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United States District Court Northern District of Florida Tallahassee Division UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF FLORIDA TALLAHASSEE DIVISION BOBBY JOE LONG, Plaintiff, CIVIL ACTION NO.__________ v. RON DESANTIS, Governor, EMERGENCY in his official capacity; INJUNCTIVE RELIEF SOUGHT JIMMY PATRONIS, EXECUTION OF STATE DEATH Chief Financial Officer, SENTENCE SCHEDULED FOR in his official capacity; MAY 23, 2019, AT 6:00 P.M. ASHLEY MOODY, Attorney General, in her official capacity; NIKKI FRIED, Commissioner of Agriculture, in her official capacity; JULIA McCALL, Coordinator, Office of Executive Clemency, in her official capacity; MELINDA COONROD, Chairman, Commissioner, Florida Commission on Offender Review, in her official capacity; SUSAN MICHELLE WHITWORTH, a/k/a S. Michelle Whitworth a/k/a Michelle Whitworth, Commission Investigator Supervisor, Florida Commission on Offender Review, in her official capacity. 42 U.S.C. § 1983 COMPLAINT FOR DECLARATORY AND INJUNCTIVE RELIEF I. NATURE OF ACTION 1. This is a civil action brought under 42 U.S.C. § 1983 for violations of Plaintiff Bobby Joe Long’s federal statutory rights under 18 U.S.C. § 3599 and for violations of his constitutional rights to have meaningful counsel present for a critical stage of his legal case unique to death-sentenced individuals in the State of Florida: executive clemency. While clemency is not itself a constitutional right, it is a necessary step under Florida’s statutory scheme for carrying out a death-sentenced individual’s execution. Florida’s creation of this critical stage in litigation unique to death-sentenced persons requires meaningful counsel under the Sixth Amendment. Mr. Long specifically asserts that his rights have been violated under 18 U.S.C. § 3599 and the Sixth and Fourteenth Amendments to the United States Constitution. 2. Mr. Long seeks injunctive relief in the form of a stay of his scheduled May 23, 2019, execution pending the completion of an executive clemency process that comports with federal law, and declaratory relief that the defendants violated his federal rights. II. PARTIES TO THE COMPLAINT PLAINTIFF 3. Bobby Joe Long is a prisoner on Florida’s death row, pursuant to his 1989 death sentence originating from Hillsborough County, Florida. Long v. State, 2 610 So. 2d 1268 (Fla. 1992), cert denied, Long v. Florida, 510 U.S. 832 (1993). He is a citizen of the United States and a resident of the State of Florida. Governor Ron DeSantis informed Mr. Long that his clemency was denied, and on April 23, 2019, signed a warrant for Mr. Long’s execution, setting it for May 23, 2019, at 6:00 p.m. at Florida State Prison, in Raiford, Florida. DEFENDANTS 4. Defendant Ron DeSantis is the Governor of Florida and the head of the Clemency Board. He is sued in his official capacity. 5. Defendant Jimmy Patronis is the Chief Financial Officer of Florida and thus a member of the Clemency Board. He is sued in his official capacity. 6. Defendant Ashley Moody is the Attorney General of Florida and thus a member of the Clemency Board. She is sued in her official capacity. 7. Defendant Nikki Fried is the Commissioner of Agriculture of Florida and thus a member of the Clemency Board. She is sued in her official capacity. 8. Defendant Julia McCall is the Coordinator of the Office of Executive Clemency. She is responsible, in part, for contracting with state clemency counsel. She is sued in her official capacity. 9. Defendant Melinda Coonrod is the Chairman of the Florida Commission on Offender Review, the agency that facilitates the clemency process on behalf 3 of the Clemency Board, including the private contracting of clemency counsel. She is sued in her official capacity. 10. Defendant Susan Michelle Whitworth (also known as S. Michelle Whitworth and Michelle Whitworth) is the Commission Investigator Supervisor of the Florida Commission on Offender Review. Ms. Whitworth is the primary source of communication, and seemingly, decision-making for capital clemency purposes, acting on behalf of the Florida Commission on Offender Review and the Clemency Board. She is sued in her official capacity. II. JURISDICTION AND VENUE JURISDICTION 11. This action arises under federal statute and the United States Constitution, and presents a federal question within this Court's jurisdiction under Article III of the Constitution and 28 U.S.C. § 1331 and § 1343(a)(3). This action is brought pursuant to 42 U.S.C. § 1983. This Court has the authority to grant declaratory and injunctive relief pursuant to 28 U.S.C. § 2201(a), § 2202, and Federal Rule of Civil Procedure 65. VENUE 12. Pursuant to 28 U.S.C. § 1391(b), venue is appropriate in the Northern District of Florida because the majority of defendants live and work in this District, and the actions and decisions giving rise to this suit occurred in this District. 4 III. STATEMENT OF FACTS1 13. This complaint concerns the clemency proceedings of Bobby Joe Long, a death-sentenced individual in the State of Florida. Clemency has long been regarded as the ultimate act of grace or mercy, and in the capital context, it is the difference between life and death. Given the gravity of the clemency process for Mr. Long and the tremendous deficiencies in his clemency presentation—including the absence of many of the basic facts about his life—a brief recitation of his life history is warranted prior to the specific facts giving rise to the violations of his rights this action concerns. A. Bobby Joe Long’s Life 14. Bobby Joe Long was born on October 14, 1953, in West Virginia, to Joe Long and seventeen-year-old Luella Long. Joe was a violent man who drank heavily in front of his young son, Mr. Long. 15. Before and after Mr. Long’s birth, his parents had a turbulent relationship. They divorced twice after Mr. Long was born and remarried three times. When his parents lived together, they fought constantly. Luella was frightened of Joe. 1 In addition to providing this statement of facts, Mr. Long submits simultaneously with this complaint an appendix of relevant documents. Materials in this appendix will be cited to as “App. at [page].” 5 16. Joe sometimes grabbed Luella by the hair, almost pulling it out. He also violently grabbed her breast and twisted it. Other times, Joe threatened Luella with a pistol. The family lived in a tiny home then, and Mr. Long either directly witnessed this violence or was close by in another room and heard his mother’s cries. Sometimes Joe directed his violence toward Mr. Long and threw things at his son. 17. When Mr. Long was eight months old, Luella Long divorced Joe Long for the first time. She started dating other men and went out around town with them. Joe started driving up next to Luella and her dates as they were walking down the street. He would force Luella into his car. Then he would drive Luella out to the countryside or a lumberyard and rape her. 18. One time when Luella arrived home, she discovered Joe had climbed through the window and was waiting for her in her room with a knife. He tried to rape her at knifepoint. Though he was unsuccessful, he held her prisoner the entire night. Luella told her mother about the abuse, and her mother twice called the police on Luella’s behalf. There were “at least six episodes where [Joe] had either abducted [Luella], taken her out to the fields, beaten her up . , or waited for her with a weapon.” 19. In part due to Joe Long’s violent stalking, Luella Long and Mr. Long moved in with Luella’s aunt in another West Virginia town. Joe became less involved 6 in Mr. Long’s life. Joe and Luella remarried later in Mr. Long’s life, but, when Mr. Long was growing up, his father lived with him for two to four years total. About two years after she left Joe, Luella moved with her son to Miami, Florida. 20. Luella moved around frequently, which resulted in Mr. Long changing schools every year. Sometimes he transferred schools two or three times in a single school year. This affected Mr. Long’s ability to learn. Despite having high average intelligence, Mr. Long failed first grade. He had problems paying attention and settling down. 21. Mr. Long suffered numerous pediatric head injuries. Mr. Long’s first head injury was when he was about 4 or 5 and fell off a swing. He was knocked unconscious for several minutes and awakened to find a stick stuck in his left eyelid. He still bears a scar there. Around the same age, he was hit by the side of the door and busted his head open. Soon after that, he fell off his bike. A few years later, he fell down the stairs. On that occasion, he was unconscious for 15 or 20 minutes, and his mother had to call a rescue squad. 22. When Mr. Long was seven years old, he was hit by a car. The car hit him in the head, tearing off parts of his face and busting his jaws. Mr. Long suffered extensive damage to his mouth, and some of his teeth smashed into his gums. Mr. Long was hospitalized for a week. He was left with a broken jaw. 7 23. A year later, Mr. Long fell down another set of stairs, this time at his grandmother’s apartment building. There was a big flight of stairs in the building, and Mr. Long fell all the way to the bottom. He was knocked out for several minutes again, but this time his family did not seek medical attention. 24. When Mr. Long was 11 or 12, he was riding a horse at a cousin’s house when the horse threw him off.
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