“Although promissory estoppel was previously viewed more narrowly as merely a substitute for consideration, more recent cases in Iowa have shifted to a broader emphasis on reliance.”

That distinction matters.

Defendants had urged dismissal partly because my work was volunteer work. Their motion argued that the claim should be dismissed “out of hand” because I had described myself as a volunteer and asserted that “equitable principles require dismissal of a promissory estoppel claim that is based on a ‘volunteer’ project.” They then repeatedly framed the absence of ongoing compensation as a reason the elements could not be satisfied.

Defendants made that theory explicit:

“Volunteering is, by definition, work that is not compensated.”

That proposition is true in the narrow sense that ordinary volunteer work is unpaid. But “unpaid” and “without value” are not the same proposition—and traditional bargained-for consideration is not one of the four elements of promissory estoppel identified in the court's own order. The elements the court listed concern a clear promise, anticipated reliance, substantial detrimental reliance, and whether injustice can be avoided only through enforcement. The order itself also acknowledged that Iowa law had shifted from viewing promissory estoppel narrowly as a substitute for consideration toward “a broader emphasis on reliance.”

I responded directly:

“my volunteer labor was performed only in accordance with the agreements which Defendants breached.”

And when defendants argued that no clear and definite promise of continuing compensation or an ongoing relationship had been alleged, I pointed the court to the two emails in which Nissen said that the SHEPH president and I were “in charge” of the garden throughout the 2022 growing season.

I also explained the reliance and detriment in concrete terms:

“I would not have performed the labor had I known the agreements would be prematurely breached.

Losing six months of labor is a loss!

[I]nstead of being able to add the results of my labor and volunteerism into my resume and portfolio, which would have added value to my life, instead I left the property ... with my reputation marred by horrendous and false allegations...”

Those were reliance allegations. They were not dependent upon showing that every hour of volunteer work had been promised an hourly wage.

Yet the dismissal repeatedly returned to compensation. For the prairie project, the court reasoned that Lockwood Café had offered “no further benefits or compensation” upon which I could reasonably rely. For the garden, it emphasized that I was an “unpaid volunteer” and reasoned that there was no promise that I would receive compensation if the project could not be completed.

The court later treated Nissen's statement that I and the SHEPH president were “in charge” through the growing season as a representation rather than a promise and characterized my volunteer relationship as terminable at will. It separately concluded that I suffered no detriment from relying on the café discount because I received that discount through March 31.

But that does not resolve the detriment I actually identified. My claimed reliance was not limited to receiving a café discount. It included devoting months of labor and planning to projects I understood I had been authorized to lead through the coming season, incurring expenditures, developing work intended to become part of my portfolio and community record, and building relationships and reputation through those projects.

That creates an appellate question I want reviewed: after recognizing that Iowa promissory estoppel places its modern emphasis on reliance rather than merely substituting for contractual consideration, could the court dismiss the claims with prejudice by focusing primarily on the absence of additional compensation—without examining the contemporaneous evidence of the promises, course of conduct, reliance, and resulting detriment?

Volunteer Work Can Create Value Even When It Is Unpaid

 

My July 30 resistance also explained why I did not regard “volunteer” as synonymous with “no valuable reliance.”

I told the court that volunteers:

“Gain experience and crucial insights which may be applied to future business and personal endeavors. This has value.

Can build portfolios which can be used to find jobs and/or start their own business. This has value.

After years of service, might become known, honored, and appreciated by the community at large. Your reputation precedes you. This has value.”

I then connected that directly to what happened here:

“Volunteers gain good reputations, and people who get kicked out of establishments due to ... accusations such as stalking and harassing gain bad reputations. It's that simple.”

The wording was informal because I was a self-represented litigant trying to explain the practical injury. But the point was concrete: unpaid community work can produce experience, portfolio value, relationships, reputation, and community standing. The fact that labor is volunteered does not mean that a person has nothing of value invested in the relationship or nothing to lose when the relationship is abruptly terminated under serious accusations.

In my case, the claimed detriment was particularly severe because the same projects that I expected to strengthen my portfolio and community reputation were later used to portray me as intrusive, controlling, unauthorized, and obsessive.

I relied on these projects partly because successful volunteer leadership had value. Then the same successful volunteer activity was retrospectively reframed into evidence of misconduct.

There is an even broader problem with allowing the word “volunteer” to do too much legal work: unpaid labor is not the same thing as valueless labor.

A volunteer makes real expenditures. At minimum, the volunteer contributes time, labor, physical or intellectual energy, and opportunity cost—resources that could otherwise have been devoted to employment, education, another project, family, community, or personal life. Depending upon the circumstances, a volunteer may also contribute money, supplies, transportation, professional skills, creative work, management, reputation, and relationships.

The organization receives the corresponding benefit without paying an ordinary wage.

Judge Currie's own October 4 order expressly recognized that fact:

“Reliable Street and Lockwood Café undoubtedly benefited from Sondra’s volunteering – working in the garden, setting up open mic nights, etc.”

Yet the order then characterized me as “merely a volunteer” and concluded that I had no right to expect payment when I was asked not to return.

To me, those are different questions. Whether I was legally entitled to an employee's wages is one question. Whether defendants received valuable benefits at my expense, whether I made those expenditures in reliance upon agreements, and whether the resulting circumstances support equitable recovery are separate questions.

The Same Value Question Affected My Unjust-Enrichment Claim

The value of the labor also mattered to my unjust-enrichment claim.

The elements argued in the case focused on whether defendants received a benefit, whether that enrichment occurred at my expense, and whether it would be unjust to permit retention of that benefit under the circumstances.

My position was straightforward: the businesses received improvements, labor, garden management, event support, promotional and creative work, and other benefits; I supplied the time, effort, skill, and some unreimbursed expenditures that produced them.

The fact that I agreed to provide labor without an hourly wage did not make that labor cease to be a benefit to the organizations or an expenditure by me. Voluntary describes the terms under which I supplied the labor; it does not answer whether the recipient received something of value.

In my July 2024 resistance, I specifically disputed defendants' reliance upon the voluntary nature of the work, explaining that I performed it “in accordance with our agreements” and that the $300 reimbursement did not cover all of my supplies and covered none of my labor.

In another filing, I relied upon the unjust-enrichment principle that:

“the critical inquiry is that the benefit received be at the expense of the plaintiff.”

My contention was that Reliable Street and Lockwood Café benefited from improvements and services produced through substantial expenditures of my own resources.

That raises another appellate question: does calling labor “volunteer” resolve an unjust-enrichment claim by itself, or must the analysis still consider the actual benefit received, the expenditures made by the volunteer, the arrangements under which the work was performed, and whether retention of the resulting benefit was unjust under the circumstances?

The Loss Was Not Merely the Loss of a Paycheck I Never Received

There was another side to the economic relationship: the value I reasonably expected the projects themselves to create for me.

Volunteer work can generate experience, completed portfolio work, references, leadership experience, professional relationships, community standing, and future opportunities. That prospective value was important to why I invested so much time into these projects.

My July 2024 filing expressly told the court that I expected the results of my labor and volunteerism to add value to my résumé and portfolio.

Instead, the relationship ended under serious accusations that damaged the very reputation and community standing the work had helped me build.

What I experienced was therefore not simply the termination of an unpaid activity. An investment of labor, time, trust, and opportunity became a loss of the expected benefits of that investment—while the manner in which the relationship ended also damaged my reputation and community standing.

Not every one of those consequences necessarily qualifies as recoverable damages under every cause of action. But treating the underlying relationship as economically meaningless because no conventional wage was paid fails to account for what both sides actually invested in and received from it.

The Court Ruled Without Examining the Garden and Prairie Exhibits

The court nevertheless held that the prairie approval was not a sufficiently clear promise and treated Nissen’s statement that the SHEPH president and I were “in charge” of the garden as a representation rather than a promise. It also concluded that the 50% café discount had not itself been breached because I received it through March 31.

Those conclusions were reached without examining the contemporaneous Garden and Prairie exhibits presented in this article. The October 4 order expressly stated:

“The Court does not have access to the exhibits and does not consider them in addressing the motion to dismiss.”

The procedural path that led to that result—including the court’s earlier directions concerning evidence, my reliance on those directions, defendants’ later objection, and the August 9 order withdrawing the evidentiary component—is reconstructed filing-by-filing in Sudden Reversal.

For Exhibit C, the important point is narrower: these records were not created years later to repair a failed claim. I had already identified and organized the underlying communications in 2024. What changed later was my effort to place the exhibits directly inside proposed amended pleadings so they could not again be treated as material outside the pleading.

 

The Court Used a Derecho Hypothetical to Reject the Reliance I Alleged

The October 4 order did not merely conclude that I had failed to allege sufficient reliance. It tested the Garden Agreement against hypothetical events that never occurred.

After acknowledging that my claim relied upon Nissen's statement that Emily Poag and I were “in charge” of the garden throughout the 2022 growing season, Judge Currie wrote:

“There was no clear and definite promise that if the project were not completed for any reason, Sondra would be entitled to any compensation. For example, if a derecho had taken out the garden, Sondra would not have completed the 2022 growing season and Sondra would not have been entitled to any particular financial benefit in exchange for her volunteer work to that point.”

The order then supplied another hypothetical:

“Similarly, if Emily moved out of state or dropped out of SHEPH to focus on schoolwork or other activities, Emily would no longer be ‘in charge’ of the project contrary to Lyndsay’s statement.”

Judge Currie then characterized Nissen's actual statement this way:

“Lyndsay’s message that Sondra and Emily were ‘in charge’ during the 2022 growing season merely conveyed her impression or understanding of a certain fact…”

and concluded:

“The statement was a representation, not a promise that Lyndsay forbear from taking action on employee complaints or that Sondra and Emily would be ‘in charge’ regardless of any other issues that could arise.”

That reasoning is important because neither hypothetical describes what I alleged happened.

The garden was not destroyed by weather. Poag did not leave SHEPH. And my promissory-estoppel claim was not that being “in charge” made me permanently immune from every possible future circumstance.

My claim concerned defendants' own conduct: whether their representations, authorizations, course of dealing, and acceptance of my performance induced substantial reliance, and whether the manner in which they later terminated those arrangements created the kind of injustice promissory estoppel is intended to address.

The order itself had just stated that Iowa's modern promissory-estoppel cases place a “broader emphasis on reliance” and identified substantial detrimental reliance and avoidance of injustice as elements of the claim.

The appellate question is therefore whether hypothetical events outside the parties' control answered the reliance claim actually alleged—or whether the parties' own promises, conduct, reliance, and termination of the arrangements required factual development before the claim was permanently dismissed.

The Later Proposed Amendments Were Designed to Put the Exhibits Inside the Pleading

My later proposed amended petitions served two related purposes.

First, they attempted to correct the procedural problem created when the court declined to consider the documentary record referenced in the June 2024 petition. My January 2026 Motion for Leave expressly stated that I was seeking amendment “to attach and incorporate documentary exhibits previously referenced but not before the Court.” It explained that the October 4 dismissal had occurred without the court reviewing the contemporaneous communications and administrative records underlying several claims.

The motion therefore proposed to cure that problem by attaching and incorporating Exhibits A–G, pleading the supporting facts more directly, and organizing the documentary evidence so the court could evaluate the claims together with the records on which they depended.

Second, the later pleadings refined the legal characterization of the same underlying transactions. The June 2026 Revised Second Amended Petition alleged that the Open Mic, Garden, and Prairie arrangements arose from the parties’ communications, mutual assent, course of conduct, authorizations, and performance, and incorporated Exhibits A–G directly into the pleading. The pleading expressly stated that the exhibits were attached and incorporated by reference and were organized to help the court evaluate the factual disputes underlying each count.

In other words, the later petitions did not create the Garden and Prairie evidence. They attempted to solve the problem that had arisen in 2024: the evidence existed and had been identified, but the court dismissed the claims without considering it. The later pleadings placed that evidence directly inside the proposed pleading while also stating the legal theories with greater precision.

Unjust Enrichment Was Also Dismissed on the "Volunteer" Characterization

These are separate legal questions. Whether I was entitled to an employee's wage is not the same question as whether I detrimentally relied upon project commitments, whether defendants received valuable benefits at my expense, or whether equitable relief was available under the circumstances.

The same facts therefore also supported my unjust-enrichment claim.

In my August 12 filing, I objected to defendants' characterization of that claim as requiring proof that they had gained increased business earnings or rental income. I quoted the principle that:

“the critical inquiry is that the benefit received be at the expense of the plaintiff.”

I then stated:

“Defendants were enriched at my expense, as both businesses, and thus both owners, benefited from improvements made to the property at my expense.”

That was a different theory from demanding wages for volunteer work. It concerned whether defendants retained benefits produced through my labor, planning, expenditures, project development, and property improvements under circumstances in which equitable restitution was warranted.

Judge Currie's order itself recognized significant portions of that premise. The court acknowledged that my labor had been performed at my expense, noted that the time could otherwise have been devoted to other work, and recognized that a garden and native-prairie restoration can have value. It assumed, without deciding, that Reliable Street and Lockwood Café had received a benefit.

The claim was nevertheless dismissed because the court concluded that justice did not require compensation where I had volunteered and that there was no agreement requiring additional remuneration if the projects were not completed.

The question I am asking on appeal is therefore not whether every volunteer becomes entitled to wages. It is whether the word “volunteer” could dispose of an unjust-enrichment claim without fully examining the actual benefits received, the resources I contributed, the arrangements under which the work was performed, and whether retaining those benefits without restitution was unjust under the circumstances.

The Deeper Problem:
Authorized Work Was Later Used as Evidence Against Me

The contractual questions are important, but Exhibit C matters to the broader case for another reason.

Nissen's later ICRC statement did not merely deny that I was owed compensation.

It transformed the nature of the work itself.

Activities documented contemporaneously as approved, coordinated, delegated, and appreciated became evidence that I was intrusive, controlling, “obsessive,” unwilling to listen, and assuming responsibilities nobody had given me.

My 2026 proposed pleading eventually articulated that distinction directly: the challenged statements were misleading not merely because particular assertions were false, but because they recharacterized conduct the defendants had previously authorized, encouraged, approved, coordinated, documented, or benefited from.

That is the bridge from Exhibit C into the rest of Political Sabotage.

The garden and prairie narrative did not remain a disagreement over volunteer work. It became part of the evidentiary foundation for portraying me as a person who ignored boundaries, took control without permission, and behaved obsessively.

And that portrayal is reinforced again in later exhibits.

Discovery Questions Raised by Exhibit C

1. What exactly did Stewart offer me when she initially approached me about managing or restoring the garden, and on whose behalf was she acting?

2. What did Nissen understand my role to be when she said I was “taking the lead on the community garden this upcoming season”?

3. What did Nissen mean when she later stated that the SHEPH president and I were “in charge of the garden this year”?

4. What authority did Nissen and Stewart have to create, approve, modify, or terminate the Garden Agreement on behalf of Reliable Street, Lockwood Café, and/or Love Club LLC?

5. What was the full consideration or expected exchange associated with the Garden Agreement, including the café discount, project opportunities, management responsibility, expenditures, and labor?

6. What communications occurred internally concerning my garden role before March 31, and when—if ever—did anyone internally characterize my work as unauthorized or unwanted before the exclusion?

7. Did any contemporaneous employee, volunteer, SHEPH participant, or other project participant complain that I was improperly taking control or refusing to coordinate? If so, what exactly was said and when?

8. Who approved the Prairie Proposal, what authority accompanied that approval, and what implementation activities were expected after approval?

9. What communications occurred among Nissen, Stewart, Colville, SHEPH participants, and others concerning implementation of the prairie project?

10. Which expenditures were expressly authorized, implicitly approved through course of conduct, independently donated, jointly funded, or later reimbursed?

11. What benefits did Reliable Street, Lockwood Café, Love Club LLC, Nissen, and Stewart actually retain from the labor, planning, improvements, coordination, and expenditures documented in Exhibit C?

12. When and why did the defendants' description of this work change from leadership, coordination, approval, and gratitude to unsolicited, unauthorized, controlling, and “obsessive” conduct?

13. What information about the Garden and Prairie projects was later communicated to Esker, who was not involved in either project, before Esker prepared a statement describing my spending, reimbursement expectations, fundraising, and interactions with SHEPH?

14. Were Nissen's later ICRC descriptions based on contemporaneous concerns that can be documented, or were those characterizations developed retrospectively after I filed the discrimination complaint?

Why I Am Asking That the Garden and Prairie Claims Be Reopened

Exhibit C does not ask an appellate court to decide every disputed contractual issue from a website article. It shows why I am asking that these claims not remain permanently barred without factual development.

The contemporaneous record documents months of authorization, coordination, leadership representations, performance, expenditures, third-party involvement, accepted benefits, and a written prairie proposal reviewed by multiple participants. The 2024 ruling nevertheless treated the relationship primarily as terminable volunteer activity and dismissed the promissory-estoppel and unjust-enrichment claims with prejudice before discovery occurred. Later proposed amendments attempted to place the contemporaneous exhibits directly before the court as incorporated parts of the pleading, while also stating the legal theories arising from those same transactions with greater precision.

My appellate position is that the factual record underlying the Garden and Prairie Agreements should be returned for further proceedings so that the parties' actual agreements, authority, course of conduct, reliance, retained benefits, and resulting damages can be developed rather than permanently resolved from an incomplete pleading-stage record.

The court did not examine Exhibit C when it dismissed these claims. As explained in Sudden Reversal, the October 4 order expressly states that the court did not have access to the exhibits and did not consider them when deciding the motion to dismiss.

 

 

One Detail from Exhibit C Will Matter Later

There is one feature of Nissen’s account worth carrying forward.

She did not describe the garden disagreement merely as poor coordination or excessive enthusiasm. She repeatedly used language suggesting unwanted persistence and intrusion: I was allegedly an “almost daily presence,” around “constantly,” finding “unsolicited projects and responsibilities,” “continuously cornering” her about the garden, becoming “obsessive,” pushing for more control, “bulldozing” others, and “over communicating.”

For now, the important point is that this language was being applied to conduct that Exhibits B and C document very differently: through requests, permissions, delegated responsibilities, collaboration, project approval, and continuing encouragement.

I am asking readers to remember those words—particularly “constantly,” “cornering,” and “obsessive.” They will matter again when this article reaches the most serious allegations in the administrative record.

 

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VII. "Exhibit E"
A Different Allegation Enters the Record — Racism and Anti-LGBT+ Conduct

View Exhibit E: Out-of-Context Messages With Denise Martinez Used to Support Allegations of Racism and Anti-LGBT+ Conduct

Exhibits B and C concern a pattern I can test substantially through my own contemporaneous records: activities later described as intrusive or unauthorized despite documentation of approval, coordination, and encouragement.

Exhibit E adds something qualitatively different.

The narrative was no longer only that I was overinvolved, controlling, or difficult to work with. Materials attributed to Denise Martinez introduced allegations that I had made racist and anti-LGBT+ statements.

Those allegations created a different evidentiary problem because the relevant pre-exclusion conversations occurred privately, outside my presence, while the later written submission was transmitted through Stewart. I therefore knew what I had and had not said, but I did not possess the private communications necessary to reconstruct authorship, transmission, or how the allegations moved among participants.

Exhibit E concerns a separate branch of the narrative built against me: allegations that I had made racist and anti-LGBT+ statements to Denise Martinez.

Stewart transmitted to the ICRC a statement and screenshot that she represented as having been prepared by Martinez. On its face, the material appears to originate with Martinez before being transmitted through Stewart and Lockwood Café. But because I never obtained the native file, metadata, drafting history, or communications surrounding its transmission, I cannot responsibly state that the version submitted to the ICRC was identical to whatever Martinez originally prepared, or that it had not been edited, rearranged, excerpted, or otherwise modified before submission.

That is not uncertainty about whether I made the conduct alleged against me. I know I did not. It is uncertainty about authorship, transmission, and document history—facts that were outside my possession and required discovery.

My June 17, 2024 amended petition (D0020) already identified this evidentiary problem. Under my first defamation claim, I alleged:

“According to Sharon Stewart's statement to ICRC, in February and March 2022, Defendants Denise Martinez and Willa Colville, then employees of Lockwood Cafe, allegedly submitted defamatory statements against me to Sharon Stewart, and then to Lyndsay Nissen.”

Amended Petition, ¶ 72, p. 32.

Later in the same pleading, under the individual-defendant allegations, I addressed Martinez specifically. I stated that Martinez and I had maintained an amicable relationship, referenced Exhibit Q2, and alleged that the statement attributed to her contained accusations of racism and anti-LGBT+ bigotry alongside private messages taken out of context.

The allegations themselves were concrete. The statement attributed to Martinez said, among other things, that I repeatedly challenged her ethnic identity and told her she could not truly be bisexual because she was in a heterosexual-presenting relationship.

I expressly denied the latter allegation in the pleading:

“I have never stated this to Denise or anyone, nor do I believe it or ever believed it.”

Amended Petition, p. 51, n.29.

The same footnote pointed the court toward communications in Q2 showing that I had invited Martinez to an LGBT+ server and, when she asked whether being bisexual “counts,” responded: “That counts. That's what the B is for!”

The petition also explained the context of the ethnicity accusation. I stated that Martinez had previously discussed the same food subject with me amicably, including telling me,

“I will get you some when I go to the Mexican store <3,”

before a portion of that exchange was later presented alongside accusations of racism.

And when I summarized the fraud allegations later in the same pleading, I expressly identified the evidentiary combination as:

“A falsified document (Q5), out-of-context statements of mine accompanied by libelous testimony (Q2), and numerous libelous statements by multiple Defendants...”

Amended Petition, ¶ 122, p. 58.

The Pleading Problem Was More Complicated Than "Slander or No Slander"

At the time I filed the amended petition, I was trying to reconstruct two different stages of communication.

First were the private February–March communications among Martinez, Colville, Stewart, and Nissen that preceded my exclusion. I was not present for those conversations. I therefore knew what I had and had not done, but I did not know the precise words Martinez used, exactly what she gave Stewart and/or Nissen, what Stewart repeated to Nissen and vice-versa, or how the accounts changed as they moved between people.

It was evident to me that slander and/or libel occurred within that chain, but it was impossible, without an honest discovery process, to articulate accurate claims while simultaneously proving every element of each claim. 

Second were the later written materials transmitted to the ICRC. By June 2024, I knew that a written statement and screenshots attributed to Martinez existed (as shown in Exhibit E), but I still did not possess the native file, drafting history, metadata, or private transmission communications necessary to determine exactly who authored or modified what.

That distinction matters because my pleading necessarily described some Martinez-related conduct as slander while simultaneously identifying written materials that could support libel. The precise boundary between those claims depended upon facts I could not obtain from my own records alone.

Judge Currie Dismissed the Oral-Defamation Claim Without Those Facts

Judge Currie's October 4 order treated the pre-exclusion communications as slander. The order identified:

1. Martinez's reported statement that she felt “unheard and disrespected” and overwhelmed by the volume of my communications;

2. Colville's reported statements about feeling harassed; and

3. the subsequent discussion among Nissen, Martinez, Colville, and Stewart.

The court then held that these statements were merely expressions of feeling:

“These statements do not rise to the level of defamatory.”

and reasoned that Nissen and Stewart:

“could have understood these to be accusations against Sondra, or instead, they could have understood the statements as Denise and Willa sharing their concerns and feelings...”

The slander claim was dismissed.

That is where I believe the appellate problem becomes much easier to see.

The court itself identified two possible factual understandings of the communications. Under one, Martinez and Colville were making accusations about my conduct. Under the other, they were merely describing their feelings.

But only weeks earlier, Judge Currie's August 9 order stated that at the motion-to-dismiss stage the court must view the petition “in the light most favorable to the petitioner” and resolve doubts in the petitioner's favor.

The question I am asking on appeal is therefore not an abstract one about whether the word “harassed” can sometimes describe a feeling. It is whether a claim could properly be dismissed with prejudice when the court itself recognized a plaintiff-favorable interpretation under which the communications were accusations about my conduct, while the exact words, recipients, context, transmission history, and supporting documents remained outside my possession and discovery had never occurred.

As I had repeatedly informed the court prior to dismissal, it was impossible to prove every element of every claim prior to discovery. All I would have been able to do is guess, which would not have been responsible on my part. Had I speculated, defendants could have coordinated, pointed to the actual facts that were only known to them, then used my misstatements to claim overreach on my part. 

The Court Also Did Not Have the Evidence the Petition Was Pointing Toward

This is where Part Five in this series, Sudden Reversal, provides essential context.

When I filed the amended petition on June 17, I was operating under court orders that had instructed the parties to prepare for an evidentiary component to the combined proceedings. On May 16, the court directed the parties to disclose whether they intended to present evidence “so that sufficient time may be set aside.” After I reported that I intended to present at least thirty exhibits, the later order contemplated “30 exhibits,” “extensive testimony,” and allowed the parties to present whatever evidence they believed appropriate at that stage.

That procedural history matters to how the June 17 pleading should be understood. The petition itself expressly told the court:

“This Amended Petition, in context with the evidence, will demonstrate to the court why it would create injustice to rule in favor of Defendants' Motions to Dismiss...”

Amended Petition, p. 2.

I was therefore not drafting the petition on the understanding that every evidentiary fact had to be reproduced inside sixty-four pages or forever lost. I was identifying the claims, identifying the evidence supporting them, organizing the exhibits the court had led me to prepare, and expecting an evidentiary process to follow.

I believed it would not have been respectful to the court to show my exhibits prior to receiving further directions form the court prior to the hearing, and I have been unable to identify any rules within the Iowa Rules of Civil Procedure or Evidence that direct Plaintiffs to attach exhibits to their pleadings.

I had never filed a civil suit, and was doing my best to navigate the rules, follow directions from the court, and respond to Defendants barrage of February 29 filings, as described in Part Four: Procedural Bombardment. That was the reason I was amending the petition—to respond directly to the motion to dismiss for failure to state a claim, motion for a more specific statement, and motion to recast. All of these motions insisted the same thing: that I articulated, as precisely as possible, everything I knew to have happened. Also within those filings, they demanded that if I could not prove every element of every claim, that each claim must be dismissed prior to discovery. For me, this was a very frustrating process, because the Defendants were essentially demanding that I prove facts that they themselves had been withholding since I was first kicked off the property on March 31, 2022, as described in Part One: Record Retaliation. 

So, when I filed my Amended Petition, I was merely following direction from the court, and I references to specific exhibits to show the court that this evidentiary process described in Judge Currie's prior orders could be made simpler through organization that had already taken place. 

After Defendants saw my Amended Petition, they expressly objected that evidence outside the pleadings could not be considered and resisted the evidentiary hearing I requested. Judge Currie's August 9 order then stated:

“There should be no reason for the Court to receive evidence at a hearing on a motion to dismiss.”

and limited the hearing to one hour of legal argument.

Finally, the October 4 dismissal expressly acknowledged:

“The Court does not have access to the exhibits and does not consider them in addressing the motion to dismiss.”

The court was deciding whether I had sufficiently alleged what Martinez said and what those communications meant while expressly not examining the very exhibit I had identified as containing the contemporaneous communications and out-of-context material necessary to understand that allegation.

The Written Defamation Claim Demonstrates Why the Distinction Mattered

The court reached a different conclusion concerning the later written statements submitted to the ICRC.

It held that publication to the ICRC investigator was enough to satisfy publication and recognized that some statements could carry defamatory meaning because they might “impute crimes”, impair my ability to work, or expose me to hatred, contempt, or ridicule. It ultimately concluded:

“The Court cannot say as a matter of law that there is no set of facts upon which Sondra could recover damages for libel.”

and:

“Viewing the facts in the light most favorable to Sondra, she has pled sufficient facts to support her written defamation claim to survive a motion to dismiss.”

That creates an important contrast:

The written defamation survived because the court recognized that factual development could support liability. The related oral-defamation claim was permanently dismissed even though the court itself acknowledged competing possible interpretations of private communications that had never been discovered.

Discovery Questions Raised by Exhibit E

If this claim is remanded, discovery could determine:

1. What exactly did Martinez say to Stewart and/or Nissen before March 31, 2022?

2. Were those communications oral, written, or both?

3. What specific factual conduct did Martinez attribute to me—as distinguished from statements describing her feelings?

4. What did Stewart and Nissen understand Martinez to be accusing me of, and how did those accusations affect their decision to exclude me?

5. Who originally drafted the written statement later transmitted to the ICRC?

6. Was the version Stewart submitted identical to the version Martinez originally prepared?

7. Were screenshots selected, cropped, rearranged, captioned, or otherwise modified before Stewart received or transmitted them?

8. What communications occurred among Martinez, Stewart, Nissen, Colville, and Esker concerning the allegations before the ICRC materials were assembled?

9. Did Martinez know that particular accusations were contradicted by her own contemporaneous communications with me?

10. Was Martinez acting within any employment role when the relevant statements were made, or acting personally—and what does that mean for the allocation of responsibility among Martinez, Stewart, and Lockwood Café?

 

If Stewart and Lockwood Café unknowingly transmitted a false written statement supplied by Martinez, the allocation of responsibility could be materially different from a scenario in which the business knowingly participated in preparing it. Discovery was necessary to distinguish those possibilities rather than simply attribute the same knowledge and intent to everyone.

Why I Am Asking the Martinez-Related Defamation Issues Be Reopened

I am not asking an appellate court to decide from this article that every unresolved Martinez-related fact has already been proved. I am asking that claims dependent upon private communications and transmission history not remain permanently barred before those facts can be discovered.

My amended petition identified both the pre-exclusion defamatory communications and the later written materials attributed to Martinez. It identified Exhibit Q2 as containing contemporaneous communications relevant to those accusations and later described the evidentiary combination as “out-of-context statements of mine accompanied by libelous testimony (Q2).”

The district court dismissed the oral-defamation claim with prejudice while expressly recognizing two possible understandings of the underlying private communications. At the same time, the court held that the written defamation claim plausibly stated a claim and could not be dismissed because there was no set of facts under which I could recover.

My appellate position is that the Martinez-related oral-defamation issues should be returned for factual development, including discovery into what was actually communicated, how it was transmitted, and who was responsible. The later written-defamation materials should likewise remain available for factual development subject to whatever privilege rulings survive appellate review.

 

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VIII. "Exhibit F":
Charlie Esker's Statement Connected Multiple Branches of the Respondents' Narrative

View Exhibit F: Esker's Statement to the ICRC and Contradictory Contemporaneous Communications

Exhibit E can still be examined as one allegation associated with one participant. Exhibit F changes the structure of the evidence.

Esker’s statement does not remain inside one factual dispute. It reaches across several of them.

The complete ICRC file contains this statement from Charlie Esker during the respondents' Tier One response period, but I have not yet verified exactly how it reached the Commission. My reconstructed Exhibit F currently identifies Stewart as the person who transmitted it. Other portions of the administrative record, however, refer more generally to statements and evidence submitted by “Stewart, Nissen, and Esker.” Exhibit A separately identifies the Colville- and Martinez-associated materials as having been transmitted through Stewart, without making the same attribution for Esker's statement.

I therefore do not presently state as fact whether Esker submitted the statement directly, gave it to Stewart for submission, or used some other route. The original transmission record, accompanying email, and related communications should establish that provenance.

Regardless, Exhibit F is important for a different reason from the preceding exhibits.

Esker did not simply make another allegation against me. Their statement crossed into several different factual disputes involving other defendants and repeated details and themes that did not originate from interactions in which Esker was documented as participating.

Esker introduced themself as a transgender Ames resident, Iowa State graduate, Lockwood Café regular, community member, and artist. They declared that they “fervently support” Lockwood Café, Reliable Street, Sharon Stewart, Lyndsay Nissen, and the Lockwood staff, and said they rejected what they characterized as my accusations of “discrimination or slander.”

My pending ICRC proceeding was a discrimination complaint. I use Esker's word “slander” here because that is how Esker described what they believed I was accusing the respondents of—not because I had filed a separate slander cause of action with the ICRC.

That wording itself creates a source-of-information question. The ICRC proceeding concerned my allegation of gender-identity discrimination. Esker nevertheless understood the dispute as involving accusations by me of both “discrimination” and “slander.” That suggests Esker knew something about my contention that false statements had been made against me—not merely that I objected to being barred.

How Esker acquired that understanding matters. It may have come from something I said publicly or directly, from another community member, from one or more respondents, from seeing material connected with the complaint, or from some combination of sources. The existing record does not establish which.

What it does establish is that information about the substance of the dispute had reached Esker before they prepared a statement defending the respondents and supplying detailed allegations of their own.

Esker possessed information about the substance of the dispute that requires a source.

What followed was not a statement about one encounter.

Esker claimed personal knowledge across several distinct subjects:

“I witnessed Sondra make racially insensitive comments and display culturally appropriated artwork.”

“I witnessed her harass the Lockwood staff at their place of work nearly every day of the week.”

“I witnessed her insert herself into leadership positions without listening to the input of the community.”

They then described my spending, alleged expectation of reimbursement, and alleged solicitation of money from people at Lockwood Café, open-mic attendees, and high-school students involved with SHEPH.

Those subjects matter because they correspond to allegations appearing in different parts of the respondents' record.

One Statement Reached Across Several Defendants' Narratives

The racism allegation overlaps with the Martinez-associated materials examined in Exhibit E.

The characterization of me as inserting myself into leadership and engaging in unauthorized activity parallels Nissen's portrayal of the Open Mic, garden, and prairie work examined in Exhibits B and C.

The spending, reimbursement, fundraising, and SHEPH allegations likewise closely track the financial narrative contained in Nissen's ICRC statement.

And the allegations of repeated communications, harassment, and unwanted attention overlap with the narrative that ultimately became the stalking-and-harassment allegations examined in Exhibit D.

That makes Esker's statement unusual. It functions almost like a bridge across several otherwise distinct accusations.

This does not by itself prove who told Esker what. But it creates a source-of-knowledge problem that cannot be dismissed merely by calling Esker an independent witness.

The Garden and Prairie Allegations Present the Clearest Source-of-Knowledge Problem

Exhibit C expressly documents that Esker was not involved in the Garden or Prairie projects. Those projects involved other defendants, volunteers, SHEPH representatives, and related participants; Esker's documentation is separated into Exhibit F precisely because they were not a participant in those projects.

Yet Esker told the ICRC that I:

— inserted myself into leadership;

— spent my own money without approval;

— expected reimbursement;

— made unnecessary purchases; and

— solicited money from Lockwood customers, open-mic attendees, and high-school students in SHEPH.

Those are not generalized impressions such as “I didn't like how Sondra behaved.”

They are specific assertions about project management, expenditures, reimbursement discussions, fundraising, and SHEPH—subjects belonging to a project in which Exhibit C documents no Esker involvement.

Nissen's own ICRC account covered substantially the same subjects. She described me as pushing for control, communicating excessively, spending money, expecting reimbursement, soliciting money for seed, attempting fundraising, and involving SHEPH.

That creates a factual question the existing record cannot answer: where did Esker's detailed knowledge of those internal project disputes come from?

There are several possibilities. Esker may have learned particular facts from Nissen, Stewart, Colville, Martinez, someone else, or some combination of people. They may have participated in discussions about the dispute that are not reflected in the records I possess.

What the record does not support is simply treating those details as obviously independent firsthand corroboration.

The Same Problem Appears in the Racism Allegations

Exhibit E documents allegations attributed to Martinez that I made racist and anti-LGBT+ comments. Those materials were transmitted through Stewart and became part of the ICRC record.

Esker separately told the ICRC:

“I witnessed Sondra make racially insensitive comments and display culturally appropriated artwork.”

I know that I did not make the racist statements attributed to me. The unresolved question is how two separate branches of the respondents' record came to contain racial allegations presented as firsthand knowledge.

Martinez-associated materials alleged racist comments and supplied selected private communications that Exhibit E places back into their surrounding context. Esker separately claimed, “I witnessed Sondra make racially insensitive comments and display culturally appropriated artwork.”

If Esker was describing an entirely separate alleged incident, discovery should identify what was supposedly said, where it occurred, when it occurred, who was present, and why no contemporaneous communication I possess reflects such an incident.

If the allegations were not independent, discovery should reveal how information moved between Martinez, Esker, Stewart, Nissen, Colville, or others before the submissions were prepared.

Similarity can look like corroboration. The critical question is whether the sources were actually independent.

Did Esker claim to be describing a separate incident? 

If so, what specific statement did Esker claim to hear, when and where was it supposedly said, and who else was present?

Did Martinez discuss her allegations with Esker? Did another respondent relay them?

Were Martinez-associated screenshots or characterizations circulated before Esker's statement was prepared?

Or did Esker independently develop an accusation that happened to resemble the allegations attributed to Martinez?

Exhibit E makes the source question especially important because the Martinez-associated racial allegations were accompanied by selected private communications that, when restored to their surrounding context, tell a materially different story. That gives me a concrete reason to ask whether Esker's similar accusation arose independently or was influenced by characterizations or materials already circulating among the respondents.

Those possibilities matter because repetition can create the appearance of independent corroboration. Discovery is necessary to determine whether these were genuinely independent sources or whether substantially similar allegations moved among participants before being presented to the ICRC.

Without the underlying communications, similarity can look like corroboration when it may instead reflect information moving among people.

That distinction is central to this case.

There is also a separate legal question arising from timing: these supporting statements were assembled during the ICRC proceeding after I had invoked civil-rights protections. That chronology later became part of my retaliation theory. Whether this particular form of post-complaint conduct satisfies the ICRA's retaliation provisions is a legal question I address separately; here, the narrower evidentiary question is how the accusations were developed and whether supposedly independent accounts actually had independent sources.

And Esker Was Not Merely a Disconnected Customer

Part One documents my firsthand relationship with Esker before March 31. Esker was regularly involved in the Reliable Street arts community, their work was exhibited there, they were close with Colville, and I frequently saw Esker, Colville, and Eli together at Lockwood Café, Reliable Street events, and open mics. We also worked together on the Valentine's Day Singles Mingle.

The way Esker was later described in the record does not fully convey that relationship.

In their own ICRC statement, Esker described themself as a Lockwood Café “regular,” “community member, and artist.” The ICRC later referred more generally to supporting statements from “employees and patrons.” And in defendants' July 5, 2024 motion to dismiss, Esker was described simply as:

“a former customer at Lockwood Café.”

I had already objected to that characterization in an April 2024 filing. At the time, I pointed out that Esker's art had been displayed in the Reliable Street gallery on multiple occasions while defendants were characterizing Esker to the court as merely a Lockwood Café customer.

None of those labels is necessarily inaccurate in isolation. But “former customer” is incomplete context for evaluating the statement that followed.

Esker was not an unrelated patron describing one isolated encounter; they were socially and artistically embedded in the same Reliable Street community and had close relationships with people whose allegations later became central to the ICRC record.

That matters not because friendship itself proves coordination, but because Esker's statement reached into detailed disputes involving Nissen, Martinez, Colville, the garden and prairie projects, SHEPH, and Lockwood staff. The closer Esker's actual relationship was to those participants, the more important it becomes to determine which information they witnessed independently and which information reached them through other people.

Esker later wrote in their ICRC statement that they had witnessed me repeatedly contacting:

“my best friend everyday, multiple times a day, with no response.”

I would not presently identify that unnamed “best friend” as Colville as an established documentary fact unless the underlying record or discovery confirms it. But Esker's known relationship with Colville makes the identity of that person—and what Esker actually observed—an obvious discovery question which I look forward to the court revealing. My unaltered records do not indicate such messages took place. 

That becomes especially important because Exhibit D preserves the contemporaneous communications between Colville and me, including friendly exchanges continuing into March 2022. Those records do not document the pattern of unanswered daily messages described in Esker's later statement.

Esker Had Told Me Something Very Different Immediately After My Exclusion

There is also a direct chronological conflict.

On March 16—approximately two weeks before I was barred—Esker contacted me warmly about a performance:

“Yesss! Eli and I performed last week Wana see the vids????”

Part One documents that exchange as ordinary and friendly, with no indication that Esker believed they had been witnessing serious misconduct.

Then, on April 1, after I told Esker that I had been removed because unidentified people supposedly felt unsafe or believed I had crossed boundaries, I expressly offered to stop contacting them if they felt that way about me.

Esker replied:

“I am not really involved in any of that, but I also do not know if us having a personal relationship is best right now.”

Exhibit F summarizes the conflict directly: the March 16 and April 1 communications were friendly, contained no accusation of racist or harassing conduct, and included Esker's statement that they were “not really involved in any of that.” Yet within the following months, Esker submitted a statement describing numerous forms of misconduct they said they had personally witnessed.

That does not merely create an inconsistency in tone. It creates a source-of-knowledge and chronology problem.

If Esker had personally witnessed me harassing Lockwood employees “nearly every day,” making racist comments, improperly assuming leadership, mishandling project finances, soliciting money from teenagers, and repeatedly contacting another person without response, why did none of that appear when I directly told Esker on April 1 that I had been barred for making people feel unsafe?

And if Esker truly was “not really involved in any of that,” how did their later statement come to contain such detailed assertions spanning multiple branches of the defendants' narrative?

Those are factual questions. They have never been answered through discovery.

But Stewart Said Even Close Friends Were Not Told What Happened

There is another evidentiary tension that I had not fully appreciated until reconstructing these records side by side.

In her ICRC statement, Stewart said that the March 31 explanation to me had been “intentionally vague” in order to protect the employees who had complained. She further described an effort to keep the dispute from becoming community gossip and stated:

“We did not slander her name or speak poorly to anyone about her. Even close friends were not told...”

Stewart Statement to ICRC, Exhibit A-4, p. 3.

That statement does not mean Esker's mere knowledge that I had been barred proves that Stewart or Nissen spoke to them. I had personally told Esker on April 1 that I had been removed after unidentified people complained that I made them feel unsafe or crossed boundaries.

But my April 1 message did not tell Esker the detailed project-finance narrative, the allegations concerning SHEPH, the racism allegations attributed elsewhere to Martinez, or the internal reasoning defendants later supplied to the ICRC. Nor did I tell Esker that I had brought a legal claim for slander.

That makes Esker's choice of words especially important. Esker did not merely say they disagreed with my discrimination complaint. They wrote that they rejected my accusations of “discrimination or slander.”

The question is therefore not simply, Did Esker know I had been barred? I know how Esker learned that: I told them.

The more important questions are: What else had Esker been told? By whom? When? And why did Esker understand my discrimination complaint as also accusing the respondents of “slander”?

This becomes even more significant when Esker's later statement is compared with the breadth of their claimed knowledge. Their letter reaches into disputes involving garden finances, reimbursement, SHEPH, alleged racism, repeated communications, staff harassment, and the circumstances surrounding my exclusion.

If Stewart's statement is accurate that even close friends were not told what had happened, then the source of Esker's detailed knowledge becomes an especially important discovery question.

This Is Where Coordination Becomes Visible as an Evidentiary Question

Coordination does not have to be inferred merely because several people disliked me or ultimately supported the same side of a dispute. The evidentiary concern arises when a purported witness begins repeating detailed information from disputes in which that person was not documented as participating, while simultaneously reinforcing allegations originating with several different participants.

That is what makes Exhibit F significant. Esker's statement reaches across the Nissen project-and-finance narrative, the Martinez racism narrative, and the Colville-associated harassment narrative. Some of the statements purport to be firsthand observations; others concern matters for which the existing documentary record provides no apparent firsthand source.

The question is therefore not simply whether several defendants independently told similar stories. It is whether information moved among them before those stories were submitted, and whether the resulting repetition created the appearance of independent corroboration where the sources may not actually have been independent.

The ICRC's Preliminary Case Review described supporting material from “employees and patrons.” Esker did not call themself a patron; they identified themself as a Lockwood Café “regular,” community member, and artist. The present record does not establish that every generic ICRC reference to a “patron” or “customer” referred to Esker. What is established is that Esker's statement was among the supporting materials the ICRC possessed, and that Esker was considerably more connected to the Reliable Street community than an unrelated customer describing a single encounter.

Discovery Questions Raised by Exhibit F

1. Which statements in Esker's ICRC submission were based on events Esker personally witnessed?

2. Which statements were based on information supplied by other people?

3. Who told Esker about the garden and prairie expenditures, reimbursement discussions, fundraising, and SHEPH?

4. What communications occurred between Esker and Nissen before Esker's statement was prepared?

5. What communications occurred between Esker and Martinez concerning allegations of racism or culturally insensitive conduct?

6. What communications occurred between Esker and Colville concerning me before and after March 31?

7. Who was the “best friend” Esker described as receiving daily unanswered communications, and what communications did Esker actually observe?

8. What did Esker mean on April 1 when they said they were “not really involved in any of that”?

9. When did Esker first learn the specific allegations later included in their ICRC statement?

10. Was Esker's statement drafted independently, discussed with other defendants beforehand, reviewed by anyone else, or transmitted through Stewart in coordination with the other ICRC submissions?

11. Were the factual details repeated in Esker's statement independently known to Esker, or were some supplied through the same participants whose accounts the statement then appeared to corroborate?

12. Why did Esker characterize my position as accusing defendants of “slander,” when the proceeding to which the statement responded was my ICRC discrimination complaint, and from whom—if anyone—did Esker learn the substance of my allegations before preparing the statement?

13. If Stewart's statement is accurate that even close friends were not told what had happened, through what source did Esker acquire the detailed information reflected in their ICRC statement?

What Exhibit F Changes

Exhibit F does not prove that every allegation originated from one source, nor does it establish the full scope of any coordination.

It changes the evidentiary question.

Before Exhibit F, a reader might understand Exhibits B, C, and E as separate disputes reported independently by different people. Esker’s statement makes that explanation harder to assume without further inquiry because it crosses among project finances, SHEPH, leadership, racism, employee harassment, and repeated-contact allegations—while the existing record does not document Esker participating firsthand in several of those underlying disputes.

The question therefore becomes not simply whether several people said similar things, but whether the sources were actually independent.

That is the question I was seeking discovery to answer.

And it is at this point—after the record has developed from disputed project characterizations, to serious accusations, to overlapping sources of information—that the article reaches the stalking-and-harassment materials in Exhibit D.

 

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IX. From “Intrusive” and “Obsessive” to Stalking and Harassment

Examine Exhibit D: How Friendly Communications With Willa Colville Were Recast as Stalking and Harassment

Exhibits B and C showed conduct documented contemporaneously as collaborative later described through words such as unsolicited, constant, cornering, controlling, and obsessive. Exhibit E added allegations of racism and anti-LGBT+ misconduct. Exhibit F showed a supporting statement crossing among several of those otherwise distinct narratives.

Exhibit D is where those threads reach the most serious characterization in the administrative record.

Nissen alleged that I had become “obsessed” with Colville, appeared during “every shift,” was “constantly cornering her,” contacted her constantly, and caused her to hide in the kitchen. Nissen then characterized that alleged conduct as:

“stalking and harassing.”

The surviving record does not establish that Colville herself used those words. It establishes that Nissen applied them to the conduct she attributed to Colville’s complaint.

That distinction becomes important when those allegations are compared with Colville’s own contemporaneous communications—and with the document later submitted as D-3.

But Exhibit D then places that account beside two things the reader has not yet seen together:

first, months of contemporaneous communications in which Colville continued treating me as a friend and affirmatively engaging with me; and second, D-3—the submitted version of my April 4 message whose added date and caption reversed the apparent chronology of the exchange.

Nissen's statement is especially important because it does more than repeat a complaint. It organizes a series of allegations into a coherent portrayal of me as someone whose contact had become obsessive, constant, cornering, and ultimately “stalking and harassing.”

What the Record Looked Like in March 2022

Before turning to D-3, it is worth placing the later allegations beside the communications that were actually occurring during the weeks immediately before my exclusion.

Nissen later described a situation in which I had supposedly become obsessive, was appearing constantly, cornering people, overwhelming employees, and engaging in conduct serious enough to characterize as stalking and harassment.

But the surviving March communications show people in the same community continuing to initiate contact with me, involve me in projects, express appreciation, and communicate warmly.

• March 4 — Austin Stewart: Lockwood Café co-owner Austin Stewart contacted me about the 50% café discount associated with the garden arrangement, apologized for not applying it, and expressed appreciation for my work. Exhibit C identifies that exchange as continuing recognition of the Garden Agreement.
• March 8 — Colville: Colville independently contacted me and asked me to record her performance so she could listen to it later. Exhibit D describes this as Colville voluntarily initiating a personal favor less than a month before March 31.
• March 16 — Colville: during an ordinary garden discussion, Colville told me “I appreciate you a lot” and apologized for having been distant.
• March 16 — Esker: Esker initiated a friendly exchange about a performance by Esker and Eli and asked whether I wanted to see the videos. The contemporaneous Exhibit F record contains no mention of the extensive harassment and misconduct Esker later said they had personally witnessed.
• March 17 — Colville: after I sent Nissen’s Venmo information for our shared prairie-seed contribution, Colville responded “Love you <3.”
• March 22–23 — Nissen: after I apologized for leaving the Open Mic before cleanup was complete, Nissen replied with three heart emojis. Exhibit B places that exchange only nine days before March 31.

Those communications do not resemble a record in which the people around me were contemporaneously communicating that my presence was intolerable, frightening, or persistently violating known boundaries.

Most importantly for Exhibit D, Colville was not merely responding politely when I contacted her. She was herself initiating contact, asking favors, participating with me in projects, apologizing for distance, expressing appreciation, and ending a March 17 exchange with “Love you <3.”

That is the contemporaneous record immediately before Nissen later described me as having been “obsessed” with Colville, appearing during every shift, “constantly cornering her,” and contacting her constantly.

The question is therefore not simply whether Colville may privately have felt discomfort that she did not communicate to me. The sharper factual conflict is this: how does the later account of months of continual boundary violation fit with the communications Colville herself was still initiating and sending in March?

The Surviving Record Does Not Show Colville Using the Words "Stalking" or "Harassing"

The surviving record does not establish whether Colville herself ever used the words “stalking” or “harassing.” What it does establish is that Nissen’s ICRC statement took allegations attributed to Colville—constant contact, being cornered, hiding in the kitchen, being watched for at work—and expressly characterized that conduct as “stalking and harassing.”

That characterization sits beside a contemporaneous record in which, only weeks earlier, Colville was still initiating contact with me, asking me to record her performance, telling me “I appreciate you a lot,” participating in the prairie project, and writing “Love you <3.” Nissen herself was still responding to me with heart emojis nine days before the exclusion.

That does not establish what Colville privately felt at every moment. It does establish a substantial conflict between the later account of months of persistent boundary violation and the relationship being communicated to me at the time.

The next question is when a boundary actually was communicated to me.

Exhibit D-3 — The Modified Document That Reversed the Apparent Chronology

 

D-3 is the most consequential documentary comparison inside Exhibit D.

Readers of Record Retaliation may remember the warning I placed at the end of the April 4 chronology:

“Remember that chronology. It will matter later.”

This is where it matters.

On April 4, 2022, before Colville had told me she was one of the complainants and before she had communicated any boundary to me, I sent her a message asking what had happened and whether I had unknowingly made her uncomfortable. I expressly told her:

“I've been reluctant to text you because I haven't heard from you and frankly I never wanted to nor want to invade your space or make you or anyone feel that way.”

I also wrote:

“If I was coming in too much or texting too much or you needed space... I was not made aware of that.”

And I ended:

“Please help me understand.”

Three days later, on April 7, Colville responded for the first time that I had allegedly been violating her personal space “for months,” while also acknowledging:

“I admit that the situation could've been handled better. If I had said something sooner, maybe things [would] be different…”

That chronology is reconstructed in Section IV of Record Retaliation.

Yet the version later submitted to the ICRC placed an April 7 date above my April 4 message and added the caption:

“Communication where Willa asked for no further communication, followed by Sondra’s response.”

The underlying words of my April 4 message were not rewritten. The date and caption changed the apparent sequence and therefore changed what the message appeared to prove.

Read as submitted, D-3 made my April 4 attempt to understand the accusation appear to be a response sent after Colville had already told me to stop contacting her.

The actual chronology is the opposite:

April 4 — I wrote first, asking what had happened.

April 7 — Colville responded three days later and communicated the boundary.

That matters because the respondents' narrative already portrayed me as obsessive, boundary-violating, stalking, and harassing. The modified presentation made an earlier good-faith attempt to understand an unexplained accusation appear to corroborate the very allegation that I refused to respect boundaries.

What D-3 Establishes — and What It Does Not

The documentary comparison establishes a narrow but important fact: the version submitted to the ICRC did not preserve the chronology of the underlying exchange. My April 4 message came first. Colville's April 7 response communicating the boundary came three days later. The submitted presentation placed an April 7 date above my April 4 message and captioned it as though Colville's request for no further communication came first.

What the surviving document does not establish by itself is who created that presentation or who knew what about it.

Before discovery, I could not determine:

— who arranged the screenshots;

— who supplied or inserted the displayed date;

— who wrote the caption;

— what Colville originally supplied to Stewart;

— whether Stewart received the material already in that form;

— who reviewed or approved the presentation before it was submitted; or

— what each participant knew about the discrepancy between the actual chronology and the submitted presentation.

Those are not questions the final document can answer on its face. They concern authorship, transmission, knowledge, and participation—and therefore required communications, document production, interrogatories, or testimony from the people involved.

This distinction also matters when assigning responsibility. The record documents Stewart's transmission of D-3 to the ICRC, but it does not presently establish that Stewart created the altered presentation or knew that its chronology was inaccurate. Nor does the present record establish that Colville created it merely because the underlying messages involved her.

The responsible conclusion is therefore not to assign the alteration to a particular person without evidence. It is to recognize that the alteration occurred, identify the factual questions it creates, and ask why those questions were permanently foreclosed before discovery could answer them.

Exhibit D-11 — "Love you <3" Two Weeks Before the Rupture

Two weeks before March 31, Colville responded “Love you <3” during an ordinary prairie-project exchange. Exhibit D preserves a longer pattern of similarly friendly communications—including “I consider us friends,” “Super appreciate you,” and “I appreciate you a lot”—without a contemporaneous warning that I was violating a boundary.

D-11 shows the relationship immediately before the rupture. D-3 shows how the later documentary presentation made my first attempt to understand that rupture appear instead to be evidence of defiance.

That is the juxtaposition.

The Evidence Does Not Assign the Same Role to Everyone

 

The records establish that people spoke with one another, complaints were discussed, statements and screenshots moved through intermediaries, and multiple submissions converged into a reinforcing narrative. They do not reveal every private conversation or establish that everyone entered into the same agreement.

The unanswered question is how much of that convergence was independent, how much resulted from information being passed from person to person, and whether some portion of it was consciously coordinated.

The record does not cause me to view every respondent's role in the same way.

Sharon Stewart's statement reads differently to me from several of the others. Much of it reads like the account of a business owner who had been given alarming information about employees she believed were being harmed and who accepted that information as true. She described concern for their “health and well being” and emphasized her responsibility to provide employees with a safe workplace.

That does not mean I agree with her account or that her own statements were accurate. For example, Stewart also asserted that after Colville's communication I “began to slander Willa's name within the community.” I know that did not happen.

But the difference matters when evaluating knowledge and intent. The present record does not establish that Stewart knew D-3 had been altered when she transmitted it to the ICRC. It is possible that she received material from someone else and submitted it believing it accurately represented what had occurred. It is also possible that she knew more. Without discovery or an admission, I cannot responsibly say which is true.

If Stewart did not know that D-3 had been altered, that would not make the alteration less significant. It would mean the evidentiary question changed: instead of asking why Stewart altered it, the question would become who supplied the altered version to Stewart, what Stewart was told about it, and whether she reasonably understood it to be authentic.

The inability to identify the person who altered D-3 does not mean responsibility disappears; nor does it mean every defendant can simply be assumed responsible. It means authorship, transmission, knowledge, and agreement become factual questions.

Stewart's transmission of the document is documented. Who created the altered presentation, who knew it had been altered, and whether anyone agreed to use it in that form remain unresolved. Those are precisely the kinds of questions discovery may still be able to answer if the case is remanded.

Nor would a lack of knowledge about D-3 necessarily resolve the separate issues I raise concerning Stewart's own conduct. My discrimination theory has always included the contention that Stewart accepted severe allegations about me and participated in punitive action without giving me a meaningful opportunity to know and answer the accusations. Her ICRC statement also contains assertions of her own that I dispute, including the claim that I began slandering Colville throughout the community.

What I Mean by "Coordination"

 

“Coordination” does not require me to imagine a secret meeting or claim knowledge of private conversations I cannot see.

At its most basic level, people coordinate when they communicate with one another, exchange allegations, transmit statements or screenshots through common intermediaries, discuss a response, or assemble materials that reinforce one another.

The available record establishes at least some of those transmission pathways. Statements attributed to Martinez were transmitted through Stewart; Esker's statement was likewise sent to the ICRC through Stewart; Stewart and Nissen described conversations with Colville and Martinez; and multiple submissions ultimately converged in the same administrative record.

Taken together, the documents strongly indicate that the submissions were not independent accounts developing in isolation. Allegations, supporting materials, and factual details moved through overlapping participants and common intermediaries, while separate statements converged around the same increasingly damaging portrayal.

That pattern is consistent with coordinated activity and supports the civil-conspiracy claim I later developed more fully.

What discovery is still needed to determine is the scope of that coordination: who originated particular allegations, who repeated or adopted them, who supplied particular documents, who knew how those documents had been presented, and whether all participants shared the same objective or whether different people played different roles.

That remains one of the central questions discovery may need to answer if the case is remanded.

I was already alleging conspiratorial or coordinated conduct in my 2024 amended pleading (D0020), but my allegation of conspiracy became substantially more developed and formally pleaded in the later proposed amendments after I had spent much more time reconstructing the evidentiary record.

In general terms, civil conspiracy concerns two or more people acting in concert toward an unlawful purpose, or using unlawful means toward a common objective, resulting in injury.

The absence of an email saying “we agree to do this” would not resolve the conspiracy question. Iowa law recognizes that an agreement may be tacit and inferred from surrounding circumstances, including the participants' acts, declarations, and conduct.

Here, the documentary record shows overlapping participants, shared subject matter, transmission through common intermediaries, matching allegations, a witness speaking to matters outside their documented involvement, selected or out-of-context communications, and a document whose presentation changed the apparent chronology. I contend those circumstances strongly support an inference of coordinated action and warranted discovery into the extent of the agreement.

The existing circumstantial evidence strongly supports the inference of a coordinated scheme; discovery is needed to determine its full membership, scope, knowledge, and purpose.

The difficult evidentiary question here is the agreement component: the documents show multiple people, shared information, common intermediaries, and mutually reinforcing submissions, but the private communications necessary to determine the extent of any agreement have not yet been obtained through discovery.

That distinction matters because repeated allegations can create the appearance of corroboration without actually being independent corroboration.

If three people independently witness the same event and later describe it similarly, that is one evidentiary situation.

If three people discuss allegations among themselves, exchange factual details, transmit screenshots through common intermediaries, and later submit mutually reinforcing accounts, the apparent number of corroborating sources can overstate the amount of genuinely independent evidence.

The ICRC file strongly raises that concern here.

 

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V. Why the Record Functioned as Political Leverage —
Regardless of Ultimate Motive

 

As Part One documents, these events unfolded during an increasingly hostile political debate over transgender healthcare and transgender women’s place in public life. That context mattered to how I understood allegations portraying me as threatening, intrusive, or violating women’s boundaries. I do not repeat that history here. What matters in Part Three is that I was already engaged in civil-rights and political work when these statements were submitted, and that the resulting record later followed me into electoral politics.

 

 

My Political Work, Through Wild Willpower, Predated My Candidacy

 

I began developing Wild Willpower in 2010 and spent years building its website, projects, public platform, and educational materials before the events at Reliable Street.

In 2018, I registered Wild Willpower PAC with the Federal Election Commission, where I publicly described it as:

“the nation's first declared Civil PAC”

The filing explained that Wild Willpower would continue developing and promoting its public platform, support candidates committed to that platform, educate civilians about pro se litigation and government accountability, and promote fact- and evidence-centered civic participation.

In other words, Wild Willpower was already an explicitly political and civic-accountability project years before the Reliable Street dispute and five years before I announced my gubernatorial candidacy.

I also regularly carried and handed out business cards directing people to WildWillpower.org, including people I knew in the Reliable Street community.

Defendants therefore did not know me merely as a café customer or casual volunteer. They knew I had an existing body of political, legal, educational, and government-accountability work.  

They knew about my work with U.S. Army Veteran and former wilderness survival instructor Richard Lonewolf and about my longstanding interests in ethnobotany, gardening, native plants, cultural preservation, and public education. They also knew about our publication More Valuable Than Gold and that I had spent years learning and working alongside him in ethnobotany, traditional plant knowledge, gardening, cultural preservation, and related public-education work. That background was part of the context in which Sharon Stewart approached me about helping manage the garden.

The documentary record independently confirms that the garden arrangement did not begin with me imposing myself on the project. Exhibit C shows that Stewart had already approached me about gardening before I raised it with Nissen, and that Nissen responded:

“That would be amazing.”

 Exhibit C also documents the progression from approval to delegated responsibility over a defined period. Nissen told a third party that I was “taking the lead on the community garden this upcoming season,” and later confirmed that I and the SHEPH president were “in charge of the garden this year.”

Those statements did more than acknowledge that I was helping. They memorialized an expected duration of responsibility extending through the upcoming garden season/year—an understanding I contend was later repudiated when I was abruptly excluded from the property.

In other words, they did not ask a random person to perform isolated volunteer tasks. The documentary record shows that I was given continuing responsibility for the garden over the upcoming season, after my background and interests were already known to them.

By early 2022, I was also speaking openly about civil-rights law and government accountability. After Judge Kelly's November 2021 ruling concerning transgender Medicaid coverage, I was studying and discussing what I understood to be possible color-of-law violations, conspiracy against rights, deprivation of rights, and the State's treatment of transgender Medicaid patients.

I know those conversations occurred because I participated in them. I do not presently have recordings or contemporaneous written records proving every conversation or exactly what each defendant remembers hearing. That is firsthand testimony, not a documentary claim.

The legal research itself is independently corroborated by the work I later incorporated into Wilson v. State of Iowa and Kim Reynolds for Iowa, including my arguments concerning Good, Medicaid rights, 18 U.S.C. §§ 241 and 242, and related civil-rights issues.

The significance is not that defendants necessarily agreed with my legal analysis. It is that they knew I was publicly engaged in civil-rights and government-accountability work before the ICRC record was created.

That fact materially changes the political context of the later accusations.

The Existing Record Then Acquired a Different Kind of Leverage

 

My candidacy did not create the allegations. It changed what those allegations could do.

By the time I entered electoral politics, the ICRC record already contained a mutually reinforcing portrayal of me as obsessive, intrusive, racist, anti-LGBT+, controlling, stalking, harassing, and unwilling to respect boundaries.

Those accusations carried potential reputational force regardless of their original motive. But placed against the political environment described in Record Retaliation—and against my own increasingly public civil-rights work—they acquired an additional kind of leverage.

A person does not have to create a record for political purposes in order for that record later to become politically useful.

The political danger did not depend on proving political motive. Retaliation alone could have created the record; the surrounding political environment gave that record leverage.

Even if the original motive had been nothing more than retaliation for filing the ICRC complaint, the accusations had been constructed in terms that could be especially damaging to someone engaged in civil-rights advocacy and, later, electoral politics.

Stalking and harassment could portray me as dangerous. Allegations concerning women's boundaries could intersect with the political stereotypes then being directed at transgender women. Allegations of racism and anti-LGBT+ conduct could undermine my credibility as someone publicly advocating for civil rights, equality, and government accountability.

The political significance therefore did not depend upon proving that anyone sat down in 2022 and said, “We need to stop Sondra Wilson from running for governor.” I had not yet announced such a campaign.

The leverage existed because of what the record portrayed me as being—and because of the public work I was already doing.

The Record Recast Me From a Civil-Rights Advocate to Instead a Civil-Rights Offender

There was another reason the record carried unusual political leverage.

I had gone to the ICRC alleging discrimination against me. The respondents' submissions did not merely deny that complaint—they constructed a counter-narrative portraying me as the person who was racist, anti-LGBT+, threatening to women, disrespectful of boundaries, and unsafe.

That reversal mattered because my public work already centered on civil rights, government accountability, and legal reform. A record portraying a civil-rights advocate as herself racist, anti-LGBT+, predatory, or unsafe does more than contradict her complaint. It attacks the credibility on which that advocacy depends.

In political terms, that is especially powerful. It permits an opponent or critic to answer not merely, “She is wrong,” but:

“She is a hypocrite.”

“She is the danger she claims to oppose.”

“Her civil-rights work should not be trusted.”

That is why the reversal belongs in this section on political leverage rather than as an aside about the ICRC record.

Whether anyone deliberately designed that reversal for political effect remains a question of motive. Its political usefulness does not.

The Allegations Carried a Separate Kind of Political Danger

There was another reason the record became especially dangerous once I entered electoral politics.

Accusations involving stalking, harassment, unwanted contact, boundary violations, or sexual impropriety can be politically devastating even before they are adjudicated.

Public officials and candidates are frequently judged in the court of public opinion long before any court determines whether an allegation is true. A headline, screenshot, leaked document, or official summary can shape public perception immediately, while the underlying evidence may take months or years to examine.

That danger was amplified in my case by the fact that I am a transgender woman.

As Part One documents, public rhetoric at the time was already portraying transgender women as dangerous, intrusive, or as men violating women's spaces. Against that background, an allegation that I had stalked or harassed a woman could carry a meaning far beyond the literal accusation. It could activate exactly the prejudice I had already seen used against transgender women in politics and public life.

That made the existing record politically explosive whether or not transgender animus had been the original motive for creating it.

The same was true of the accusations that I was racist or anti-LGBT+. Those allegations could attack my credibility from another direction by portraying a civil-rights advocate as a hypocrite.

By the time I became a candidate, I therefore did not experience the possibility that these allegations might surface as some abstract or distant risk. The record already existed. The accusations were serious. The supporting materials had already been assembled.

From my perspective, the question was not whether I should simply hope no one ever used them. It was whether I could responsibly run for public office while leaving those accusations unresolved and available to be surfaced against me.

I concluded that I could not.

Before I could ask voters to trust me, I needed to be able to show the underlying record and ask a court to determine what was true.

By the time I became a candidate, I no longer experienced the risk as a remote “if.” Given the seriousness of the accusations, the documentary presentation supporting them, and the political environment in which I was entering public life, I experienced it as a threat that could surface at any time.

The Motive Remains Unresolved; the Political Leverage Is Visible

I want to distinguish carefully between motive and effect.

The record supports an inference of coordinated activity, but motive may have differed among participants. The presently available evidence does not yet permit me to assign a single motive to every respondent.

Those remain factual questions that discovery may still help answer if the case is remanded.

But I do not need to know the ultimate motive in order to explain why I experienced the resulting record as politically dangerous.

The record already existed. The accusations were already framed in ways capable of undermining my credibility as a civil-rights advocate. My political and legal work was already known within the community. And after I announced my candidacy, the same record became capable of damaging a statewide political campaign.

That is why I use the phrase Political Sabotage in this series.

It describes not only the unresolved question of why the record was created, but also what the record was capable of doing once political activity, litigation against the State, and eventually a gubernatorial campaign entered the picture.

The precise motive remains disputed.

The leverage is visible in the record itself.

That does not establish why any particular respondent made a particular statement. It does establish that my civil-rights and political work did not suddenly appear after this dispute.

My gubernatorial candidacy came later. Once I entered electoral politics, however, the danger I already saw in the record became considerably sharper.

Why Filing the Lawsuit Was Necessary Rather Than Merely Voluntary

 

Filing this lawsuit was technically an act I chose to perform. But calling it merely “voluntary” strips away the circumstances that made litigation necessary.

By the time I received the complete ICRC file, the accusations were no longer an interpersonal disagreement I could simply walk away from. They had acquired institutional permanence inside a government record. They portrayed me as stalking, harassing, obsessive, intrusive, racist, anti-LGBT+, controlling, and unwilling to respect women's boundaries. The file contained supporting material that I contend had been selectively presented or modified, including D-3.

I also already knew that damaging government records could acquire consequences far beyond the proceeding in which they originated.

In 2022, while trying to understand the Reliable Street accusations, I had reopened my old 2006–2009 records and discovered that the surviving court record showed guilty pleas to charges I had personally pleaded not guilty to—including Interference With Official Acts. I also obtained a police summary portraying me as repeatedly refusing instructions and being “uncooperative,” an account I dispute.

After the Reliable Street respondents placed new accusations into the ICRC record portraying me as stalking, harassing, obsessive, intrusive, and dangerous, I became seriously concerned that my existing criminal record could be used to reinforce those new accusations or support additional false allegations. That concern was one of the reasons I retrieved the older records in the first place.

The new ICRC record therefore did not exist in isolation. It increased the leverage of an older government record I had already learned could tell a damaging story about me that I disputed.

At the same time, my political and civil-rights work was already public. Wild Willpower and my legal-research projects predated this litigation by years. The accusations therefore threatened not only my personal reputation, but an existing body of political, civic, and government-accountability work.

Under those circumstances, doing nothing was itself a consequential choice.

Walking away would not have erased the allegations, corrected D-3, resolved who originated the accusations, prevented the record from resurfacing, or restored my reputation. It would have left the government's file intact while memories faded and evidence became harder to preserve.

That is why I do not describe this lawsuit as merely voluntary. I filed because, from the information available to me at the time, litigation had become the remaining mechanism through which I could preserve the evidence, compel factual development, clear my name, and protect my safety, reputation, legal rights, and political work.

The decision to litigate therefore did not begin with a desire to prolong a private dispute. It began with my conclusion that I could not safely leave this record unresolved.

 

 

Generalized Anti-LGBT Hostility Does Not Fully Explain the Record

 

The surrounding evidence makes a simple explanation of generalized anti-LGBT hostility less persuasive as the dominant motive. Reliable Street and Lockwood Café publicly presented themselves as LGBT+-inclusive spaces, and at least one participant who strongly supported the respondents identified themself as transgender. Those facts matter. But they do not establish what motivated every individual actor, nor do they exclude discrimination based on stereotypes, differential treatment, retaliation, interpersonal hostility, political concerns, or mixed motives.

Political Sabotage By-Effect 

The surviving record does not yet establish a single motive shared by every participant.

I therefore distinguish motive from effect.

The available evidence supports substantial inferences of coordination and deceptive presentation. What it does not yet establish is why every participant acted: whether the dominant motive was retaliation for my ICRC complaint, hostility toward my political or civil-rights work, an effort to protect friends or institutions, interpersonal conflict, some combination of those motives, or something else.

Discovery may still answer that question.

But the political character of the resulting harm does not depend entirely upon proving that someone expressly announced a political objective.

Before I announced my gubernatorial candidacy, I had already founded and regularly operated Wild Willpower PAC and had spent years building public-facing legal, civil-rights, civic-education, and government-accountability work. My political activity did not begin with the campaign. The record therefore threatened an existing political organization and an existing body of public work before it ever threatened a ballot campaign.

When I later became a candidate, that leverage intensified.

The accusations placed into the ICRC record were not politically neutral in their potential effect. They portrayed me as stalking, harassing, intrusive, racist, anti-LGBT+, controlling, dishonest, and unwilling to respect women's boundaries. Those are accusations capable of destroying the credibility of a political advocate or candidate regardless of whether their creator ever uses the words political sabotage.

That distinction is why I use the title Political Sabotage.

I do not presently claim that discovery has established that every respondent acted pursuant to an admitted political objective. I contend that the record functioned as political sabotage in effect: it created durable reputational leverage capable of discrediting my political organization, my civil-rights work, and ultimately my candidacy; it forced me to devote years to clearing my name; and the resulting litigation consumed time and resources that otherwise could have gone toward that political work.

The political effect therefore existed independently of whether political motive can ultimately be proved.

The unresolved question is why the record was created and reinforced. The political leverage it produced is already visible.

The inference does not rest on one suspicious circumstance. It rests on multiple documented circumstances pointing in the same direction.

The lawsuit did not create the burden. It was my response to a burden that already existed.

Political What I Mean by "Political Sabotage"

Sabotage does not require destruction by explosives, hacking, or some formal political operation. In ordinary usage, it means deliberately damaging, obstructing, weakening, or undermining a person, organization, project, or effort.

In this article, I use political sabotage in two related senses:

By motive, if evidence ultimately shows that the record was created or reinforced in order to damage my political, civic, or government-accountability work.

By effect, where the resulting record objectively operated to undermine that work regardless of whether a political motive can ultimately be proved.

The present record does not yet establish a single motive shared by every participant. But the political effect is not speculative. The ICRC file preserved allegations capable of discrediting me as a civil-rights advocate, damaging Wild Willpower's public work, and later devastating a candidacy once I entered electoral politics.

 

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VI. The Severe Time Constraints, What I Filed,
and How the Claims Became Developed Across Four Petitions 

Fifty-Five Days Turn the Newly-Revealed Record Into a Lawsuit

The unusually compressed development of the pleadings cannot be separated from the administrative process that preceded them. I received the complete respondent file only fifty-five days before the right-to-sue deadline expired. Whether that process itself creates any separate basis for equitable or other relief is a legal question I am evaluating separately; here, its significance is factual and procedural: it materially constrained the time available to reconstruct and plead a complex multi-defendant case.

Because the evidentiary reconstruction developed over time, not every claim or legal argument appeared in identical form in every pleading. Where relevant below, I link the pleading in which a particular claim was asserted or more fully developed.

What is a Claim?

A claim is the legal basis on which a plaintiff asks a court for relief. A claim is not itself proof, and pleading a claim does not mean a court has found it true. The question at this stage of the series is narrower: what claims did I present or seek to present, and what evidence did I contend supported them?

My claims developed over several pleadings as I reconstructed the record. I filed the original petition under the December 5, 2023 deadline, then sought to amend as additional evidence, causes of actions and legal arguments, and relationships among the facts became clearer. The later proposed pleadings were substantially more detailed because by 2026 I had spent years reconstructing evidence I had possessed for only fifty-five days before the original filing deadline.

 

 

The Burden of Proof in Civil Cases is Different Than in Criminal Cases

The burden of proof is the level of persuasion a party must satisfy before a factfinder may decide an issue in that party’s favor. Different kinds of proceedings and different claims can require different burdens.

The familiar criminal standard—beyond a reasonable doubt—does not govern ordinary civil claims.

In civil litigation, many factual propositions are decided under the preponderance of the evidence standard: whether the evidence shows that a fact is more likely true than not.

Some civil claims impose a more demanding formulation. Iowa fraud cases, for example, describe the proof as a preponderance of evidence that is clear, satisfactory, and convincing.

The important distinction for this article is that pleading a claim is not the same thing as proving it at trial. At the pleading stage, the question is whether the allegations are legally sufficient to state a claim. Discovery and trial are the stages in which disputed facts and evidentiary burdens are ordinarily developed and tested.

That distinction matters here because the evidence I present is largely documentary and circumstantial: original communications, later submissions, chronology, transmission pathways, inconsistent accounts, and surrounding conduct. The question is not whether I possess an admission saying, “we conspired” or “I intended to defraud her.” The question is what reasonable factual inferences the combined record supports.

The Claims Developed as the Record Developed

The claims and legal arguments in this case did not all appear in identical form on December 5, 2023.

I received the complete ICRC file only fifty-five days before the filing deadline. I then had to preserve the case while self-represented, attending school, meeting litigation deadlines, and continuing to reconstruct a multi-party evidentiary record that would ultimately take years to organize.

My pleadings therefore became more detailed as the documentary record became more organized and as I learned how the facts related to particular causes of action.

That development can be seen directly in the filings.

The increasing length and specificity of these pleadings should not be mistaken for claims invented years after the fact. In several instances, the later pleadings separated, refined, or supplied legal labels for factual allegations or grounds already appearing in earlier filings. In other instances, later-occurring litigation conduct created claims that could not have existed in December 2023.

My June 22, 2026 Reply Brief in Support of Renewed Motion for Leave to File Second Amended Petition (D0105) put the problem succinctly: after the October 2024 ruling, I was still attempting to reconstruct:

“a complex record involving multiple Defendants, multiple entities, multiple projects, ICRC submissions, disputed chronology, and alleged documentary distortions,”

while the deadline for reconsideration fell immediately before final examinations at Iowa State University.

The same June brief says the Revised Second Amended Petition was necessary to:

“place the exhibit-supported allegations before the Court in organized form”

December 5, 2023:
Original Petition:
Filed in Polk County Before Judge Gronewald

My December 5, 2023 2-page petition (see D0001, pp. 143-144) was intentionally short because I was filing under a hard deadline in Iowa's notice-pleading system. It expressly identified discrimination, fraud, promissory estoppel, and defamation, described the underlying dispute, and requested relief. Iowa Rule of Civil Procedure 1.403(1) requires a “short and plain statement” of a claim—not a completed evidentiary presentation. I wrote

“this action involves the torts of discrimination, fraud, promissory estoppel, and multiple acts of defamation (libel per se) against me.”

The original petition expressly identified discrimination, fraud, promissory estoppel, and defamation. It also alleged facts later developed into my unjust-enrichment claim, including that defendants retained the benefit of months of labor I would not have performed had I known the agreement would be breached.

The defense nevertheless challenged the petition's specificity and organization, including under Rule 1.412 and the more-specific-statement procedure. Those procedural disputes became part of why later pleadings grew dramatically in length.

Amended Petition:
Filed June 17, 2024 in Story County Before Judge Currie

 

In my Amended Petition (D0020) I articulated my claims with additional clarity, albeit the drafting of this petition was performed under severe time constraints. I wrote:

“The nature of this action involves the tortious acts of unjust enrichment, defamation, discrimination, promissory estoppel, and fraud performed by the various Defendants, who, through their seemingly coordinated and malicious acts, caused and continue to cause severe harm to me.”

And conspiracy was already being alleged factually, even though it was not yet separately enumerated as its own count. The same petition referred to Esker as a “co-conspirator” and described coordinated/fraud-scheme allegations.

January 6, 2026:
Proposed Second Amended Petition:
Filed in Story County Before Judge Doyle

My Second Amended Petition (D0079) clarified additional claims:

— Promissory estoppel

— Promissory estoppel

— Defamation

— Iowa constitutional equality claim

— Unjust enrichment

— ICRA retaliation

— Fraudulent misrepresentation to a government agency

— Abuse of process

— Civil conspiracy

— Tortious interference with contractual and prospective relations

June 15, 2026:
Proposed Revised Second Amended Petition:
Filed in Story County Before Judge Doyle

My proposed Revised Second Amended Petition (D0100) became even more tailored to the reconstructed evidence. It separately pleaded, among other claims:

— Breach of oral and implied-in-fact contract — Garden Agreement

— Breach of oral and implied-in-fact contract — Prairie Agreement

— Promissory estoppel — Garden Agreement, in the alternative

— Promissory estoppel — Prairie Agreement, in the alternative

— Unjust enrichment

— Defamation

— False light invasion of privacy

— Iowa constitutional equality claim

— ICRA retaliation

— Conspiracy

— Declaratory judgment

— Abuse of process

And its preliminary statement expressly alleged that defendants had submitted material that was:

“false, misleading, defamatory, selectively excerpted, rearranged, altered, or otherwise presented in a manner that created false impressions concerning Plaintiff's conduct.”

It further alleged that certain materials:

“changed their apparent meaning, reversed the chronology of events, and created false and misleading impressions during the ICRC investigation.”

Why the Civil-Conspiracy Claim Became More Developed in the Later Pleadings

The progression above is especially important to understanding the civil-conspiracy claims.

I did not possess the complete factual record when this dispute began or even while the ICRC was investigating my complaint. I knew from the Preliminary Case Review that serious accusations had been made, but I did not receive the respondents' complete statements and supporting materials until October 11, 2023—only fifty-five days before I had to file suit.

Only after receiving that file could I begin comparing the respondents' separate submissions against one another and against the contemporaneous messages, project records, agreements, photographs, and other evidence I had preserved.

That comparison revealed facts that were not apparent from the ICRC's summary alone: overlapping allegations, common intermediaries, statements addressing matters outside a participant's documented involvement, selected or out-of-context communications, mutually reinforcing narratives, and Exhibit D-3's altered chronological presentation.

Those facts are why my civil-conspiracy theory became progressively more developed as the litigation continued. I had already alleged coordinated or conspiratorial conduct in my 2024 amended pleading, but the later proposed amended petitions pleaded the theory more formally after I had spent substantially more time reconstructing the administrative record and identifying the relationships among the evidence.

That development should not be confused with inventing a new factual dispute after the fact. The underlying conduct was already contained in the ICRC materials; what changed was my ability to see, organize, compare, and legally characterize it.

The procedural history then created another obstacle. Before ordinary discovery occurred, I was required to respond to overlapping disputes concerning service, venue, dismissal, pleading specificity, amendment, and other procedural matters. Yet many of the facts necessary to establish the full extent of any agreement—private communications, authorship, transmission, knowledge, and the respective roles of the participants—remained within defendants' possession or knowledge.

By the time I formally pleaded civil conspiracy in the later proposed amendments, I had enough circumstantial evidence to allege coordinated action, but still needed discovery to determine the agreement's actual scope, participants, knowledge, and purpose.

The district court did not grant leave for those later pleadings to become operative. That is why conspiracy is not merely an evidentiary issue in this series; it is also an amendment and access-to-discovery issue I intend to raise on appeal.

The question is therefore not whether I could prove the entire conspiracy before discovery. The question is whether the facts available to me were sufficient to permit amendment and discovery into a claim whose most probative evidence necessarily concerned communications and agreements among the defendants themselves.

 

Resistances, Replies, and Reply Briefs:
Filed Subsequently After the Various Petitions, to Support the Pleadings

My later resistances, replies, and briefs do not automatically become pleadings merely because they were filed. But they are part of the procedural record and show what factual allegations, evidence, and legal arguments I repeatedly brought to the Court's attention as the record developed. Rule 1.457 separately recognizes that, where issues outside the pleadings are actually tried by consent, they may ultimately be treated as though pleaded.

Because this case never reached discovery and trial on the disputed factual claims, I was never able to reach the stage at which the evidentiary record could be fully developed and, where appropriate, conformed to the pleadings.

The links below allow readers to compare the claims as I pleaded them at different stages with the evidence presented above. Later installments—especially Dangerous Precedent—examine what happened procedurally to those claims and why I contend several were dismissed prematurely.

 

 

 

VII. What the Claims Mean —
and How the Evidence Supports Them

 

Garden and Prairie Agreements — Claims Based on the Agreements and My Labor

 

Exhibit C also supports claims that are independent of the later reputational narrative. I alleged that the garden and prairie arrangements constituted oral or implied-in-fact agreements and later pleaded promissory estoppel in the alternative. The communications document approval, delegated responsibility, performance, expenditures, and acceptance of benefits.

The same evidence therefore performs two jobs: it supports my contractual/reliance theories while also contradicting the later characterization that I simply inserted myself into projects without authorization.

Breach of oral and implied-in-fact contract

Promissory estoppel

Unjust enrichment

Claims Based on the False and Misleading Record

Defamation and false light — recasting the contemporaneous record

 

The defamation and false-light theories arise from the later descriptions of conduct documented very differently in the contemporaneous record: approved project work characterized as unauthorized or obsessive; a friendly relationship reframed through stalking and harassment; and contextual communications used to support allegations of racism and anti-LGBT+ misconduct.

The evidence matters because the dispute is not merely over whether someone's opinion of me later changed. The exhibits permit direct comparison between specific factual characterizations and the underlying communications from the time.

Fraud — a pattern of circumstances pointing toward intentional deception

Fraud is rarely proved by an admission that someone intended to deceive. Courts frequently infer fraudulent intent from surrounding circumstances considered together.

Legal authorities sometimes describe suspicious circumstances carrying evidentiary force as “badges of fraud” or indicia of fraud. The traditional “badges of fraud” doctrine developed largely in fraudulent-transfer cases, so I do not contend that every traditional badge applies here. I use the concept more generally to describe circumstances which, considered together, support an inference of intentional deception rather than mistake or innocent misunderstanding.

The ICRC record contains multiple such circumstances:

• contemporaneous communications sharply contradicting later descriptions of the same conduct;
• multiple accounts converging around the same damaging narrative;
• a supporting witness repeating detailed allegations concerning projects in which that witness was not involved;
• private messages excerpted or presented without their full context;
• allegations escalating from interpersonal discomfort into stalking and harassment;
• and D-3, in which an added date and caption changed the apparent chronology of the underlying communication.

Any one circumstance might be explained away in isolation. Their combination has substantially greater evidentiary force.

That pattern is one reason I pleaded fraud and later developed a more explicit civil-conspiracy theory.

Civil conspiracy — the evidence of concerted action

 

My later civil-conspiracy claim was based on more than the fact that several people said negative things about me. It was based on the pattern of shared information, overlapping participants, common intermediaries, mutually reinforcing accounts, escalation of allegations, and supporting materials assembled around those accounts.

Civil conspiracy generally concerns two or more persons acting in concert toward an unlawful objective or using unlawful means toward a common objective, resulting in injury. The agreement need not necessarily appear in a written contract; the theory can depend upon circumstantial evidence of concerted conduct.

I contend the record strongly supports an inference of coordinated action. Discovery remains important not because the existing evidence shows nothing, but because it may identify the full membership, communications, division of roles, knowledge, and scope of that coordination.

Claims Based on Retaliation and Later Procedural Conduct

ICRA retaliation

Tortious interference

Abuse of process

Iowa constitutional equality claim

 

 

 

 

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VIII. How Procedural Irregularities Prejudiced My Rights
and Prevented the Evidence From Reaching Ordinary Discovery and Factual Adjudication

The evidence presented in this article was not left unexamined because I waited until after dismissal to claim that it existed.

The problem began before the lawsuit: the accusations acquired institutional permanence before I acquired equal access to the record necessary to rebut them. The litigation was my attempt to correct that asymmetry. The procedural history that followed repeatedly prevented the factual comparison from reaching ordinary discovery and adjudication.

Before the court ruled on my amended petition, I had already identified the need for discovery, organized a substantial documentary record, described that evidence throughout my pleading, and relied upon court orders directing the parties to prepare for an evidentiary component to a combined hearing.

What followed was not one isolated procedural event.

At multiple turning points, the procedural path changed in ways that prevented the factual record from being fully developed while operating to defendants' advantage. I contend that the cumulative effect materially prejudiced my ability to present, clarify, preserve, and ultimately obtain adjudication of my claims.

The first major example occurred in 2024, when the court established an evidentiary process for a combined hearing, I relied upon it for months, defendants objected only after the expanded pleading and organized evidentiary structure had become visible, and the court foreclosed the evidentiary presentation three days before the hearing.

That was not the final instance.

The later history—including dismissal with prejudice, the circumstances surrounding reconsideration, subsequent motions for leave to amend, discovery, and the eventual foreclosure of trial—shows additional points at which the ordinary path toward factual development was interrupted.

The complete 2024 sequence is reconstructed in Sudden Reversal. Later installments document what followed. This section brings those stages together for one purpose: to explain why, after years of litigation, the central evidence still has not gone through the discovery, authentication, factual development, and adjudication that I sought from the beginning.

March-April, 2024:
Judge Gronewald and the Transferred Record —
I Had Already Explained Why Discovery Was Necessary

 

he discovery problem did not begin with Judge Currie. It was already visible in the first defense filings. Defendants demanded defendant-specific facts concerning conduct, knowledge, agreements, and responsibility, while I repeatedly explained that some of those facts concerned private communications and information exclusively within defendants' control. I therefore identified discovery as necessary before the case was transferred to Story County.

In my March 15 omnibus filing, I explained:

“One of the primary purposes of this action is to substantiate the claims asserted; this will generally occur during the discovery process and trial. Thus far no government investigation and thorough review of evidence has occurred.”

March 15 omnibus filing, p. 5, ¶ 4; D0001, p. 92.

I also objected to dismissal at that stage:

“I object to Defendants’ multiple requests to dismiss this action in its entirety, as they are attempts to deny me due process and disallow evidence and testimony to be presented....

Upon reviewing the evidence, it will become self-evident to the judge the exact reason Defendants have gone to such great length to try to prevent evidence from being examined.

It would create a miscarriage of justice to dismiss this case during this early phase of the action.”

March 15 omnibus filing, pp. 16–17; D0001, pp. 103–104.

In an April filing, I separately explained that defendants' lack of transparency had made it impossible for me to identify each person's precise role and that interrogatories and depositions were necessary to determine who knew what, who submitted what, and how the participants were connected.

The distinction mattered then, and it matters now: some facts were supported by evidence I already possessed; others concerned private communications, authorship, knowledge, coordination, motive, and individual participation that I could not obtain without discovery.

The Polk County Sequence Also Became Part of My Later Abuse-of-Process Claim

One circumstance supporting my later abuse-of-process allegation was the sequencing of the service challenge. Five defendants sought to quash service before transfer. Four days after Judge Gronewald granted the requested transfer to Story County, those same defendants accepted service and immediately joined the remaining motions to dismiss, recast, and require greater factual specificity.

That sequence does not require me to speculate about a private conversation or undisclosed motive. The procedural change itself is documented in the docket. What it meant, why the service objection ceased to matter after transfer, and how that sequence bears upon the proper use of judicial process are questions I analyze more fully in Procedural Bombardment.

A second recurring pattern also began during this phase. Emergency filings I made to keep the case alive while studying abroad were later cited as evidence that additional time was unnecessary. Defendants argued that because I had demonstrated an ability to “ably file documents from London,” I did not need the limited continuance I was requesting—even though my professors had granted academic extensions so I could make those court filings.

That procedural pressure became self-reinforcing: the work I completed by sacrificing time from my education was then used as evidence that I could absorb still more litigation. That pattern would become more consequential in later proceedings when requests for additional time were characterized as part of a supposed history of delay.

The evidence in this article did not remain unexamined because it was discovered only after dismissal. I had already identified and organized substantial portions of it before the October 2024 ruling, while other essential facts remained within defendants’ control and required discovery. The procedural sequence that prevented that record from reaching ordinary factual development is reconstructed in full in Sudden Reversal.

Plausible Deniability documents the requests, responses, academic schedule, and consequences in detail.

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X. Why Discovery Never Happened, Why It Is Still Necessary, and What the Iowa Supreme Court Can Do About It

A plaintiff must adequately plead a legally cognizable claim; she is not ordinarily required at that stage to prove disputed facts as though the case has already gone through discovery and trial.

 

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XI. Why "Justice So Requires" Further Proceedings

"Justice So Requires"

 

Iowa Rule of Civil Procedure 1.402(4) states that leave to amend:

“shall be freely given when justice so requires.”

My position on appeal is not that the Iowa Supreme Court should decide these disputed facts itself. It is that claims supported by unresolved factual disputes, documentary evidence, and issues requiring discovery should not have been permanently terminated before those processes occurred.

I am asking for the opportunity to return the claims to the district court, clarify the pleadings where necessary, conduct discovery, authenticate and test the evidence, and present triable factual disputes to a jury where the law provides that right.

 

 

Remand for Further Proceedings

I am asking the Supreme Court to reverse the rulings I challenge and return appropriate claims to the district court so the unresolved factual disputes can be developed and adjudicated through the ordinary civil process.

Discovery and Trial by Jury

Remand would potentially restore:

• discovery;
• depositions;
• document requests;
• authentication;
• source/knowledge questions;
• evidentiary rulings;
• and, for triable issues where the right applies, jury determination.

Right to trial by jury is inviolate. 

 

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XII. Where This Case Goes Next

This record is still legally relevant.

I am presently organizing these materials not only for public examination, but also for appellate use as I prepare filings due before the Iowa Supreme Court. I am asking that claims dismissed below be reinstated and returned for further proceedings.

If the case is remanded, factual questions involving authorship, transmission, knowledge, intent, coordination, authenticity, and the meaning of the documentary record may still be developed through discovery and adjudication.

I remain self-represented and would welcome assistance from qualified appellate or civil-litigation counsel willing to review the record. Attorneys interested in discussing possible representation or assistance may contact me at Sondra.Wilson777@gmail.com.

 

Judge Doyles final dispositive order denying my consolidated motions to reconsider or amend (D0114) was issued on August 11, 2026. Rule X allows 30 days to file Notice of Appeal. Mine is due September 10. 

The Iowa Rules of Civil Procedure would allow me to potentially file the following documents which would substantially assist the court in reviewing this case for consideration to remand: 

[list of possible types of filings).

I am currently finishing the development of this article series , with docket numbers, dates of filing, and direct quotes, brought into context, to help the public follow the case and to assist me in preparing upcoming filings. Wild Willpower is broadcasting this series for First Amendment purposes, as the outcome of this case is of public interest for three primary reasons. These reasons are articulated on the series landing page. The landing page will not be fully updated until the rest of the series is complete.  

 

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OLD SOURCE MATERIAL — DO NOT PUBLISH IN THIS LOCATION

The material below contains earlier drafts, chronology, legal arguments, and factual observations that may be moved into Sections VIII–XI or later installments. Much of it has already been incorporated above and should not remain in the final article in duplicate form.

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XI. Why the Evidence Has Not Yet Been Fully Adjudicated

The absence of factual adjudication to date does not mean these questions can never be examined. They remain among the issues I am asking the Iowa Supreme Court to return for further proceedings.

 

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When I finally received the file, I found that the accusations, as described in the ICRC's Preliminary Case Review, were much less severe than what the file actually contained. In addition to the false statements accusing me crimes and misconduct, a modified document and out-of-context messages between myself and the defendants were used in order to bolster these collaborative narratives.

The case file, therefore, validated my concerns that defendants intended to file false charges against me in retaliation for filing the complaint, and probably for political reasons as well. They were aware that I was building a lawsuit that would later become Wilson v. State of Iowa and Kim Reynolds for Iowa, and that I was politically active with the organization I founded years before, Wild Willpower. They also knew about the previous arrests, including the older 2009 assault record I had on my criminal record, because I recounted these experiences at Reliable Street's open mic only 2 days before I was unexpectedly barred from the premises on March 31, 2022, as documented in Record Retaliation.

And when I finally received this file, which exposed a local conspiracy involving fraud, defamation, and other complex claims I had no idea how to effectively prove in court, the ICRC's statutorily regulated process, built and signed into law by Iowa's legislative and executive branches, left me with only fifty-five days to file in court  without the help of an attorney.

I have always known, since first reading the review and seeing the description of what the defendants wrote, that the Reliable Street records were deliberate rather than mere accidental. By comparing the contemporaneous communications laid out in Part One of this series, Record Retaliation, with the statements and altered documentary record the defendants sent to the Iowa Civil Rights Commission, as laid out in Part Three, Political Sabotage, you will find what I have been attempting to prove for years. And, if you read through this long series of articles, you will learn how my evidentiary exhibits were prevented from being operative (the court did not consider them), and how discovery process was never allowed to take place (yet).

I had also spoken with people in the Reliable Street community about the lawsuit I had already been developing concerning government violations of transgender rights.

This was not a vague discussion about politics or discrimination.

I was discussing the legal framework I had been studying and the case I was trying to build—including federal civil-rights laws addressing conspiracy against rights and deprivation of rights under color of law.

At that time, I had not yet discovered Iowa's Ongoing Criminal Conduct Act, which I would later use to connect the alleged pattern of unlawful conduct in Wilson v. State of Iowa and Kim Reynolds for Iowa (see Popularizing Discrimination to learn more about that section of the lawsuit). But I was already thinking in terms of recurring rights violations, governmental actors, federal civil-rights protections, and the possibility of litigation challenging what I understood to be unlawful State conduct.

My later Amended Petition described that work as a lawsuit I had been

“building ... for several years following more than a decade of diligent legal research.”

That context matters because, when the Reliable Street dispute later produced allegations portraying me as stalking, harassing, obsessive, racist, intrusive, and dangerous, I had reason to be concerned about more than an ordinary interpersonal conflict.

People in that community knew I was studying and discussing serious claims involving government misconduct and civil-rights violations.

I cannot establish from the records presently available what motive any particular respondent had when the ICRC submissions were prepared. But I also do not want to erase the political and legal context that existed before those submissions were made.

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Why This Case Still Matters Under Iowa Law in 2026

 

This case is sometimes described as a civil-rights case because it began with a complaint filed under the Iowa Civil Rights Act. But the litigation that followed is broader than a discrimination claim.

It also involves allegations and proposed claims concerning fraud, defamation, conspiracy, false light, unjust enrichment, tortious interference with contractual relations, promissory estoppel, abuse of process, and related torts and constitutional issues, many of which are examined separately in later installments of this series.

A reader does not have to agree with me about transgender policy—or even care about transgender politics—to understand the legal questions raised by this record.

The core questions are familiar ones: whether people may place materially false or misleading information into government proceedings; whether documents may be altered or presented in a way that changes their apparent meaning; whether reputational injury can be redressed; whether parties should receive discovery into disputed authorship, motive, and coordination; whether courts should decide contested factual questions without allowing the evidence to be developed; and whether legal rights that existed when an alleged injury occurred can later receive meaningful adjudication.

Iowa’s civil-rights structure and law have also changed substantially since the events underlying this case occurred.

As of July 1, 2024, the Iowa Civil Rights Commission is based within the Iowa Office of Civil Rights, and the Commission was reduced from seven members to five gubernatorially appointed commissioners.[1] More significantly, in 2025 the Iowa Legislature enacted Senate File 418, which removed gender identity as a protected basis under Iowa Code chapter 216, effective July 1, 2025.[2]

Those later changes did not govern the events underlying this case. When the conduct at issue occurred in 2022, when I filed my complaint with the Iowa Civil Rights Commission, when the Commission processed and administratively closed that complaint, and when the right-to-sue process occurred in 2023, gender identity remained expressly protected under the Iowa Civil Rights Act.[3]

That distinction matters. The discrimination component of this litigation arises from conduct that allegedly occurred while Iowa law expressly protected transgender people from discrimination in public accommodations and other covered areas. The later removal of gender identity from the statute did not change what Iowa law provided at the time of the underlying events.

My later proposed amended pleadings also asserted an independent equality claim under the Iowa Constitution. Those proposed pleadings were not permitted to become operative, and I am continuing to develop and preserve that constitutional theory as part of my efforts to obtain further district-court and appellate review.

This case may therefore be among the later Iowa cases arising from conduct that occurred while gender identity remained expressly protected under the Iowa Civil Rights Act. I do not suggest that it is the final such case; claims involving pre-July 1, 2025 conduct could continue to arise or remain pending after the statutory change.[4]

That change in Iowa law makes the historical record in this case more—not less—important. But the importance of the case does not depend upon readers sharing my identity, political views, or understanding of civil-rights law.

It concerns broader principles that should matter across ideological lines: truthful records, fair process, access to evidence, protection against defamation and fraud, meaningful discovery, judicial review, and the ability to obtain a decision based upon the facts and law.

For me, that makes this case about more than restoring my own claims. It is also about whether legal rights that existed when an injury occurred can receive meaningful enforcement—and whether any Iowan, regardless of politics or identity, can reasonably expect serious factual disputes to be examined before they are permanently resolved.

I. Before Examining the Evidence: Why the Court Never Conducted the Factual Inquiry I Was Seeking

The second is especially good because it precisely describes your contention without requiring the reader to accept a legal conclusion before seeing the chronology.

Then immediately explain:

Some of these materials were filed or tendered at different stages of the litigation. The problem was not simply that the court had never physically received a document. The problem was that my repeated efforts to make the full evidentiary record part of operative claims, obtain discovery into disputed authorship and intent, and secure adjudication of those facts were unsuccessful.

---

 

I. Why the Evidence Was Not Examined by the Court, 
Despite Repeated Efforts

Before asking readers to judge the evidence, explain why no court has yet done the full evidentiary comparison the article is about.

That section could establish:

— December 5, 2023: two-page notice-pleading petition filed under the 55-day deadline.

— February 2024: multiple defense motions begin consuming the case.

— your repeated attempts to amend and develop claims;

— the court's initial invitation to provide evidence;

— your preparation of the exhibit record;

— the subsequent limitation or withdrawal of that opportunity;

— later attempts to attach Exhibits A–F to amended pleadings;

— the fact that those proposed pleadings never became operative;

— discovery requests or attempts and what happened to them;

— later summary-judgment/privilege rulings;

— therefore, why the evidentiary record the public is now seeing was never tested in the manner you were seeking.

Then make the transition:

The absence of a merits determination does not mean the evidence was examined and rejected. Much of the central evidence was never reached in the procedural posture in which I was attempting to present it.

That is why Part Three now turns to the evidence itself.

the ICRC file was finally received October 11;
the deadline was December 5;
the file revealed mutually reinforcing accounts, approved work characterized differently, disputed chronology, and questions of authorship;
the evidentiary reconstruction ultimately grew to more than seventy exhibits;
the opening petition therefore had to preserve claims before the complete reconstruction was finished.

I am presently reconstructing this record not only for public examination and appellate review, but also because I intend to ask the district court, through whatever post-judgment procedure is properly available, for leave to place a fully developed amended and supplemental pleading before the court. Iowa Rule of Civil Procedure 1.402(4) provides that leave to amend “shall be freely given when justice so requires.” Whether justice requires that relief in this case will be one of the questions I ask the court to decide.

II. Political Sabotage

 

November 2, 2022 — The Civil-Rights Record Reopened an Older Court Record

 

The Reliable Street dispute also forced me to reopen a much older chapter of my life.

Two days before I was barred from Reliable Street, I had described the traumatic experiences I had back in 2006 and 2009 with the Ames police and courts during an open-mic performance. After reading the accusations later summarized by the Iowa Civil Rights Commission, I became concerned that the criminal record resulting from those events might be used to reinforce the new portrayal of me as threatening, intrusive, or prone to harassment.

That concern led me, in November 2022, to obtain copies of the old court dockets. 

For years, I had believed that the attorney who assisted me after the 2006 arrests had secured an apology from the City of Ames, obtained a $1,500 payment, and helped establish a precedent protecting transgender people. That was what I distinctly remember that he told me, because it became an important part of my memory of this extraordinarily painful experience.

The court records caused me to understand the matter very differently. I discovered filings indicating that my not-guilty pleas had been changed to guilty pleas through an agreement I did not authorize and had never been shown. I also found that the filings identified me under my former name and as male. The records requests I later submitted to the City of Ames and Story County did not locate an official copy of the apology letter or documentation establishing that the payment and letter had been incorporated into the court record as the precedent I believed had been created.

After discovering this, I filed a complaint with the Iowa Supreme Court Attorney Disciplinary Board. The attorney maintained that I had verbally consented to the plea changes—something I would not have done, and I certainly was never told about. The Board acknowledged that the better practice would have been to obtain my signature or retain written documentation of the conversation and consent. But because the matters were approximately seventeen years old, the attorney no longer had the file, and the Board believed memories could fade or change, it concluded that it could not independently verify what had occurred and dismissed the complaint.

The attorney maintained that I had verbally consented to the plea changes. That is not what happened. I remember the agreement clearly: I agreed to accept an apology letter, a $1,500 payment, and what I was told would help establish a precedent. I did not authorize guilty pleas, and I was never told that my not-guilty pleas would be changed. I learned years later that the filings did not reflect the agreement as it had been represented to me.

The Attorney Disciplinary Board did not determine that the attorney’s account was true. It concluded that, because approximately seventeen years had passed, the attorney no longer retained the file, and there was no written documentation of my consent, it could not meet its burden of proving misconduct. The result was that the dispute became my word against his—not because my memory was uncertain, but because the safeguards that could have documented the truth had never been used.

That experience became part of the reform requested in my later lawsuit against the State of Iowa and Kim Reynolds for Iowa. I argued that clients should have a protected right to review material filings made on their behalf and that attorneys should be required to obtain documented client approval before changing a plea, settling a matter, or making other decisions that belong to the client. My petition described this as a proposed “right to review,” intended to prevent future disputes from becoming unverifiable contests between an attorney’s memory and a former client’s memory.

2022–2023 — Two Limitations Periods Were Closing at Once

 

The discovery created a second and uncertain limitations problem.

I am not an attorney. I was a low-income, self-represented person attempting to determine which Iowa laws applied to conduct I alleged had been concealed from me for approximately sixteen years. In researching the issue, I found Iowa Code section 802.5, which provides an additional period following discovery when fraud or breach of fiduciary obligation is an element of an offense. I understood that provision to mean that I could not safely wait longer than one year after discovering what had occurred.

Section 802.5 appears within Iowa’s criminal-procedure laws and governs the time allowed for commencing a prosecution, rather than directly establishing the filing period for a private civil action. I did not understand that distinction when I prepared my petition without counsel. Iowa’s civil discovery rules, tolling doctrines, and claim-specific limitations periods presented separate and considerably more complicated questions that I was not professionally trained to resolve.

What mattered practically was that I had discovered the plea changes on November 2, 2022, and could not responsibly assume that Iowa law would allow me unlimited additional time to act. I therefore treated the approaching one-year anniversary as a deadline I could not safely disregard. Before filing suit, I attempted to pursue the available administrative remedies, including a complaint to the Attorney Disciplinary Board and a claim through the Iowa State Appeal Board.

In my later petition, I argued that the filing periods should not have expired before I had a reasonable opportunity to discover the concealed conduct and act upon it. I relied upon discovery-based rules and equitable doctrines, but the court never resolved which limitations periods or tolling principles properly governed each claim.

This was not a situation in which a represented litigant knowingly selected among clearly explained legal rules. It was an unrepresented person trying in good faith to preserve potentially expiring claims while navigating multiple statutes, administrative prerequisites, and overlapping cases without access to affordable legal counsel.

At the same time, deadlines governing the Reliable Street dispute were also approaching. The broader two-year period for claims involving injury to my person or reputation continued to run, and requesting the right-to-sue letter would trigger a separate ninety-day deadline for filing the civil-rights action. I was therefore attempting to preserve one case arising from evidence I had only recently discovered while preparing another case whose complete administrative record the Iowa Civil Rights Commission had still not released.

This is why the two cases overlapped. The Reliable Street accusations prompted me to investigate the old record. The old record revealed an additional dispute requiring administrative complaints, records requests, legal research, and eventually separate litigation.

While I was trying to obtain and understand the Reliable Street file, I was also trying to preserve claims arising from the newly discovered court record. Deadlines associated with both matters were moving toward me at the same time.

That is why I ultimately filed both Wilson v. Reliable Street Inc., et al. and Wilson v. State of Iowa and Kim Reynolds for Iowa within the same period.

September 8, 2023 — Why I Finally Requested the Right-to-Sue Letter

 

By September 2023, I had spent more than a year attempting to obtain counsel and assistance.

The Commission had directed me toward private attorneys. Private counsel remained unaffordable or unavailable. Legal-aid organizations could not take the case. The Ombudsman could examine procedure but not decide the disputed facts. Law enforcement did not undertake the requested investigation. The EEOC did not independently resolve the allegations. Other government contacts did not correct the record.

I eventually faced a choice:

Continue searching indefinitely while the underlying file remained hidden, or request the right-to-sue letter, begin the ninety-day deadline, and finally obtain the documents necessary to understand what had been submitted.

On September 8, 2023, I requested the right-to-sue letter and immediately requested the complete case file.

The petition records that sequence as the step I took only after contacting more than fifty attorneys, legal-aid organizations, law-enforcement offices, the Attorney General’s Office, the Ombudsman, and the EEOC.

October 11–December 5, 2023 — Fifty-Five Days to Examine the File and File Suit

 

The events that initially gave rise to my claims occurred on March 31, 2022.

Iowa Code 614.1(2) generally allows two years to bring actions involving injury to a person or reputation. Based upon that provision, the outside deadline for claims governed by that limitations period appeared to be March 31, 2024.

On paper, two years may sound like ample time.

But I did not possess the respondents’ underlying submissions for most of that period.

The Commission had closed my complaint in August 2022, yet it would not provide the complete case file unless I first requested a right-to-sue letter. That step ended the Commission’s involvement and imposed a separate ninety-day deadline for commencing the civil-rights action.

I delayed taking that step because the Commission itself had warned me to consult an attorney first. I spent the intervening period attempting to obtain representation, appeal the closure, seek review from the Ombudsman, contact legal-aid organizations, pursue the EEOC process, and determine whether any government office or law-enforcement agency could examine the allegedly false information.

None of those efforts gave me access to the complete record or produced representation.

Eventually, I had to choose between continuing to search for help without seeing the evidence or requesting the right-to-sue letter, ending the administrative process, and beginning the ninety-day litigation deadline.

I requested the letter in September 2023 and immediately sought the complete file.

The Commission did not provide the complete case file until October 11, 2023.

By then, the right-to-sue deadline required me to commence the civil action by December 5, 2023.

Although approximately eighteen months had passed since March 31, 2022, I had possessed the underlying evidence for none of that time.

Once the file finally arrived, only fifty-five days remained before I had to sue.

For the first time, I could read the respondents’ submissions in their own words and compare the supporting materials with the original communications in my possession.

I allege that the file revealed:

• mutually reinforcing narratives from multiple people;
• approved work later characterized as unauthorized or intrusive;
• excerpts presented without their complete surrounding context;
• communications involving Willa Colville presented in a manner that distorted their chronology;
• private messages involving Denise Martinez used to support allegations of racism and anti-LGBT+ hostility;
• and statements from Charlie Esker describing conduct Esker claimed to have personally witnessed despite earlier communications suggesting limited involvement.

Readers can examine the respondents’ submissions alongside the original communications in Part Four, Dangerous Precedent, which presents the principal court exhibits and explains the alterations, omissions, chronology disputes, and contradictory accounts I later sought to plead in greater detail.

Those factual allegations were never adjudicated on their merits.

Important questions of responsibility also remained unresolved. The file did not conclusively establish whether Sharon Stewart knowingly transmitted a misleading account or relied upon information supplied by others. Nor did it establish whether Willa Colville altered the disputed message presentation before providing it to Stewart, whether Stewart altered it afterward, or whether both understood how the materials had been presented. Those were among the questions I expected discovery to help answer.

But receiving the file fundamentally changed what I knew.

The Preliminary Case Review had shown me the accusations.

The complete file showed me the underlying submissions and allowed me, for the first time, to examine how those accusations had been constructed and supported.

But receiving the file did not mean that the evidence was suddenly organized, fully understood, or ready to plead.

The case involved seven defendants, communications across multiple platforms, several organizations, competing versions of documents, disputed chronology, questions of authorship and alteration, two judicial venues, and eventually three judges. The complete evidentiary record would grow to include more than seventy exhibits, each of which had to be located, preserved, compared with the respondents’ submissions, placed into chronological order, and explained in relation to an increasingly complex set of claims.

That work could not be completed within fifty-five days. In reality, reconstructing the record would take years.

During those years, I was not working on the evidence under stable conditions. I was completing demanding academic obligations while responding to continuing litigation pressure, managing overlapping cases, researching unfamiliar procedural rules, and attempting to meet limitations periods affecting both Wilson v. Reliable Street Inc., et al. and Wilson v. State of Iowa and Kim Reynolds for Iowa. Later, I was also developing and conducting a statewide gubernatorial campaign.

At the same time, I was living through the consequences of continuing state-level civil-rights and Medicaid disputes affecting transgender Iowans, including interruptions to medically necessary care. The emotional pain associated with those losses existed within a broader national and political climate in which transgender people were repeatedly portrayed as threats by public figures and media personalities. That rhetoric did not remain abstract. It contributed to public harassment and to the continuing fear that ordinary activities—including entering a restroom—could lead to confrontation or arrest.

The result was a pressure cooker. I was expected to reconstruct a concealed and disputed record, identify viable claims, litigate without counsel, remain academically functional, protect my medical and civil rights, and prepare for public office—while mandatory deadlines continued to run.

I therefore could not wait until every exhibit had been fully assembled, every contradiction mapped, every question of authorship resolved, and every legal theory developed. Limitations periods required me to preserve the claims first and continue building the record afterward.

The Iowa Civil Rights Commission had consumed most of the broader two-year period while withholding the materials necessary to understand the case. Then, once I took the procedural step required to obtain those materials, the right-to-sue process imposed its own ninety-day deadline.

By the time the evidence was actually delivered, I had fifty-five days.

During those fifty-five days, I had to:

— review and organize hundreds of messages and records involving seven defendants;

— compare the original communications with the statements and documents submitted to the Commission;

— determine who may have authored, altered, transmitted, or relied upon particular materials;

— identify potentially applicable claims involving discrimination, retaliation, defamation, fraud, breached agreements, and related conduct;

— teach myself how to draft and file a civil petition;

— prepare original notices;

— understand the rules governing service upon seven defendants;

— and preserve the case before the right-to-sue deadline expired.

I had no attorney.

I therefore filed a two-page petition on December 5, 2023, to preserve the action before the right-to-sue deadline expired—even though the evidentiary reconstruction had only just begun.

Iowa Rule of Civil Procedure 1.403(1) requires a petition to contain a “short and plain statement” showing that the plaintiff is entitled to relief. It does not require the opening petition to prove every allegation or include every supporting exhibit.

It was not intended to contain every exhibit, resolve every question of authorship, or prove the entire case. It was a good-faith attempt to preserve the action before the deadline expired under Iowa’s notice-pleading system.

Filing the petition did not create the time needed to complete the evidentiary reconstruction. Almost immediately, the case shifted into disputes over service, venue, pleading sufficiency, recasting, dismissal, and other procedural issues. The time I needed to finish organizing the exhibits and develop the petition was repeatedly redirected toward preventing the case from being dismissed before discovery.

That cycle continued for years. I was never given a quiet period in which I could simply sit down with the complete record, follow every evidentiary thread, and draft the fullest possible petition with access to all necessary information. The case remained under procedural pressure while key evidence concerning authorship, transmission, intent, and coordination remained within the defendants’ control.

That history is part of why the Revised Second Amended Petition I sought leave to file in 2026 includes an abuse-of-process claim. The coming installments explain how the complexity grew, why discovery became essential, and how procedural demands repeatedly displaced the work needed to reach the merits.

The practical effect of the administrative process was extraordinary.

A limitations period that appeared to provide two years for claims involving injury to my person or reputation did not give me two years with the evidence. The Commission retained the underlying submissions while I appealed, sought counsel, and exhausted other possible avenues. When it finally provided the materials, only fifty-five days remained before the litigation deadline the right-to-sue process had triggered.

That is the civil-rights trap described in the title of this article.

The process did not merely fail to resolve my complaint.

It consumed nearly the entire period in which I could prepare to litigate what the process itself had allowed into the record.

That is how litigation became unavoidable.

Not because I rushed toward court.

Because the evidence required to understand and plead the case was withheld until the final fifty-five days.

The administrative process withheld the evidence needed to secure representation and consumed all but fifty-five days of the period available to prepare and file suit.

V. Why My Burden Was Not "Self-Created" —
Filing Wilson v. Reliable Street Inc., et al. Was Necessary to Clear My Name

Why I Went to Court in the First Place

 

What led to the first lawsuit was not a misunderstanding, a private disagreement, or litigation I casually chose to initiate. It was the placement of false, extremely damaging allegations into official records — allegations I believe threatened my safety, reputation, campaign, publications, and future work.

Before going to court, I tried to use the civil‑rights process Iowa provides to people who report discrimination. That process is supposed to investigate disputed facts and help resolve disputes without requiring people to file lawsuits.

That did not happen here.

Instead, my complaint was closed without investigation, while false and damaging allegations remained in government records. Litigation became the only available path to obtain discovery, expose what happened, and clear the record.

That is why I reject the Court’s characterization of this burden as “self‑created.” I did not file suit because I wanted litigation to consume my campaign. I filed because allowing false records to remain unchallenged during a statewide campaign was not a real option.

There was no third option.

Why False Records Become Campaign Weapons

 

Some people may ask why I could not simply ignore the lawsuit and move on. This is why: false records become weapons during campaigns.

But this was never only about one campaign.

Long before I ran for Governor, I had founded Wild Willpower PAC. I had already spent years writing, organizing, building public platforms, and trying to create a legacy rooted in civil rights, public accountability, democratic participation, Indigenous knowledge, environmental restoration, and social repair.

The allegations lodged into the Iowa Civil Rights Commission’s records did not merely threaten a future ballot-access effort. They threatened my life’s work.

They threatened my reputation as an author, advocate, organizer, role model, and public figure. They threatened the credibility of Wild Willpower PAC and the broader work I have done to challenge corruption, institutional abuse, civil-rights violations, and systemic failures in Iowa.

They also threatened work that does not belong only to me.

As an author and organizer, I have worked alongside people whose lives and contributions matter, including Richard Lonewolf, Professor Frank Schiavo, Ashawna Hailey, Bill Hill, and others whose teachings, stories, advocacy, and reputations became connected to projects I helped carry forward. Some are still alive. Others are no longer here to defend the meaning of their work.

That matters deeply to me.

When false allegations enter administrative records, they do not damage only the person named in them. They can contaminate the public understanding of everything that person has built. They cast suspicion over organizations, books, political work, educational projects, cultural work, public advocacy, and the people associated with them.

If Wild Willpower PAC is discredited by a false official record, years—or even decades—of work can be undermined by allegations that were never properly adjudicated. The harm becomes larger than personal reputation. It becomes historical. It affects how that work is remembered, how collaborators are perceived, and whether future readers, researchers, voters, supporters, and institutions consider it credible.

Everything I had worked to build was placed at risk by allegations lodged into administrative records—and therefore preserved within the historical record.

That is why I could not simply “move on.”

Reporters, bloggers, campaigns, opposition researchers, attorneys, government actors, employers, institutions, researchers, and members of the public review court records, administrative records, regulatory filings, and other official documents. When false allegations appear in those materials, they become searchable, quotable, and easily weaponized.

Most people will not read the full exhibits. Most will not ask whether documents were modified, rearranged, selectively excerpted, or taken out of context. They will see the accusation and judge.

That danger becomes even greater during an election. Public records—including court filings, administrative summaries, affidavits, exhibits, institutional emails, and derivative filings—can shape public perception of candidates before any court reaches a final determination. A document is surfaced, quoted, clipped, shared, and amplified. By the time the truth catches up, the political and historical damage may already be done.

This is why confidentiality did not protect me. Even when an administrative file is technically confidential, the narrative inside it can escape through leaks, indirect references, public court filings, summaries, public-records requests, informal circulation, or strategic political use. Civil-rights proceedings often generate secondary records — motions, affidavits, timelines, exhibits, emails, and summaries — that may not remain confidential once they appear elsewhere. Once a respondent repeats, paraphrases, or incorporates allegations from a confidential administrative file into a public filing, the confidentiality barrier begins to collapse.

Confidentiality also creates a one-sided danger. It can prevent the injured person from fully correcting the record publicly while still allowing the false narrative to circulate. A respondent can imply allegations outside the administrative process. A political opponent can hint at “concerns.” A journalist can reference derivative filings. A leak can circulate privately before becoming public. But the person harmed by the false allegations may be restricted from releasing the underlying evidence needed to rebut them. That asymmetry magnifies reputational harm. It does not prevent it.

If a public or semi-public record says a transgender woman, author, organizer, Wild Willpower PAC founder, and candidate for Governor stalked or harassed a female employee, the harm is immediate and severe. That harm is not hypothetical. It is foreseeable. As a transgender woman in a hostile political environment, I knew that false allegations of this kind could be misused to discredit me, dehumanize me, and undermine my campaign before voters ever reached the issues.

That is why I could not simply “move on.” Moving on would have meant allowing false-record allegations to remain unchallenged during a statewide campaign, available to be found, quoted, leaked, summarized, circulated, or used against my campaign and my life’s work. I was not willing to let that happen.

These unresolved records created the conditions that made litigation unavoidable. And that litigation consumed the very weeks Iowa law required for ballot access.

I understood these allegations as carrying a danger beyond their literal wording. In politics, a “dog whistle” is a message that can communicate something more damaging to a receptive audience than it says expressly. Allegations portraying a transgender woman as stalking, harassing, invasive, threatening, dishonest, or sexually inappropriate can operate in much the same way: they can activate preexisting stereotypes without anyone having to state those stereotypes openly.

That was the political danger I saw in the record. The accusations did not have to say, “Sondra Wilson is unfit for public office.” If they surfaced during a campaign, the insinuation could do that work on its own.

II. Why I Suspect It Was Political Sabotage,
and Not Merely Discrimination-Related

I began developing a political organization called Wild Willpower in 2010. Although it was originally designed to

 

Walking away was not a neutral option. The records I was challenging contained allegations of stalking and harassment that I contend were false, together with documents I contend were materially altered. Leaving those allegations unanswered in government records would have left a reputational time bomb behind—one that could be rediscovered, quoted, and weaponized against my work with Wild Willpower or any future political campaign.

That is why calling the litigation simply something I “chose to bring” misses the point of what I was trying to protect myself from.

I Knew Civil Law Could Sometimes Address Conduct That Was Also Criminal

By the time I was forced to prepare Wilson v. Reliable Street Inc., et al. without counsel, I did not have fifty-five days available for leisurely research into every possible Iowa doctrine, historical case, and statutory cross-reference.

I had fifty-five days to review a newly released administrative file, determine what had happened, identify potentially viable claims, preserve those claims before I believed applicable limitations periods expired, and draft a lawsuit myself.

But I was not starting from zero.

I was already familiar with legal dictionaries, legal terminology, and the basic distinction between criminal and civil law. One of the concepts I knew was a “penal action”—a civil action through which a penalty may, in appropriate circumstances, be recovered for conduct prohibited by statute.

That mattered because I had already identified conduct that I believed fell within an Iowa criminal fraud statute.

The Statute I Had Already Invoked: Iowa Code § 714.8(4)

Before filing the civil case, I repeatedly sought a law-enforcement investigation under Iowa Code § 714.8(4).

In a March 25, 2023 email to Ames Police, I wrote that I wanted the matter investigated under the provision stating that a person who:

“makes any entry in... any public records... knowing the same to be false”

is guilty of fraud. I told police that I believed false statements had been entered into the Iowa Civil Rights Commission record and asked them to investigate.

That was not a theory I invented after filing suit.

My June 17, 2024 Amended Petition later recounted the same history almost verbatim. I told the district court that Officer Nicholas Schieffer and I had been discussing my effort to file a complaint concerning what I alleged was a violation of § 714.8, quoting the provision as:

“any person who makes any entry in... any public records... knowing the same to be false, is guilty of fraud.”

The petition then identified what I believed the allegedly fraudulent conduct consisted of: severely damaging statements placed into the ICRC record, a document I alleged had been falsified to bolster those statements, and another document I alleged used out-of-context material to make the statements appear true.

The 2022 Iowa Code in effect during the underlying events listed § 714.8 as “Fraudulent practices defined.”

I First Tried to Get Law Enforcement to Address It

My initial response was not to assume that I personally could prosecute a crime.

I tried to get the government officials responsible for criminal investigation and prosecution to examine it.

The history I later placed into the record was extensive: I contacted Ames Police; I was initially told to ask the ICRC who had jurisdiction; I contacted the Attorney General's Office; an investigator directed me to its fraud department; personnel there told me they did not investigate that type of fraud; I contacted the Story County Attorney's Office; and after additional research I returned to Ames Police citing § 714.8(4).

Ames Police then told me that the Story County Attorney's Office regarded the matter as outside Story County's jurisdiction. The matter was effectively passed toward Polk County, where the ICRC was located, while no agency actually undertook the factual investigation I was requesting.

So by the time I was preparing a civil action, I was confronting a practical legal question:

If government officials would not investigate conduct I believed violated a criminal statute, did Iowa law nevertheless permit the person allegedly injured by that conduct to seek civil relief?

I Already Knew the Concept of a “Penal Action”

I did not need Hall v. Montgomery Ward & Co. to tell me that such a legal concept existed.

I already knew the term from legal dictionaries.

And I actually put it into my Reliable Street pleading.

Under the heading “Application for Punitive Damages,” my June 17, 2024 Amended Petition quoted Black's Law Dictionary:

“A civil proceeding in which either the state or a common informer sues to recover a penalty from a defendant who has violated a statute. Although civil in nature, a penal action resembles a criminal proceeding because the result of a successful action is a monetary penalty intended, like a fine, to punish the defendant.”

I then immediately asked the court to consider punitive damages.

That is important historical evidence.

It shows exactly what I understood at the time: civil law and criminal law were not necessarily sealed off from one another merely because the same conduct might violate a criminal statute.

Iowa's Own Civil-Procedure Statute Uses Similar Language

I have since located an Iowa statute that makes the connection even more explicit.

Iowa Code § 611.2 defines a civil action as a proceeding seeking protection of a private right or redress of a private wrong, and then states:

“It may also be brought for the recovery of a penalty or forfeiture.”

That provision is part of Iowa's chapter governing civil “Actions.” The Iowa Legislature separately maintains § 611.21, titled “Civil remedy not merged in crime.”

I had not located and briefed those provisions in the fifty-five days available to me before filing.

But they matter now because they show that the concept I was working from was not foreign to Iowa law.

The Iowa Supreme Court Had Gone Even Further

The case law I have now located is even more significant.

In Hall v. Montgomery Ward & Co., the plaintiff did not rely upon an ordinary common-law tort. The Iowa Supreme Court said that he instead:

“planted his feet squarely on our criminal statute on malicious threats.”

The Court emphasized that the criminal statute itself contained “no provision for civil relief.”

Nevertheless, after discussing Iowa Code § 611.21 and older Iowa precedent, the Court stated:

“This court has, however, interpreted the statute as itself providing a civil right for violation of a criminal statute.”

And its holding was direct:

“We thus hold that violation of § 720.1 itself gave Hall a civil cause of action in the present case.”

The Court added an important qualification: Hall still had to fall within the protection of the statute and his injury had to flow from the conduct the statute prohibited.

That is not a dictionary definition.

That is an Iowa Supreme Court decision recognizing an affirmative civil claim founded upon violation of a criminal statute.

Seeman Did Not Erase Hall

Five years later, in Seeman v. Liberty Mutual Insurance Co., the Iowa Supreme Court expressly described Hall this way:

“In Hall this court held that violation of a criminal statute gave rise to a civil cause of action.”

The Court again quoted § 611.21 and explained that it had previously been interpreted as providing a civil tort action for violation of a criminal statute.

But Seeman also clarified the limitation that matters here.

The Court explained that a criminal statute supports a civil cause of action only when such a remedy appears, expressly or by clear implication, to have been intended by the legislature.

Shumate Clarified the Modern Rule Further

In Shumate v. Drake University, the Iowa Supreme Court stated:

“Not all statutory violations give rise to a private cause of action.”

It explained that a private statutory cause of action exists only when the statute explicitly or implicitly provides one, and retained Iowa's multi-factor inquiry into legislative intent.

So the modern question is not as simple as either extreme.

It is not:

A statute is criminal, therefore a private person can never sue.

But neither is it:

A statute is criminal, therefore every injured person automatically has a private civil action.

The question is whether Iowa law recognizes a civil remedy for the particular statutory violation—expressly, implicitly, through an existing common-law cause of action, or through another recognized form of civil relief.

That Was the Distinction I Did Not Have Time to Fully Research

I now understand the issue more precisely than I did when I had fifty-five days to prepare the lawsuit.

What I knew then was real:

• Iowa law recognized civil actions for penalties;
• the legal concept of a penal action existed;
• I believed § 714.8(4) described the conduct I was trying to have investigated;
• law enforcement had not provided a forum for determining whether that statute had been violated;
• and I was trying to determine what civil remedies remained available to me.

What I had not yet had time to determine was whether § 714.8(4), specifically, supplied an implied private cause of action under the Iowa Supreme Court's Hall–Seeman–Shumate line of cases, or whether the same allegedly fraudulent conduct instead had to be pursued through established civil causes of action such as fraud, defamation, abuse of process, conspiracy, or another recognized theory.

That is a materially different proposition from saying I simply misunderstood the difference between civil and criminal law.

My Own Petition Shows What I Actually Did

The pleading itself is the best evidence.

I did not ask the district court to incarcerate anyone.

I brought a civil lawsuit asserting civil claims and seeking civil remedies.

My amended pleading expressly labeled the penal-action material an “Application for Punitive Damages,” quoted the civil definition of penal action, and then asked the court to consider punitive damages.

At the same time, I continued to allege civil wrongs arising from what I believed were knowingly false or misleading submissions made during the ICRC process.

The later Revised Second Amended Petition became much more precise. It identifies claims arising under Iowa common law, the Iowa Civil Rights Act, and equitable doctrines and seeks relief authorized by statute and common law.

That evolution reflects legal research and refinement over time.

It does not erase the reality I faced in 2023:

I had fifty-five days, no attorney, a newly released evidentiary record, officials who had declined to investigate the conduct I believed violated Iowa's fraud statute, and a legal obligation to either file something capable of preserving my claims or risk losing the opportunity to obtain judicial relief altogether.

 

Why I filed In Polk County Instead of Story County

 

By the time I was preparing to file suit, another problem remained unresolved.

I had attempted to report what I believed were false entries or fraudulent materials submitted to a government agency. Ames Police consulted the Story County Attorney’s Office and directed me toward Polk County. Des Moines authorities directed me back toward Ames. Ultimately, no law-enforcement agency investigated the underlying allegations.

That left me trying to determine whether the same conduct could be addressed through civil court.

While researching the issue as a self-represented litigant, I encountered an old legal concept: the penal action. Black’s Law Dictionary described it, among other formulations, as a civil proceeding in which a statutory violation can result in a monetary penalty intended to punish the wrongdoer.

I did not invent that concept, nor is the basic distinction between criminal punishment and parallel civil redress foreign to Iowa law.

Iowa Code § 611.21—whose statutory ancestry reaches back to the Code of 1851—is titled “Civil remedy not merged in crime.” It preserves the principle that civil redress may exist independently of criminal punishment.

Iowa courts historically interpreted that principle broadly. In Hall v. Montgomery Ward & Co., 252 N.W.2d 421 (Iowa 1977), the Iowa Supreme Court permitted a plaintiff to maintain a civil damages action based upon conduct prohibited by a criminal statute even though the criminal statute itself contained no express civil remedy. The Court relied upon § 611.21 and older Iowa precedent recognizing civil remedies for injuries resulting from public offenses.

I therefore was not unreasonable to investigate whether alleged statutory fraud affecting me could also support civil relief merely because prosecutors had declined or failed to pursue a criminal case.

But Iowa law contains an important limitation that I did not yet fully understand.

Later Iowa Supreme Court decisions clarified that not every criminal statute automatically creates a private lawsuit. In Seeman v. Liberty Mutual Insurance Co. and later Shumate v. Drake University, the Court explained that a private statutory cause of action ultimately depends upon whether the legislature expressly or implicitly intended to permit private enforcement. Section 611.21 preserves civil remedies; it does not automatically manufacture a new civil cause of action from every criminal prohibition.

That distinction is much clearer to me now than it was when I was racing against the filing deadline without an attorney.

But the underlying principle I was trying to understand was real: the fact that conduct may constitute a public offense does not necessarily mean the injured person is limited to waiting for criminal prosecution before seeking civil redress.

Indeed, Iowa law still contains statutes expressly authorizing private civil actions for conduct carrying public penalties, including qui tam actions under Iowa’s False Claims Act and private actions for statutorily prohibited consumer fraud.

My own civil case was never dependent upon one “penal action” theory. The original petition asserted discrimination, fraud, promissory estoppel, and defamation and sought compensation for reputational, emotional, labor, and other injuries. The penal-action research was part of my attempt to understand whether alleged statutory wrongdoing could also have civil consequences when the public officials I had asked to investigate would not do so.

I later expressly cited Black’s Law Dictionary’s definition of “penal action” in my June 17, 2024 amended petition while discussing punitive damages.

So I would delete this sentence from the earlier draft:

“That was a distinction I did not yet fully understand when I filed the original case without counsel.”

and replace it with something more precise:

What I did not yet fully understand was not whether civil remedies can coexist with criminal violations—they can—but the separate question whether the particular criminal statute I was examining created or implied its own private cause of action under Iowa law.

That is much better.

And your other sentence can be strengthened to:

I later learned that a legal definition can accurately describe a recognized category of civil action without establishing that every statute carrying a criminal penalty creates such an action. Under modern Iowa law, the additional question is whether the legislature expressly or implicitly intended the particular statute to be privately enforceable.

That explains what you learned without portraying the original research as foolish or imaginary.

Why discovery would be necessary: 

Discovery was necessary to determine the answer to crucial questions, such as "Who created the document?", "Who knew about the document?", "Who was in on this coordinated attack?", "Did they all know about this?", and "Was anyone coerced into going along with it?"

I. The Evidence
The Court Never Allowed to Become Part of My Operative Claims

 

Before we get into the case, first there are some important facts to understand about why my claims were dismissed, and why I strongly contend my due process rights were violated. I intend to appeal soon, and will seek to have my claims re-opened.

Additionally, this section of the article, discussing my repeated attempts to show the court my evidence, is followed by the story about what actually happened that led me to file the lawsuit on December 5, 2023. If you wish to skip forward to the read the about what happened, skip forward to Section II. 

This article presents a wide variety of evidence I compiled to prove my claims, including fraud, discrimination, defamation, promissory estoppel, conspiracy, false light, unjust enrichment, tortious interference with contractual relations, and related torts. This evidence was extracted from the following exhibits I attempted, on more than one occasion, to enter into the court record:

Exhibit A — ICRC Correspondence; Exhibit B — Open Mic and Flier Agreements; Exhibit C — Garden and Prairie Agreements; Exhibit D — Colville/Stalking-and-Harassment Record; Exhibit E — Martinez Materials; and Exhibit F — Esker Statement and Related Communications.

Caution: These exhibits include evidence examined later in the series, and are unpacked in full in Part Three: Political Sabotage. Readers who want to experience the events in the same order I did may prefer to follow the article first and open the exhibits when they are fully presented later. 

In total, I filed four petitions throughout the proceedings. The exhibits were attached to the third and fourth ones, both filed in 2026, however they were improved when attached to the fourth.  This section of the article provides a chronology of the four, as well as some background about them and how they were (or were not) received.

 

First — "Original Petition"

 

On December 5, 2023, I filed a two-page petition to commence the proceedings. My claims were discrimination, defamation, fraud, promissory estoppel for violation of two separate agreements which had written confirmation, and unjust enrichment. It was a simple petition that conformed to Rule 1.403(1) within the Iowa Rules of Civil Procedure:

“A pleading which sets forth a claim for relief … shall contain a short and plain statement of the claim showing that the pleader is entitled to relief and a demand for judgment for the type of relief sought.”

It also conformed to Rule 1.402(2)(a:

“Each averment of a pleading shall be simple, concise, and direct. No technical forms of pleadings are required.”

I only had 55 days to file this lawsuit after finally having access to the initial evidence due to the Iowa Civil Rights Commission's process that is notorious for favoring respondents, as described in Part Two of this series, Iowa's Civil-Rights Trap. Also, there was an exorbitant amount of evidence to compile in that short timeframe. That is why the Original Petition was not more elaborate. 

On February 29, 2024, my petition was met by five motions filed on the same day by Attorney Paul Esker of Bradley & Riley PC on behalf of the seven defendants: Reliable Street Inc., Lockwood Cafe, Lyndsay Nissen, Sharon Stewart, Willa Colville, Denise Martinez, and Charlie Esker. Their motion to change venue included a misrepresentation of the Iowa venue law, stating:

“The location of the office of the Iowa Civil Rights Commission has no bearing on the question of venue.”

And:

“No exception contained in Iowa Code § 616 is applicable.”

What they wrote is not true, however. Iowa Code § 616.18 sets forth:

“Actions arising out of injuries to a person... may be brought... in which the injury or damage is sustained.”

I addressed this in my response, but before anything was decided on, first I needed to address a separate matter.

On March 15, I filed a omnibus motion for Judge Gronewald to recuse prior to deciding on any other motions because she was appointed by Kim Reynolds, who was a defendant in a case I filed on February 8, 2024, Wilson v. State of Iowa and Kim Reynolds for Iowa. Judge Gronewald was assigned to both cases.

It was necessary to file both actions  as a result of the limitations period for both cases was set to expire during the time I was scheduled to participate in DMACC's London Abroad Program, which I left for on February 9.

In my resistance to the motion to change venue, I wrote:

"Iowa District Court in and for Polk County has subject matter jurisdiction over the majority of claims, injuries, and rights described within my Petition, and upcoming Amended Petition, including but not limited to:

(a) the fraudulent document that was filed with the Iowa Civil Rights Commission by Sharon Stewart on behalf of Lockwood Cafe, and

(b) various libelous statements made against me, which were made by all named Defendants, within documentation submitted to the Iowa Civil Rights Commission by Sharon Stewart, Lyndsay Nissen, and Charlie Esker.”

Then, I challenged the defendants' assertion that all relevant conduct occurred in Story County:

“Within Defendants' ‘Motion to Change Venue and Dismiss’, Defendants moved to change the venue to Story County ‘where all relevant conduct is alleged to have occurred; however, acts of libel and the fraudulent document were submitted within Polk County to the Iowa Civil Rights Commission. The majority and more severe injurious acts against me, with regard to this action, occurred in Polk County.”

That same day, on March 15, Judge Gronewald denied my motion to recuse and simultaneously granted their motion to change venue to Story County.

Shortly thereafter, defendants accepted service, which they had objected to in their February 29 filing, and filed a motion to augment Judge Gronewald's order and have their attorney's fees and the transfer costs assigned to me.

This is only part of what took place in the Polk County District Court.

My Original Petition is found all the way down in pages 143-144 of D0001. To learn how it got buried down at the bottom of of a 144 page PDF along with numerous other filings spanning from December 2023 through April 9, 2024, read Procedural Bombardment. That is where this section of the case is unpacked.

Notably, following six separate filings including two two motions to recuse, two motions to reconsdier, and two complaints with the Iowa Judicial Qualifications Commission(one filing of each for both cases), Judge Currie finally recused from Wilson v. State. But not before adversely impacting this case.

 

Second — "Amended Petition"

 

Amended Petition will be covered soon. The rest of this article is finished. 

 

Third — "Second Amended Petition"

 

Second Amended Petition will be covered soon. The rest of this article is finished. 

Fourth — "Revised Second Amended Petition"

"

Revised Second Amended Petition will be covered soon. The rest of this article is finished. 

Endnotes

 

[1] 2024 Iowa Acts ch. 1170, §§ 252–254 (amending Iowa Code §§ 216.2–.3 and placing the Iowa Civil Rights Commission within the Iowa Office of Civil Rights; reducing the Commission from seven members to five); Iowa Office of Civil Rights, Current Commissioners (stating that the Commission consists of five members appointed by the governor, subject to Senate confirmation). See also Iowa Office of Civil Rights, Local Human & Civil Rights Agencies (“As of July 1, 2024, the Iowa Civil Rights Commission is based within the Iowa Office of Civil Rights.”).
2024 Iowa Acts chapter 1170
Iowa Civil Rights Commission — Current Commissioners

[2] 2025 Iowa Acts, S.F. 418, signed Feb. 28, 2025, effective July 1, 2025 (removing gender identity as a protected basis under Iowa Code chapter 216). The Iowa Legislature’s enrolled-bill records identify the Act’s effective date as July 1, 2025.
Iowa Legislature — Senate File 418 bill history

[3] Iowa Code § 216.7(1)(a)–(b) (2022) prohibited owners, managers, agents, and employees of public accommodations from denying accommodations, services, privileges, or otherwise discriminating against a person because of, among other protected characteristics, “gender identity.” Chapter 216 likewise used gender identity as a protected classification in other areas of Iowa civil-rights law during the relevant period. See, e.g., Iowa Code ch. 216 (2022); Iowa Code ch. 216 (2023).
Iowa Code § 216.7 (2022)
2022 Iowa Code archive

[4] Legislative Services Agency, Fiscal Update: Senate File 418 — Gender Identity, Civil Rights, Schools, and Public Records Act (2025) (explaining that after July 1, 2025, complaints based on gender identity could still be filed within the applicable filing period if they concerned conduct occurring before July 1, 2025).
Legislative Services Agency fiscal analysis of S.F. 418