UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF IOWA BILLY DEWAYNE FRAZIER IV, Plaintiff, v. STATE OF IOWA, et al., Defendants. Case No.: 1:25-CV-00033-CJW-MAR THIRD AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF Filed under: 42 U.S.C. § 1983 (Civil Rights Violations) 18 U.S.C. § 1962 (RICO Act) Title Il of the Americans with Disabilities Act (ADA) The Federal Tort Claims Act (FTCA) All applicable state and federal constitutional provisions COMPLAINT SUBMITTED UNDER EXTREME DURESS, COGNITIVE PRESSURE, AND DISABILITY Plaintiff is an ADA-protected indigent single father of four, federal whistleblower, civil rights activist, and advocate. Diagnosed with PTSD, ODD, and cognitive impairments, Plaintiff files this complaint under coercive conditions of retaliation, obstruction, and intimidation carried out by state and federal officials. Judges C.J. Williams and Mark A. Roberts have refused recusal despite conflicts of interest and pre-existing bias. Plaintiff asserts this complaint underemergency circumstances and reserves the right to amend. SYSTEMIC JUDICIAL CORRUPTION TIMELINE (2007-2025) The following breakdown outlines the organized misconduct perpetrated by each category of official over a span of 18+ years: |. LAW ENFORCEMENT OFFICERS Pattern: Unlawful detainment, coerced statements, fabricated charges, surveillance, ADA violations, search and seizure abuse. Nathan Trimble (Cedar Rapids PD) — Participated in unconstitutional stop/search leading to OWI charge. Ben McAtee (Cedar Rapids PD) — Submitted false affidavit, violated ADA rights. Cody Mosher (Cedar Rapids PD) — Gave perjured testimony at DOT trial. Emily Kuba / Emily Cooper (Cedar Rapids PD) — Submitted tampered body cam footage. Jacob Paulson (Cedar Rapids PD) — Collusion in false narrative of OWI case. David Dostal (CRPD Chief) — Oversight and failure to discipline misconduct. Tom Votter (Federal Agent) — Intimidated Plaintiff regarding federal gun case. Unknown Officers (Marion PD 2006-2007) — Kicked in Plaintiff's door in retaliatory act; aided illegal gun case. Il. JUDGES AND COURT OFFICIALS Pattern: Procedural obstruction, blanket denials, coercion,denial of due process and ADA accommodations. Casey Jones — Conflict of interest (2007 PD, 2024 judge); failed to recuse. Carrie Bryner — Forced religious daycare placement; DHS collusion. Russell Keast — Ignored constitutional violations in OWI case. Linda Reade — Threatened 72-month sentence; signed coerced plea. Nicholas Scott — Trial judge for OWI; violated right to present evidence. Mark Fisher — Obstructed OWI judicial review. lan Thornhill — Refused to intervene when notified of misconduct. Rachel Morgan — ALJ; manipulated DOT proceedings. C.J. Williams — Denied injunctive relief; demonstrated bias. Mark A. Roberts — Failed to recuse; obstructed ADA filings. Edward Mansfield, Thomas Waterman, Christopher McDonald — lowa Supreme Court Justices who rubber- stamped denials. Kay (Linn County Transcriber) — Filed transcript to wrong docket. Ill. PROSECUTORS / DISTRICT ATTORNEYS Pattern: Suppression of exculpatory evidence, coercion of pleas, selective prosecution. + Heidi Carmer — Coerced 2016 plea using children as leverage.Heidi Weiland — Altered witness testimony; colluded with officers. Valerie Clay — Prosecuted under false DHS pretenses. Jerry Vander Sanden — Oversaw systemic corruption in DAs office. Nicholas Maybanks — Approved retaliatory filings. Robert Teig — Federal prosecutor in 2007 gun case; coerced guilty plea. Brenna Bird — Ignored whistleblower complaints. Pat Reiner — U.S. Attorney's Office; suppressed communication. IV. PUBLIC DEFENDERS AND PRIVATE ATTORNEYS Pattern: Ineffective assistance, waiver manipulation, collusion, abandonment. Amber Foley — Embedded waiver of speedy trial. + Jeffrey Fields — Held ex parte meetings with prosecution. + Corey Goldensoph — Discouraged Plaintiff from calling witnesses. + Jeremy Elges — Refused to file motions; ineffective assistance. + Nikedra Tucker — Allowed DA to threaten Plaintiff into plea. + Jane Kelly — Coerced Plaintiff in 2007; now 8th Cir. judge. + Shoemaker & Jacobson — Sabotaged civil suit in 2014. Matthew Petrazellka — Conflict of interest and bribery allegations.V. DHS / SCHOOL / CHILD SUPPORT OFFICIALS Pattern: Unconstitutional removals, religious coercion, custody interference, surveillance. Kristen Denniger — Enforced daycare mandate under threat. Ashley Habhab — Retaliated through DHS complaints. Will Hanchett — Fraudulent child support actions. Julia & Marv Treacha — Interfered with custody; Linn County Advocates. Melissa Clifton — Colluded with foster family. Brian Cobb — Authorized illegal removal from Wright Elementary. School Officials — Raseak, Happel, Muters, Estate of Noreen Bush; assisted DHS. Unknown DHS Officers — Created 30+ cases against Plaintiff. VI. OTHER GOVERNMENT / CIVILIAN ACTORS Pattern: Surveillance, property interference, aiding prosecution. Rick Green — Evidence tampering. Robert Gast — Withheld FOIA records. Alfred Malinowski Jr. — Retaliatory plant; stole U.S. flag, exposed himself. Courtney Russell — Known plant; involved in domestic setup. Professional Hearing Solutions — Contracted for illegalsurveillance. D&D Real Estate — Assisted officers in harassment. 1311 Center Street Landlord — Aided in property interference. Deidra Terpkosch-Anderson — Colluded in 2007 public defender sabotage. Hannah Bibiano — DHS agent or public official; retaliated. Edward & Robert Tigus — Tampered with Plaintiff's vehicle and license. lowa DOT Personnel — Violated ADA and court orders. Vil UNNAMED / UNKNOWN ACTORS Pattern: Obstruction, interference, retaliation, fraud. Unknown Officers (2006-2025) — Unidentified Marion/ CRPD actors. Clerks of Court — Blocked filings; manipulated docket. Marshals, FBI, Postal Agents — Intimidation, mail tampering. Jail Staff — Sabotaged habeas filings. Transcribers — Intentionally misfiled appellate transcripts. Jane Doe (USAO Secretary) — Obstructed access. All others discovered through FOIA and discovery CONSTITUTIONAL AND STATUTORY VIOLATIONS First Amendment: Redress, religion, freedom of expression Fourth Amendment: Illegal search and seizureFifth Amendment: Due process, coerced pleas Sixth Amendment: Right to effective assistance and fair trial Fourteenth Amendment: Equal protection, selective prosecution ADA Title Il: Failure to accommodate disabilities 42 U.S.C. § 1983: Civil rights violations 18 U.S.C. § 1962: RICO conspiracy FTCA: Federal liability for tortious acts SUPREME COURT PRECEDENTS + Haines v. Kerner, 404 U.S. 519 (1972) Brady v. Maryland, 373 U.S. 83 (1963) + Giglio v. United States, 405 U.S. 150 (1972) Bounds v. Smith, 430 U.S. 817 (1977) INCORPORATION OF PRIOR FILINGS Plaintiff incorporates all documents, exhibits, transcripts, and filings submitted in: + OWCR154106 CVCV106294 Federal Habeas Corpus (28 U.S.C. § 2254) Emergency Injunction & TRO filings Appeals: 25-1933, 25-1934, 25-1936 RESERVATION OF RIGHTS Due to active retaliation and ADA impairment, Plaintiff expressly reserves the right to: + Amend this complaint as new defendants are identified Join similarly affected individuals under Rule 20 & 23 + Include further evidence of judicial conspiracyRequest a Special Master to oversee all federal filings Respectfully submitted, Billy Dewayne Frazier IV Pro Se Plaintiff ADA-Protected, Federal Whistleblower, Civil Rights Activist Filed: July 1, 2025 DECLARATION UNDER PENALTY OF PERJURY Pursuant to 28 U.S.C. § 1746, |, Billy Dewayne Frazier IV, declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge, belief, and understanding. All allegations are based on direct evidence, firsthand experience, public record, and/or information and belief pending discovery, FOIA returns, or further investigation. | declare that each named defendant is sued in their individual and official capacities, and | reserve the right to amend this complaint as additional defendants, facts, and claims emerge through continuing investigation, FOIA responses, and formal discovery.