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) United States District Court

Andrew U. D. Straw ) Northern District of Indiana

Plaintiff, )

) Case No.: 3:14-cv-1772

v. )

Brenda Sconiers, and ) Jury Trial Demanded

Thomas Dixon, Sconiers’ )

Attorney, and )

St. Joseph County )

Superior Court, )

Defendants. )

 AMENDED COMPLAINT 

1. I, plaintiff Andrew U. D. Straw, having considered the Court’s 

ORDER of December 30, 2014, ask for leave to amend under 

Federal Rule of Civil Procedure 15(a)(2).

2. Rule 15(a)(2) provides that, “Other Amendments. In all other 

cases, a party may amend its pleading only with the opposing 

party's written consent or the court's leave. The court should 

freely give leave when justice so requires.” Because it is now past 

the time wherein an amendment by right may be had, I seek leave 

to amend.

3. This amended complaint has exhibits attached. These provide the 

evidence of tortious conduct that I seek to remedy in this court 

under several different legal theories. They also show that justice 

would be served by allowing this amended complaint.

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DEFENDANTS

4. Upon review of the facts, I have decided that the defendants in 

this action will be attorney Thomas M. Dixon, Indiana Supreme 

Court Employment Law Director and ADA Coordinator Brenda 

Rodeheffer, individually and as an officer of the Indiana Supreme 

Court, and the Indiana Supreme Court. Because the Attorney 

General’s office has already appeared in this case on behalf of the 

State of Indiana and Dixon has appeared on his own behalf, and 

the Attorney General will represent Rodeheffer in her capacity as 

a state officer, service will be through the Court’s CM/ECF system.

COUNTS

5. The counts I make include intentional infliction of emotional 

distress against Defendant Dixon, intentional infliction of 

emotional distress against Rodeheffer (individually and as a Court

employee), and 42 U.S.C. § 1983 against Rodeheffer and the State 

of Indiana for violations of my civil rights as a person with 

physical and mental disabilities.

FACTUAL RECITATIONS AND EXPLANATION

DISABILITIES BACKGROUND

6. My disabilities began with exposure to PCE, TCE, and other 

chemicals on Camp LeJeune Naval Base while my father was 

serving there as a Marine in 1969. I was born at Camp LeJeune 

Naval Hospital. (Exhibits A1, A2) The poisoning issue has been 

covered in the media, and was the cover story in Newsweek on 

July 25, 2014. (Exhibit B) The poisoning was the topic of a book, 

A Trust Betrayed: The Untold Story of Camp LeJeune and the 

Poisoning of Generations of Marines and Their Families, by Mike 

Magner, 2014. 

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7. While my father was training for his deployment to Vietnam, I 

was being poisoned by the very base where he trained.

8. The Janey Ensminger Act of 2012, signed by President Obama, 

recognized officially that the poisons at Camp LeJeune caused at 

least a list of 15 different ailments, including breast cancer and 

neurobehavioral effects. The Veterans Administration lists these 

on its Camp LeJeune Public Health website. (Exhibit C)

9. Among my disabilities from the poisoning at the Base are bipolar 

disorder, migraines, anxiety, and severe allergies for which I took 

desensitization shots for 14 years. My weakened immune system 

resulted in hospitalization for pneumonia. I have a diagnosis 

letter from my psychiatrist which proves the bipolar, which is the 

principal disability at issue here. (Exhibit D)

10. My mother, Sandra, died of breast cancer which was 

diagnosed at age 46. (Exhibit E) She died during my second year 

of law school, February 1997. (Exhibit F)

11. I turn 46 in March of 2015. (Exhibits A1, A2) 

12. As a result of her death, I dropped one class, the one I felt 

was most stressful to me. This was Trial Process. I withdrew 

from only one class during law school. (Exhibit F, p. 3)

13. My U.S. Navy Federal Tort Claims Act file number for my 

poisoning claim is 140367. I am the administrator of my mother’s 

estate as per In Re: Estate of Sandra Stevens, 32D05-1409-EU000204 (Hendricks Sup. Ct. #5). Sandra Stevens’ Estate’s U.S. 

Navy FTCA file number for her wrongful death is 150475.

14. I have scoliosis, the only one in my family with the exception 

of my daughter, who had back surgery to stabilize her spine with 

rods and screws on December 11, 2011. I attribute this to the 

teratogenic qualities of the poisons I was exposed to. 

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15. I have inquired with the National Scoliosis Foundation to 

learn more about the chemical and genetic causes of this condition 

my daughter and I have. I have considered attaching the photos 

of my daughter’s surgery, but am choosing not to in order to 

protect her privacy.

16. I have been in the hospital for bipolar about 10 times. The 

first time was following my mother’s death, after I graduated from 

law school, in 1998.

17. My proposed bill to provide compensation and medical care 

and other protections was covered on KLTV on January 27, 2015: 

http://kltv.videodownload.worldnow.com/kltv_20150127194806120

AA.mp4

18. Other Children of Camp LeJeune are currently lobbying for 

this bill to pass Congress. (Exhibit PP)

WORK AND DISABILITIES

19. My mother’s cancer was discovered in December 1994. I 

went with her to the oncologist. This is about the time I learned I 

was admitted to law school also. I began law school in August of 

1995.

20. As a law student, I was approximately at the middle of my 

class, but I was extremely active on the Bloomington campus of 

Indiana University. A friend and I founded College Democrats on 

the campus, which now has over 500 members. I represented the 

Law School in the IU Student Association, the student 

government. I was Dean Alfred C. Aman’s research assistant, and 

I also helped Professor F. Thomas Schornhorst and Professor Paul 

Craig of Oxford and was a student member of the Law School 

Educational Policy Committee.

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21. The worse my mother’s cancer got, the harder I worked, 

until every minute was planned. As a result, the IU Student 

Association recognized me as one of the most active student 

leaders on the campus, while I was a 1L law student. (Exhibit G)

22. After law school, I worked for Alan M. Voorhees, a famous 

transportation planner who was on a UDT-11 (SEAL) team during 

WWII in the Pacific. His “gravity theory” of traffic flow made the 

Interstate Highway System possible, especially in urban areas, 

and he planned the Metro in Washington as well as transportation 

in lower Manhattan. He owned an important aerospace firm, 

Autometric, which protects American civilian and military air 

traffic with satellite surveillance, as well as several other high 

tech companies that worked in national defense and with the FBI.

23. I was his corporate counsel, and he involved me heavily in 

his court automation and other projects. (Exhibit H)

24. To learn the paper flow of the court, I worked with Clerk 

Rosa Forrester in Richmond County, Virginia, and with Judge 

Joseph E. Spruill, Jr., former president of the Virginia State Bar. 

Judge Spruill trusted me with the constitutional research for a 

triple murder-arson trial that came before him. This case was 

also an opportunity to arrange documents and categorize them for 

Clerk Forrester. We also had family law and civil cases.

25. I worked directly with Mr. Voorhees’ cutting edge court 

records automation system, and I provided feedback on the system 

to the programmers in Russia who made upgrades based on my 

suggestions. I did similar things for Lizardtech, which developed 

the image compression software for the FBI fingerprint database.

26. While working on the court automation project, I came up 

with a proposal for a statewide e-filing system for the Virginia 

Supreme Court using the various technologies and paper flow 

information I had learned. I represented Alan M. Voorhees before 

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legislative committees, in meetings with the Virginia Supreme 

Court staff, and with court clerks statewide.

27. The Virginia State Bar invited me to be a member of its new 

Task Force on Technology, and I became the Education of Bench 

and Bar committee’s co-chair. (Exhibit I)

28. My grief over my mother’s death was not over in 2000. 

When Mr. Voorhees told me his wife was dying of cancer, it caused 

me to become very sad, and unwell.

29. At the time, my wife was finishing her Ph.D. in Chinese 

documentary film and media studies, so moving back to 

Bloomington, Indiana, was wise for us.

INDIANA SUPREME COURT: STATISTICAL ANALYST

30. I applied for a job with the Indiana Supreme Court while 

still working for Mr. Voorhees and on the recommendation of Dean 

Robel at the Law School and former Dean Aman, and Mr.

Voorhees, the Court hired me to be its statistical analyst in August 

of 2000. (Exhibit J) Note the list of duties in the job description

and the “very high” level of responsibility. I never received the 

performance review promised in the hiring letter.

31. On February 22, 2001, I was in a head-on car accident that 

nearly took my life and the life of my passenger, Jenny Bauer, a 

colleague at the Supreme Court. We were on our way to work.

(Exhibit K)

32. My legs were crushed and my right hip. (Exhibit L – total 

hip replacement, 4/11/2012)

33. When I returned to work, in July of 2001, my boss, Kurt 

Snyder began complaining that I did not walk fast enough, that I 

was not working fast enough. He complained that I was using the 

Internet too much.

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34. This despite the fact that I was designing the new Supreme 

Court webpage, communicated with the state trial judges about 

the new system to provide them email, and did the normal 

statistical work covering 400 courts.

35. Mr. Jeff Bercovitz, a senior staff member in the Judicial 

Center, told me that my job had too many responsibilities for one 

person and when he helped design the role, and that is what he 

said to the others.

36. I worked with Mr. Bercovitz on the weighted caseload study 

and analysis, and several months after I was fired, he gave me 

recognition for the work I did. (Exhibit M, p. 1 and p. 3) The 

Chief Justice gave me no credit for any of the work I did, including 

my work with deaf and blind court users, which I did on my own 

initiative.

37. Despite my accident and its aggravation of my bipolar 

disorder such that I was sluggish and found it difficult to 

concentrate, I had national recognition for an idea I came up with 

to help domestic violence victims.

38. In 2000, President Clinton made the first presidential 

webcast, on June 24, 2000. (Exhibit N) In this webcast, the 

president announced an e-government contest. The president 

said, 

“Third, in conjunction with the nonprofit Council for 

Excellence in Government, we’re launching a major 

competition to spur new innovative ideas for how 

Government can serve and connect with our citizens 

electronically. The Council will award up to $50,000 to those 

students, researchers, private sector workers, or 

Government employees who present the most creative 

ideas.” (Exhibit N, p. 2)

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39. Students at the Kennedy School of Government at Harvard 

and Council for Excellence staff reviewed and narrowed down the 

entries to eight national finalists.

40. My idea for a database of protective orders, updated in real 

time at the trial court level and available to police across the 

country immediately, was one of these eight national finalists. 

(Exhibit O)(Exhibit P)

41. I had worked with the Council for Excellence, had attended 

their leadership and innovation seminars, and trained with senior 

officials at Health and Human Services in the Council’s 

government leadership programs. Mr. Voorhees had provided 

their office space in Washington and start-up funds in the early 

1980s, and he went with me to meet the president of the Council 

for Excellence. The Council had all ex-US presidents on its board.

42. There was no recognition from the Court when I received 

this national honor, but Justice Sullivan gave me approval to go to 

Washington to present it, 2 weeks after I returned from my 

accident.

43. Instead, what happened is that I received the criticism 

mentioned above. This idea apparently was much more popular 

than the Chief Justice admitted, because after he fired me, he 

sought out a federal grant and spent that money to build my idea 

with no reference to the Imagine E-Government Award. (Exhibit 

Q)

44. This was both dishonest and disability discrimination, to 

take my idea in this way after having treated me so poorly, firing 

me, as the former Chief Justice of Indiana did on July 11, 2002. 

This was one month after I was admitted to the Indiana bar.

45. When I came to the Indiana Supreme Court, the reason I 

was hired was my background working on trial court technology 

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and document automation technology. My protective order 

database idea was no different from my other work except for the 

fact that I came up with the idea on my own, no one else at the 

Court. I had received a great deal of training in a short time in 

Virginia, and in the Mid-Atlantic this was recognized. (Exhibit R)

46. I never received recognition for my initiative to get a visionimpaired trial judge JAWS software so he could use his computer. 

I did not receive recognition when I went to the Indiana 

Association of the Deaf and talked with them about the new trial 

court transcription automation system I was staffed.

47. When I work on something, a disability aspect always 

emerges.

48. As the Court may be aware, Indiana’s Board of Law 

Examiners asks disability-related questions on its application, 

and I answered them honestly. I said I had bipolar disorder.

49. Immediately after this, my boss at work, Ron Miller, started 

making negative comments about people who have bipolar 

disorder. He put all of my work tasks on a huge white board in 

the hallway outside my office and said when you get something 

done, tell me and I will cross it off. Miller sent me to get remedial 

Microsoft Excel training. I felt humiliated by everything Miller 

did.

50. When I offered to help with the new Case Management 

System, which ultimately failed under his leadership, costing the 

state millions of dollars, he did not even answer as I stood in the 

doorway.

51. I had warned the Executive Director, Lilia Judson, by email 

that the federal government was investigating Computer 

Associates. Like with Miller, I never received any response. 

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52. Later, in 2007, I worked on a major international corporate 

fraud audit, and translated hundreds of pages from Italian into 

English to facilitate the government investigation.

53. I worked as corporate counsel for a famous entrepreneur, 

Alan M. Voorhees, whose company invented the bar code used in 

retail. He was worth hundreds of millions of dollars, and I worked 

directly for him, my office next to his. 

54. But once I told the court (privately, I thought) that I had

bipolar on its bar exam application, I was not worth a reply from 

my superiors. Apparently, having bipolar meant nothing I said 

was reliable, my work product was automatically poor despite the 

evidence otherwise, and my accomplishments were to be picked 

like cherries for themselves.

55. But the SEC was investigating Computer Associates in 2002. 

The evidence is available on the Internet. (Exhibit S) There were 

federal indictments and the CEO of Computer Associates was 

convicted and got a 12-year federal sentence for securities fraud 

and obstruction of justice. (Exhibit S1)

56. Ignoring my advice and firing me had consequences. The 

Indiana Law Blog stated that over $6 million was spent on a 

system that simply did not work. The money went to Computer 

Associates, a company obviously not reliable. It is ironic in the 

extreme that the part of the system that did not work right was its 

accounting module, to take care of court fines and costs. (Exhibit 

T)

57. I took the bar exam in February of 2002.

58. I passed the bar exam. I had a character and fitness 

interview, which went fine. I had no criminal record and in fact I 

was admitted to practice in Virginia in 1999.

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59. But my bipolar disorder was an issue for the Board. I was 

ordered to come before a room full of people, some of them people I 

worked with at the Court. I was interrogated on my bipolar 

disorder and forced to answer extremely sensitive private 

information about my health, in particular, every time I had ever 

been manic. Again, in front of people with whom I worked at the 

Court.

60. The Board forced me to sign a consent agreement before it 

would give me a law license. (Exhibit W)

61. All of this was very upsetting, and when I was sworn in on 

June 7, 2002, some of those same people who interrogated me 

were present. 

62. I became unwell the night of my swearing in as an Indiana 

attorney, and called my doctor. Doctor Michael Wenzler of 

Bloomington told me to stay home from work for four weeks.

63. I gave the note to my work, stayed home for four weeks, and 

when I came back to work, Lilia Judson called me into her office 

and fired me. I was escorted out of the building by two large 

security guards. This was July 11, 2002, 11 days before my 

daughter’s birthday.

64. Lilia Judson said to me before I left that “at least now you 

have your law license.”

65. Justice Sullivan, who was not my direct supervisor, was the 

person who showed me humanity after my car accident. (Exhibit 

X) I appreciate him, but the decisions about my work lay with 

Executive Director Lilia Judson and Director Ron Miller once I 

revealed I had my bipolar disorder.

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66. In 2006, the Board of Law Examiners threatened to take my 

law license away unless I continued doing what the consent 

agreement demanded that I do.

67. I responded that the Board was violating the Americans with 

Disabilities Act, Title II, as explained in Tennessee v. Lane, 541 

U.S. 509 (2004). (Exhibit Y)

68. The Board immediately thereafter removed the conditions on 

my license.

69. There was a newspaper story in the South Bend Tribune in 

2010 about trial court statistics and why they are so wrong. I 

contacted the reporter and gave my opinion as the former 

statistical analyst in charge of that for all 400 courts.

70. Lilia Judson insulted me in a follow-up story on November 

14, 2010, stating that I “had no authority” to talk about court 

statistics and that I was merely a “disgruntled” ex-employee. She 

admitted that there were mistakes to the reporter, which is what I 

was saying. (Exhibit U)

71. On March 2, 2014, I asked the Indiana Supreme Court to 

hire me to address the disability rights matters I had experienced, 

but Brenda Rodeheffer on March 20, 2014, stated that no position 

like that was open and I would not be hired to do any such thing. 

(Exhibit V)

72. I filed a Petition for Redress of Grievances on August 15, 

2014, with the Indiana Supreme Court because I felt it had 

violated my Indiana constitutional rights, my rights as a human 

being, and my federal constitutional rights in discriminating 

against me as a continuous matter over a long period of time. 

(Exhibit Z) 

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73. The Clerk of Court, Kevin S. Smith, refused to accept my 

petition by letter on August 28, 2014, stating that the Indiana 

Supreme Court had no original jurisdiction to review its own 

actions in how it treated its employees and people who applied to 

its agency for bar admission. (Exhibit AA)

74. I submitted the Petition again with further explanation, 

including Indiana Constitution, Article 7, Section 4, and copied it 

to all members of the Indiana House and Indiana Senate, as is my 

right under Indiana Constitution, Section 31, Right of Assemblage 

and Petition. Clerk Smith rejected it again, despite this language:

Section 4. The Supreme Court shall have no original 

jurisdiction except in admission to the practice of law; 

discipline or disbarment of those admitted; the unauthorized 

practice of law; discipline, removal and retirement of justices 

and judges; supervision of the exercise of jurisdiction by the 

other courts of the State; and issuance of writs necessary or 

appropriate in aid of its jurisdiction. The Supreme Court 

shall exercise appellate jurisdiction under such terms and 

conditions as specified by rules except that appeals from a 

judgment imposing a sentence of death shall be taken 

directly to the Supreme Court. The Supreme Court shall 

have, in all appeals of criminal cases, the power to review all 

questions of law and to review and revise the sentence 

imposed. Ind. Const., Article VII, Section 4. (Exhibit BB)

75. In this second letter from Clerk Smith, he referred my 

petition to the Court’s Employment Law Director, Brenda 

Rodeheffer. She again denied my petition and demands for justice

on September 19, 2014.

76. To be explained below, one of my civil rights clients has had 

a malpractice case against me. Sconiers v. Straw, 71D07-1310-CTUSDC IN/ND case 3:14-cv-01772-JD-CAN document 31 filed 01/30/15 page 13 of 33
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00265 (St. Joseph Ct. Sup. Ct.) The plaintiff’s lawyer in that case 

is Thomas M. Dixon, IndianaBar #18611-71.

77. Attorney Dixon has filed emails that he received from 

Brenda Rodeheffer in his malpractice case. (Exhibit DD) 

78. Note that Rodeheffer informed Dixon in these emails that 

she was filing a disciplinary complaint against me on September 

3, 2014, 5 days after I filed my Petition for Redress of Grievances. 

This is strong indication that her actions were in retaliation for 

my demand for justice on the basis of the Court’s disability 

discrimination against me.

79. It appears the Dixon had entered only two emails from a 

conversation of more emails, but these two emails were entered as 

Exhibits C and D in the malpractice case.

80. Rodeheffer did indeed file a disciplinary complaint on 

September 3, 2014, and the Indiana Attorney Disciplinary 

Commission demanded that I respond to it, despite the fact that 

nothing Rodeheffer listed in the complaint was an ethical violation 

of any kind. (Exhibit EE)

81. Ironically, just 15 days before Rodeheffer’s claim, my 

psychiatrist, Dr. Maria Estrada, wrote a letter for me in support of 

taking my Virginia law license out of disabled status and putting 

it into active status. She said that I was symptom-free, have not 

been hospitalized in 4 years, and am “quite productive.” (Exhibit 

BBB)

RODEHEFFER’S DISCIPLINARY COMPLAINT

82. She made a bald statement that my mental disorder is so 

severe that I am unfit to practice law, and then she listed a 

number of things I work on, including political asylum cases for 

Ukrainians.

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83. Perhaps Rodheffer is unaware, but Russia has invaded 

Ukraine and over 4,800 people have been killed, and many more 

injured. My fiancée, Victoria Yaroshenko, is from Ukraine and she 

helps me when someone needs to speak Russian. She is a 

paralegal and is a graduate student at Argosy in mental health 

counseling.

84. My life is probably much more international than 

Rodeheffer’s. I speak Italian fluently and have studied German 

and French, and am learning Russian. My children are bilingual 

in English and Italian and have citizenships in the USA, the EU, 

and Oceania. I took and passed the U.S. Foreign Service Exam in 

1998 and worked for the Italian Foreign Ministry in 1995. Just 

because Rodeheffer does not have such experiences does not make 

me unwell. It makes her parochial, and quick to accuse me of 

being unfit with no cause. Quick to discriminate and hurt me.

85. To be quite honest, if I were in a position of authority at the 

Indiana Supreme Court and saw such a phony disciplinary 

complaint, Rodeheffer would not be there long. The person who 

supervises her would also be required to explain. 

86. That person is Lilia Judson. She is not done discriminating 

against me, apparently.

87. Yes, I filed a lawsuit against the American Bar Association 

and the top 50 law schools because they are hiding the disability 

statistics of law school classes. Straw v. ABA, 1:14-cv-05194 (N.D. 

Ill.) There was good reason.

88. The Law School Admission Council admitted to 

discriminating in administering the LSAT. This is not my 

imagination. The U.S. Department of Justice announced it in May 

of 2014 (Exhibit FF)

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89. The Department of Justice has started holding the 

discrimination of state supreme courts to account in their bar 

admissions, especially applicants with mental disabilities, like 

mine. (Exhibit GG)

90. Many civil rights organizations oppose behavior that the 

Indiana Supreme Court has continued to this time, similar to the 

Louisiana Supreme Court’s, as evidenced in this letter to the 

Justice Department.

http://www.bazelon.org/portals/0/In%20Court/Current%20Cases/C

urrent%20Cases/Louisiana%20Bar%20Conditional%20Admissions

/National%20Support%20Letter_1-8-14.pdf

91. It appears that the day of reckoning for discriminating state 

supreme courts and their discriminating court bureaucrats has 

arrived. I have been waiting a very long time for it, asking again 

and again with rejections of my pleas.

92. These people, Rodeheffer and Judson and Clerk Smith, have 

discriminated against me on the basis of the bipolar disorder that 

I got from being poisoned while my father was training to fight in 

Vietnam.

93. My background is in law and disability rights. Instead of my 

activities being evidence of mental illness, quite the contrary. In 

2013, I asked the IU-Maurer School of Law to be more accessible 

to students with disabilities. Instead of filing a disciplinary 

complaint against me, Indiana University Provost Lauren Robel 

wrote, “Sparkling flying colors is the right standard, Andy. You are 

a brilliant lawyer. It has always been wonderful to watch your 

advocacy, Lauren,” November 11, 2013. (Exhibit HH)

94. After demanding that the Indiana Supreme Court and the 

IU Maurer School of Law and the U.S. Supreme Court and the 

ABA become more accessible, the 2014-2015 president of the 

National Association of Law Students with Disabilities, Angeli 

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Rios, contacted me. She did not say I was unfit to practice law. 

She said, “Wow, I have to admire your drive & passion for 

advancing the rights of people with disabilities...as far as I can tell 

it is pretty unmatched!!” December 15, 2015 (Facebook Message)

95. I contacted the National Center for State Courts and told 

them that I wanted to do a study or even a book on how mental 

illness in lawyers is treated by state courts. Instead of saying I 

am unfit to practice law, Nicole Waters, Senior Court Research 

Association of the NCSC said, “We agree that this effort would 

benefit the state courts, enabling them to make more informed 

policy decisions with regard to mental illness and commend you on 

raising this important agenda.” (Exhibit II)

96. And in fact, I intend to do doctoral level work on this subject 

now, and that is what gave me standing in my ABA case.

97. There is even more evidence that I am more a national 

expert on disability matters, rather than unfit to practice law. I 

applied to be the General Counsel of the U.S. Access Board, which 

sets the standards for physical disability access for the entire 

USA. The Access Board found me to be “qualified” for the position

in 2014. (Exhibit JJ)

98. The U.S. Army Medical Command evaluated me to be an 

Attorney Advisor (civilian equivalent of a Lt. Colonel), and found 

me to be “qualified” and referred me to the selection official in 

2014. (Exhibit KK)

99. Presumably due to my technology background and legal 

background, the U.S. Army Network Enterprise Technology

Command found me “qualified” and referred me to the selection

official for another Attorney Advisor position (civilian equivalent 

of Lt. Colonel). (Exhibit LL)

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100. National Council on Disability: “This is a fascinating inquiry. 

I confess I have never paused to consider the relation between 

receipt of SSDI and one’s FICO score...Thanks for bringing the 

question to us. I’m hopeful we can find at least a few helpful bread 

crumbs on the hunt for the answers.” Anne Sommers, National 

Council on Disability Legislative Director, January 7, 2015. 

Exhibit.

101. Social Security Administration: “Thank you for posing what I 

considered to be important research and policy questions.” Bob 

Williams, Social Security Administration Senior Advisor, January 

7, 2015. Exhibit.

102. I was a finalist for the position of Executive Director in 2013, 

Indiana Protection & Advocacy Service (IPAS), the independent 

state agency which protects the rights of Hoosiers with 

disabilities. (Exhibit AAA)

103. I appear to be “qualified” to do many things, but I have not, 

in the past 5 years, gotten an interview for anything of this kind. 

I believe it is because the Indiana Supreme Court is telling

employers that I am NOT FIT TO PRACTICE LAW. It is logical 

that if the Employment Law Director is making discriminatory 

complaints against me on the basis of my bipolar disorder, she is 

saying the same things to people checking my references.

104. Lilia Judson’s 2002 “at least you have a law license” was a 

cruel joke. The Court first grudgingly gave me a license after a 

star chamber torture session, and even then with conditions, a 

consent agreement. In 2014, the Court was done with me having 

a law license. 

105. Its Employment Law Director filed a disciplinary complaint. 

Not because I violated any rule, but precisely on the grounds that 

I have bipolar disorder. (Exhibit EE)

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106. I give credit where credit is due. In my letter, printed in the 

Indiana State Bar Association’s Res Gestae, November 2014 issue, 

I thanked the Indiana CLE Commission for accommodating my 

migraines by letting me do all of my CLE online.

THOMAS M. DIXON FACTS AND EXPLANATIONS

1. The case against Defendant Dixon relies on the following facts. 

He brought a malpractice case, Sconiers v. Straw, 71D07-1310-CT00265 (St. Joseph Ct. Sup. Ct.), against me knowing that his client 

had never asked me to file any suit for her, and that his client (my 

ex-client) had actually signed my representation agreement 

agreeing explicitly that I would not do any trial work for her. 

Exhibit.

2. Dixon presented no evidence, written or verbal, that Sconiers had 

asked for this service, which I could not have done in any event 

because I had not at that point set up an e-filing account with the 

Court, which I now have and am using. (Exhibit MM). The fact 

that I was top of my class in Negotiations and that Trial Process 

was the only class in law school from which I withdrew are also 

indicative of what the situation was. (Exhibit F) There is, in 

other words, no reason to believe any malpractice occurred.

3. The trial court, located in South Bend, refused my attorney’s Trial 

Rule 56 motion, and at this point I realized that I do not trust any 

Indiana court. Neither trial nor appellate. I directed my attorney 

to negotiate with Dixon for a settlement. My unopposed 

assertions that Dixon’s client never asked me to file anything,

never asked me to do anything beyond the negotiations that were 

clearly laid out in the representation agreement were ignored. 

(Exhibit NN)

4. I explained to Defendant Dixon via email on June 5, 2013 that I 

have mental and physical disabilities that I was accommodating 

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in 2012 such that I did not wish to file any court case or prosecute 

one at that time. (Exhibit OO). 

5. When I opposed the Democratic Headquarters in South Bend 

being inaccessible for people with physical impairments, and 

opposed the Indiana Democratic Party’s Rule 10, which 

discriminates against people with mental impairments, I received 

threats. Butch Morgan, the district chair and state committee 

member, shook my brother’s hand in 2011 and told me 

simultaneously that there would be a lawsuit against me. A news 

reporter was present when he made this threat, Jason Aubry of 

ABC 57 in South Bend.

6. My brother, US Air Force Capt. Jason Lee Straw (ret), was a 

critical care trauma team nurse in Afghanistan and saved the 

lives of soldiers blown up on the battlefield. His patients were all 

missing limbs, some four limbs. (Exhibit RR) Capt. Straw and his 

team saved the lives of about 40 people with the most severe 

injuries. His uniform reflects it. (Exhibit SS)

7. My opposition to the disability rights violations was not casual. I 

reported to the Department of Justice and to the Indiana Civil 

Rights Commission. (Exhibit TT) My case is before the Indiana 

Supreme Court now: Straw v. Indiana Democratic Party, 93A02-

1406-EX-00399. 

https://courtapps.in.gov/Docket/Search/Detail?casenumber=93A02

1406EX00399

8. Sconiers appeared at the same time I was making my Indiana 

Civil Rights Commission complaint. Fall of 2012, immediately 

after my campaign for Congress in South Bend ended.

9. Because the lawsuit threat was there from one of the top 

Democratic leaders for 20 years, and Sconiers’ case had no merit, 

and the court is in South Bend, I decided to direct my lawyer to 

settle.

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10. I do not trust the legal system in Indiana, even though I am 

licensed there. If Butch Morgan can get the Vice Chair of the 

Indiana Election Commission to represent him in his losing felony 

trial for forging presidential ballot petitions, including forging 

former Governor Kernan’s name, it is reasonable to believe that 

foul play is at work in Sconiers’ case. (Exhibit VV)

11. Morgan wished to retaliate against me, and it is not hard to 

see why. I ran against him for his district chair spot following the 

U.S. Census. I did so to demand disability access at the 

headquarters. (Exhibit WW) My continued opposition was 

covered on ABC 57 in South Bend. (Exhibit XX) The original 

video is available here: 

https://www.youtube.com/watch?v=2DebpmIA0oc

12. Dixon’s judgment on legal matters can be demonstrated in 

the Indiana Court of Appeals case of Dixon v. Lucero, 71A04-0810-

CV-592. In this case, Dixon fought his ex-wife regarding child 

support for their three children to the Indiana Court of Appeals. 

The Court rejected Dixon’s arguments over and over again: 

“Again, we reject Dixon’s premise.”

13. In that case, regarding Dixon’s request for sanctions, the 

Court of Appeals cited the trial court in his case:

Well, all I can say is: There’s been enough ill will and strife in 

this case, and that’s why [you] ended up in the high-conflict 

classes. I asked the parties to go to Dr. Rupley. The parties had 

previously been to mediation with Charlie Asher, I believe. I 

asked the parties to go to Dr. Rupley, and I got a report back 

from Dr. Rupley. I asked for comments on the report.

And I think you agreed to the recommendation -- or Petitioner

agreed to the recommendation of Dr. Rupley.

And from Mr. Dixon, what I got from you was about a five-page 

tirade of all the things that are wrong with Mr. Hains, wrong 

with your wife, wrong with Dr. Rupley. And since it was 

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addressed to me, I assume it didn’t include me; but the next 

one may. (p. 14)

http://www.ai.org/judiciary/opinions/pdf/03090905msm.pdf

14. Dixon’s sanctions were denied.

15. Dixon also claimed to be discriminated against in child 

support because he is a man. (p. 9) This claim was also rejected by 

the Court of Appeals.

16. Dixon makes poor legal judgments as witnessed in his own 

case at the Court of Appeals, and he has demanded sanctions 

without any factual basis in that case. It is in this context that 

Dixon filed a malpractice case in state court without factual 

foundation and asked for sanctions before this Court. 

17. It is with that background that Dixon was unable to 

understand that entering the Supreme Court’s employment law 

director’s emails into the record was a violation of Indiana Rules 

of Professional Conduct, Rule 8.4(e).

18. Dixon seems not to understand when he is hurting others.

19. Rule 8.4(e): “It is professional misconduct for a lawyer to... 

state or imply an ability to influence improperly a government 

agency or official or to achieve results by means that violate the 

Rules of Professional Conduct or other law;”

20. Dixon entered Rodeheffer’s emails to him, announcing her 

disciplinary complaint and her cooperation with him, into the 

Sconiers case. The only purpose for this is attempting to influence 

the state trial court with Indiana Supreme Court interference.

21. That is not how the system should work. Trial courts try 

issues, and then they are appealed to the appellate courts on 

matters of law. 

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22. The Supreme Court must not stick its finger on the scale at 

the trial court level in this manner. Dixon should not have invited 

it to do so. 

23. My father after leaving the Marine Corps opened his own 

butcher shop. I know how important having a true scale is.

24. A rational person can see the fact that Dixon has no evidence 

for malpractice and is relying on the influence of Indiana Supreme 

Court staff to win his frivolous case for him.

25. Dixon has also been receiving lucrative legal work from the 

City of South Bend since filing this malpractice case against me. 

(Exhibit QQ)

26. Mayor Buttigieg’s administration approved that work for 

Dixon.

27. It is Mayor Buttigieg’s ADA-violating ramp at the 

Democratic HQ that is now under fire in Straw v. Indiana 

Democratic Party. 

28. I made an APRA request to get records about the ramp issue 

from Buttigieg’s administration in 2012, prior to meeting Sconiers. 

It is now 2015 and I have not yet received the records from the 

City.

29. The connections are not hard to see. I complained as a 

lawyer and congressional candidate about ADA and Indiana Civil 

Rights Law violations in 2011 and 2012. The Democratic boss 

threatened a lawsuit. Sconiers arrives in 2012, asking only for 

negotiations work, which I did. Then, in 2013, she sued me for 

malpractice because I did not do trial work for her. Dixon refuses 

to acknowledge my disability and filed suit in October of 2013. 

Dixon begins to get legal work from the City of South Bend. Dixon 

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gets assistance from the office that discriminated against me on 

the basis of disability at the Indiana Supreme Court.

30. The just outcome would be that the Supreme Court staff are 

disciplined for getting involved and once again injuring my legal 

career, and Dixon held to account in his evidence-less malpractice 

case.

31. With no demand for services, no demand that I even help her 

find someone to file suit, Sconiers has had no case.

32. And it is even more apparent what the true motivation was 

when disgraced Democratic leader Butch Morgan threatened a 

lawsuit against me for political reasons while shaking my 

brother’s hand in October of 2011. Morgan did so in front of an 

ABC 57 reporter, Jason Aubry.

33. When Dixon is favored with lucrative legal work by the city 

of South Bend (Democratic Council and Mayor), it shows his 

politically-motivated and disability rights-violating malpractice 

case is bearing fruit for him.

34. If I had filed a federal lawsuit for Sconiers under these

circumstances, it would have been unethical first and foremost, 

since I had no instruction to do so from my client. Not having any 

instruction, I am prevented in Indiana from filing a federal 

lawsuit under Indiana Rules of Professional Conduct, Rule 1.2(a) 

(“a lawyer shall abide by a client’s decisions”), since I had limited 

my representation as allowed by Rule 1.2(c) (“A lawyer may limit 

the scope and objectives of the representation if the limitation is 

reasonable under the circumstances and the client gives informed 

consent.”). 

35. Dixon has prosecuted a frivolous malpractice case against 

me at the state level which has stretched from 2013 to 2015. 

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36. Further, Dixon refused to respect my reasons for not wanting 

to file any case for Sconiers in 2012, namely, my mental and 

physical disabilities. This violates my disability civil rights.

37. Dixon dumped poison on me every bit as much as the U.S. 

Navy did when I was born at Camp LeJeune. He has accused me 

of malpractice and it has appeared since October 2013 on 

http://mycase.in.gov, the case search website of the Indiana 

Supreme Court. 

38. Dixon has a very healthy criminal law practice. (Exhibit YY) 

Although there is nothing wrong with this, he seems to 

misunderstand the difference between a shadow of a doubt to 

relief someone of punishment, and punishing a lawyer with a 

malpractice case with a shadow of evidence. And that evidence is 

interference from the Indiana Supreme Court.

39. Malpractice complaints drive clients away, and that is why 

when I ask for damages as I do, they are justified by the damage 

Dixon did. Combined with false and defamatory disciplinary 

charges refuted by my doctor even before the charge was made, 

and it is obvious that there is a conspiracy to end my legal career 

right here, right now.

40. All involved must be accountable.

41. Knowing that I have these disabilities before he filed his 

case, including physical disabilities from a car wreck, Dixon 

should have refrained from filing a malpractice case. His lack of 

factual evidence was enough to not file, and this was more reason.

42. In the absence of factual evidence and any reasonable legal 

theory, the malpractice case appears on its face to be harassment 

for my disabilities.

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COUNT I: INDIANA SUPREME COURT AND ITS EMPLOYEES FOR 

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

43. The actions of the Indiana Supreme Court by its 

Employment Law Director, Brenda Rodeheffer, and other 

employees have caused me extreme emotional damage, damage to 

my career, damage to my ability to earn money as an attorney. 

Filing a disciplinary complaint based on my disability alone was 

meant to injure. It did. Sharing that complaint’s existence with a 

lawyer who was suing me for malpractice was also meant to 

injure. It did. This is intentional infliction of emotional distress, 

which is actionable as a tort under Indiana law. Williams v. 

Tharp, 889 N.E.2d 870 (Ind. Ct. App. 2008). The tort is from

Rodeheffer individually and in her official role, and the Court that 

authorized her actions must be responsible for them. My demand 

is for $90,000 from Rodeheffer individually and $150,000 from the 

Indiana Supreme Court for intentional infliction of emotional 

distress.

44. I respectfully seek this relief from this honorable court and 

additional relief as the Court deems fit.

COUNT II: INDIANA SUPREME COURT AND ITS EMPLOYEES FOR 

CONSTITUTIONAL TORTS

45. The repeated refusal to accept my demands for justice are 

due process violations, and justify my claim for damages under 42 

U.S.C. § 1983. I also have a right to petition the government for 

redress of grievances under the First Amendment of the U.S. 

Constitution, and this must apply to state supreme courts which 

violate the rights of disabled citizens, myself in this case. That 

right flows through the 14th Amendment as a command to the 

states. It is incorporated.

46. I also claim that my constitutional rights as a person with

disabilities were violated. I claim injury from discrimination 

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under the Equal Protection Clause. What the Indiana Supreme 

Court and its employees did is the epitome of discrimination and 

intentional harm.

47. My Social Security income statement shows that since my 

firing at the Indiana Supreme Court, my income evaporated.

(Exhibit CCC) Injury was severe.

48. I seek $100,000 from due process damages by the Indiana 

Supreme Court and its employees’ actions. I seek $100,000 from 

the Equal Protection Clause violations by the Indiana Supreme 

Court and its employees’ actions.

49. I seek $100,000 for the violation of the right to petition the 

government for redress of grievances under the First Amendment.

50. I respectfully seek this relief from this Honorable Court and 

any other just relief deemed appropriate by the Court.

COUNT III: ATTORNEY THOMAS M. DIXON FOR INTENTIONAL 

INFLICTION OF EMOTIONAL DISTRESS

51. Attorney Dixon took the emails of Brenda Rodeheffer and 

injected them into the record of a malpractice case. Not to shed 

any light on the merits of the malpractice case, because 

Rodeheffer’s disciplinary complaint was irrelevant to that. 

52. He did so in order to show that the Indiana Supreme Court 

was behind him. This was a defamatory purpose, meant to injure 

me and win his case in an unethical fashion. Indiana Rules of 

Professional Conduct, Rule 8.4(e), prohibits attempting to use 

improper influence.

53. I made a complaint to the Indiana Attorney Disciplinary 

Commission about Dixon, but the Court agency was consistent 

with its previous actions and biased against me. My request was 

denied.

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54. Dixon entered Rodeheffer’s email announcing the 

disciplinary complaint to harm me. He did it on purpose.

55. Dixon and Rodeheffer colluded together so that I would be 

hit with both a malpractice suit and a disciplinary complaint at 

the same time.

56. Intentional infliction of emotional distress is a tort available 

in Indiana. Williams v. Tharp, 889 N.E.2d 870 (Ind. Ct. App. 

2008). Dixon committed this tort.

57. Dixon’s frivolous malpractice suit and exhibits from the 

Indiana Supreme Court stating disciplinary complaints were 

being filed were intentional infliction of emotional distress, 

designed to get me to agree to ask my insurance company to settle 

with him. 

58. He communicated with the employment lawyer of my exemployer, which happens also to have power over my law license. 

59. Now, it is absolutely incontrovertible that Dixon and 

Rodeheffer worked together to injure me, and it has caused a 

great amount of pain and injury to me emotionally. I am facing 

the destruction of my legal career from two directions, both intent 

on revenge for my disability rights work—for my having a 

disability.

60. Dixon is not only are trying to get $120,000 from me without 

merit, but Dixon is cooperating with the Indiana Supreme Court 

to take away my only active state law license. That will make it 

impossible to continue my legal career as a disability rights 

lawyer.

61. I have bipolar disorder and this is a condition that affects 

the emotions, making them more sensitive. 

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62. I will prove that Dixon caused me extreme emotional 

distress just as if a person punched the skull of a person with 

glass bones syndrome. Even if I am in remission and am “quite 

productive,” as my doctor says, I still feel emotional attacks such 

as Dixon’s at a higher level and with more pain than a normal 

person would.

Indiana recognizes the tort of intentional infliction of 

emotional distress as extreme and outrageous conduct 

intentionally or recklessly causing severe emotional distress 

to another. Cullison v. Medley, 570 N.E.2d 27, 31 (Ind.1991). 

The basis of the tort is the intent to cause intentional 

emotional harm. Id. Conduct is considered "extreme and 

outrageous" when:

the conduct has been so outrageous in character, and so 

extreme in degree, as to go on beyond all possible bounds of 

decency, and to be regarded as atrocious, and utterly 

intolerable in a civilized community. Generally, the case is 

one in which the recitation of the facts to an average 

member of the community would arouse his resentment 

against the actor, and lead him to exclaim, Outrageous!

Powdertech, Inc. v. Joganic, 776 N.E.2d 1251, 1264 

(Ind.Ct.App .2002)(cited in Roell v. American Senior 

Communities, 20A03-1111-CT-524 (Ind. Ct. App. 2012)).

63. In the civilized community of lawyers, to attack a disabled 

man’s profession as a lawyer by filing a malicious and fact-less 

malpractice case and by entering notice of a disciplinary complaint

based only on his disability into evidence in that case is 

“outrageous in character.” 

64. Dixon knew I had disabilities because I told him. He knew 

Sconiers never asked me to help her find anyone to help with her 

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case. Dixon knew that Sconiers never asked me to file any lawsuit 

for her. He knew that his malpractice case was devoid of merit.

65. On top of this, knowing that I have disabilities, he filed 

Rodeheffer’s email announcing that she was filing a disciplinary 

complaint against me. That complaint was on the basis of my 

mental disability status.

66. Dixon was punching me in the way only an attorney can do. 

Frivolous filings and false attacks on my law license hurt me 

terribly; it was dirty pool, motivated by the Indiana Democratic 

Party and the Indiana Supreme Court, two organizations against 

which I have had grievances for years. Intentional infliction of 

emotional distress is a tort available to address such attacks.

67. Dixon must compensate me for the intentional, deliberate, 

and intense pain he has caused me. I seek $300,000 for 

intentional infliction of emotional distress.

68. I respectfully seek this relief from this Honorable Court. I 

also ask for other relief as the Court deems just under the 

circumstances.

EEOC CHARGE

69. As previously mentioned, I have filed a complaint with the 

EEOC for the Indiana Supreme Court’s actions as an ex-employer. 

These charges are based on violations of the Civil Rights Act of 

1964, Title VII, and the Americans with Disabilities Act. The 

EEOC charge number is 470-2015-00699. When the EEOC is 

done investigating, I may ask the court to merge that case with 

this one, with the Court’s permission.

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REQUEST FOR RELIEF: SUMMARY

70. Due to the facts recited above and the laws cited in support 

of relief in each of the above 3 counts, I respectfully request the 

following relief from this Honorable Court:

71. Count I: Indiana Supreme Court Intentional Infliction of 

Emotional Distress, $150,000. Rodeheffer Intentional Infliction of 

Emotional Distress, $90,000.

72. Count II: Indiana Supreme Court Constitutional Torts 42 

U.S.C. § 1983: $300,000

73. Count III: Dixon, Intentional Infliction of Emotional 

Distress: $300,000

74. For the reasons given, factual and legal, I respectfully 

request that this Honorable Court provide the relief described 

above.

VENUE

75. The venue of this case is currently the Northern District of 

Indiana, South Bend Division. Venue lies in this District and this 

Division pursuant to 28 U.S.C. § 1391 because events giving rise 

to this action occurred in St. Joseph County, Indiana.

JURY DEMAND

76. I demand the right of trial by jury for this civil case under 

the 7th Amendment of the U.S. Constitution.

JURISDICTION

77. Jurisdiction over the claims between myself and Thomas M. 

Dixon and are based on diversity jurisdiction, 28 U.S.C. 

§1332(a)(1), as the amount in controversy is greater than $75,000. 

I live in Cook County, Illinois, and Dixon’s office is within the 

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Northern District of Indiana, in Osceola, Indiana. Jurisdiction 

over the claim against Rodeheffer is in her personal capacity is

also based on diversity jurisdiction, 28 U.S.C. §1332(a)(1) or 

federal law. These defendants live in Indiana, either the Northern 

or Southern District. The claims based on violations of the 42 

U.S.C. § 1983, or 42 U.S.C. § 1985(3) are federal law-based claims 

and do not require diversity. Bell v. Hood, 327 U.S. 678, 684 

(1946) also provides that constitutional violations give rise to 

federal jurisdiction.

I, Plaintiff Andrew U. D. Straw, verify that to the best of my 

knowledge, information, and belief, formed after an inquiry 

reasonable under the circumstances, that the above statements and 

factual representations are true.

Respectfully submitted,

ANDREW U. D. STRAW

1900 E. Golf Rd., Suite 950A

Schaumburg, IL 60173

Telephone: (312) 985-7333

Fax: (877) 310-9097

andrew@andrewstraw.com

January 30, 2015

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CERTIFICATE OF SERVICE 

I, Andrew U. D. Straw, certify that I filed the above AMENDED 

COMPLAINT with the Court via its electronic CM/ECF system on 

January 30, 2015, and that the electronic CM/ECF system will serve 

the AMENDED COMPLAINT on all counsel of record and pro se

parties.

When initiated, the St. Joseph County Superior Court was a defendant 

for purposes of the injunctive relief, and is represented by the Indiana 

Attorney General. Several Attorney General attorneys are receiving 

notice in the CM/ECF system.

The new party added to this case is Brenda Rodeheffer. The Indiana 

Supreme Court is also added as a defendant, as State of Indiana. All of 

these parties are employees of the State of Indiana or are the State of 

Indiana, and therefore currently represented in the case by the Indiana 

Attorney General.

Respectfully submitted,

ANDREW U. D. STRAW

1900 E. Golf Rd., Suite 950A

Schaumburg, IL 60173

Telephone: (312) 985-7333

Fax: (877) 310-9097

andrew@andrewstraw.com

January 30, 2015

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