Dr. Boyle Confronts Oconee County Council on Corruption, Files Federal Lawsuit
History of corruption in Oconee County must stop. Lawsuits are perhaps a mechanism to spur accountability.
April 15, 2025 — Seneca, SC
In a bold move highlighting systemic corruption, Dr. Jason Boyle delivered a powerful address to the Oconee County Council, outlining longstanding constitutional violations and law enforcement misconduct. Following his presentation, Boyle personally handed council members, County Administrator Amanda Brock, and County Attorney David Root formal notice of a soon to be filed federal civil rights lawsuit.
Overview of Lawsuit
Dr. Boyle alleges multiple severe constitutional violations, including unlawful arrest, detention, harassment, and retaliation against himself and his family by Oconee County officials and law enforcement.
Entities Sued
Oconee County
The lawsuit accuses Oconee County of deliberately ignoring a documented history of corruption and misconduct within its law enforcement entities. Boyle claims the county’s persistent failure to address numerous complaints facilitated an environment where constitutional abuses flourish unchecked.
Oconee County Sheriff’s Office
Dr. Boyle describes the Sheriff's Office as engaging in widespread misconduct, including unlawful investigations, arrests without probable cause, retaliation, and intimidation against individuals critical of county officials.
Oconee County Detention Center
The Detention Center is accused of illegally holding Boyle without proper authority or case documentation. Despite clear procedural violations, officials continued detaining Boyle under a fictitious "probate hold."
Individuals Sued
Sheriff Mike Crenshaw
Sheriff Crenshaw is named individually for his direct role in facilitating and covering up unconstitutional actions. Boyle highlights Crenshaw’s personal involvement in initiating unauthorized investigations and failing to document official activities, evidencing deliberate indifference to constitutional protections.
Deputies Jimmy Dixon and Berry Owens
Deputy Dixon is accused of conducting an unauthorized investigation at Boyle’s residence under false pretenses, fabricating police reports, and engaging in harassment. Boyle asserts Dixon’s actions were aimed at intimidating his family due to pending legal testimony against prominent local figures. Deputy Owens participated in these unlawful activities.
Captain Jeremy Chapman
Chapman, head of the Detention Center, knowingly detained Boyle without a valid legal basis, ignoring explicit notification of procedural irregularities. His deliberate continuation of unlawful confinement violated Boyle’s constitutional rights and voided Chapman’s qualified immunity.
Officer Honea
Officer Honea is accused of unlawful trespassing onto Boyle’s clearly marked private property without a warrant or exigent circumstances, violating constitutional protections against unreasonable search and seizure.
Key Incidents
Illegal Arrest and Detention
On May 29, 2024, Boyle was arrested in a courthouse lobby by order of Probate Judge Danny Singleton, who lacked jurisdiction and issued no formal warrant or case number. Boyle was detained for eight days, with procedural irregularities continuing thereafter.
Retaliation and Harassment
The lawsuit details multiple retaliatory actions, notably on March 14, 2024, when Deputies Dixon and Owens initiated a baseless "missing child" investigation at Boyle’s home. This action coincided suspiciously with Boyle’s wife preparing testimony implicating local attorney Richard McDuff.
Unauthorized Release of Private Communications
Boyle’s private phone calls made during detention were improperly accessed and disseminated without a valid subpoena. Attorney Jim Logan’s involvement indicates prior illegal access to these communications, raising further privacy violations.
Relief Sought
Boyle seeks compensatory and punitive damages, declaratory and injunctive relief against future constitutional violations, and accountability for all defendants involved.
Dr. Boyle’s lawsuit is a significant challenge to Oconee County, potentially setting a precedent for how local governments address internal corruption and accountability.
THE FULL DOCUMENT GIVEN TO COUNCIL IS HERE:
NOTICE OF INTENT TO SUE
Date: Tuesday, April 15, 2025
Plaintiff Jason Michael Boyle, a resident of Seneca, South Carolina, hereby provides formal notice of his intent to file a federal civil rights lawsuit against the following entities and individuals:
Oconee County
Oconee County Sheriff’s Office
Oconee County Detention Center
Multiple deputies of the Oconee County Sheriff’s Office, in their individual capacities
A draft copy of the proposed complaint is being delivered today, April 15, 2025, to the following officials:
Members of the Oconee County Council
Amanda Brock, County Administrator
David Root, County Attorney
This notice is submitted in anticipation of litigation involving serious constitutional violations and related misconduct.
INTRODUCTION
Plaintiff Jason Boyle, a resident of Oconee County, South Carolina, brings this action to challenge a pattern of unlawful arrests, detentions, and harassment perpetrated by the Oconee County Sheriff’s Office and the Oconee County Detention Center. The events giving rise to this lawsuit began in September of 2020, when multiple witnesses watched my wife being chased by Adam Pierce as he threatened to kill her while calling her the N-word. The Oconee County Sheriffs Deputies arrived on scene and refused to produce a police report. Gregory Pierce, the brother of Adam, yelled for Dorothy to “call the law” well aware they would do nothing to help her.
On May 29, 2024, the plaintiff was arrested for the violation of a court order he was unaware of and sentenced to jail in a public lobby by a judge that held not jurisdiction. The sentencing was so egregious that the court was unable to produce a case number or warrant number.
Over the ensuing weeks, the procedural irregularities mounted. Mr. Boyle was repeatedly detained under documents referencing an unrelated estate case, effectively bypassing the normal safeguards of a criminal prosecution. Despite no criminal docket number ever being assigned, the Oconee County Sheriff’s Office and Detention Center continued to enforce these fraudulent orders, holding Dr. Boyle for extended periods on a mere “probate hold.” When Dr. Boyle sought injunctive relief to prevent his unlawful detention, the County and its sub-entities failed to rectify the procedural defects or provide a lawful basis for his continued confinement.
Several problems extended beyond the May incident. For Example, on March 14, 2024, Dr. Boyle experienced a separate instance of harassment at his private residence, where deputies arrived under the pretense of investigating a missing child claim—an investigation that was abruptly abandoned when Dr. Boyle insisted they obtain a warrant. Attempts by Dr. Boyle to obtain records or verify the legitimacy of this investigation were met with contradictory statements, outright lies, and incomplete police reports, suggesting a broader culture of weaponizing the police and a disregard for citizens’ constitutional rights within local law enforcement. By this action, Dr. Boyle seeks accountability for these abuses, declaratory and injunctive relief to prevent further violations, and monetary damages to redress the harm he has suffered.
Oconee County and the Sheriff’s Department are well versed not only on the atrocities committed against my family, but many other Oconee residents.
JURISDICTION AND VENUE
1. This action arises under the Constitution and laws of the United States, including 42 U.S.C. § 1983. This Court has subject matter jurisdiction pursuant to 28 U.S.C. § 1331 (federal question jurisdiction) and 28 U.S.C. § 1343 (civil rights jurisdiction).
2. Venue is proper in this judicial district pursuant to 28 U.S.C. § 1391(b), because the events and omissions giving rise to these claims occurred in Oconee County, South Carolina, which is within the District of South Carolina, Anderson Division.
PARTIES
1. Plaintiff:
Jason Boyle is a resident of Oconee County, South Carolina. At all relevant times, Plaintiff was within the jurisdiction of this Court.
2. Defendants:
(a) Oconee County is a political subdivision of the State of South Carolina with authority over various entities, including the Sheriff’s Office and Detention Center. By failing to address longstanding corruption within the Sheriff’s Office, Oconee County has fostered an environment where misconduct is permitted to flourish. Oconee County’s inaction, despite receiving reports of wrongdoing from Plaintiff and others, demonstrates deliberate indifference to constitutional violations committed by its employees and agents.
(b) Oconee County Detention Center is a municipal entity (or sub-unit thereof) situated in Oconee County, South Carolina. It operates the jail facility where Plaintiff was detained without legal authority or a valid case number. The Detention Center is responsible for ensuring that detentions are conducted lawfully and within the bounds of constitutional protections.
(c) Oconee County Sheriff’s Office is a municipal entity (or sub-unit thereof) tasked with law enforcement in Oconee County, South Carolina. It is responsible for the actions and omissions of its employees under the doctrine of Monell liability when those actions are taken pursuant to an official policy, custom, or practice, or reflect a failure to train or supervise amounting to deliberate indifference. The Sheriff’s Office has engaged in a pattern of corruption and unlawful detention of citizens, including Plaintiff, which the County Council has failed to address despite Plaintiff’s formal complaints.
(d) Jimmy Dixon, in his individual capacity, is a law enforcement officer employed by the Oconee County Sheriff’s Office. On March 14, 2024, Dixon facilitated the weaponization of the Sheriff’s office by harassing Jason Boyle and Dorothy Pierce at their residence. Dixon’s actions appear to be motivated by an upcoming court date in which Plaintiff’s wife, Dorothy Pierce, was scheduled to provide an affidavit implicating Richard Hunt McDuff, a prominent local attorney, in criminal conduct. Dixon’s actions were part of a coordinated effort to harass and intimidate Plaintiff and his wife, which violated Plaintiff’s constitutional rights under the Fourth and Fourteenth Amendments.
(e) Mike Crenshaw, in his individual capacity, is the Sheriff of Oconee County and holds supervisory authority over the Oconee County Sheriff’s Office. Crenshaw is responsible for overseeing all operations of the Sheriff’s Office, including investigations and law enforcement actions carried out by his subordinates. On or about March 16, 2024, Crenshaw admitted during a phone conversation that he had received an anonymous phone call directly to his personal phone alleging a missing child, which he then communicated to Jimmy Dixon via another phone call, both of which were not recorded or logged. Crenshaw’s actions actively covered up and/or facilitated the unconstitutional nature of the investigation at Plaintiff’s residence, conducted by Jimmy Dixon and Berry Owens. Additionally, Crenshaw failed to maintain adequate record-keeping and permitted Jimmy Dixon to perform an official investigation while off duty without any documentation. Crenshaw’s conduct reflects deliberate indifference to Plaintiff’s constitutional rights, including the Fourth and Fourteenth Amendments, and his failure to act within the law contributed directly to the harm Plaintiff suffered.
(f) Jeremy Chapman, in his individual capacity, serves as the Captain of the Oconee County Detention Center and oversees the operations of the detention facility. Chapman knowingly and willfully detained Plaintiff without a valid case number after being notified of the lack of legal authority to do so. By continuing to detain Plaintiff without proper legal authority, Chapman violated Plaintiff’s constitutional rights under the Fourth and Fourteenth Amendments. Such conduct constitutes a clear abuse of power, thereby stripping Chapman of qualified immunity.
(g) John/Jane Does: The identities of certain individuals who participated in Plaintiff’s detention and harassment are presently unknown. These defendants are employees, agents, or servants of Oconee County, the Sheriff’s Office, and/or the Detention Center whose acts or omissions contributed to the violations alleged in this Complaint. Plaintiff will amend this Complaint to name these individuals once their identities are ascertained.
FACTUAL ALLEGATIONS
IMPORTANT NOTE: Actions of the probate court and probate court judge Danny Singleton are noted for context. The actions of the probate court and probate court judge will be addressed in a separate filing.
1 - Initial Recording Incident (May 24, 2024)
a. Recording at Clerk’s Window
On or about May 24, 2024, Plaintiff recorded video while standing at the clerk’s window in the courthouse lobby. Plaintiff was unaware of any court order prohibiting this conduct at the time of recording.
b. Alleged Violation of Administrative Order
Plaintiff was subsequently informed of a South Carolina Supreme Court Administrative Order that unconstitutionally prohibits the use of electronic devices at the clerk’s window.
(Exhibit XX - South Carolina Supreme Court Administrative Order restricting the use of electronic devices in courthouses)
c. Failure to Post Notice of Order
The Administrative Order mandates that notice of the order be posted on the courthouse door; however, no such notice was posted at the courthouse entrance on the date in question.
d. Lack of Warning or Instruction
During the entirety of the recording on May 24, 2024:
Plaintiff was not instructed by any courthouse personnel to cease recording.
Plaintiff was not warned that recording was prohibited.
Judge Singleton did not witness the recording firsthand; instead, he learned of it through hearsay and saw the video posted on YouTube.
2 - Rule to Show Cause and Arrest Order (May 29, 2024)
a. Issuance of Rule to Show Cause
A Rule to Show Cause was later issued against Plaintiff under the case number associated with the Doyle Pierce Estate.
At the time of the recording, Plaintiff was present at the courthouse to pay a bill on behalf of a party involved in the Pierce Estate matter.
b. Judge Singleton's Statement of Unrelatedness
During a June 17, 2024, open court proceeding, Judge Danny Singleton expressly stated on the record that the contempt matter was unrelated to the Pierce Estate case.
(Exhibit XX - Transcript of June 17 from criminal trial held in probate court)
c. Return to Courthouse for Rule to Show Cause
On or about May 29, 2024, Plaintiff returned to the Oconee County Probate Court lobby to receive the Rule to Show Cause.
(Exhibit XX - Rule to Show Cause)
d. Recording Without Allegation
During this visit, Plaintiff recorded video; however, no allegations of misconduct related to the May 29 recording have been made.
e. Verbal Arrest Order
While Plaintiff was waiting for the Rule to Show Cause to be served, Judge Danny Singleton ordered Plaintiff’s arrest for direct contempt of court.
This order was issued verbally in the courthouse lobby, outside of any formal, on-the-record court proceeding.
Judge Singleton was not present for the recording of May 24, he learned of it through hearsay and the video posted on YouTube.
f. Lack of Case Number in Conviction and Sentencing
The resulting conviction and sentencing order, dated May 29, 2024, did not include a case number or any details related to the purported violation.
(Exhibit XX - Sentencing Orders from May 29, June 5, and June 17)
g. Arrest and Booking
Upon the verbal request of Judge Singleton, the Plaintiff was placed under arrest by the Oconee County Sheriff’s Department and booked into the Oconee County Detention Center. An order lacking a case number would later be produced.
3 - Incarceration Following Arrest (May 29, 2024)
a. Probate Judge Danny Singleton’s Directive
On May 29, 2024, Probate Judge Danny Singleton directed Oconee County Sheriff’s deputies to arrest Plaintiff for what he described as direct contempt of court.
This directive was given in the courthouse lobby, not in an open court.
b. Incarceration Duration
Plaintiff was then taken into custody and incarcerated for eight days.
4 - Release and Mistrial (June 5, 2024)
a. Incarceration Duration
Plaintiff remained incarcerated at the Oconee County Detention Center for eight days following the May 29, 2024 Order from the probate court without a case number.
b. Criminal Hearing and Mistrial
On June 5, 2024, a criminal hearing was held in the Oconee County Probate Court.
The hearing ended in a mistrial due to issues related to Plaintiff’s counsel and the active involvement of Attorney Richard Hunt McDuff, an attorney associate with the Doyle Pierce Estate case.
McDuff was associated with the Pierce estate case, but was seated at the prosecutor’s desk during the unrelated criminal trial proceeding.
c. Release Order Without Case Number
The release of Plaintiff was ordered by Judge Singleton, again with no reference to any case number.
(Exhibit XX - Release Order dated June 6, 2024)
d. Filing of Appeal
Upon Plaintiff’s release from the initial ten-day incarceration, Plaintiff filed an appeal on June 14, 2024, challenging the May 29, 2024 contempt finding and sentencing.
The appeal is identified as Case Number 2024-CP-3700451.
5 - New Rule to Show Cause and Subsequent Hearing (June 6 - June 17, 2024)
a. Service of New Rule to Show Cause
On June 6, 2024, a new Rule to Show Cause was served on the Plaintiff, again using the Doyle Pierce Estate case number.
(Exhibit XX - Rule to Show Cause dated June 6)
b. Hearing Before Judge Singleton
On June 17, 2024, another criminal hearing took place in the Oconee County Probate Court before Judge Danny Singleton.
c. Judge Singleton’s Clarification on Record
During the hearing, Judge Singleton stated that the contempt charge had been initiated via a Rule to Show Cause under the Pierce estate docket.
He clarified that the contempt charge was solely related to Plaintiff’s behavior and had nothing to do with the Pierce case.
d. Continuation of Improper Case Number Usage
Despite this clarification, During the appeal proceedings in the 10th circuit court, the Pierce estate case number continued to appear on official court documents associated with the contempt proceedings.
(Exhibit XX - June 17, 2024 Hearing Transcript)
6 - Emergency Motion for Injunction (June 26, 2024)
a. Filing of Emergency Motion
On June 26, 2024, Plaintiff filed an “Emergency Motion for Injunction to Prevent the Unlawful Detention of Jason Boyle” in the appeal Case Number 2024-CP-3700451.
b. Grounds for Motion
The filing outlined reasons the detention was alleged to be improper, including:
The absence of a valid case number.
The lack of a formal warrant.
Additionally, the Oconee Sherriff never established probable cause for the arrest. The verbal request of an elected judge outside of open court while standing in public space does not have legal standing.
c. Service of Copies
Copies of the motion were served on Oconee County, the Oconee County Detention Center, and the Oconee County Sheriff’s Department.
(Exhibit XX - June 26, 2024 Emergency Motion for Injunction)
8 - Unlawful Detention Under Probate Court Hold (July 11, 2024)
a. Inmate Search Results
As of July 11, 2024, an Oconee County inmate search continued to show Plaintiff (listed as Jason Boyle) on a “Hold for probate court” with an arrest date of June 17, 2024. (Exhibit XX – Printout of inmate search on July 11)
The listing did not reference a warrant, a case number, or any specific statutory violation.
Publicly accessible court records do not reveal any docket or case number for this matter.
b. Unclear Criminal Record Status
It remains unclear whether Plaintiff has a criminal history, as no conviction documents with a valid case number appear in the record.
9 - Improper Handling of Recorded Calls (September 3, 2024)
a. Release of Calls Without Subpoena
Recordings of calls Plaintiff made to his wife from jail were released to the public without a subpoena.
b. Jim Logan’s Subpoena Request
On September 3, 2024, Attorney Jim Logan filed a subpoena for exact recordings from June 19, between specified times. Plaintiff made calls to his wife an estimated 20 days throughout his incarceration. Logan knew the exact date and time of the call he wanted before the subpoena for discovery during an appeal was issued.
The subpoena suggests that Logan was either already in possession of the recordings or had knowledge of their contents.
c. Motion to Quash Filed by Plaintiff
Before the end of day on September 3, Plaintiff filed a Motion to Quash and served it on Jeremy Chapman, the captain overseeing the detention center.
d. Chapman’s Assurance
Chapman confirmed that the calls had not been released and stated he would ensure they were not released until the Motion to Quash was heard.
e. Logan’s Admission
Jim Logan later confirmed, in his response, that the Motion to Quash was moot because he was already in possession of the recordings.
10 - Record of Harassment from Oconee County Sheriff’s Department
a. Encounter at Plaintiff’s Residence (March 14, 2023)
On March 14, 2024, at approximately 11:50 AM, an unmarked Oconee County squad car approached the Plaintiff’s residence at 750 Mourning Dove Lane, Seneca, South Carolina.
The vehicle was driven by Captain Jimmy Dixon, with Investigator Berry Owens riding in the passenger seat.
b. Claim of Missing Child Investigation
Captain Dixon claimed that three days prior, a potential missing child report had been made and that he was there to complete an investigation.
c. Plaintiff’s Response and Dixon’s Withdrawal
Plaintiff informed Dixon and Owens that they were to leave the property pending a warrant and stated that the Plaintiff was willing to bring the purported missing child to the Sheriff’s office to complete the welfare check.
At this point, Dixon stated he was no longer interested in checking the welfare of the child and left the property.
d. Suspicion of Harassment
Plaintiff noted the timing of the incident as suspicious, as it occurred on the same day his wife, Dorothy Pierce, was planning to submit a damning affidavit to the Circuit Court during afternoon hearings. (Exhibit xx – affidavit of Sandra Pierce)
11 - Attempt to Obtain Police Report and Contradictory Statements
a. Visit to Sheriff’s Office for Report (March 14, 2023)
At approximately 4:00 PM on March 14, 2024, Plaintiff visited the Oconee County Sheriff’s Office in Walhalla to request a police report concerning the earlier incident.
The desk clerk informed Plaintiff that he had the wrong officer, stating that Jimmy Dixon was not on duty that day.
b. Recorded Conversation and Promise of Report (March 29, 2023)
On March 29, 2024, during a recorded conversation at the Oconee County Sheriff’s Department, Jimmy Dixon reluctantly agreed to produce a police report within a week.
c. Retrieval Attempt and Discovery of Report Errors (Following Week)
Plaintiff returned to the Sheriff’s Office the following week to retrieve the report and discovered multiple inconsistencies:
The report incorrectly stated that the visit by Dixon and Owens occurred on March 13, 2024, rather than March 14, 2024.
Plaintiff possesses text records proving he was in Greenville, South Carolina, all day on March 13, 2024, which is approximately an hour’s drive from his residence.
The report provided no information about who made the missing child report or how the report was made.
12 - Conflicting Statements by Law Enforcement Officials
a. Statements by Jimmy Dixon
In a phone conversation, Jimmy Dixon stated that he believed the report came from DSS (Department of Social Services).
b. Statements by Sheriff Mike Crenshaw
During a phone conversation, Sheriff Mike Crenshaw stated that the call was made directly to his phone by an anonymous caller, ensuring no record of it existed.
Crenshaw further stated that, on the same day, he instructed Jimmy Dixon to investigate via a separate phone call, also without a record.
Despite this instruction, Dixon waited three days before visiting the Plaintiff’s house in a squad car, wearing official OCSD gear while off duty.
Dispatch records indicate no record of anyone visiting the Plaintiff’s residence on or about March 14, 2024.
13 - Filing of Complaints Against Officers
a. Complaints Against Dixon, Owens, and Crenshaw
Plaintiff filed formal complaints against Captain Jimmy Dixon, Investigator Berry Owens, and Sheriff Mike Crenshaw for their involvement in the alleged harassment and failure to follow standard investigative procedures.
(Exhibit XX - Officer Complaints)
14 - Officer Honea Trespasses
a. Trespassing Incident
On or about May 28, 2024, Officer Honea of the Oconee County Sheriff’s Department arrived at the locked gate of 750 Mourning Dove Lane to serve two Rules to Show Cause to the Plaintiff and his wife. Both Rules to Show Cause were issued from the Oconee County Probate Court.
The entrance to the property was clearly marked with a “No Trespassing” notice affixed to the locked gate, indicating that unauthorized entry was strictly prohibited.
b. Unauthorized Entry
Without making any effort to contact the Plaintiff or his wife via phone, or other reasonable means, Officer Honea circumvented the secured gate.
Officer Honea drove his vehicle through the surrounding fields, bypassing fences and other barriers to access the Plaintiff’s residence. This was done in blatant disregard for the prominently displayed “No Trespassing” notice.
c. Violation of Property Rights
Officer Honea’s unauthorized entry constituted an unlawful trespass upon private property, executed without proper justification or exigent circumstances.
This unwarranted intrusion was a clear violation of the Plaintiff’s established property rights and an overreach of Officer Honea’s authority.
The incident raises significant concerns regarding the respect for constitutional protections against unreasonable searches and trespasses by law enforcement.
Exhibit 1: South Carolina Supreme Court Administrative Order restricting the use of electronic devices in courthouses.
Exhibit 2: Transcript of June 17, 2024, criminal trial held in probate court.
Exhibit 3: Rule to Show Cause issued under the Doyle Pierce Estate case number.
Exhibit 4: Sentencing Orders from May 29, June 5, and June 17, 2024.
Exhibit 5: May 29, 2024, Detention Records (Possible Exhibit B).
Exhibit 6: Release Order dated June 6, 2024.
Exhibit 7: June 26, 2024, Emergency Motion for Injunction to Prevent the Unlawful Detention of Jason Boyle.
Exhibit 8: Printout of Oconee County Inmate Search on July 11, 2024.
Exhibit 9: Affidavit of Sandra Pierce related to the submission of evidence to the Circuit Court on March 14, 2024.
Exhibit 10: Officer Complaints filed against Captain Jimmy Dixon, Investigator Berry Owens, and Sheriff Mike Crenshaw.
CAUSES OF ACTION
CAUSE OF ACTION 1
42 U.S.C. § 1983 — Fourth Amendment Unlawful Entry / Trespass (Officer Honea)
Parties and Incorporation of Facts
Plaintiff incorporates all preceding paragraphs as though fully set forth herein.
This claim is brought against Officer Honea in his individual capacity.
Violation of Fourth Amendment
Under the Fourth Amendment, made applicable to the states through the Fourteenth Amendment, individuals have the right to be free from unreasonable searches and seizures.
Specific Conduct
On or about May 28, 2024, Officer Honea unlawfully entered Plaintiff’s property by bypassing a locked gate marked “No Trespassing.”
No warrant, exigent circumstances, or other legal justification supported this intrusion.
Damages
As a direct and proximate result of Officer Honea’s unconstitutional actions, Plaintiff suffered harm including emotional distress, invasion of privacy, and other compensable injuries. Plaintiff lives with continued fear of harassment at his home.
Prayer for Relief
Plaintiff seeks compensatory and punitive damages, attorneys’ fees under 42 U.S.C. § 1988, and all other relief the Court deems just and proper.
CAUSE OF ACTION 2
42 U.S.C. § 1983 — Fourth Amendment Unlawful Investigation without Cause or Record, and Filing of a False Police Report.
Parties and Incorporation of Facts
Plaintiff incorporates all preceding paragraphs as though fully set forth herein.
This claim is brought against Officer Jimmy Dixon in his individual capacity.
Violation of Fourth Amendment
Dixon conducted an investigative visit to Plaintiff’s residence while off duty, in a marked squad car, wearing official gear, and without a warrant, probable cause, or dispatch record.
Specific Conduct
Jimmy Dixon, acting under color of law and without legal authority, willfully weaponized his position as a sheriff’s deputy by initiating an off-the-record investigation based on an fabricated or unverified report. He visited the Plaintiff’s home without a warrant, probable cause, or dispatch authorization, then later produced a vague police report containing knowingly false information, including the wrong date of the alleged incident.
Damages
As a direct and proximate result, Plaintiff suffered loss of liberty, emotional distress, reputational harm, and other compensable injuries.
Prayer for Relief
Plaintiff seeks compensatory and punitive damages, attorneys’ fees, and all other relief deemed appropriate by the Court.
CAUSE OF ACTION 3
42 U.S.C. § 1983 — Supervisory Liability (Sheriff Crenshaw)
Parties and Incorporation of Facts
Plaintiff incorporates all preceding paragraphs as though fully set forth herein.
This claim is brought against Sheriff Mike Crenshaw in his individual and/or official capacity as a supervisory official in Oconee County.
Supervisory Liability Standard
A supervisor can be held liable under § 1983 if (a) they personally participated in the constitutional violation, or (b) there is a causal connection between the supervisor’s actions and the violation.
Specific Conduct
Sheriff Crenshaw either instructed, approved, or was deliberately indifferent to the actions of Officer Dixon, Officer Honea, Chapman and the officers who carried out unlawful arrests and detentions.
Sherrif Crenshaw actively participated I the fabrication of the Narrative that weaponized Oconee Deputies and the coverup thereafter.
Sheriff Crenshaw failed to adequately supervise or correct repeated violations of the Fourth and Fourteenth Amendments.
Damages
The failure or refusal to prevent these constitutional deprivations proximately caused Plaintiff’s injuries, including wrongful detention, emotional distress, and privacy violations.
Prayer for Relief
Plaintiff seeks compensatory and punitive damages, attorneys’ fees, and such other relief deemed just and proper.
CAUSE OF ACTION 4
42 U.S.C. § 1983 — Fourteenth Amendment Due Process Violations (Oconee County Sheriff’s Department and the Oconee County Detention Center)
Parties and Incorporation of Facts
Plaintiff incorporates all preceding paragraphs as if fully set forth herein.
Brought against all relevant officers and officials who caused or contributed to the denial of due process.
Violation of Fourteenth Amendment
The Fourteenth Amendment’s Due Process Clause requires valid legal process before depriving an individual of liberty or property.
Specific Conduct
Defendants failed to provide due process protections during “investigations” into plaintiff, interactions with plaintiff and during Plaintiff’s arrest and detention.
No proper documentation (warrant or docketed case number) was provided, depriving Plaintiff of constitutionally protected Due Process rights.
Damages
Plaintiff suffered wrongful incarceration, emotional distress, and financial harm as a direct and proximate result of these due process violations.
Prayer for Relief
Plaintiff seeks compensatory and punitive damages, attorneys’ fees, and all other relief deemed just and proper.
CAUSE OF ACTION 5
42 U.S.C. § 1983 — First Amendment Retaliation (Oconee County Sherrif’s Office and its Employees)
Parties and Incorporation of Facts
Plaintiff incorporates all preceding paragraphs as though fully set forth herein.
Brought against any Defendant who took adverse action in retaliation for Plaintiff’s, and his wife’s, protected speech or expressive conduct (e.g., public criticism of public officials, public servants and other prominent figures within Oconee County).
Violation of First Amendment
The First Amendment protects individuals from retaliatory actions by government officials for exercising free speech.
Specific Conduct
Defendants arrested or threatened Plaintiff, in part, because Plaintiff recorded public officials and criticized their actions.
No legitimate governmental interest justified the retaliatory arrest or harassment.
Damages
Plaintiff suffered a chilling effect on his speech, emotional distress, and additional harm as a direct and proximate result of the retaliation.
Prayer for Relief
Plaintiff seeks compensatory and punitive damages, attorneys’ fees, and all other relief deemed just and proper.
CAUSE OF ACTION 6
42 U.S.C. § 1983 — Unauthorized Release of Phone Calls (Right to Privacy / Fourth & Fourteenth Amendments)
Parties and Incorporation of Facts
Plaintiff incorporates all preceding paragraphs as though fully set forth herein.
Brought against all persons and entities responsible for releasing Plaintiff’s phone calls without lawful authority (e.g., jail officials, attorneys acting under color of law).
Constitutional Violation
The Supreme Court recognizes a reasonable expectation of privacy under certain circumstances, and official interception or release of telephone communications violates the Fourth Amendment and the Fourteenth Amendment’s Due Process Clause.
Specific Conduct
Recorded calls between Plaintiff and his wife were released to the public without a valid subpoena or judicial approval.
The subpoena that was eventually issued was improper and sought to collect post-trial evidence during an appeal, in violation of law.
Damages
As a direct and proximate result, Plaintiff suffered invasion of privacy, emotional distress, and harm to his legal interests.
Prayer for Relief
Plaintiff seeks compensatory and punitive damages, attorneys’ fees, and any additional relief the Court deems appropriate.
CAUSE OF ACTION 7
Monell Liability — 42 U.S.C. § 1983 (Policy, Custom, or Practice) — Oconee County
Parties and Incorporation of Facts
Plaintiff incorporates all preceding paragraphs as though fully set forth herein.
Brought against Oconee County and/or the Oconee County Sheriff’s Office in their official capacities.
Monell Standard
Municipalities may be held liable under § 1983 when a deprivation of constitutional rights is caused by a policy, custom, or practice, or by a failure to train or supervise.
Relevant Case Law: Monell v. Department of Social Services, 436 U.S. 658 (1978).
Specific Policy / Custom / Failure to Train
Oconee County maintained or permitted an unofficial policy allowing arrests without probable cause or due process.
Failure to address the abundance of complaints filed against the Oconee County Sheriff’s department shows an indifference to the culture of corruption that afflicts the vulnerable constituents of Oconee County.
Deliberate Indifference
Policymakers were on notice of consistent corruption form within the Oconee Sherrif but did nothing to remedy or discourage such conduct, demonstrating deliberate indifference.
Damages
Plaintiff’s unlawful arrests, detentions, and privacy violations were the foreseeable and proximate result of these municipal policies and customs.
Prayer for Relief
Plaintiff seeks compensatory and punitive damages (to the extent permitted), attorneys’ fees, and all other relief deemed proper.
CAUSE OF ACTION 8
Vicarious Liability
Parties and Incorporation of Facts
Plaintiff incorporates all preceding paragraphs as though fully set forth herein.
This claim is asserted under state law theories of vicarious liability.
Scope of Employment
Officers Honea, Dixon, and others were employees of Oconee County Sheriff’s Office, acting under the supervision of their employment at all relevant times.
Employer Responsibility
Under the doctrine of respondeat superior, Oconee County is responsible for its officers’ tortious actions performed in furtherance of County business.
Relevant Case Law: Although federal law under § 1983 does not recognize respondeat superior alone as a basis for liability (Monell), state tort law typically holds employers liable for employees’ acts within the scope of employment.
Damages
Because Officers engaged in trespass, false imprisonment, or other torts while on duty, Oconee County (as their employer) is liable for the resulting harm to Plaintiff.
Prayer for Relief
Plaintiff seeks damages, costs, and any other relief deemed just and fair under state law.
CAUSE OF ACTION 9
State Law Trespass — Against Officers Honea and Dixon
Parties and Incorporation of Facts
Plaintiff incorporates all preceding paragraphs as though fully set forth herein.
This claim is asserted under South Carolina common law of trespass.
Definition of Trespass
Trespass is an unauthorized entry onto another’s property.
Officer Honea and Officer Dixon each entered Plaintiff’s property without consent, warrant, or lawful justification on one or more occasions.
Specific Conduct
Honea bypassed a locked gate marked “No Trespassing” on or about May 28, 2024.
Dixon entered the property under pretext (e.g., missing child) or without valid cause, thereby infringing on Plaintiff’s possessory interest.
Damages
As a direct result, Plaintiff suffered emotional distress, interference with quiet enjoyment, and invasion of privacy.
Prayer for Relief
Plaintiff demands compensatory damages, punitive damages where permissible, costs, and all other relief the Court deems proper.
CAUSE OF ACTION 10
State Law False Imprisonment — Against All Relevant Officers
Parties and Incorporation of Facts
Plaintiff incorporates all preceding paragraphs as though fully set forth herein.
Definition of False Imprisonment
Under South Carolina law, false imprisonment occurs when a person is unlawfully restrained of their liberty without justification.
Specific Conduct
Officers arrested and detained Plaintiff based on an invalid order outside any formal judicial proceeding.
No probable cause, warrant, or lawful authority existed to justify Plaintiff’s confinement.
Plaintiff was detained for nearly 40 days without a case number of criminal violation on record.
Damages
This unlawful restraint caused Plaintiff to suffer loss of freedom, emotional harm, and reputational damage.
Prayer for Relief
Plaintiff seeks compensatory damages, punitive damages, and other relief the Court deems just and proper under state law.
CAUSE OF ACTION 11
Intentional (or Negligent) Infliction of Emotional Distress (IIED/NIED)
Parties and Incorporation of Facts
Plaintiff incorporates all preceding paragraphs as though fully set forth herein.
Brought against all Defendants who participated in extreme and outrageous conduct.
Extreme and Outrageous Conduct
Arresting and detaining Plaintiff without valid legal authority, trespassing on private property, and releasing private phone calls exhibit conduct that goes beyond all possible bounds of decency. This is targeted and orchestrated harassment.
Emotional Distress
Defendants knew or should have known their actions would cause severe emotional harm to Plaintiff, given the brazenness of the alleged misconduct.
Damages
Plaintiff suffered severe emotional distress, humiliation, anxiety, and other psychological harms as a direct and proximate result.
Prayer for Relief
Plaintiff seeks compensatory damages, including costs for counseling or medical treatment, punitive damages, and all other relief deemed appropriate.
CAUSE OF ACTION 12
State Law Abuse of Process
Parties and Incorporation of Facts
Plaintiff incorporates all preceding paragraphs as though fully set forth herein.
Elements of Abuse of Process
Abuse of process occurs when a party uses legal process for an ulterior or unlawful purpose, distinct from the purpose for which the process was designed.
Specific Conduct
Attorney Jim Logan, acting on behalf of Oconee officials, issued a subpoena for Plaintiff’s recorded calls during an appeal, even though new evidence gathering is disallowed.
This was done either to harass Plaintiff, gain illicit advantage, or otherwise misuse the judicial process.
Damages
As a direct result of this misuse of process, Plaintiff suffered emotional distress, invasion of privacy, and potential prejudice in legal proceedings.
Prayer for Relief
Plaintiff seeks compensatory and punitive damages, attorneys’ fees, and all other relief deemed just and proper under South Carolina law.