TO:

Superintendent Michael J. Burke
The School District of Palm Beach County
3300 Forest Hill Blvd.
West Palm Beach, FL 33406

Shawntoyia Bernard, Esq.
General Counsel
The School District of Palm Beach County
3300 Forest Hill Blvd., C-316
West Palm Beach, FL 33406
Email: shawntoyia.bernard@palmbeachschools.org

Chief Sarah Mooney, Chief of School Police
Office of the Chief of Police
The School District of Palm Beach County
3300 Forest Hill Blvd.
West Palm Beach, FL 33406

RE: First Amendment Violation – Notice of Federal Lawsuit Against the School District of Palm Beach County and Its Officials

Dear Superintendent Burke,

This letter serves as formal notice that your administration’s continued efforts to block, censor, or otherwise restrict my access to public discourse on official social media platforms operated by The School District of Palm Beach County constitute ongoing and deliberate violations of my First Amendment rights.

I have been unlawfully blocked and silenced from engaging with these government-run digital public forums, which are routinely used to broadcast official school information, respond to public comment, and engage with the community at large. These platforms, including but not limited to X (PBSchoolsPD), Facebook (PBSchoolsPD) and Instagram (pbschoolspd), are designated public forums by virtue of their consistent use for official government communication.

This conduct is in direct violation of multiple binding federal precedents, including:

• O’Connor-Ratcliff v. Garnier (601 U.S. ___, 2024),

• Knight First Amendment Institute v. Trump (928 F.3d 226),

• Davison v. Randall (912 F.3d 666).

These cases clearly affirm that when government entities or officials use social media accounts for official purposes, they are prohibited from engaging in viewpoint-based exclusion. Your actions are not only unconstitutional—they are willful, retaliatory, and part of a broader pattern of rights suppression.

This communication is not a request for reconsideration. Regardless of whether access is restored in the coming days, I intend to file a federal civil rights lawsuit under 42 U.S.C. §1983 seeking:

• A declaratory judgment affirming the violation of my First Amendment rights,

• A preliminary and permanent injunction,

• Nominal damages,

• And attorneys’ fees and costs pursuant to 42 U.S.C. §1988.

You are now formally on notice. All parties copied herein are advised to preserve all relevant digital evidence, including comment histories, page administrator logs, block lists, internal communication regarding social media moderation, and any records relating to my exclusion.

This District is accountable to the public, not immune from it. A federal court will make that clear.
Govern yourselves accordingly!

Submitted: June 12, 2025