Intent to sue, sent 4.30.25 to shawn.sherrouse@lakelandgov.net esther.ott@lakelandgov.net Palmer.Davis@lakelandgov.net shawn.sherrouse@lakelandgov.net
Chief Hans Lehman
https://www.facebook.com/LakelandPD
The complaint and files
RE: NOTICE OF INTENT TO SUE – Civil Rights Violations by Lakeland Police Officers on September 15, 2024
To Whom It May Concern,
Please accept this letter as formal notice of my intent to initiate a federal civil rights lawsuit against the City of Lakeland and officers of the Lakeland Police Department pursuant to 42 U.S.C. § 1983. This legal action arises from egregious violations of my First and Fourth Amendment rights and those of my son, Jacob Blume, during a police encounter at our residence on September 15, 2024.
Summary of Violations:
- Retaliation for Protected Speech (First Amendment)
- Officer Roberto Garibaldi (#164) approached me while I was filming from my private property and brandished handcuffs in a threatening manner, stating:
“Are you gonna run your mouth, or are you gonna shut up?”
This was an unprovoked intimidation tactic in direct response to my verbal and lawful act of filming—a constitutionally protected activity. - Officer Kenneth Vanderpool (#336) unlawfully threatened me with arrest, falsely claiming I was “antagonizing” by speaking to my son and warning him of police misconduct.
- Both officers attempted to suppress my constitutionally protected speech and retaliated against me for exercising freedom of the press under clearly established law, including:
- Glik v. Cunniffe, 655 F.3d 78 (1st Cir. 2011)
- Houston v. Hill, 482 U.S. 451 (1987)
- Hartman v. Moore, 547 U.S. 250 (2006)
- Officer Roberto Garibaldi (#164) approached me while I was filming from my private property and brandished handcuffs in a threatening manner, stating:
- Unlawful Seizure and Detention (Fourth Amendment)
- My son, Jacob Blume, was seized, patted down, and detained without reasonable suspicion or probable cause, in violation of Florida v. Royer, 460 U.S. 491 (1983).
- He was subsequently Baker Acted based on hearsay and officer discretion alone, absent any articulable mental health crisis or dangerous behavior, violating his due process rights under O’Connor v. Donaldson, 422 U.S. 563 (1975), and Addington v. Texas, 441 U.S. 418 (1979).
- Conduct Unbecoming & Departmental Negligence
- Officer Garibaldi admitted during sworn internal affairs interviews that his actions were intended to obtain compliance by force or intimidation.
- Body-worn camera (BWC) footage and cellphone video contradict officers’ narratives and confirm a pattern of unprofessional conduct, retaliation, and unconstitutional policing.
- Supervisory failure to discipline or correct these officers—despite their own admissions—may indicate municipal liability under Monell v. Department of Social Services, 436 U.S. 658 (1978).
This letter serves as pre-litigation notice. I am currently preparing a complaint in federal court and will be seeking compensatory and punitive damages for violations of our civil rights, emotional distress, and other legal claims stemming from this incident.
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