UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF FLORIDA 

Pensacola Division 

LOUIS REYNOLDS, JASON 

KENNEDY, RONALD 

MCCRANEY JR., all on behalf of 

themselves and all others similarly 

situated; and JEFFERY MILLER; 

 Plaintiffs, 

v. 

WENDELL HALL, in his official 

capacity as Sheriff for Santa Rosa 

County, Florida, 

 Defendant. 

/

No. 3:10-cv-355 MCR/EMT 

Class Action 

FIRST AMENDED COMPLAINT

Plaintiffs LOUIS REYNOLDS, JASON KENNEDY, RONALD 

MCCRANEY JR., all on behalf of themselves and all others similarly situated, and 

JEFFERY MILLER sue Defendant WENDELL HALL (“Hall”) in his official 

capacity as Sheriff for Santa Rosa County, Florida, and allege as follows: 

INTRODUCTION

1. Plaintiffs challenge Sheriff Hall’s recently instituted policy and 

practice (“Postcard-Only Mail Policy”) that forbids inmates of the Santa Rosa 

County, Florida, Jail (“Jail”) from sending letters enclosed in envelopes to their 

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parents, children, spouses, friends, other loved ones, or other correspondents. 

Instead, Jail inmates must write all of their correspondences in a postcard format 

except for privileged/legal mail. This new policy impermissibly restricts inmates’ 

ability to exercise their rights to communicate with correspondents outside the jail 

and these correspondents’ right to receive these inmates’ communications and 

expressions, in violation of the First and Fourteenth Amendments to the United 

States Constitution. 

2. Plaintiffs ask this Court to enjoin the Postcard-Only Mail Policy and 

declare that it violates their constitutional rights. Plaintiff Miller seeks this and 

nominal damages of $1. 

JURISDICTION AND VENUE

3. Plaintiffs bring this action pursuant 42 U.S.C. §1983 for violations of 

civil rights under the First and Fourteenth Amendments to the United States 

Constitution. 

4. This Court has subject-matter jurisdiction over this matter pursuant to 

28 U.S.C. §1331 (federal question) and 28 U.S.C. §1343(a)(3) (civil rights). 

5. Venue is proper in this judicial district and division pursuant to 28 

U.S.C. §1391(b) and N.D. Fla. Loc. R. 3.1. Defendant Hall resides in this district and 

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division and the unlawful practices that give rise to the claims herein occurred within 

this district and division. 

PARTIES

6. Plaintiff Louis Reynolds (“Reynolds”) is a Jail inmate. He has 

remained in the Jail as an inmate since May 21, 2010. As set forth in the “General 

Allegations” section, he has been, and continues to be, deprived of constitutional 

rights as a result of the Postcard-Only Mail Policy. 

7. Plaintiff Ronald McCraney Jr. (“McCraney”) is a Jail inmate. He 

has remained in the Jail as an inmate since June 28, 2010. As set forth in the 

“General Allegations” section, he has been, and continues to be, deprived of 

constitutional rights as a result of the Postcard-Only Mail Policy. 

8. Plaintiff Jason Kennedy (“Kennedy”) is a Jail inmate. He has 

remained in the Jail as an inmate since February 11, 2010. As set forth in the 

“General Allegations” section, he has been, and continues to be, deprived of 

constitutional rights as a result of the Postcard-Only Mail Policy. 

9. Louis Reynolds, Jason Kennedy, and Ronald McCraney Jr., and the 

class of similarly-situated inmates in the Jail shall be referred to collectively as 

“Jail Inmate Plaintiffs.” 

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10. Plaintiff Jeffery Miller (“Miller”) is a friend of Plaintiff Reynolds. 

Miller lives in Illinois and has not visited because of the long distance and cost. 

As set forth in the “General Allegations” section, he has been, and continues to be, 

deprived of constitutional rights as a result of the Postcard-Only Mail Policy. 

11. Miller shall be referred to as “Correspondent Plaintiff.” 

12. Defendant Sheriff Wendell Hall is now, and at all material times has 

been, the Sheriff of Santa Rosa County, Florida. As Santa Rosa County Sheriff, he 

is charged with the care and custody of inmates at the Santa Rosa County Jail. He 

exercises overall responsibility for the policies and practices of the Jail, including 

the Postcard-Only Mail Policy. Plaintiffs sue Hall in his official capacity for 

injunctive and declaratory relief and attorneys fees and costs. 

13. Defendant Hall at all times relevant hereto was acting and continues 

to act under color of law. 

14. Jail correction officers, deputies, their supervisors, working in the Jail 

are agents and employees of Sheriff Hall. 

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GENERAL ALLEGATIONS

15. The Santa Rosa County, Florida, Jail (“Jail”) is located in Milton, 

Florida. It houses both convicted prisoners and pretrial detainees. It has a rated 

capacity of 506 inmates (before the planned physical expansion of the Jail facility 

to include more beds). 

16. Effective July 26, 2010, Sheriff Hall instituted a policy that required 

all outgoing mail, except legal or privileged mail, sent by an Jail inmate to be in a 

postcard form (hereinafter “Postcard Only Mail Policy”). Only mail to or from the 

courts, attorneys, government officials or agencies, and news media is considered 

legal or privileged (hereinafter collectively “privileged”). 

17. Reynolds and Miller have been, and continue to be, deprived of 

constitutional rights as a result of the Postcard-Only Mail Policy: 

(a) Prior the implementation of the Postcard-Only Mail Policy, 

Reynolds wrote multi-page letters several times a week to both his son and Miller, 

among other persons. He often included drawings he had made. In some of these 

letters, Reynolds would discuss sensitive issues including his health, details and 

directions for his property and finances, religion, and advice to his son. 

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(b) However, now Reynolds may no longer send these letters and 

drawings. Now, his son, Miller, and other correspondents may no longer receive 

these letters and drawings. Though Reynolds would like to continue to discuss 

sensitive and personal topics with correspondents, he no longer includes this 

information in his mailed messages on postcards because they may be easily read 

by a host of people. Reynolds’s son lives with the son’s maternal grandmother, 

who may now read the messages Reynolds writes on postcards. Reynolds wants to 

be able to write his son messages without the grandmother reading them, but 

because of the Postcard-Only Mail Policy he cannot do that. Instead, Reynolds 

now sends no drawings and the messages in his mail are shorter. 

(c) Reynolds must now express all of his thoughts and messages in 

an abbreviated and incomplete form as there is insufficient room on the postcard to 

fully develop and communicate his thoughts and ideas. 

(d) Reynolds wants to immediately to send letters and include 

drawings, but does not because of the Sheriff’s Postcard-Only Policy. 

(e) Reynolds’s son lives in Ohio and other correspondents live in 

Illinois. Because his son and friends lack financial resources, they are unable to 

pay for telephone collect calls from Reynolds. Accordingly, mail correspondence 

is the only practical way for him to stay in contact with them. 

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(f) As a result of Sheriff Hall’s Postcard-Only Mail Policy, Miller 

no longer receives letters and drawings from Reynolds, who is in the Jail. Instead, 

he can receive only truncated messages on postcards. Absent Sheriff Hall’s 

Postcard-Only Mail Policy, Reynolds would send Miller letters and drawings that 

Miller would like to receive. 

18. Ronald McCraney Jr. has been, and continues to be, deprived of 

constitutional rights as a result of the Postcard-Only Mail Policy: 

(a) Prior the implementation of the Postcard-Only Mail Policy, 

McCraney regularly wrote multi-page letters to numerous family members, 

including his mother who received a letter from him nearly daily. Nearly weekly, 

he included a color drawing on a large sheet of paper (approx. 17 inches by 11 

inches) in these correspondences for his niece or family. In some of these letters to 

his mother, McCraney would relate private details of his health so his mother may 

assist him. Through other letters, McCraney would discuss plans for the future or 

use the process of letter writing as a way to work through ideas. 

(b) However, now McCraney may no longer send these private 

letters or drawings. Now, his family and friends may no longer receive these 

letters and drawings. Though he would like to continue to discuss sensitive topics 

with correspondents, he no longer includes this information in his mailed messages 

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on postcards because they may be easily read by a host of people. Instead, Ronald 

McCraney now sends fewer pieces of mail and no drawings and the messages in 

his mail are shorter. 

(c) McCraney must now express all of his thoughts and messages 

in an abbreviated and incomplete form as there is insufficient room on the postcard 

to fully develop and communicate his thoughts and ideas. 

(d) McCraney wants to immediately send letters and include 

drawings, but does not because of the Sheriff’s Postcard-Only Policy. 

(e) McCraney’s father is currently in Alaska and McCraney’s 

family has limited financial resources. Accordingly, mail correspondence is the 

only practical way for McCraney to stay in contact with his father. 

19. Jason Kennedy has been, and continues to be, deprived of 

constitutional rights as a result of the Postcard-Only Mail Policy: 

(a) Prior the implementation of the Postcard-Only Mail Policy, 

Kennedy regularly wrote numerous letters to family members, including his 

mother and his children. He sent drawings to his eight-year-old daughter who 

suffers from a mental disability. He would share personal information about his 

health with his mother. 

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(b) However, now Kennedy may no longer send these private 

letters or drawings. Now, his family and friends may no longer receive these 

letters and drawings. Though he would like to continue to discuss sensitive topics 

with correspondents, he no longer includes this information in messages because 

on postcards they may be easily read by a host of people. Instead, Kennedy now 

sends fewer pieces of mail and no drawings and the messages in his mail are 

shorter. 

(c) Kennedy must now express all of his thoughts and messages in 

an abbreviated and incomplete form as there is insufficient room on the postcard to 

fully develop and communicate his thoughts and ideas. 

(d) Kennedy wants to immediately to send letters and include 

drawings, but does not because of the Sheriff’s Postcard-Only Policy. 

(e) Because his family and friends cannot often visit him and the 

expense of telephone calls, mail correspondence is the best way for him to stay in 

contact with his family. 

(f) Having little or no money in the Jail’s inmate account, he is 

considered indigent and relies on his friends and family and Sheriff Hall for daily 

necessitates including a supply of writing and mail supplies. Therefore, often the 

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number of pieces of mail he may send is limited to the Jail’s supplied allotment of 

mail supplies. 

20. All Jail inmates are in the custody and under the control of Sheriff 

Hall. As Jail inmates, the Jail Inmate Plaintiffs remain subject to the policies, 

practices, and customs of Sheriff Hall. 

21. Before Sheriff Hall instituted the Postcard Only Mail Policy, Jail 

inmates freely sent mail in a letter form that consisted of one or more sheets of 

paper enclosed in an envelope to correspondents outside the jail. Inmates tendered 

for collection outgoing letters in unsealed, open envelopes to Jail officials (though 

at times deputies would permit inmates to seal the envelopes themselves). During 

the nightshift (7 pm – 7 am) Sheriff’s deputies would at times read or scan the nonprivileged outgoing mail emanating from the housing unit to which they were 

assigned that evening. After reading or scanning the outgoing letter mail, the 

deputy would seal closed the envelope. Indigent inmates would receive stationary, 

sufficient postage, and envelopes to send two letters per week. For each letter, 

indigent inmates would be supplied with two sheets of 8.5 inch by 11 inch paper 

on which they could write on both sides. 

22. Now, Sheriff Hall and those acting under his authority will not 

transmit to a correspondent outside the jail non-privileged outgoing mail that does 

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not conform to the Postcard Only Mail Policy. For example, under the Postcard 

Only Mail Policy Martin Luther King Jr. could not have sent the letter he sent from 

the Birmingham Jail on April 16, 1963, to his fellow clergymen. Likewise, the 

Apostle Paul under the challenged Postcard Only Mail Policy could not have 

written his fellow Christians his Epistles while imprisoned by the Romans. 

23. Under the Postcard Only Mail Policy, inmates may obtain postcards 

from Jail officials. Jail officials will give indigent inmates two per week. All 

postcards received from Jail officials are sized 4.5 inches by 6 inches. 

Alternatively, Jail inmates may receive metered postcards from friends and family. 

However, these metered postcards must have been purchased from the United 

States Postal Service (USPS), which since July 26, 2010, has only sold them in 

sizes that were no more than 4-1/4 inches high x 6 inches long. Postcard Only 

Mail Policy prohibits inmates from sending any non-legal mail unless it is on a 

postcard received from Jail officials or one purchased from the USPS. 

24. Sheriff Hall requires that the front of the postcard contain only the 

addressee’s name and address, the sending inmate’s name and return address, and 

postage. Only the back may contain a substantive message. However, the inmate 

must leave an area of 1 inch by 2 inches blank so that Jail officials may stamp the 

following message (actual size) in the bottom, right corner: 

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25. The Postcard-Only Mail Policy prohibits drawings or unnecessary 

marking on all non-privileged mail. 

26. The Postcard Only Mail Policy shifted the task of reading or scanning 

outgoing mail from the nightshift deputies to daytime administrative personnel. 

27. This policy is reflected in the written Outgoing Mail Procedure 

(Standard Operating Procedure No. 15.48), revised on August 14, 2010, attached 

as Exhibit 1. 

28. Although Sheriff Hall restricts incoming mail in other respects, he 

permits incoming mail to be in letter form and consist of one or more sheets of 

paper contained inside an envelope. 

29. Jail inmates have few alternatives to mail by which to communicate 

privately and freely with friends and family. Telephone calls from Jail inmates in 

the housing areas are limited to collect telephone calls, which are very expensive. 

Fellow inmates may easily overhear these telephone calls, which are made in a 

common area in a row of telephones. Family and friends may only visit a Jail 

inmate during a specific two-hour time period during the week, which prevents 

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many friends and family with a conflict during this time period from visiting at all. 

Friends and family who do not live near the Jail or in another state (like Miller) 

cannot easily visit Jail inmates. When family and friends can visit a Jail inmate, 

they speak over a telephone to each other in ways that may be overheard by other 

inmates or visitors. Therefore, for all these reasons, mail correspondence for many 

Jail inmates and their family and friends is the most feasible, practical, and private 

way to communicate and maintain a relationship. 

30. The Postcard-Only Mail Policy impermissibly curtails the ability of 

Jail inmates to express themselves and their correspondents to receive the 

expressions inmates desire to transmit. It allows indigent inmates less then oneeighteenth the amount of writing space permitted under the former policy and 

practice. Instead of sending one one-ounce letter for 44¢, Jail inmates must use 

over 18 postcards with postage at 28¢ each and costing a total of $5.04 to transmit 

the same amount of information. The Postcard-Only Mail Policy prevents Jail 

inmates from fully expressing their thoughts. Instead, Jail inmates must express 

these messages in an abbreviated and incomplete form as there is insufficient room 

on the postcard to fully develop and communicate the inmates’ thoughts and ideas. 

The Postcard-Only Mail Policy prevents family and friends of inmates from 

receiving these fully developed and complete messages from Jail inmates. 

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31. In addition, the postcards expose the content of the inmates’ 

communications to anyone who handles, processes, or views in route the postcards, 

both within the jail and after the postcards leave the facility. Prior to the PostcardOnly Mail Policy, Jail inmates including the Jail Inmate Plaintiffs would regularly 

write letters to family and friends that contained sensitive information, including 

medical, spiritual, intimate, and financial information. Because these letters were 

enclosed in envelopes and only subject to review by a Sheriff deputy, Jail inmates 

felt confident that this sensitive information would not be exposed for others to 

see, including postal carriers. The Postcard-Only Mail Policy has forced Jail 

inmates to either abandon including sensitive information in their non-privileged 

correspondence or risk divulging confidential, sensitive information to unknown 

third-parties who can easily intercept these messages on postcards. Including 

sensitive financial information on a postcard increases the chance that the Jail 

inmate may become a victim of identity thief or fraud. The Postcard-Only Mail 

Policy either chills Jail inmates from writing about sensitive matters entirely, or it 

requires them to expose their communications to a host of strangers or unintended 

recipients—such as postal employees, an office secretary, or a child who retrieves 

from the mailbox a postcard that discusses sensitive details intended only for the 

parent’s eyes. 

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32. At times, Jail inmates deliver their mail by placing it on the bars of 

their cell or on the glass on the door leading from the dorms. In many 

circumstances, fellow inmates may view the contents of the postcard placed for 

delivery in this manner. 

33. The Sheriff’s Postcard-Only Mail Policy has and continues to inhibit, 

infringe, limit, chill, suppress, and interfere with the Plaintiffs’ constitutionallyprotected communications between inmates and correspondents or intended 

correspondents. 

34. The Plaintiffs have suffered and will continue to suffer an injury as a 

result of the Postcard-Only Mail Policy. Sheriff Hall caused and will continue to 

cause this injury. The Postcard-Only Mail Policy infringes on the U.S. 

Constitution’s First Amendment free speech rights of Jail inmates Plaintiffs to 

communicate in a complete and meaningful way with and to express themselves 

fully to their family and friends. Likewise, the Postcard-Only Mail Policy deprives 

Miller of his U.S. Constitution’s First Amendment free speech right to receive such 

communications. 

35. Sheriff Hall’s Postcard-Only Mail Policy has and will continue to 

inhibit, infringe, limit, chill, and suppress the constitutionally protected 

communications from Jail inmates to their correspondents. 

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36. Sheriff Hall has acted and threatens to continue acting under color of 

state law to deprive Plaintiffs of their constitutional rights. Plaintiffs face a real and 

immediate threat of irreparable injury as a result of these actions and threatened 

actions of Sheriff Hall and the existence, operation, and threat of enforcement of 

the Postcard-Only Mail Policy. 

37. Jail Inmate Plaintiffs desire to and would write non-privileged letters 

to family and friends, including Correspondent Plaintiff and include sensitive 

information and drawings absent the Postcard-Only Mail Policy. 

EXHAUSTION OF ADMINISTRATIVE REMEDIES

38. Each of the Jail Inmate Plaintiffs has filed formal grievances and 

exhausted all available administrative remedies. 

CLASS ACTION ALLEGATIONS

39. The individual Jail Inmate Plaintiffs bring this action on behalf of 

themselves and all others similarly situated, pursuant to Rule 23(a) and 23(b)(2) of 

the Federal Rules of Civil Procedure. 

40. The individual Jail Inmate Plaintiffs seek to represent a class defined 

as “all current and future detainees in the Santa Rosa County, Florida, Jail 

who are subject to or affected by the Postcard-Only Mail Policy.” 

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41. The proposed class is so numerous and so fluid that joinder of all 

members is impracticable and uneconomical. With over seven thousand persons 

admitted to the Jail annually and an average Jail inmate population of around five 

hundred, the approximate size of the class is over five-hundred persons at a time. 

42. There are questions of law and fact common to the members of the 

Plaintiff Class. The same policy and practice applies to all class members. The 

question common to all members of the Plaintiff Class is what justification Sheriff 

Hall has for instituting and maintaining his Postcard-Only Mail Policy and whether 

these reasons justify the specific free-speech restrictions of the Plaintiff Class. 

These common questions predominate. 

43. The claims of the Jail Inmate Plaintiffs are typical of the claims of the 

members of the class. The Jail Inmate Plaintiffs suffer injuries similar in kind and 

degree as the class. They raise questions of fact and law common to the class. 

Their injuries arise from the same conduct as the class injuries. The Jail Inmate 

Plaintiffs seek a permanent injunction to end the unlawful policy and practices as 

the class would desire. 

44. The named Jail Inmate Plaintiffs will fairly and adequately protect the 

interests of the class. Jail Inmate Plaintiffs have no interest that is now or may be 

potentially antagonistic to the interests of the class. Jail Inmate Plaintiffs 

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understand the duties and responsibilities of serving as class representatives. Jail 

Inmate Plaintiffs are represented by attorneys employed by or working in 

cooperation with the ACLU Foundation of Florida, and the Florida Justice 

Institute, which have extensive experience in class action cases involving federal 

civil rights claims for inmates. 

45. Defendants have acted or refused to act on grounds generally 

applicable to the class, thereby making appropriate final injunctive and declaratory 

relief with respect to the class as a whole. 

COUNT 1: SUPPRESSION OF PROTECTED SPEECH

(Jail Inmate Plaintiffs - 42 U.S.C. §1983) 

46. Jail Inmate Plaintiffs reallege and incorporate by reference all of the 

preceding paragraphs in this complaint. 

47. The Defendant has deprived, and continues to deprive, Jail Inmate 

Plaintiffs of their rights under the First Amendment to the United States 

Constitution, which are secured through the Fourteenth Amendment. The Sheriff’s 

Postcard Only Mail Policy established by Defendant is the cause in fact of the 

constitutional violations. 

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48. Absent intervention by this Court the Jail Inmate Plaintiffs will suffer 

injury as a result of the Defendant’s unconstitutional practices. 

49. Unless restrained by this Court, the Defendant will continue to 

enforce the Postcard Only Mail Policy. Jail Inmate Plaintiffs have been and will 

continue to be irreparably harmed by the Defendant’s denial of Plaintiffs’ 

fundamental constitutional right to free speech. 

50. Jail Inmate Plaintiffs have no adequate remedy at law for the denial of 

their fundamental constitutional rights. 

51. In depriving the Jail Inmate Plaintiffs of these rights, Defendant acted 

under color of state law. This deprivation under color of state law is actionable 

under and may be redressed by 42 U.S.C. §1983. 

COUNT 2: SUPPRESSION OF PROTECTED SPEECH

 (Miller - 42 U.S.C. §1983) 

52. Miller realleges and incorporates by reference paragraphs 1 through 

37 of this complaint. 

53. The Defendant has deprived, and continues to deprive, Miller of his 

rights under the First Amendment to the United States Constitution, which are 

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secured through the Fourteenth Amendment. The Sheriff’s Postcard Only Mail 

Policy established by Defendant is the cause in fact of the constitutional violations. 

54. Absent intervention by this Court Miller will suffer injury as a result 

of the Defendant’s unconstitutional practices. 

55. Unless restrained by this Court, the Defendant will continue to 

enforce the Postcard Only Mail Policy. Miller has been and will continue to be 

irreparably harmed by the Defendant’s denial of Miller’s fundamental 

constitutional right to receive speech from Reynolds. 

56. Miller has no adequate remedy at law for the denial of their 

fundamental constitutional rights. 

57. In depriving Miller of these rights, Defendant acted under color of 

state law. This deprivation under color of state law is actionable under and may be 

redressed by 42 U.S.C. §1983. 

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RELIEF REQUESTED

WHEREFORE, Plaintiffs respectfully request the following relief: 

A. An order certifying this matter as a Plaintiff Inmate class action 

pursuant to Rule 23; 

B. An order declaring Defendant’s Postcard-Only Mail Policy alleged 

above to be in violation of the First and Fourteenth Amendments to the U.S. 

Constitution; 

C. An order permanently enjoining Defendant and his officers, agents, 

affiliates, subsidiaries, servants, employees, successors, and all other persons or 

entities in active concert or privity or participation with him, from continuing their 

unlawful Postcard-Only Mail Policy or any other policy that limits outgoing mail 

to postcards, thus restoring the status quo that previously existed, including 

enjoining Defendant from: 

1. Restricting all non-privileged outgoing mail to be in a postcard 

format; 

2. Prohibiting categorically all “drawings or unnecessary 

marking” on all non-privileged mail, regardless of the message of the drawing or 

marking; 

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D. An order commanding the Defendant to provide notice to all current Jail 

inmates and Jail officials implementing the Defendant’s policies that the PostcardOnly Mail Policy is terminated; 

E. An order permanently enjoining Defendant and his officers, agents, 

affiliates, subsidiaries, servants, employees, successors, and all other persons or 

entities in active concert or privity or participation with him, from taking retaliatory 

action against Plaintiffs for bringing this lawsuit; 

F. Entry of judgment for Miller against Defendant Hall for nominal 

damages of $1 for the constitutional deprivations alleged above; 

G. An award to Plaintiffs of reasonable attorneys’ fees and costs incurred 

in connection with this action from the Defendants pursuant to 42 U.S.C. §1988; 

H. An order retaining the Court’s jurisdiction of this matter to enforce the 

terms of the Court’s orders; and 

I. Such further and different relief as is just and proper or that is 

necessary to make the Plaintiffs whole. 

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Dated: September 20, 2010 

Respectfully Submitted, 

s/ Benjamin James Stevenson

Benjamin James Stevenson (Fla. 

Bar. No. 598909) 

American Civil Liberties Union 

Found. of Fla. 

Post Office Box 12723 

Pensacola, FL 32591-2723 

bstevenson@aclufl.org 

T. 786.363.2738 

F. 786.363.1985 

Randall C. Berg, Jr. (Fla. Bar No. 

318371) 

Florida Justice Institute, Inc. 

100 SE Second St., Ste. 3750 

Miami, Florida 33131-2115 

RBerg@FloridaJusticeInstitute.org 

T. 305.358.2081 x 225 

F. 305.358.0910 

Randall C. Marshall (Fla. Bar No.: 

181765) 

RMarshall@aclufl.org 

Maria Kayanan (Fla. Bar No.: 

305601) 

MKayanan@aclufl.org 

American Civil Liberties Union 

Found. of Fla. 

4500 Biscayne Blvd., Ste. 340 

Miami, Florida 33137 

T. 786.363.2707 

F. 786.363.1108 

Counsel for Plaintiffs 

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