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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 Not Demanded

Thomas Dixon, Sconiers’ )

Attorney, and )

St. Joseph County )

Superior Court, )

Defendants )

COMPLAINT 

1. I, plaintiff Andrew U. D. Straw, for my complaint for redress of 

damages from Americans with Disabilities Act violations by 

defendants Brenda Sconiers and Thomas Dixon, her attorney, and 

to preclude any violations by the St. Joseph County Superior 

Court, complain as follows:

STATEMENT 

2. Plaintiff, Indiana Attorney Andrew U. D. Straw, alleges that 

defendants Sconiers and Dixon did discriminate, harass, and 

retaliate against him on the basis of his disability by bringing a 

malpractice action in St. Joseph County Superior Court against 

him.

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3. Plaintiff Straw alleges that defendants did harm him emotionally

and professionally with such activity and seeks relief as this 

honorable Court deems fit.

4. Defendant Sconiers alleged that she was sexually harassed in her 

work at the St. Joseph County Public Library, and she filed her 

own Equal Employment Opportunity Commission complaint, 

alleging injury and damages on or about July of 2012. (See, 

Plaintiff’s Exhibit 1)

5. Sconiers received a letter of right to sue with a time limit for filing 

in a federal court in early September of 2012. (See, Plaintiff’s 

Exhibit 1)

6. Sconiers met with Straw in a church in South Bend on or about 

September 18, 2012, and they discussed how he might negotiate a 

settlement for her with the Library for damages, increased salary, 

and an apology, inter alia.

7. Sconiers and Straw agreed upon terms, and Attorney Straw 

agreed to negotiate with the Library and present her demand. He 

specifically excluded any court or trial work in the representation 

agreement, and it was understood that he has had disabilities 

which prompted him to limit his practice choices to negotiation at 

that time.

8. Straw is disabled and has a handicap parking placard. He has 

bipolar disorder and this was public knowledge and published in 

the South Bend Tribune on May 22, 2011.

9. Straw alleges that he has the right to limit the services he offers 

clients based on the disabilities he has, and providing only

negotiation services and not trial work was part of his own 

accommodations for himself at that time.

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10. Straw alleges that under the ADA, Titles II and IV, he has 

the right to accommodate his own disabilities and does not need to 

explain or justify himself to clients in doing so.

11. Straw alleges that so long as he provides the services agreed 

upon, he is not obliged to increase or change services to meet the

convenience of a client, especially when the terms were set in a 

representation agreement and both parties agreed.

12. Straw presented Sconiers’ demand to the Library, which 

rejected it outright and absolutely on or about October, 2012.

13. Straw went with Sconiers to the South Bend Police 

Department for her to file a complaint.

14. Sconiers never received compensation from the Library or an 

apology.

15. Sconiers never paid Straw any compensation for the work he 

did on her case. Straw and Sconiers agreed that compensation 

was to be on contingency, and Sconiers received no payment from 

the Library. Straw’s receiving no payment is in accordance with 

the representation agreement.

16. Sconiers, after being informed that there was to be no 

negotiated agreement, did nothing to prepare for or file her federal 

case. She did not ask Straw what she should do, how to prepare, 

or even how to draft a complaint. She did not file her case, despite

the fact that her letter of right to sue which she received from the 

EEOC stated the deadline to sue in bold print and underlined. 

(Plaintiff’s Exhibit 1)

17. Straw went to Istanbul, Turkey in late September through 

the end of October, 2012. He went there for personal and 

professional reasons, and studied the disability access conditions 

of the city on the Anatolian side.

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18. Defendant Dixon has claimed that Straw’s trip to Istanbul 

was the cause of his not filing Sconiers’ federal case for her. This 

despite the fact that the entire negotiation and communications 

with Sconiers and the Library happened while Straw was in 

Istanbul and this fact had no impact whatsoever on Straw’s ability 

to work and communicate. The Library never stated that its 

reason for refusal was Straw being located in Turkey while the 

negotiation took place.

19. Sconiers and Dixon have alleged that Straw took on the 

responsibility of filing Sconiers’ case in federal court, despite the 

fact that Straw explicitly said in the representation agreement 

that he was not going to do these services, but would seek for 

someone to help her.

20. Straw mentioned her case to other attorneys, but none were 

interested in helping with her case. Straw at no point said that if 

he was unable to find another attorney that he would do trial 

work for Sconiers.

21. Sconiers was apparently able to find a malpractice trial 

attorney, Mr. Dixon, who filed the malpractice suit. Sconiers v. 

Straw, 71D07-1310-CT-00265. Straw alleges that Sconiers was 

entirely capable of finding her own trial attorney, such as 

defendant Dixon, after Straw timely informed her that the 

negotiation Straw conducted was over.

22. Straw is a disability rights attorney who has been very 

active in Indiana and the 2nd congressional district, where he ran 

for Congress and where Ms. Sconiers lives. Straw opposed 

discrimination by the 2nd district chair of the Indiana Democratic 

Party, who served on its State Committee and as an Indiana 

Election Commission member. Straw has a case against the 

Indiana Democratic Party for violations of the Indiana Civil 

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Rights Law at the Indiana Court of Appeals, Straw v. Indiana 

Democratic Party, 93A02-1406-EX-00399. 

23. Straw ran for circuit court judge in Elkhart County in 2010, 

but Straw alleges that the Democrats in Elkhart County refused 

to slate him due to his mental disability, such that the Democratic 

Party had no candidate for that office that year. Straw ran for 

superior court judge in St. Joseph County in January of 2013, and 

was interviewed by the committee chaired by an Indiana Supreme 

Court justice. Straw worked on disability issues as a staff 

member at the Indiana Supreme Court, and was deemed 

“qualified” to be the General Counsel for the U.S. Access Board in 

June of 2014. The U.S. Access Board sets the standards for 

disability access in the USA for the built environment.

24. Straw was deemed “highly qualified” to be the Director of 

Human Resources Management for the U.S. Department of 

Transportation in July of 2014. This is a Senior Executive Service 

position. Straw was also deemed “highly qualified” to be AttorneyAdvisor for the U.S. Army Medical Command in May of 2014. 

This position is to advise disabled U.S. Army veterans on their 

rights and benefits.

25. Straw was the January 2014 ABA Commission on Disability 

Rights “Spotlight Attorney” with disabilities. In 2012, Straw was 

a member of the Green National Committee as the only Indiana 

Delegate to the Green National Convention, and he established 

the Green Party of the United States Disability Advisory 

Committee at the national level, with over 100 members. Straw 

founded the Disability Party of the United States, and this Party

has over 1,200 followers in 38 countries as of July 2014.

26. Straw has had disability-based complaints before state and 

federal agencies and courts. These include the U.S. Treasury, the 

U.S. Department of Justice, the Indiana Civil Rights Commission, 

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the Indiana Attorney General, the Illinois Attorney General, and 

the U.S. Navy (Camp LeJeune toxic water complaint). 

27. Straw has a human rights and defamation state civil suit 

against a major newspaper and the Streamwood Chamber of 

Commerce in Illinois. Straw v. Chamber, et. al., 2013L063066 

(Cook Cty. Cir. Ct. 2013) He has a federal suit against a large 

Chicago law firm currently before the U.S. Court of Appeals for 

the 7th Circuit for invasions of his health information and privacy, 

as a civil RICO matter. Straw v. Kloecker, 14-1714 (7th Cir. 2014)

28. Finally, Straw has a federal case against all of the top 50 law 

schools in the United States for discrimination in law school 

admissions that affects Straw’s Ph.D. choices to write his 

dissertation on discrimination in the American legal system 

against disabled lawyers and judges. 

29. Straw has written to the U.S. Supreme Court seeking 

establishment of a disability office or officer to expand access in 

the federal courts. He asked for a similar office in the Indiana 

Supreme Court. Straw is advising a judge candidate who has 

disabilities in Indiana in 2014. 

30. Straw alleges that the reason he took Brenda Sconiers’ case 

was due to his experience fighting sexual harassment and 

discrimination in South Bend against the Housing Authority 

there, and in his work at the Indiana Supreme Court. Straw 

proposed a national database of protective orders at the FBI to 

protect domestic violence victims across state lines. Harvard’s 

Kennedy School of Government and the Council for Excellence in 

Government chose this idea as one of the top e-government ideas 

in the United States in 2001. This contest was announced in the 

first U.S. presidential webcast in 2000. Several years later, the 

Indiana Supreme Court created a pilot project, and in 2009, the

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Indiana legislature mandated this protective order registry in 

every Indiana county.

31. Straw thought Sconiers had a credible case with some 

evidence, but her insistence now, after the fact, that Straw was 

mandated to file court cases for her is totally unsupported by 

evidence, and contrary to Straw’s rights as a lawyer with a 

disability to run his practice in a way that accommodates his 

disability.

32. Straw has not appeared for any client in a court case from 

the time his Indiana law license was reactivated in 2010, when he 

returned to the USA from New Zealand. Straw has appeared in 

the above court cases on his own account, but these are disability 

matters unique to him.

33. The state superior court should dismiss Sconiers’ case as 

contrary to law. Straw asks this honorable Court to order the 

state court to dismiss Sconiers’ case as contrary to the Americans 

with Disabilities Act. Straw asks for costs, attorney fees incurred 

as a result of the discriminatory malpractice action, and other 

relief as this honorable Court deems fit.

JURISDICTION 

34. The Court has jurisdiction over this action pursuant to the 

Americans with Disabilities Act, 42 U.S.C. §12101 et. seq. The 

alleged disability discrimination and retaliation are federal law 

subject matter.

VENUE 

35. Venue lies in this District and this Division pursuant to 28 

U.S.C. § 1391 because the events giving rise to this action 

occurred in St. Joseph County, Indiana.

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REQUEST FOR RELIEF 

36. Plaintiff respectfully requests this honorable Court for 

injunctive relief. In particular, St. Joseph County superior court 

should be mandated to dismiss the Sconiers v. Straw case with 

prejudice. The state case below is based entirely on the fact that 

Straw refused to do trial or court work for clients, and he molded 

his practice in this manner consistently based on health reasons 

that were well known in the community. Straw never promised 

anything that Sconiers uses as reasons for her malpractice case, so 

the case is purely discriminatory in nature and should be 

dismissed with prejudice.

37. Straw has not represented any client in state or federal court 

up to this time, or made an appearance for a client in court. The 

Sconiers v. Straw case is in retaliation against Straw’s right, 

which he exercised, not to do work that aggravated his disabilities 

at that time. The ADA, Title II, states, “...no qualified person 

with a disability shall, by reason of such disability...be subjected 

to discrimination by such entity.” 42 U.S.C. §12132. The state 

court is governed by ADA, Title II, and must not discriminate, and 

Sconiers and her attorney are inappropriately using the state 

court in their discrimination and retaliation scheme. Straw has a 

right against retaliation and coercion. 42 U.S.C. §12203(a, b). 

Straw has the right to remedies. 42 U.S.C. §12133, 42 U.S.C. 

§12203(c).

38. Straw has incurred expenses in defending against Sconiers’ 

discriminatory malpractice case. This federal case costs $400 to 

file. He has incurred attorney expenses not covered by insurance

in the malpractice case. Straw respectfully requests this 

honorable Court to order Defendants Sconiers and Dixon to 

reimburse Straw costs and attorney fees, in particular because 

Sconiers’ malpractice case is in its entirety a violation of the 

Americans with Disabilities Act and that Act provides for attorney 

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fees and costs. 42 U.S.C. §12205. Straw has a right against 

retaliation and coercion. 42 U.S.C. §12203(a, b). Straw has the 

right to remedies. 42 U.S.C. §12133, 42 U.S.C. §12203(c).

39. Straw has incurred emotional distress from a public attack 

on his competence as a lawyer in the filing of the Sconiers v. Straw

lawsuit, which is an attempt to force Straw’s insurance to pay 

$120,000 based on a false claim that is founded on discriminatory 

and retaliatory premises. Straw respectfully seeks relief from

Defendant Brenda Sconiers and Defendant Attorney Thomas M. 

Dixon, jointly and severally, to compensate for these violations and 

damages as this honorable Court deems just under the Americans 

with Disabilities Act.

40. Plaintiff requests that trial of the above action should be 

held in South Bend, Indiana, and that the case be calendared 

accordingly. Plaintiff does not request trial by jury.

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I, Plaintiff Andrew U. D. Straw, certify 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

241A Brittany Drive

Streamwood, IL 60107

Telephone: (574) 971-0131

Fax: (877) 310-9097

andrew@andrewstraw.com

August 3, 2014

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CERTIFICATE OF SERVICE 

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

the Court via its electronic CM/ECF system on August 3, 2014, and sent 

the above COMPLAINT with notice form and request for waiver of 

summons to the following via certified U.S. Mail, postage prepaid, on 

August 3, 2014:

Brenda Sconiers &

Thomas M. Dixon, Attorney at Law

Indiana Bar # 18611-71

55255 Birchwood Court

Osceola, IN 46561

Tel: (574) 315-6455

St. Joseph County Superior Court

101 South Main Street

South Bend, IN 46601

Tel: (574) 235-9635

Fax: (574) 235-9838

Respectfully submitted,

ANDREW U. D. STRAW

241A Brittany Drive

Streamwood, IL 60107

Telephone: (574) 971-0131

Fax: (877) 310-9097

andrew@andrewstraw.com

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