Complaint of Joshua Garton and Exhibits 1 4

IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF TENNESSEE

AT NASHVILLE
JOSHUA GARTON, §
§
Plaintiff, §
§
v. § Case No. ___________
§
W. RAY CROUCH, DAVID RAUSCH, § JURY DEMANDED
BRADLEY NEALON, RUSSELL §
WINKLER, JOSHUA MELTON, §
JOSEPH CRAIG, DONALD ARNOLD, §
ANDREW VALLEE, and §
CITY OF DICKSON, TENNESSEE, §
§
Defendants. §
COMPLAINT
For his Complaint against the Defendants, Plaintiff Joshua Garton states to the
Court and the Jury as follows:
I. INTRODUCTION
1. In January 2021, Plaintiff Joshua Garton was investigated and arrested by
a joint law enforcement taskforce for posting a fake photograph on social media that was
critical of law enforcement. The fake photograph at issue was crudely designed to look as
though people were urinating on the grave of a deceased police officer. Mr. Garton’s fake
photograph also included the overtly political message: “Just showing my respect to
Deputy Daniel Baker from the #dicksonpolicedepartment.”
2. The Defendants who were responsible for arresting Mr. Garton had actual
knowledge—at the time that they arrested and charged him—that the photograph that Mr.
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Garton had posted on Facebook was fake. At the urging of Defendant W. Ray Crouch,
though—who wanted Mr. Garton punished for disrespecting law enforcement within his
jurisdiction—they arrested Mr. Garton anyway and took him into custody. Thereafter,
Mr. Garton was charged with a crime, and he was incarcerated for nearly two weeks while
he awaited a hearing. Mr. Garton was ultimately released from jail after the bogus charge
at issue was dismissed for lack of probable cause following Mr. Garton’s first appearance
in court.
3. Internal correspondence among the Defendants obtained through a public
records request confirms both the Defendants’ actual knowledge that “we violated [Mr.
Garton’s] 1st amendment rights” and the Defendants’ actual knowledge that Mr. Garton
“has a right to post.” See Collective Exhibit #1, pp. 104–05. 1 Even so, because Mr.
Garton had disrespected law enforcement, the Defendants vowed that: “[t]hat doesn’t
mean there are no consequences.” Id. at p. 105. Accordingly, the Defendants arrested
Mr. Garton, charged him with a crime, and held him in jail on a bogus charge for nearly
two weeks while he awaited a hearing. In the interim, the Defendants also humiliated Mr.
Garton through reputationally damaging press releases and other media that prominently
featured Mr. Garton’s mugshot and the fact of his arrest.
4. Upon review by a court, the bogus criminal charge that the Defendants filed
against Mr. Garton was dismissed outright for lack of probable cause that Mr. Garton’s
speech constituted a criminal offense. Thereafter, one Defendant lamented: “That is not
good.” Another Defendant complained—correctly—that: “We are finished.” This action
followed.
1The redactions in the appended public records are the TBI’s. The TBI’s counsel has also refused to affirm
or certify independently that the redactions are legally warranted.
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II. PARTIES
5. Plaintiff Joshua Garton is a transient resident of Rutherford County who
was investigated, arrested, prosecuted, and incarcerated by a joint law enforcement
taskforce for disrespecting law enforcement. He is a citizen of Tennessee and may be
contacted through his counsel.
6. Defendant W. Ray Crouch is the current District Attorney General for
Tennessee’s 23rd Judicial District. At all times relevant to this action, Defendant Crouch
was professionally obligated to comply with the Constitution, to maintain a minimum
level of professional competence, to refrain from abusing the legal process, and to avoid
acting in “knowing disregard of obligations” or engaging in “a systematic abuse of
prosecutorial discretion.” Upon information and belief, Defendant Crouch failed to
comply with these obligations by directing law enforcement to investigate, retaliate
against, arrest, and charge Mr. Garton because he had disrespected law enforcement.
Defendant Crouch is sued in his individual capacity regarding specified tort claims and in
his official capacity regarding the Plaintiff’s claim for injunctive relief. Defendant Crouch
may be served at his residence located at 119 Stratton Blvd., Ashland City, Tennessee,
37015-1613, or wherever he may be found.
7. Defendant David Rausch is the current Director of the Tennessee Bureau of
Investigation, a statewide law enforcement agency. In that role, upon information and
belief, Defendant Rausch participated in the Defendants’ investigation of, false arrest of,
malicious prosecution of, and unconstitutional retaliation against Mr. Garton. At all
times relevant to this action, Defendant Rausch had an obligation to comply with the
Constitution and enforce the law, rather than participate in a conspiracy to violate it.
During the events giving rise to this Complaint, Defendant Rausch also maintained that
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citizens who care about the First Amendment and criticize law enforcement are akin to
insurrectionists. Defendant Rausch is sued in his individual capacity regarding specified
tort claims and in his official capacity regarding the Plaintiff’s claim for injunctive relief.
Defendant Rausch may be served at his residence located at 1121 Brentwood Way,
Kingston, Tennessee, 37763-3160, or wherever he may be found.
8. Defendant Bradley Nealon is the Deputy Director of the TBI. In that role,
upon information and belief, Defendant Nealon participated in the Defendants’
investigation of, false arrest of, malicious prosecution of, and unconstitutional retaliation
against Mr. Garton. Defendant Nealon is sued in his individual capacity only, and he may
be served at his residence located at 1594 Golliher Rd., Rockwood, Tennessee, 37854-
5252, or wherever he may be found.
9. Defendant Russell Winkler was at all times relevant to this Complaint the
Special Agent in Charge at the Tennessee Bureau of Investigation. In that role, upon
information and belief, Defendant Winkler participated in the Defendants’ investigation
of, false arrest of, malicious prosecution of, and unconstitutional retaliation against Mr.
Garton. Defendant Winkler is sued in his individual capacity only, and he may be served
at his residence located at 725 Heritage Rd., Lebanon, Tennessee, 37087-6547, or
wherever he may be found.
10. Defendant Joshua Melton is the Assistant Director of the Criminal
Investigation Division of the Tennessee Bureau of Investigation. In that role, upon
information and belief, Defendant Melton participated in the Defendants’ investigation
of, false arrest of, malicious prosecution of, and unconstitutional retaliation against Mr.
Garton. Defendant Melton is sued in his individual capacity only, and he may be served
at his residence located at 1433 Swamp Leanna Rd., Murfreesboro, Tennessee, 37129, or
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wherever he may be found.
11. Defendant Joseph Craig is an Assistant Special Agent in Charge at the
Tennessee Bureau of Investigation. Defendant Craig has served as a TBI agent for twenty-
two years and is currently assigned to the Middle Tennessee Criminal Investigations
Division, where he supervises field agents covering territory that encompasses Dickson
County. In that role, Defendant Craig participated in the Defendants’ investigation of,
false arrest of, malicious prosecution of, and unconstitutional retaliation against Mr.
Garton. At all times relevant to this Complaint, Defendant Craig acted, by virtue of his
position as a TBI agent, under color of state law. Defendant Craig is sued in his individual
capacity only, and he may be served at his residence located at 2437 New Cut Rd.,
Greenbrier, Tennessee, 37073-5165, or wherever he may be found.
12. Defendant Andrew Vallee is a Special Agent with the Tennessee Bureau of
Investigation. Defendant Vallee is assigned to the Technical Services Unit and specializes
in digital forensics, cellular network analysis, WiFi analysis, and various other technology
related disciplines. In that role, Defendant Vallee participated in the Defendants’
investigation of, false arrest of, malicious prosecution of, and unconstitutional retaliation
against Mr. Garton. At all times relevant to this Complaint, Defendant Vallee acted, by
virtue of his position as a TBI agent, under color of state law. Defendant Vallee is sued in
his individual capacity only, and he may be served at his residence located at 631 Keeton
Ave. 1, Old Hickory, Tennessee, 37138-3813, or wherever he may be found.
13. Defendant Donald Arnold is a Captain in the Dickson Police Department
who was responsible for working with the Tennessee Bureau of Investigation, on behalf
of the City of Dickson, to falsely arrest, maliciously prosecute, and unconstitutionally
retaliate against Mr. Garton. Defendant Arnold is sued in his individual capacity, and he
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may be served at his residence located at 1012 Laurel Hills Dr., Dickson, Tennessee,
37055-4068, or wherever he may be found.
14. Defendant City of Dickson, Tennessee, is a Tennessee municipality. The
City of Dickson is liable for its official policies, customs, and practices and for its failure
to train its employees when it acts with deliberate indifference to a plaintiff’s clearly
established constitutional rights, as it did here. The City of Dickson is a political
subdivision of the State of Tennessee and, among other functions, it operates and
maintains a law enforcement agency known as the Dickson Police Department. At all
times relevant to this action, the City of Dickson and its agents acted under color of state
law. Service upon the City of Dickson may be made upon Mayor Don L. Weiss Jr., at 600
East Walnut Street, Dickson, TN 37055.
III. JURISDICTION AND VENUE
15. This Court has jurisdiction over the Plaintiff’s federal claims in this civil
action pursuant to 28 U.S.C. §§ 1331 and 1343(a).
16. This Court has supplemental jurisdiction to adjudicate the Plaintiff’s state
law claims related to the Plaintiff’s federal claims in this action pursuant to 28 U.S.C.
§ 1367(a).
17. As the judicial district in which a substantial part of the events or omissions
giving rise to the Plaintiff’s claims occurred, venue is proper in this Court pursuant to 28
U.S.C. § 1391(b)(2).
18. As the judicial district in which one or more Defendants reside, and all
Defendants being residents of the State of Tennessee, venue is additionally proper in this
Court pursuant to 28 U.S.C. § 1391(b)(1).
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IV. FACTUAL ALLEGATIONS
19. The Plaintiff is a 29-year-old disabled male who suffers from mental illness.
As a result of the Defendants’ unconstitutional and tortious misconduct, the Plaintiff
spent nearly two weeks in jail for a non-existent crime and became homeless.
20. In January 2021, the Plaintiff pseudonymously posted the following
political message and accompanying fake photograph—otherwise known as a “meme” 2—
on Facebook, a social media website:
21. The above photograph does not actually depict the gravesite of Sergeant
Baker. Indeed, it looks nothing like Sergeant Baker’s gravesite. Instead, the photograph
was an altered image from The Rites’s 2009 album “Pissing On Your Grave” that
2A “meme” is an “interesting item (such as a captioned picture or video) or genre of items that is spread
widely online especially through social media.” See Merriam-Webster, https://www.merriam-
webster.com/dictionary/meme (last accessed April 15, 2021).
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contained a crudely integrated professional headshot of Sergeant Baker, a public figure,
paired with the Plaintiff’s commentary regarding a matter of public concern. 3
22. Defendant Crouch was offended by the Plaintiff’s meme because it
disrespected a deceased member of local law enforcement. Accordingly, Defendant
Crouch demanded that the Tennessee Bureau of Investigation and the other Defendants
in this matter conduct a criminal investigation regarding it. Thus, at the direction of
Defendant Crouch, a joint task force of state and local law enforcement undertook to
investigate the Plaintiff’s meme in an effort to identify the Plaintiff and arrest him.
23. Through herculean investigative work—including “TBI agents visit[ing] the
gravesite of Baker”—the Defendants “quickly determined the photograph [was] not
authentic.” Defendant Craig, in particular, realized that the meme was a photoshopped
image in “a few seconds.”
24. The fact that the Plaintiff’s meme was not authentic complicated the
Defendants’ desire to arrest the Plaintiff for an actual criminal offense, such as
desecrating a grave. Believing that disrespecting law enforcement still merited
“consequences,” though, the Defendants—acting in concert with one another—resolved
to continue their investigation and arrest the Plaintiff for some other crime instead.
25. Accordingly, even after determining that the meme at issue was not a
genuine photograph—and despite lacking any reason to believe a crime had been
committed—the TBI launched a manhunt and issued an all-points bulletin asking the
3 In May of 2018, Sergeant Daniel Baker of the Dickson Police Department was killed in the line of duty.
His death sparked widespread media coverage and, among other things, prompted the Tennessee General
Assembly to enact the controversial “Sergeant Daniel Baker Act”—codified at Tenn. Code Ann. § 39-13-
206—which accelerates review of death penalty cases and promotes faster executions. At the time, State
Representative Mary Littleton (R-Dickson), who sponsored the bill, was quoted in The Tennessean at saying
the bill was named to “memorialize Sgt. Baker and to continue his memory for those in Dickson County as
well as around the state.”
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public for help identifying the meme’s creator.
26. As examples of the TBI’s public statements and manhunt regarding the
Plaintiff’s meme, during the Defendants’ investigation into the Plaintiff’s meme, and to
secure assistance regarding it, the TBI issued the following public “news alert[s]”:
27. Ultimately, tips from local citizens and a “technical investigation conducted
by [Defendant] Vallee identified [Plaintiff] Joshua Garton as the individual possibly
responsible for the posting.”
28. After identifying the Plaintiff as the individual responsible for the meme,
the Defendants located the Plaintiff, interrogated him, charged him with Harassment,
booked him into the Dickson County Jail, and set his bond at a punitive amount of
$76,000.00 to ensure that he would remain incarcerated for an extended period of time.
29. The Defendants did not have probable cause to arrest the Plaintiff or to
believe that the Plaintiff had committed any crime, and they knew it. The Plaintiff’s
photograph concerned a public figure regarding a matter of public concern. It also was
not directed to any member of Sergeant Baker’s family, though clearly established U.S.
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Supreme Court precedent dictated that it would have been constitutionally protected even
if it had been. See generally Snyder v. Phelps, 562 U.S. 443 (2011). Despite the meme’s
heavy attention and its recirculation on social media, the Defendants also declined to
investigate or arrest any other person who posted the photograph at issue—including
individuals who did send it to members of Sergeant Baker’s family. Instead, as the
publisher of the meme at issue and the person who was responsible for its anti-law
enforcement message, the Defendants singularly targeted, falsely arrested, and
maliciously prosecuted the Plaintiff alone because the Plaintiff was the person who had
expressed a viewpoint that disrespected and offended them.
30. At all times relevant to this action, the United States Supreme Court had
clearly established that:
Official reprisal for protected speech “offends the Constitution [because] it

threatens to inhibit exercise of the protected right,” Crawford–El v. Britton,
523 U.S. 574, 588, n. 10, 118 S.Ct. 1584, 140 L.Ed.2d 759 (1998), and the law
is settled that as a general matter the First Amendment prohibits
government officials from subjecting an individual to retaliatory actions,
including criminal prosecutions, for speaking out, id., at 592, 118 S.Ct. 1584;
see also Perry v. Sindermann, 408 U.S. 593, 597, 92 S.Ct. 2694, 33 L.Ed.2d
570 (1972) (noting that the government may not punish a person or deprive
him of a benefit on the basis of his “constitutionally protected speech”).
Hartman v. Moore, 547 U.S. 250, 256 (2006).
31. At all times relevant to this action, the United States Supreme Court had
also clearly established that the “bedrock principle underlying the First Amendment is
that the government may not prohibit the expression of an idea simply because society
finds the idea itself offensive or disagreeable,” Texas. v. Johnson, 491 U.S. 397, 414
(1989), and that “[g]iving offense is a viewpoint.” Matal v. Tam, 137 S. Ct. 1744, 1763
(2017). Indeed, the United States Supreme Court has held
time and again that “the public expression of ideas may not be prohibited
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merely because the ideas are themselves offensive to some of their hearers.”
Street v. New York, 394 U.S. 576, 592, 89 S.Ct. 1354, 22 L.Ed.2d 572 (1969).
See also Texas v. Johnson, 491 U.S. 397, 414, 109 S.Ct. 2533, 105 L.Ed.2d
342 (1989) (“If there is a bedrock principle underlying the First
Amendment, it is that the government may not prohibit the expression of
an idea simply because society finds the idea itself offensive or
disagreeable”); Hustler Magazine, Inc. v. Falwell, 485 U.S. 46, 55–56, 108
S.Ct. 876, 99 L.Ed.2d 41 (1988); Coates v. Cincinnati, 402 U.S. 611, 615, 91
S.Ct. 1686, 29 L.Ed.2d 214 (1971); Bachellar v. Maryland, 397 U.S. 564,
567, 90 S.Ct. 1312, 25 L.Ed.2d 570 (1970); Tinker v. Des Moines
Independent Community School Dist., 393 U.S. 503, 509–514, 89 S.Ct. 733,
21 L.Ed.2d 731 (1969); Cox v. Louisiana, 379 U.S. 536, 551, 85 S.Ct. 453, 13
L.Ed.2d 471 (1965); Edwards v. South Carolina, 372 U.S. 229, 237–238, 83
S.Ct. 680, 9 L.Ed.2d 697 (1963); Terminiello v. Chicago, 337 U.S. 1, 4–5, 69
S.Ct. 894, 93 L.Ed. 1131 (1949); Cantwell v. Connecticut, 310 U.S. 296, 311,
60 S.Ct. 900, 84 L.Ed. 1213 (1940); Schneider v. State (Town of Irvington),
308 U.S. 147, 161, 60 S.Ct. 146, 84 L.Ed. 155 (1939); De Jonge v. Oregon,
299 U.S. 353, 365, 57 S.Ct. 255, 81 L.Ed. 278 (1937).
Id.
32. At all times relevant to this action, the United States Court of Appeals for
the Sixth Circuit had also clearly established that the applicable and binding precedent
regarding offensive speech is not ambiguous, and that government officials are obliged to
comply with it. See, e.g., McGlone v. Metro. Gov't of Nashville, 749 F. App'x 402, 406,
n.2 (6th Cir. 2018) (“Nashville’s ‘guess’ is correct. Speech deemed hateful and offensive
is not only still protected by the First Amendment, it is the speech most in need of First
Amendment protection.”) (citing Texas v. Johnson, 491 U.S. 397, 414, 109 S.Ct. 2533, 105
L.Ed.2d 342 (1989) (“If there is a bedrock principle underlying the First Amendment, it
is that the government may not prohibit the expression of an idea simply because society
finds the idea itself offensive or disagreeable.”)).
33. The Defendants—one of whom is an attorney who wields extraordinary
prosecutorial authority—neither care about nor feel constrained by clearly established
First Amendment law. Indeed, the Defendants’ internal correspondence reflects that they
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abhor the rights that the First Amendment guarantees individuals like the Plaintiff.
34. For example, Defendants’ correspondence reflects their actual knowledge
that “we violated [Mr. Garton’s] 1st amendment rights” and that Mr. Garton “has a right
to post.” According to the Defendants, however, “[t]hat doesn’t mean there are no
consequences,” which the Defendants collectively ensured the Plaintiff experienced:
35. The “consequences” that the Defendants ensured would result from
disrespecting law enforcement included subjecting the Plaintiff to a false arrest and
malicious prosecution, incarcerating him for weeks, and broadcasting his mugshot and
the fact of his arrest to news media and the public in retaliation for disrespecting police.
36. The Defendants similarly believe that criticizing their constitutionally
repugnant behavior is unwarranted. Indeed, the Defendants routinely characterized
criticism of their behavior as “threats.”
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37. Defendant Rausch, in particular—the current Director of Tennessee’s top
law enforcement agency—believes that arresting citizens for offensive speech is not only
appropriate, but that criticizing law enforcement for violating the First Amendment is
akin to defending insurrection:
38. After arresting the Plaintiff, the Defendants acted in concert to prepare and
issue a media release regarding the Plaintiff’s arrest that included his full name, his
mugshot, his date of birth, a reference to unrelated criminal charges, and the fact that the
Defendants had secured a substantial bond that ensured the Plaintiff would be
incarcerated for an extended time period. The purpose of this release was to humiliate
and retaliate against the Plaintiff, and to deter other similarly situated persons who
wished to exercise their constitutional rights to criticize or disrespect law enforcement
from doing so.
39. The public reaction to the Defendants’ press release and their celebration of
the Plaintiff’s arrest was not what the Defendants anticipated it would be. See Collective
Exhibit #2. 4 In response to their press release, the TBI received dozens of critical calls
4 Again, the redactions are the TBI’s.
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from citizens across the nation who were upset about the Defendants’ flagrant disregard
for the Constitution and their extreme ignorance of basic First Amendment rights. Upon
receiving such criticism, one TBI dispatcher complained: “We did not sign up for this.”
40. In response to the legitimate public criticism that they were receiving, the
Defendants did not release the Plaintiff or take steps to remedy their flagrantly
unconstitutional conduct. Instead, to inhibit such criticism, the TBI began tracking the
critical calls they were receiving, surveilling callers, and, in at least one instance, decided
to “try[] to pin down who [the caller was] so we can ask the local police and maybe have
them go out there and ask him to stop.”
41. After issuing their press release regarding the Plaintiff, the TBI began
receiving requests for comment from local and national news outlets asking them to
explain how they could have lawfully arrested the Plaintiff under the circumstances.
42. Because the Plaintiff’s arrest was not lawful and could not plausibly have
been lawful, the TBI was unable to do so. Accordingly—and notwithstanding that
Defendants employed by the TBI had investigated and then arrested the Plaintiff,
participated in the charging decision at issue, and that Defendant Craig himself had sworn
out the affidavit enabling the Plaintiff’s criminal charge, see Exhibit #3—the TBI
misleadingly deflected responsibility to Defendant Crouch, and responded with some
version of the following statement:

___________________________________________________
When requested to investigate an incident by a District Attorney

General, TBI agents serve as factfinders.
The DA determines what, if any, charges are placed.
For that reason, we will need to refer you to the District Attorney
General with questions regarding the charge in this case.
____________________________________________________
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43. The Plaintiff would ultimately be incarcerated for nearly two full weeks
before he was able to appear before a judge for a hearing on the charge at issue. The
Plaintiff was thus continuously incarcerated at the Dickson County Jail from January 22,
2021, until his preliminary hearing before Judge Craig Monsue on February 3, 2021.
44. During the Plaintiff’s preliminary hearing, Defendant Craig repeatedly
admitted that the Plaintiff had not posted the meme at issue with an unlawful purpose,
which was a threshold element of the harassment charge that he and the other Defendants
had conspired to initiate and then did initiate against the Plaintiff.
45. At the conclusion of the Plaintiff’s preliminary hearing on February 3, 2021,
Judge Monsue ordered as follows: “the Court cannot find that there’s probable cause to
believe that the posting of this photograph constitutes a threat of harm to Lisa Baker, but
is instead, a denigration of Sergeant Baker’s memory. Therefore respectfully, the Court
dismisses this count.”
46. Judgment dismissing, for lack of probable cause, the harassment charge
that the Defendants initiated against the Plaintiff was entered thereafter, see Exhibit #4,
and only then was the Plaintiff finally released from jail. The Plaintiff became homeless
as a result of the Defendants’ conduct, however, so by that point, he had no home to return
to. Accordingly, the Plaintiff now resides at a homeless shelter.
47. As a direct and proximate result of the Defendants’ unlawful actions, the
Plaintiff suffered extreme damages, a deprivation of his constitutional rights, unlawful
detention, psychological and emotional trauma, and damage to his reputation.
V. CAUSES OF ACTION
CLAIM #1: MALICIOUS PROSECUTION UNDER 42 U.S.C. § 1983 AND TENNESSEE COMMON LAW
48. The Plaintiff incorporates and realleges the foregoing allegations as if fully
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set forth herein.
49. Acting in concert with one another, and without probable cause to arrest the
Plaintiff, the Defendants wrongfully instituted legal process against the Plaintiff and
subjected the Plaintiff to a wrongful investigation, wrongful prosecution, and wrongful
incarceration in violation of the Fourth and Fourteenth Amendments to the United States
Constitution.
50. All Defendants made, influenced, or participated in the decision to
investigate, arrest, and/or charge the Plaintiff, and they acted in concert with one another
to ensure that the Plaintiff was investigated, charged, and prosecuted for his speech. The
Defendants thus acted both individually and collectively in pursuit of a common plan
under color of law with malicious intent to deprive the Plaintiff of his rights secured by
the United States Constitution.
51. All Defendants, individually and collectively, lacked probable cause to
institute criminal process against the Plaintiff.
52. The Defendants’ criminal prosecution was enabled by a constitutionally
defective and facially invalid Affidavit of Complaint signed by Defendant Craig that
asserted, among other things, that the Plaintiff’s speech had criminally “caused emotional
distress to . . . the law enforcement officers from Dickson County.”
53. As a consequence of the Defendants’ wrongful institution of legal process
against the Plaintiff, the Plaintiff suffered a deprivation of liberty apart from his initial
seizure, including continuous detention in jail for nearly two weeks without probable
cause.
54. The Plaintiff’s criminal proceeding was resolved in the Plaintiff’s favor.
55. The Plaintiff’s criminal proceeding was not resolved due to any plea or
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settlement, but was resolved in the Plaintiff’s favor because he was innocent of any
criminal charge and because the Defendants lacked probable cause to believe that he had
committed any crime.
56. Although inessential to his malicious prosecution claim, the Defendants
acted with malice toward the Plaintiff and subjected the Plaintiff to a wrongful
investigation, wrongful prosecution, and wrongful incarceration because of the
constitutionally protected, anti-law enforcement, and disrespectful viewpoint that the
Plaintiff had expressed regarding the Dickson County Police Department.
57. Unrelated to Defendant Crouch’s preparation for the initiation of a
prosecution or for judicial proceedings, and unconnected to the judicial process,
Defendant Crouch performed and directed investigative and administrative functions to
facilitate and enable the Plaintiff’s arrest without probable cause; he directed a search for
clues and corroboration that would give him probable cause to recommend that the
Plaintiff be arrested; and he played the role of an advocate against the Plaintiff before he
had—and without ever acquiring—probable cause to have the Plaintiff arrested.
58. In so doing, Defendant Crouch acted independent of his prosecutorial role
as a District Attorney and, separately, in violation of his professional ethical obligations,
among other things, to refrain from abusing the legal process, to avoid acting in “knowing
disregard of obligations,” and to avoid engaging in “a systematic abuse of prosecutorial
discretion.”
59. As a direct and proximate result of the Defendants’ malicious prosecution
of the Plaintiff, the Plaintiff suffered injuries, including, but not limited to, actual
damages, economic damages, a deprivation of his constitutional rights, unlawful
detention, psychological and emotional trauma, and damage to his reputation.
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CLAIM #2: FALSE ARREST (42 U.S.C. § 1983)
set forth herein.
61. At all times relevant to this action, no Defendant had probable cause to
arrest or direct the arrest of the Plaintiff.
62. The Plaintiff was nonetheless arrested at the Defendants’ behest and
direction based on a facially invalid warrant that was premised upon Defendant Craig’s
materially false statements and/or material omissions.
63. At all times relevant to this action, all Defendants, both individually and
collectively, lacked reasonable grounds for belief supported by more than mere suspicion
that the Plaintiff had committed a crime.
64. The totality of the circumstances and the facts and circumstances of which
the Defendants had knowledge at the moment of the Plaintiff’s arrest were insufficient to
warrant a prudent person in believing that the Plaintiff had committed an offense.
65. Even so, the Plaintiff was falsely arrest for a violation of Tenn. Code Ann. §
39-17-308 by Defendant Craig—in concert with and at the direction of Defendant Crouch
and the other Defendants—without probable cause.
66. The charges against the Plaintiff resulted in a deprivation of the Plaintiff’s
liberty, in that the Plaintiff was taken into custody, jailed continuously between January
22, 2021, and February 3, 2021, and forced to attend a preliminary hearing to obtain his
freedom from the false and malicious charge that the Defendants concocted against him
without probable cause to believe the Plaintiff had committed any crime.
67. The Defendants acted with malice when they falsely arrested and baselessly
charged the Plaintiff with violating Tenn. Code Ann. § 39-17-308.
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68. The Defendants falsely arrested and charged the Plaintiff with violating
Tenn. Code Ann. § 39-17-308 despite their actual knowledge that clearly established law
made clear that the Plaintiff’s speech was constitutionally protected and was not illegal.
69. The Plaintiff suffered actual damages as a proximate result of the
Defendants’ false arrest.
CLAIM #3: FIRST AMENDMENT RETALIATION (42 U.S.C. § 1983)
set forth herein.
71. At all times relevant to this Complaint, the Plaintiff had First Amendment
rights as a citizen that were not inconsistent with his status as a suspect or defendant.
72. Retaliation based upon a citizen’s exercise of his constitutional rights
violates the Constitution.
73. By posting the meme at issue, the Plaintiff engaged in speech and
expression protected by the First and Fourteenth Amendments to the Constitution.
74. In retaliation for the Plaintiff engaging in speech and expression protected
by the Constitution, the Defendants planned and then took extreme adverse actions
against the Plaintiff, including, but not limited to, subjecting the Plaintiff to a wrongful
investigation, wrongful prosecution, and extended wrongful incarceration; publicly
humiliating the Plaintiff through press releases touting the Defendants’ false arrest of the
Plaintiff; maliciously prosecuting the Plaintiff; and seeking and securing a high, punitive
bond to prevent the Plaintiff’s timely release from jail.
75. The adverse actions that the Defendants took against the Plaintiff would
deter a person of ordinary firmness from continuing to engage in constitutionally
protected conduct and would likely have a strong deterrent effect on others similarly
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situated, which is precisely what the Defendants’ actions were designed to do.
76. The Defendants took adverse actions against the Plaintiff at least in part
because of the Plaintiff’s exercise of constitutionally protected conduct and his clearly
established First Amendment rights.
because the Defendants disagreed with the viewpoint that the Plaintiff had expressed.
because the Defendants wished to see the Plaintiff suffer significant “consequences” for
his speech.
because the Defendants do not respect fundamental First Amendment guarantees and
because the Defendants do not believe that they are constrained by them.
80. As a proximate result of the Defendants’ unconstitutional retaliation against
the Plaintiff, the Plaintiff suffered damages.
CLAIM #4: CIVIL CONSPIRACY/AGENCY LIABILITY
set forth herein.
82. At all times relevant to this matter, the Defendants acted in concert with, at
the direction of, and as agents of, one another to commit the foregoing tortious
misconduct, and all Defendants acted under color of law.
83. At all times relevant to this matter, the Defendants had the intent and
knowledge of one another’s intent to accomplish by concert an unlawful purpose—or to
accomplish by concert a lawful purpose by unlawful means—all of the foregoing tortious
misconduct, including conspiring with one another to effect the Plaintiff’s false arrest,
-20-

malicious prosecution, and take other unconstitutionally retaliatory acts against him.
84. The Defendants conspired with one another and agreed to injure the
Plaintiff through unconstitutional action under color of law.
85. The Defendants shared in the general conspiratorial objective to injure the
Plaintiff for expressing a viewpoint critical of law enforcement, causing the Plaintiff
injury.
86. The Defendants are liable for one another’s acts undertaken in furtherance
of their civil conspiracy, and each Defendant is jointly and severally liable for the unlawful
acts of each other Defendant pursuant to Tenn. Code Ann. § 29-11-107(b)(1) and general
federal common law, see Hooks v. Hooks, 771 F.2d 935, 944 (6th Cir. 1985).
CLAIM #5: THE CITY OF DICKSON’S UNCONSTITUTIONAL POLICIES AND PRACTICES
set forth herein.
88. The City of Dickson, acting by and through its policymakers, officers, and
agents, including Defendant Arnold, and acting under color of state law, violated the
Plaintiff’s clearly established rights secured by the First and Fourteenth Amendments to
the United States Constitution.
89. The tortious acts and omissions of the City of Dickson, acting by and
through its policymakers, officers, and agents, including Defendant Arnold, were the
direct and proximate result of official municipal policies or customs created by the City of
Dickson and their execution or implementation against the Plaintiff, causing the Plaintiff
injury.
90. The City of Dickson’s customs, practices, or de facto policies are evidenced
by actions taken by officials with final decision-making authority, policies of inadequate

-21-

training or supervision, and a custom of tolerance or acquiescence of federal rights
violations, including, in this instance, the City of Dickson’s premeditated and public
commitment to violating the Plaintiff’s clearly established First Amendment rights and
its failure to remedy its unconstitutional conduct even after acquiring actual knowledge
that it had acted unconstitutionally.
91. Upon information and belief, the City of Dickson, through its employees,
engages in a clear and persistent pattern of unconstitutional action against those who
express views critical of law enforcement; it has notice or constructive notice of that fact;
it has tacitly approved of the unconstitutional conduct at issue, such that its deliberate
indifference can be said to amount to an official policy of inaction; and the City of
Dickson’s unconstitutional custom was the moving force or direct causal link in the
deprivation of the Plaintiff’s constitutional rights. This pattern specifically includes, but
is not limited to, the initiation of the investigation into the Plaintiff as well as the Plaintiff’s
subsequent arrest and prosecution, and it is evident from the Defendants’ requests to
other law enforcement agencies to launch investigations into individuals who contacted
the TBI to protest the Plaintiff’s treatment.
92. Upon information and belief, the City of Dickson fails to train or supervise
its employees to prevent constitutional violations like those the Plaintiff suffered, and it
provides training and supervision that is inadequate to prevent such violations.
93. The City of Dickson’s inadequate training is a result of the City of Dickson’s
deliberate indifference to federal constitutional rights. For example, the text message
exchange between two Defendants explicitly stating that even though the Plaintiff
exercised his First Amendment rights, he could still be subject to “consequences”—up to
and including prosecution and incarceration at the hands of the state—indicates a lack of
-22-

understanding of the very nature of the First Amendment. Coupled with the City of
Dickson’s and its employees’ repeated violations of the Plaintiff’s and other citizens’ First
Amendment rights, this demonstrates a widespread pattern of ignorance of or deliberate
indifference to the First Amendment, indicating a widespread failure of training.
94. The City of Dickson’s inadequate training was closely related to or actually
caused the Plaintiff’s injury.
95. The City of Dickson has failed to promulgate appropriate policies or
procedures or take other measures to prevent violations of the First Amendment by its
employees, agents, or officers, and upon information and belief, no employee involved in
the Plaintiff’s false arrest, malicious prosecution, or unconstitutional retaliation,
including Defendant Arnold, has been disciplined for misconduct.
96. As a direct and proximate consequence of the City of Dickson’s failure to
develop, implement, and otherwise devise a policy of adequate training and/or
supervision for its employees, agents, and officers, the Plaintiff was deprived of his civil
and constitutional rights, privileges, and immunities and was subjected to criminal
prosecution and an extended period of unlawful incarceration. Properly trained and
supervised employees, agents, and officers would have known not to engage in the acts
which resulted in the deprivation of the Plaintiff’s civil and constitutional rights.
97. As a direct and proximate result of the customs, practices, and/or de facto
policies of the City of Dickson and the City of Dickson’s deliberate indifference to the
Plaintiff’s clearly established constitutional rights, the Plaintiff suffered damages.
CLAIM #6: INJUNCTIVE AND DECLARATORY RELIEF AGAINST THE CITY OF DICKSON AND
DEFENDANTS CROUCH AND RAUSCH IN THEIR OFFICIAL CAPACITIES
-23-

set forth herein.
99. Upon information and belief, Defendant Crouch desires to re-prosecute the
Plaintiff regarding this specific instance of protected speech and will seek his indictment
via direct presentment in the absence of an injunction prohibiting him from doing so.
100. Upon information and belief, Defendant Rausch will direct his agency’s
resources toward investigating the Plaintiff and anyone who expresses support for the
Plaintiff if Plaintiff again exercises his constitutional right to criticize law enforcement.
101. Upon information and belief, Defendant Rausch, acting in his official
capacity as the Director of and policymaker for TBI, demonstrated a clear and persistent
pattern of failing to discipline the TBI’s employees, agents, or officers for constitutional
violations, has policies that are insufficient to protect the constitutional rights of
individuals as those policies are applied and understood within the TBI, and/or actively
allows and participates in retaliation when citizens exercise their constitutionally
protected rights. This is evident from, among other things, the fact that every TBI
employee, agent, or officer involved in the tortious misconduct set forth in this Complaint
violated the Plaintiff’s clearly established First Amendment right to express an offensive
viewpoint regarding a matter of public concern. Each of those employees, agents, or
officers retaliated against Plaintiff and, upon information and belief, none of those
individuals was found to have violated a TBI policy thereafter. Each of those employees,
agents, or officers misused their positions as law enforcement agents by investigating
Plaintiff without reasonable articulable suspicion or probable cause that any crime had
occurred, and Director Rausch personally oversaw the implementation of these polices
and personally and expressly approved the actions of his employees in this matter.
102. Upon information and belief, Defendants Crouch, Rausch, and the City of
-24-

Dickson may or will continue to pursue the investigation and prosecution of the Plaintiff
regarding this specific instance of protected speech absent an injunction.
103. If the Plaintiff continues to be investigated and prosecuted, the Plaintiff will
necessarily suffer immediate and irreparable harm, harm resulting from incarceration,
and harm resulting from having to defend against a false and malicious prosecution.
104. Because Defendants Crouch, Rausch and the City of Dickson have
previously subjected the Plaintiff to an investigation, arrest, and a prolonged period of
incarceration as a result of his exercise of clearly established First Amendment rights, and
because the Plaintiff credibly fears that he will experience the same consequences if he
exercises his clearly established First Amendment rights in the same manner again, the
Plaintiff’s speech will be irreparably chilled in the absence of a permanent injunction.
105. Remedies available at law, such as monetary damages, are inadequate to
compensate the Plaintiff for the injury to his First Amendment rights.
106. Considering the balance of hardships between the Plaintiff and Defendants
Crouch, Rausch, and the City of Dickson, a remedy in equity is warranted.
107. The public interest would not be disserved and would be furthered by a
permanent injunction forbidding Defendants Crouch, Rausch, and the City of Dickson
from taking adverse action against the Plaintiff as a result of his exercise of clearly
established First Amendment rights, which Defendants Crouch, Rausch, and the City of
Dickson have made clear they do not and will not respect.
108. The Plaintiff is additionally and alternatively entitled to declaratory relief
under both federal law and Tenn. Code Ann. § 1-3-121 for the same reasons. In the event
that this Court finds that injunctive relief is not warranted, the Plaintiff is still entitled to
declaratory relief sufficient to inform state and local law enforcement that the Plaintiff’s
-25-

speech and expression are fully protected under the First Amendment and may not result
in the Plaintiff’s arrest, prosecution, or governmental retaliation of any kind.
VI. PRAYER FOR RELIEF
WHEREFORE, the Plaintiff prays for the following relief:
1. That process issue, and that the Defendants be required to appear and
answer this Complaint within the time required by law;
2. That the Plaintiff be awarded all compensatory, consequential, incidental,
and punitive damages to which he is entitled in an amount not less than $1 million;
3. That the Plaintiff be awarded all costs and discretionary costs of trying this
action;
4. That the Plaintiff be awarded his reasonable attorney’s fees pursuant to 42
U.S.C. § 1988(b);
5. That a jury of 12 be empaneled to try this cause;
6. That pre-judgment and post-judgment interest be awarded to the Plaintiff;
7. That permanent injunctive and declaratory relief issue; and
8. That the Plaintiff be awarded any and all further relief to which it appears
he is entitled.
Respectfully submitted,
/s/ Daniel A. Horwitz__________

Daniel A. Horwitz, BPR #032176
Lindsay B. Smith, BPR # 035937 (MDTN
admission pending)
HORWITZ LAW, PLLC
4016 Westlawn Dr.
Nashville, TN 37209
[email protected]
[email protected]
(615) 739-2888
Attorneys for Plaintiff

-26-

TENNESSEE BUREAU OF INVESTIGATION
901 R.S. Gass Boulevard
Nashville, Tennessee 37216-2639
(615) 744-4000
Facsimile (615) 744-4500
BILL LEE
TDD (615) 744-4001
DAVID B. RAUSCH
Governor Director
Daniel A Horwitz, Esq. Via Email Only

[email protected]
March 16, 2021
Dear Mr. Horwitz,
This letter is in reference to your public records request related to Joshua Garton. Please
be informed we are in receipt of payment; as such, please find enclosed the final
installment of records responsive to your request. Redactions were made pursuant to
Tenn. Code Ann. §10-7-504(a)(2)(A).
As mentioned in our previous communications, pursuant to the above-mentioned

statute, “All investigative records of the Tennessee Bureau of Investigation…shall be
treated as confidential and shall not be open to inspection by members of the public. The
information contained in such records shall be disclosed to the public only in compliance
with a subpoena or an order of a court of record.” As such, investigative records are not
considered public record and are not included herein. Additionally, records considered
confidential pursuant to attorney-client privilege are also not included.
This is the final installment of records. Therefore, your public records request is
considered fulfilled.
Sincerely,
Heather Thorne
Professional Standards Unit
Tennessee Bureau of Investigation
Case 3:21-mc-09999 Document 272-1 ACCREDITED

INTERNATIONALLY Filed 04/27/21 Page 1 of 136 PageID #: 13267
SINCE 1994
MEDIA RELEASE
"Jh111 !:J.11il1 ~h ,,/111111 11,(1•11/"-' 11r1r i 111,,,l'e>"''-' s11/(u,·''
FOR IMMEDIATE RELEASE CONTACT: JOSH DEVINE

JANUARY 22, 2021 PHONE: (615) 744•4295 (OFFICE)
EMAIL: [email protected]
LYLES MAN ARRESTED, CHARGED WITH DOCTORING 8c POSTING HARASSING PHOTOGRAPH
DICKSON COUNTY - Special Agents from the Tennessee Bureau of Investigation, working alongside investigators
from the Dickson Police Department, have arrested and charged a Lyles man accused of manufacturing and
disseminating a harassing photograph on social media.
At the request of 23 rd District Attorney General Ray Crouch, TBI Agents began investigating the origin of a
photograph that depicted individuals desecrating the grave of a deceased local law enforcement officer, Sgt.
Daniel Baker of the Dickson County Sheriff's Office. Agents subsequently visited Baker's gravesite this morning
and determined the photograph was digitally manufactured. Further investigative efforts led to the
identification of Joshua Andrew Garton (DOB 1-31-92) as the individual who manufactured the image and
distributed it on social media.
This afternoon, Agents arrested Garton and charged him with one count of Harassment and booked him into
the Dickson County Jail where, because of this charge and other, unrelated legal issues, he was being held on a
$76,000 bond.
###
AboutTBI
Since 1980, the Tennessee Bureau of Investigat ion has served as the state's independent, lead law enforcement agency. Every day,
focused on the agency's core values of truth, bravery, and integrity, the TBl's approximately 600 employees provide a variety of
advanced criminal and drug investigative, forensic, and criminal justice services to assist local, state, and federal law enforcement
partners, to fulfill the agency's promise, " That Guilt Sholl Not £scape Nor Innocence Suffer." Learn more about the TBI online at
tn.gov/tbi, and connect with the agency on Facebook, Twitter, and lnstagram at @TBlnvestigation.
Case 3:21-mc-09999 Document 272-1 Filed 04/27/21 Page 2 of 136 PageID #: 13268
Melany Martin
From: Leslie Earhart

Sent: Saturday, January 23, 2021 5:31 PM
To: David Rausch; Josh DeVine; Brad Nealon; Joshua J. Melton; Russ Winkler
Cc: Susan Niland; Keli McAlister
Subject: FYI - Dickson County case
Good evening,
I'm passing this article along in case you havent seen it.
I just wanted to make you aware.
https:ljwww.google.com/amp/s/lawandcrime.com/crazy/constitutionally-illiterate-tennessee-authorities-arrest-man-
for-posting-an-anti-police--meme-on-social-media/amp/
Take care,
Leslie
1
2/5/2021 Joshua Andrew Garton Unconstitutionally Arrested by TBI
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Kill Nancy Pelosi Told Alex Jones. Fire Him
'Constitutionally Illiterate' Tennessee Authorities

Arrest Man For 'Posting an Anti-Police Meme' on
Social Media
JERRY LAMBE Jan 23rd, 2021, 5:07 pm 91
Joshua Andrew Garton
Ad\lertisement
https://lawandcrlme.com/crazy/cons11tutlona11y-llllterate-tennessee-authorilies-arrest-man-for-posting-an-anti-police-meme-on-social-medla/ 1/19
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Spec and
Dick!
posting a fake photograph on social media depicting two men
urinating on the grave of a police officer who was tragically killed on
duty in 2018. The arrest, and subsequent bond demanded for his
(elease, outraged attorneys who were quick to point out that despite
being horrifically insensitive, the doctored photo in question is
undoubtedly protected under the First Amendment of the U.S.
Constitution.
"This morning, District Attorney General Ray Crouch requested the

TBI to investigate the origin of a troubling photograph, getting
considerable attention on social media, that seemed to depict
individuals desecrating the grave of a deceased local law
enforcement officer," the TBI tweeted Friday.
"Agents visited the gravesite and quickly determined the photograph

is not authentic. The TBl's work, however, continues and, to that end,
the Bureau would encourage anyone with information about who may
be responsible for manufacturing the image to call at 1-800-TBI-
FIND."
Tennessee Bureau of Investigation O @TBI... · Jan 22, 2021 "!I

This morning, District Attorney General Ray Crouch requested
the TBI to investigate the origin of a troubling photograph,
getting considerable attention on social media, that seemed to
depict individuals desecrating the grave of a deceased local
law enforcement officer. (1/2}
Tennessee Bureau of Investigation 0

@TBInvestigation
Agents visited the gravesite and quickly determined the

-'-'-•-'"''""""h :.- ,...,-♦ ....,,,-+h .... -+;,- Th,... TDl 1r ,.,.,... ..t, h_,.,,u,,., ...
)(
htlps:1/lawandcrime.com/crazy/conslitutlonally-illilerate-tennessee-authorifies-arresl-man•for-pqstlng-an-anll•pollce-meme--on-soclal•medlal 2(19
2/5/2021 Joshua Andrew Ganon Unconstitutionally Arrested by TBI
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news and updates.
Cancel
12:05 PM •Jan 22, 2021 from Franklin, TN <D
Adve,tisemel'l1
The bureau 's investigation led them to arrest Joshua Andrew Garton,
who they charged with Harassment and held on $76,000 bond.
Tennessee Bureau of Investigation O @TBI... • Jan 22, 2021 'W

Replying to @TBlnvestigation
Agents visited the gravesite and quickly determined the
photograph is not au,hentic. The TBl's work, however.
continues and, to that end, the Bureau would encourage
anyone with information about who may be respohSible for
manufacturing the image to call at 1-800-TBI-FIND. (2/2)
Tennessee Bureau of Investigation 0

@TBltwestigation
UPDATE: Investigative efforts, by TBI and the Dickson

Police Department today, have led to a Harassment
charge for a man accused of doctoring and posting a
hltpsi(/lawandcrime.com/crazy/constitutionally-llllterate-lennessee-authoritles-arrest-man-for-posling-an-antl-pollce-meme-on-social•media/ 3/19
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Cancel 1 •
7:01 PM • Jan 22, 2021 CD
But as Tennessee attorney Danlel A. Horwitz, who specializes In First

Amendment litigation noted, the specific conduct the TBI arrested
Garton for is simply ''not a crime."
"The First Amendment clearly ahd unmistakably protects this man's

right to post an offensive photo about a police officer," Horwitz told
Law&Crime. "The only people Who broke the law here were the police
officers and TBI agents who participated in this flagrantly
unconstitutional arrest."
Aaverttsement
"This is the photo that our constitutionally illiterate law enforcement

officers think is a crime to share," Horwitz tweeted, attaching a
screenshot of the picture that resulted in Garton's arrest.
Daniel A. Horwitz @Scot_Blog • Jan 23, 2021

Replying to @Scot_Blog
To the surprise of no one, @TBlnvestigation was involved as
..
Ix
hltps://lawandcrlme.com/crazy/constitutionally•illllerale•lennessee-authorities-arrest•man•for-posting-en-anti-police-meme-on•social•media/ 4/19
2/5/2021 Josh1Ja Andrew Garton Unconstitutionally Arrested by TBI
~ _____
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Daniel A. Horwitz
@Scot_Blog
This is the photo that our constitutionally illiterate law

enforcement officers think is a crime to share.
9:18 AM • Jan 23, 2021 CD
Additionally, under Tennessee law, harassing conduct requires

communications that result in a person being "frightened,
intimidated or emotionally distressed."
Asked how a deceased person could be the subject of criminal

harassment, Horwitz replied that the TBI and Dickinson Police
Department likely "set out to arrest [Garton] for one thing, quickly
hltps://lawandcrime.com/crazy/constllutionalfy-illlterate•tennessee-authorilies-arrest-man-for-posting-an-anti-polic&-meme-on-social-media/ 5/19
2/5/2021 Joshua Anorew Garton Unconstitutionally Arrested by TBI
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phot,
"Piss
Actvert1aement
Bryan Stephenson
@TNCrimDefense
Oh. The photo is from a band's album cover (10 years

ago). Next up, they're gonna rally Tipper Gore to help
them prosecute NWA, Ice T, & 2 Live Crew.
Daniel A. Horwitz @Scot_Blog

This is not a crime.• @dicksonpolice. Get yourselves a lawyer.
newschannelS.com/news/man-charg...
\ 2:03 PM • Jan 23, 2021 <D

X
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LIV h I IJ\V (. "
OffiC( Ca ncel
posti
precedent set in Miller v. California, New York v. Ferber, and Ashcroft
v. Free Speech Coalition. The TBI said all questions regarding the
charges should be directed to the District Attorney's office. Crouch's
office has not responded to the inquiry at the time of publication.
[image via TBI]
Have a tip we should know? [email protected]
Flied Under: ;r,., ,\me,, 111.:wl hnm·• ,rrnml Jo 1111 And, ·11• G,1rlo11 n 1y I 1uw,11 Tl I Tt•nne:,~ lnl ,wrul /\1 ,es.I
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Myth Buster • 11 days ago

This is the scary thing. Too many people out there claiming lo love their country and are willtng to
fight to maintain their Constitutional Rights; yet, have never read the Founding Document, don't
even care to, so almost complete ignorance of what's in It and are so willing to abuse others'
rights.
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BIROFISH1 950 · 11 \Jays sgo

yes this does not shock me!III!
I have been a victlm of false arrest!!!!!
yes when i was a youngster i did get into some tussles with the police but not since 1971
because I found Jesus!!!!!!!
but not even 20 years ago the police came right to my house!
yes right to my house!
they said my grandbaby was making a racket with the music!
no this was not true because i was sleeping
and no l do not like young folks music but when i was young the old timers did not like my music
either
about 1Ooops came right into my apartment without even having a warrant and that racket dld
wake me up
when i demanded my rights and demanded all the badge numbers they arrested me!!ll1!!11
now they did not beat me with those sand filled gloves like when i was a kid
but they took me to the lockup
I chanted and prayed all night
the captain let me go in the morning!!!!!!!!!
and no i did not even get one penny for the false arrest!l!lfl!
this sort of thing happens every day!ll!!!I!!!!
I )(
hllps://lawandcrime.com/crazyfconsUluUonatly•llliterate-tennessee--authoriUes•arresl-man-for-postlng-an-antl-pollce-meme-ol'}-SOOial•media/ 10/19
2/5/2021 Joshua Andrew Garton unconstitutionally Arrested by TBI
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and i did t
Dragonfattooz • 12 days.ago
Lucky guy. Make sure you invest some of your settlement money.
2" v • Reply • Share >
Ray Bluth · 12 days ago

I never knew the TBI was a thing. They react to their mistakes just like most LEO's, cover up or
scramble to find something they can charge this hapless fool with. We need LE O's but there
needs to be a better way to vet them.
2" ..., • Reply • Share >
malls1 ,+ Ray Bluth • 12 days ago • edited

Yeah every state has their own form of the FBI (TBf, CBI, NCSBl).Half the time Its part of
the State Police but the other half of the time. Its separate under the state AG.
2 " v • Reply , Share 1
taedlum_vitae • 12 days ego • edited

Loll Sweet payday coming to hlllbilly shooper.
3 " v • Reply • Share >
MindBender/Godspeed • 12 doys ago

Prosecutorlal misconduct. Too bad they have Immunity.
2 " v , Reply • Share >
Suplrist ..+ MlndBimder/Godspeeo • 12 days ago

The state doesn"t have immunity, this guy is gonna get paid!!
5 "' v • Reply • Share ,
MindBender/Godspeed ,+ Su~rist • 12 days ago

I hope you're right.
1 "' v • Reply • Share >
Mytllblaster • 12 (feys ago

Is It purely coincidental that TBI also means Traumatic Brain Injury?
2 "' v • Reply • Stiare >
BomperScruggs • 12 days ago

There are some first amendment lawyers salivating right now.
ZombiePoster99 • 12 days ago
Where are the right Wingers screaming about government overreach?

12 "' ..., • Reply • Share,
Ooc2222 ,+ ZomblaPoster99 • 12 days ago
Yeah, I was wondering that myself...... ! thought It was only leftle, commie, socialists, blah,
1, X l
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2/5/2021 Joshua Andrew Garton Unconstltutional!y Arrested by TBI
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defendants will have to 1 Cancel

time off from normal acti
unpaid time off from wor
19 "'- v • Reply • Share 1
Martha Smith ,+ NlghlriderXP1 • 12 days ago

"You can beat the rap, but you can't beat the ride."
3 " v • Reply • Share ,
spg210 ..+ NfghtriderXP1 • 12 days ago• edite.d

Right. Then the defendant will definitely file a lawsuit for 1st Amendment violation, false
arrest, harassment, etc., which he will certainly win. The cops will quickly settle out of
court to avoid the public humlllation from a judge.
Easy money.
6 ,., v • Reply • Share ,
Nlghtrldet"XP1 ..+ spg210 • 12 days 1190

You may not be able to understand this, but a lot of Innocent Americans get
arrested and jailed every single day, yet few ever win Civil laWsuits. They're lucky if
they can avoid conviction. And once you're arrested, It goes on your permanent
record even if you win acquittal or the case is dropped. Some States allow you to
remove criminal records from your permanent record, but that can be costly too...
11 " v • Reply , Share >
Nlghtflyer ..+ NlghlrlderXP1 • 12 days ago
Some states have limits on how much they pay to persons who are wrongly
Imprisoned, once they cut you loose, too.
AND if you're wrongly imprisoned and cut loose, you do not qualify for
rehab benefits and assistance given to parolees, which includes mental
health counseling and job training or job-finding.
NfghtriderXP1 ,+ Nightflyer • 12 days ago • edited

I was a victim of a false arrest a few years ago. I was assaulted by a couple
or teenagers while I was walking my dogs at a local park. I called 911. So
did they. And they convinced the officer that responded to their call that I
had assaulted them. There was plenty of evidence in their public record
that they had a history of doing what they did to me, but for whatever
reason, their responding officer believed them even though my record is
cleah. The officerthat responded to my 911 call claimed that he believed
me so I'm not really sure why I ended up being arrested. II cost $4500 to
hire lawyers for my defense. Eventually, my lawyer got the case dropped,
but the lawyer said that the police wouldn't go baok and arrest the kids for
what they did to me. I wlll never unders1and why not. I found out how easy
it is to be wrongly accused of a crime from that experience. We almost
need to be wearing body cams whenever in public to protect ourselves
from crap like that. The guy from the coupte had recently gotten out of jait.
The cops should have been abte to see that on their computers before they
picked sides ...
)(
https://lawandcrfme.com/crazy/consllluUonally-illlterate-tennessee-authorilies-arrest-man-for-posting-an-anll-police-meme-on-social-media/ 12/19
2/5/2021 Joshua Andrew Garton Unconstitutionally Arrested by IBI
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In
wil
my attacKers Knew now to play the game. The guy·s mother Is also a
sleezebalL She has a long criminal record yet for whatever reason, she
remains free. According to the mother, both kids did the same thing lo her.
Her protective orders against both of the kids was publicly viewable onllne,
which is why the cops should have been able to read them too...
3 ;,, " • Reply , Share ,
Collectivist ..+ Nightr1derXP1 • 11 days ago

Geezusl
2 ;,, v , Reply • Share 1
Julie G .+ NlghlrlderXP1 • 11 days ago

I could tell you some stories, but it would just get me steamed all over
again. I'll just say, the boys in my family are magnets for LEO harrassment,
maybe because they won't suffer fools no matter what unmarked unlfomis
they wear.
3 .,.., v • Reply • Share 1
NightriderXP1 ..+ Julfe G • 11 days ago • edited

Perhaps they need to start wearing body cams in public at all times too.
LEOs know that they can gel away with murder and they know how much a
false arrest can cost their victims. They often make up their own laws out of
whole cloth, then enforoe them. The only way for them to get away with it is
when no one pushes back. Qualifled immunity needs to stop and the many
bad apples In LE need to be sued and removed. It's hard to argue that
there are a lot of good apples in LE when few will stand up to the bad
apples...
6 "- v • Reply • Shere >
Manha Smith ..+ spg210 • 12 days a_go

I which he will certainly win.
Nope. The cops have qualified immunity, as do the prosecutors.
2 " v • Reply • Share 1
Micheal Pelt .+ Martha Smith • 12 days ago

The qualified Immunity Is criminal law, not civil law. Qualified immunity does
not protect them from being sued Into the dirt.
3 ;,, v • Reply • Share 1
dreamjoehfll2 ..+ Micheal Pell • 11 days ago

Your interpretation of qualified immunity is wrong. Qualified immunity
applies to civil law as well.
"Qualified immunity is a judicially created doctrine that shields government

officials from being held personally liable for constitutional vlo!alions-like
the right to be free from excessive police force-for money damages under
fc:af'io.ral l!a,u c:n lnr,n A~ the:) n ffit"'t::.lc:: tii,i nn♦ \linl::.to 'r-l~~rh, ~c::♦::ihli~hoti' •~-"''
hltps;//lawandcrime.corn/crazy/constilulionally-ililterate-tennessee-authorities-arrest-man-for..posllng-an•antl-police-meme-on-social•media/ 13/19
2/5/2021 Joshua Andrew Garton UnconsliMionally Arrested by TBI
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1 .
BetterThanFabuloso · 12 days ago
Looks like an insurrectionist
Lock him up
2 " v 6 • Reply • Share >
booyahcooservatlve · 12 days 1190

These cops acted worse than the protesters who got upset over cartoon Muhammad
5 r.. V · Reply • Share >
Smlles • 12 days ago

Law enforcement is corrupt from the top down.
IF 99% of law enforcement are "great people" ... they sure do seem to stand around and protect
a two tier justice system along with their blue wall.
frNelomar ,+ Smiles • 12 days 8!10

This is the basis of the BLM and aotifa protests.
10,,.. v • Reply · ShareJ
SmRes -+ FrNetomar • 12 days ago

You mean the same people that police did hardly anything to the past year and a
half they have been looting, rioting and burning things down ?
2 ,.. v 12 • Repty • Share >
2words1flnger ,+ Smlles • 11 <;lays ago

Well, we know wt,o you voted for now. Thanks for outing your..etf.
,.. V • Reply • Share ,
FrNelomar ..+ Smiles • 12 days ago

(shrugs) Those people were arrested, and prosecuted. They represent a
tiny fraction of the protesters. 100% of the insurrectionists who ehtered the
capitol committed felonies.
Perspectlve, please.
10 ,.. v 3 • Reply • Share >
Smile s -+ FrNelomar • 12 days ago

No. those people really weren't arrested as you claim and they certainty
were not prosecuted. Many of those that attacked a Federal Court House
for nearly a week es(;<lped ever being charged. Who was arrested for
settlng fi re to the historical church In DC ?
It has been widely seen on video officers opening gates and allowing
protesters Into the US Capitol. It will be interesting to see those videos
surface at trial.
2" v 8 • Reply • Share >
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~ ['-_ _L_I_,_' _r•_l _I_'.!_,·~
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1 " ; v • Reply • Share >
Satanlc_Hamster ..+Smiles• 12 days ago

You don't actually get any of your news outside of Brletbart, do you?
4 " ; v • Reply • Share >
BetterThanfabuloso • 12 days ego

You have to give credit to Kamala
Even In this #MeToo era, she proved that you can still rkk your way to the top
i .v 13 • Reply • Shere>
2 ,...
Bruce Rogle ..+ BetterThanFabuloso • 12 days ego

WIiiie Brown appointed her California Attorney General? Who knew.
1 " r v • Reply• Share>
ADDISON GAINOUS .+ BelterThanFabuloso • 12 days ago

My guess is you are Jealous because YOU would not be able to sleep your way through to
top garbage collector at the dump.
2" J v 1 • Reply • Share>
Lincoln Rhyme • 12 days ago
Top of Today
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Melany Martin
From: David Rausch

Sent: Sunday, January 24, 2021 6:05 PM
To: Joshua J. Melton
Cc: Russ Winkler; Brad Nealon
Subject: Re: [EXTERNAL] Fwd: Threats to law enforcement
Thank you
Sent from my iPhone
On Jan 24, 2021, at 5:16 PM, Joshua J. Melton <[email protected]> wrote:
Thank you Russ. I will continue to pass this along.
Thanks, Josh
Sent from my iPhone
On Jan 24, 2021, at 5:36 PM, Russ Winkler <[email protected]> wrote:
FYI
Begin forwarded message:
From: Joe Craig <[email protected]>

Date: January 24, 2021 at 4:30:32 PM CST
To: Russ Winkler <[email protected]>
Subject: Fwd: [EXTERNAL] Fwd: Threats to law enforcement
You may want to forward up the chain.
Sent from my iPhone
From: Andy Davis <[email protected]>

To: Ray Crouch <[email protected]>, Joe Craig
<[email protected]>
Subject: [EXTERNAL) Fwd: Threats to law enforcement
Sent from my iPhone
l
From: Christopher Lashlee

<[email protected]>
Date: January 24, 2021 at 4:26:13 PM
CST
To: All Sheriffs Office
<[email protected]>
Subject: Threats to law enforcement
Today we received several phone

patches through dispatch and through
the jail where individuals are making
threats against Law Enforcement
officers. These threats are stemming
from the arrest of Joshua Garton and
the posts he had put on social media.
There is a group that calls
themselves "The Watch Dog" and
another individual by the name of
William R. Lord that are making threats
towards us. They stated that it doesn't
matter if we are in uniform or not that
we better watch our backs and that
they would rather take care of us from
a distance. Be Vigilant and watch your
six.
Cpl. Lashlee
Confidentiality Notice:
The information contained in this email message and any attachment(s) ,s
the property of Dickson County
and may be protected by federal laws governing disclosure of private
information It is intended solely
for the use of the entity to whom this email is addressed. If you are not the
intended recipient,
you are hereby notified that reading, copying or distribution of this
transmission is STRICTLY PROHIBITED.
The sender has not waived any applicable privilege by sending the
accompanying transmission
If you have received this 1ransmission in error,
please notify the sender by returning and deleting
The information contained in this email message and
any attachment(s) is the property of Dickson County
and may be protected by federal laws governing
disclosure of private information. It is intended solely
for the use of the entity to whom this email is
2
addressed. If you are not the intended recipient,
you are hereby notified that reading, copying or
distribution of this transmission is STRICTLY
PROHIBITED.
The sender has not waived any applicable privilege by
sending the accompanying transmission.
If you have received this transmission in error,
please notify the sender by returning and deleting the
message and attachment(s) from your system.
All Email Scanned by Barracuda Spam/ Virus Filter
3
Melany Martin
From: Joshua J. Melton

Sent: Friday, January 22, 2021 12:19 PM
To: Brad Nealon; David Rausch
Subject FW: Revised Statement?
The below is what is going out to the media.
-----Original Message-----
From: Josh Devine <[email protected]>
Sent: Friday, January 22, 202111:52 AM
To: Joshua J. Melton <[email protected]>; Russ Winkler <[email protected]>
Subject: Revised Statement?
This morning, District Attorney General Ray Crouch requested the TBI to investigate the origin of a troubling photograph,
getting considerable attention on social media today, that seemed to depict individuals desecrating the grave of a
deceased local law enforcement officer.
Agents visited the gravesite this morning and quickly determined the photograph is not authentic. The TBl's
investigation, however, continues and, to that end, the Bureau would encourage anyone with information about who
may be responsible for manufacturing the image to contact the TBI at 1-800-TBI-FIND.
Sent from my iPhone. Please excuse any typos and brevity. Thanks!
Melany Martin
From: David Rausch

Cc: Brad Nealon
Subject: Re: Revised Statement?
Thank you
Sent from my iPhone
> On Jan 22, 2021, at 1:19 PM, Joshua J. Melton <[email protected]> wrote:
>
> The below is what is going out to the media.
>
> -----Original Message-----
> From: Josh DeVine <[email protected]>
> Sent: Friday, January 22, 202111:52 AM
> To: Joshua J. Melton <[email protected]>; Russ Winkler <[email protected]>
> Subject: Revised Statement?
>
> This morning, District Attorney General Ray Crouch requested the TBI to investigate the origin of a troubling
photograph, getting considerable attention on social media today, that seemed to depict individuals desecrating the
grave of a deceased local law enforcement officer.
>
> Agents visited the gravesite this morning and quickly determined the photograph is not authentic. The TBl's
>
> Sent from my iPhone. Please excuse any typos and brevity. Thanks!
1
Melany Martin
From: Brad Nealon

Cc: David Rausch
Subject Re: Revised Statement?
Thank you
Sent from my iPhone
> On Jan 22, 2021, at 1:19 PM, Joshua J. Melton <[email protected]> wrote:
>
> The below is what is going out to the media.
>
> -----Original Message-----
> From: Josh DeVine <[email protected]>
> Sent: Friday, January 22, 202111:52 AM
> To: Joshua J. Melton <[email protected]>; Russ Winkler <[email protected]>
> Subject: Revised Statement?
>
> This morning, District Attorney General Ray Crouch requested the TBI to investigate the origin of a troubling
>
>
1
Melany Martin
From: Josh DeVine

Sent: Friday, February 5, 2021 6:56 AM
To: Joe Crc~ig; Russ Winkler; Joshua J. M elton; Brad Nealon; David Rausch
Subject: Fwd: [EXTERNAL] Public Records Request Re: Joshua Garton
Good morning, all.

Jeanne's team has this, but I wanted to be sure you were immediately aware, as well.
Thanks,
Josh
Sent from my iPhone. Please excuse any typos and brevity, Thanks I
From: Josh DeVine <[email protected]>

Date; February 5, 2021 at 5:27:02 AM CST
To: TBI Public Records <T81.Pub1icRecords@tn .gov>
Cc: Jeanne Broadwell <[email protected]_ov>
Subject: Fwd: [EXTERNAL) Public Records Request Re: Joshua Garton
FYI
Sent from my iPhone. Please excuse any typos and brevity. Thanks I
From: Daniel Horwitz <[email protected]>

Date: February 4, 2021 at 11:40:13 PM CST
To: TBI Media <[email protected]>
Subject: [EXTERNAL} Public Records Request Re: Joshua Garton
...... Th1s 1s an EXTERNAL email. Ploase exercise caution. DO NOT open

attachments or click links from unknown senders or unexpected email - STS-
Security. "".-
Mr. OeVlne:
This is a public records request for any and all documents in your possession or any
other employee ofthe TBl's possession concerning or relating in any way to Joshua
Garton. The time period of this request is January 20, 2021 until the present. This
request includes all text messages, emails, and private or direct messages. If you claim
an exemption regarding any responsive record, please identity the basis for the claimed
exemption in detail.
A litigation hold notice to you and others will follow upon production.
All the best,
, ,.., I f
-Daniel Horwitz
Daniel A. Horwitz, Esq.

[email protected]
www.danielhorwitz.com
2
Melany Martin

Sent: Thursday, February 4, 2021 9:13 PM
To: Jeanne Broadwell
Cc: Brad Nealon; David Rausch; Russ Winkler
Subject: fwd: [EXTERNAL] Fwd: Litigation Hold Notice Re: Forthcoming J. Garton Lawsuit
Attachments: Litigation Hold Notice Re J. Garton Lawsuit (2-4 -21).pdf
Jeanne,
Please see the attached legal communication.
Thanks, Josh
Sent from my iPhone

To: "Joshua J. Melton" <[email protected]>, Russ Winkler <[email protected]>
Subject: Fwd: [EXTERNAL] Fwd: Litigation Hold Notice Re: Forthcoming J. Garton Lawsuit
Sent from my iPhone
From: Joseph Craig <[email protected]>

To: Joe Craig <[email protected]>
Subject: [EXTERNAL] Fwd: Litigation Hold Notice Re: Forthcoming J. Garton Lawsuit
"** Thi s is an EXTERNAL email. Please e)(erclse caution. DO NOT open

attachments or click links from unknown senders or unexpected email - STS-
Securlty, •~•
---------- Forwarded message ---------

From: Daniel Horwitz <daniel.a.horwitz@gmai l.com >
Date: Thu, Feb 4, 2021 at 2:19 PM
Subject: litigation Hold Notice Re: Forthcoming J. Garton Lawsuit
To: <TipsToTBl@tn .gov>, <fcraig(@curriberland.edu>, <[email protected]>,
<[email protected]>
Dear Forthcoming Defendant:
1
Please find a litigation hold notice attached.
All the best,
-Daniel Horwitz

daniel.a.honvir1:@g111ail.com
2
Melany Martin
From: David Rausch

To: Melany Martin
Attachments: Litigatio n Hold Not ice Re J. Garton Lawsuit (2-4-21 ).pdf
Mel, please check my email and print any records on this subject. Thank you.
Sent from my iPhone
From: "Joshua J. Melton" <[email protected]>

Date: February 4, 2021 at 10:13:11 PM EST
To: Jeanne Broadwell <[email protected]>
Cc: Brad Nealon <[email protected]>, David Rausch <[email protected]>, Russ Winkler
<[email protected]>
Jeanne,
Thanks, Josh
Sent from my iPhone

To: "Joshua J. Melton" <[email protected]>, Russ Winkler
<[email protected]>
Subject: Fwd: [EXTERNAL] Fwd: Litigation Hold Notice Re: Forthcoming J. Garton
Lawsuit
Sent from my iPhone

Subject: [EXTERNAL] Fwd: Litigation Hold Notice Re: Forthcoming J.
Garton Lawsuit
1
... This Is an EXTERNAL email. Please exercise caution. DO NOT
open attachments or click links from unknown senders or
unexpected email - STS-Security. ***
---------- Forwarded message --------

From: Daniel Horwitz <[email protected] rn>
Subject: Litigation Hold Notice Re: Forthcoming J. Garton Lawsuit
To: <[email protected]>, <jcraig@cu mberland.edu>,
<cop@d icksonpd.org>, <[email protected]>
All the best,
-Daniel Horwitz

[email protected]
www.danielhotwitz.com
2
To: Heather Thorne
Subject: FW: nn News Release • Dickson County - Joshua Garton
Date: Tuesday, February 16, 2021 7:26:44 PM
Attachments: 1ma9e001.png
1-22-21 Dickson Harassment <Joshua Garton).odr
Joshua Garton ,PNG

Sent: Tuesday, February 16, 2021 7:23 PM
To: Heather Thorne <Heather, [email protected]>
Subject: FW: TBI News Release - Dickson County - Joshua Garton
Another one with attachments
From: Josh Devine <losh [email protected]>

To: Joe Craig <[email protected]>; Russ Winkler <Russ [email protected]>
Cc: Ray Crouch (wrcrouch1@tndagcorg) <wrcrouch@toda€c org>
Subject: TBI News Release - Dickson County- Joshua Garton
LYLES MAN ARRESTED, CHARGED WITH DOCTORING & POSTING HARASSING PHOTOGRAPH
DICKSON COUNTY ~ Special Agents from the Tennessee Bureau of lnvestigatTon, working alongside
investigators from the Dickson Police Department, have arrested and charged a Lyles man accused
of manufacturlng and disseminating a harassing photograph on social media.
At the request of 23 rd District Attorney General Ray Crouch, TBI Agents beg;m invest igat ing
the origin of a phot ograph that depicted individuals desecrating the grave of a deceased local
law enforcement officer, Sgt. Daniel Baker of the Dickson County Sheriff's Office. Agents
subsequently visited Baker's gravesite this morning and det ermined the photograph was
digitally manufactured . Further investigative efforts led to the identification of Joshua And rew
Garton {DOB 1-31-92} as the individual who manufactured the image and distributed it on
social media .
This afternoon, Agents arrested Ga rton and charged him with one count of Ha rassment and
booked him into t he Dickson County Jail where, ~ecause of this charge and other, unrelat ed
legal issues, he was being held on a $76,000 bond.
###
Josh DeVine I Communications Director
Nashville, TN 37216
OFFICE: (61S} 744-4295
''To unsubscribe from the TBIMEDIA list, send an email to [email protected] and type
"Unsubscribe TBIMEDIA" in the message body. To subscribe to the TBIMEDIA list, send an email to
[email protected] and type "Subscribe TBIMEDIA" in the message body."
horn: Joshua J. Melton
To: Heather Thome
Subject: FW: Release - Please Review
Date: Tuesday, February 16, 202.1 7:30:15 PM
Attachments: imaae001.ona

Sent: Friday, January 22, 20215:40 PM
To: Russ Winkler <Russ.Winkler@tn .gov>; Joshua J. Melton <[email protected]>
Subject: Release - Please Review
Given the sensitivity of this one, could you please review this draft of the release.
Thanks,
Josh DeVine
DICKSON COUNTY - Special Agents from the Tennessee Bureau of Investigation have arrested and
charged a Lyles man accused of manufacturing and disseminating a harassing photograph on social
media.
At t he request of 23 rd District Attorney Genera[ Ray Crouch, TBI Agents began invest igating
the origin of a photograph that depicted individuals desecrating the grave of a deceased local
law enforcement officer, Sgt. Dan iel Baker of the Dickson County Sheriff's Office. Agents
subsequent ly visit ed Baker's gravesite this morning and determined the photograph was not
authentic. Further investigat ive efforts led to the identificat ion of Joshua Andrew Garton (DOB
1-31-92) as the individual who manufactured t he image and distributed it on social media.
Th is afternoon, Agents arrested Garton and charged him with one count of Harassment and
booked him into t he Dickson County Jail where, because of this charge and other, un related
Josh DeV1ne I Communications Director

Nashville, TN 37216
OFFICE: (615) 744-4295
From: JQShua J. Melton
To: Heather Thome
Subject: FW: Revised Statement?
•··•-Original Message-----
From: Russ Winkler <[email protected]>
To: Josh DeVine <[email protected]>
Cc: Joshua J. Melton <[email protected]>
Looks good to me.
> On Jan 22, 202 1, at 11:52 AM, Josh DeVine <[email protected]> wrote:
>
> This morning, District Attorney General Ray Crouch requested the TB! to investigate the origin of a troubling
>
>
To: Heather Thorne
Subject: FW: ReVised Statement?
Date: Tuesday, February 16, 2021 7:39: 11 PM
-···•Original Message•-·
To: Brad Nealon <[email protected]>; David Rausch <[email protected]>
Subject: FW: Revised Statement?
•----Original Message--•··
From: Josh DeVine <[email protected]>
Sent: Friday, January 22, 202 I 11: 52 AM
This morning, District Attorney General Ray Crouch requested the TB! to investigate the origin ofa troubling
photograph, gelling considerable attention on social media today, that seemed to depict individuals desecrating the
Agents visited the gravesite this morning and quickly determined the photograph is not authentic. The TBl's
To: Heather Jboroe
Subject: FW: [EXTERNAL) Fwd: Litigation Heid Notice Re: Forthcoming J. Garton Lawsuit
Attachments: Lit:lgation Hokl Notjce Be J Garton Lawsuit t2+21).odf

To: Jeanne Broadwell <[email protected]>
Cc: Brad Nealon <[email protected]>; David Rausch <[email protected]>; Russ Winkler
<[email protected]>
Subject: Fwd: [EXTERNAL] Fwd : Litigation Hold Notice Re: ForthcomingJ. Garton Lawsuit
Jeanne,
Thanks, Josh
Sent from my iPhone

To: "Joshua J. Melton" <[email protected]>, Russ Winkler
<[email protected]>
Subject: Fwd: [EXTERNAL] Fwd: litigation Hold Notice Re: Forthcoming J. Garton
Lawsuit
Sent from my iPhone

To: Joe Craig <Joe,Crajg@to gov>
Subject: [EXTERNAL] Fwd: Litigation Hold Notice Re: Forthcoming J.
Garton Lawsuit
u• This is an EXTERNAL email. Please exercise caution. DO NOT open

attachments or click links from unknown senders or unexpected email -
STS-Security. ~••
-------- Forwarded message--------
From : Daniel Horwitz <daniel.a.horwitz@gmail com>
Subject: Litigation Hold Notice Re: Forthcoming J. Garton Lawsuit
To: <[email protected]>, <[email protected]>,
<[email protected]>, <[email protected]>-
All the best,
~Daniel Horwitz
D aniel A. Horwitz, Esq.

[email protected]
www.daniethorwitz.com
To: Heather Thome
Subject: FW: [EXTERNA.L] Public Records Request Re: Joshua Garton
From: Josh DeVine <Josh.DeVine@tn .gov>

To: Joe Craig <[email protected]>; Russ Winkler <[email protected]>; Joshua J. Melton
<Joshua.J [email protected]>; Brad Nealon <Brad.Nealon@tn .gov>; David Rausch
<[email protected]>
Subject: Fwd: [EXTERNAL) Publlc Records Request Re: Joshua Garton
Good morning, all.

Jeanne's team has this, but I want ed to be sure you were immediately aware, as well.
Thanks,
Josh
Sent from my iPhone. Please excuse any typos and brev1ty. Thanks!
From: Josh DeVlne <Josh [email protected]>

Date: Febr uary 5, 202 1 at 5:27:02 AM CST
To: TBI Public Records <TBLPublicRecords@tn •.gov>
Cc: Jeanne Broadwell <JPanne Broadwell@tn gov>
Subject: Fwd: (EXTERNAL} Public Records Request Re: Joshua Garton
FYI
Sent from my IPhone. Please excuse any typos and brevity. Thanks!
Begin forw arded message:
From: Daniel Horwitz <d;miel a.horwitz@smajl,com>

Date: Febr uary 4, 2021 at 11:40:13 PM CST
To: TBI Media <TBI.Media@tn gay>
Subject: (EXTERNAL] Public Records Request Re: Joshua Garton
""" This is an EXTERNAL email. Please exercise caution. DO NOT open

attachments or click links from unknown senders or unexpected email -
STS-Security. """
Mr. Devine:
This is a public records request for any and all documents in your
possession or any other employee of the TBl's possession concerning or
relating in any way to Joshua Garton. The time period of this request is
January 20, 2021 until the present. This request includes all text
messages, emails, and privat e or direct messages. If you claim an
exemption regarding any responsive record, please identity the basis for
the claimed exemption in detail.
A litigation hold notice to you and others will follow upon production.
All the best,
-Daniel Horwitz

[email protected]
www.danielhorwitz com
f rom : Joshua J. Melton
To: Heather Thome
Subject: FW: [EXTI:RNALJ Fwd: Litigation Hold Notice Re: Forthcoming J. Garton Lawsuit
Attachments: L~ioatlon Hold Notice Re J. Garton Lawsuit f2-4·21\.Qdf

To: Joshua J. Melton <[email protected]>; Russ Winkler <Russ.Winkler @tn.gov>
Subject: Fwd: [EXTERNAL] Fw d: Litigatio n Hold Notice Re: ForthcomingJ . Garton Lawsuit
Sent from my iPhone
Begin forw arded message:
From: Josep h Cr aig <[email protected]>

To: Joe Craig <Joe Crais@tn gov>
Subject: [EXTERNAL] Fwd: Litigation Hold Notice Re: Forthcoming J. Garton Lawsuit
_. This is an EXTERNAL email. Please exercise caution. DO NOT open attachments

or click links from unknown senders or unexpected email• STS-Security. *0
- - - Forwarded message -·--·-

From: Daniel Horwit z <daoiela,[email protected]>
Subject: litigatio n Hold Notice Re: Forthcoming J. Garton Lawsuit
To: <[email protected]>, <[email protected]>, <[email protected]>,
<wrcrouch@tndasc,ore>
Pl ease find a litigation hold notice attached.
AJJ the best,
-Daniel Horwitz
Daniel A. H orwitz, Esq.

daniel a bw:witz@grnail com
www.daoieJhonvitz.com
From: Joshua J, Melton
To: Heather Thorne
Subject: FW: [EXTERNAL] Fwd: Litigation Hold Notice Re: Forthcomfng J. Garton Lawsuit
Attachments: Litigation Hold Notice Re J. Garton Lawsultr2+21).odf
From: Joe Crafg <[email protected]>

To: Joshua J.Melton<[email protected]>; Russ Winkler<[email protected]>
Sent from my iPhone
From: Joseph Craig <Jcra/[email protected]>

Subject: [EKTERNAL] Fwd: Litigation Hold Notice Re: Forthcoming J. Garton Lawsuit
...._. This is an EXTERNAL email. Please exercise caution. DO NOT open attachments
or click links from unknown senders or unexpected email • STS-Security. " 0
---------- Forwarded message -----

From : Daniel Horwitz <[email protected]>
Subject: Litigation Hold Notice Re: Forthcomfng J. Garton Lawsuit
To: <JipsJoJBl@tn.~ov>, <jccaig@cuo,berland edu>, <cop@dicksonpd,oce>,
<[email protected]>
Dear Forthcom ing Defendant:
Please find a litigation hold notice attached
All the best,
-Daniel Horwitz

daoiel a honvii-z@gmail mm
From: Joshua J Melton
To: Heather Thome
Subject: FW: L£ SenS1tlve
Date: Tuesday, February l6, 2021 7:28:58 PM
Attachments: ReoortsearchBmort Garton Complaint caus.x1sx

Sent: Monday, January 25, 202112:32 PM
To: Joe Craig <.Joe,[email protected]>; Joshua J. Melton <[email protected]>
Subject: FW: LE Sensitive
From: Michael Frizzell <[email protected]>

Sent: Monday, Jan uary 25, 2021 8:31 AM
To: Russ Winkler <RussWinkler@tn gov>
Subject: LE Sensitive
The attachment contains two worksheet tabs: 1) Dut y Officer Calls; 2) Syst em call logs.
We have received a total of 21 calls from 8 unique numbers, which began on Saturday, January 23rd .
M ichael D. Frizzel l
Tennessee Bureau of {nvestigation
Special Agent-in -Charge
Protective Services Unit
90J RS. Gass Blvd
Nashville, TN 37216
615.744.4000 - Main
615.744.4088 - Office
615.521.0811 - Cell
i
I,
I
8
l:1 Start ~ate· •. j -·:'1
~,f'?;:·, Duration .'!;J!i Extension.Used ·:,..~ Dialed/CU number }>:, ,(•.',~ Cali d~llnation · ;'!\ Call direction Call type Trui;I<~ Cost ,,~•:/~-.:1
l/23/2021 09:54:30 AM 00:08:30 3311 816-401-3585 KANSASCITY, MO INCOMING Incoming 601001 $0.00
~124! 202'1 08:ZS:42 :6.M 00!01:18. 3311. 5,03-805·80.78 P0fiTLANO, OR INCOMING lncomfng C?OlOOI $MO
1/24/2!)21 08:'27:00 AM 00,01:00 3:lll 503-805·8078 PORTLAND, 0R- INCOMING lrfCOinlr;lg 601001 $0.00
1-/24/21m 08:28; 36AM 00:01:24 3311 5(')3-805-elrl8 PORlLANO, OR INC0MING 111.comlng 601001 S0:00
1/24/202108:31:QOAM 00:01:00 3311 503-805'-8078 P<:>RMN[?, OR INCOMIN.G Incoming 601001 $0.00
l/24/2021 09:39:30 AM 00:05:30 3311 732-662-0310 METUCHEN, NJ INCOMING Incoming 601001 so,oo
1/24/2021 01:15:48 PM 00:03:l2 S510 586-610·3308 MT CLEMENS, Ml INCOMING Incoming 601001 $0-90
1/24/202101:17:00 PM 00:00:00 3911 586-610-3308 MT CLEMENS, Ml INCOMING Incoming 609021 $0,00
l/24/2021 01.:25:18 PM 00:01:42 3311 214-874-5605 DALLAS, TX INCOMING Incoming 601001 $0.00
l/24/2021 01:37:06PM 00:01:54 3311 214-874-5605 DALLAS, TX INCOMING Incoming 601001 $0,00
1/24/202103:48:30 PM 00:01:30 3311 209-263-7235 LODl,CA INCOMING Incoming 601001 $0.00
1/'1:4/,20'll 07:63:S6 P.M 00:0Ch24 3312 850-'148-8656 PENS~COLA, FL II\IC0MING lh§omlng. 60~001 $0.00
1{2~1021, 07:SS,42 Pr-,1 G0:0Ch18 3312 8,S0•7~!Wl656 P~NSACOLA, Fil INGOMING IOOO.mlr,ig 601002 .$0.QO
1/24/2021 07:S8:54PM 00:00100 301-1 850-748-86S6 PENSACOl!A, FL INCOMIJIIG lheomlns· 601001 $0.!)0
1/~4/,2021 O'l:59!00 PM 00:00:00 :m1 850-748-8656 f>ENSA.E:01:A, FL IN.GOMING Incoming 601001 So.oo
1/24/20M._07;5S-:OO PM 00:._00;00 3311 8S0-7ll8-81i56 PENS~CC!ll!A, ~L IN.C0MING lncoml;ng 6Ql001 $0.00
ll2f+/2.02-1 Q7;59:5~ PM 00:00:06 33-12 850.748-8656 PENSACOLA, FL INCdMING lhaomlng 601001 $0.00
l/24/2021 Q8100:00 PM oo:9g:09 3311 SS(),-748·8656 PEfilSACO~FL IN<i:0MING l~pmlng 601002 $0.00
~/24(2021 08:00:00 PM 00:00':00 3312 850-748-8656 PENSACOLA, FL INCOMING 1(1<:0mlng 601001 $0,00
a/24/2'021 08:00:00 PM ® 106:001 331J 850-748-8656 PEN.SMOLA, R INC::OMING Incoming 6.01001 St>.00
1/25/2.02112:06:18 AM 00:01:42 3312 267-393-4275 YARDLEY, PA INCOMING Incoming 601001 $0.00
To: Heather Thome
Subject: FW: [EXTERNAL] Fwd: Threats to law enforcement
From: Brad Nealon <[email protected]>

To: Joshua J. Melton <[email protected]>
Cc: Russ Winkler <[email protected]>; David Rausch <[email protected]>
Subject: Re: [EXTERNAL) Fwd: Threats to law enforcement
Thank the
Sent from my i Phone
Thanks, Josh
Sent from my iPhone
On Jan 24, 2021, at 5:36 PM, Russ Winkler <[email protected]> wrote:
FYI

To: Russ Winkler <Russ.Winkler@tn .~oy>
Subject: Fwd: [EXTERNAL] Fwd: Threats to law
enforcement
Sent from my iPhone
From: Andy Davis
<[email protected]>
To: Ray Crouch <[email protected]>, Joe
Craig <.Joe.Craig@tn gov>
Subject: [EXTERNAL] Fwd: Threats to law
enforcement
Sent from my iPhone

<[email protected]>
Date: January 24, 2021 at 4:26:13
PM CST
<[email protected]>
Subject: Threats to law
enforcement
Today we received several

phone patches through dispatch
and through the jail where
individuals are making threats
against Law Enforcement officers.
These threats are stemming from
the arrest of Joshua Garton and
t he posts he had put on social
media. There is a group that calls
William R. lord that are making
threats towards us. They stated
that it doesn't matter if we are in
uniform or not that we better
watch our backs and that they
would rather take care of us from
a distance. Be Vigilant and watch
your six.
Cpl. Lashlee
The information contained in this email message and any
attachment(s) is the property of Dickson County
and may be protected by federal laws governing disclosure of
private information It is intended solely
for the use of the entity to whom this email is addressed. If you
are not the intended recipient,
you are hereby notified that reading, copying or distribution of
this transmission is STRICTLY PROHIBITED.
The sender has not waived any applicable privilege by sending
the accompanying transmission
The information contained in this email
message and any attachment(s) is the property
of Dickson County
and may be protected by federal laws
governing disclosure of private information. It
is intended solely
addressed . If you are not the intended
recipient,
you are hereby notified that reading, copying
or distribution of this t ransmission is STRICTLY
PROHIBITED.
The sender has not waived any applicable
privilege by sending the accompanying
t ransmission.
please notify the sender by returning and
deleting the message and attachment(s) from
your system.
All Email Scanned by Barracuda Spam/ Virus

Filter
From: Joshua J, Melton
To: tteather n,orne
Subject: FW: [EXTERNAL) Fwd: Threats to law enforcement
Date: Tuesday, February 16, 2021 7: 29:40 PM
From: David Rausch <[email protected]>

To: Joshua J. Melton <Joshua.J [email protected]>
Cc: Russ Winkler <[email protected]>; Brad Nealon <[email protected]>
Than k you
Sent from my iPhone
Thanks, Josh
Sent from my iPhone
On Jan 24, 2021, at 5:36 PM, Russ Winkler <Russ.Wjnkler@to gov> wrote:
FYI

Date: January 24, 2021 at 4 :30:32 PM CST
Subject: Fwd: [EXTERNAL] Fwd: Threats to law
enforcement
Sent from my iPhone
From: Andy Davis
<ADAYIS@dicksonco1;1nty,net>
To: Ray Crouch <[email protected], Joe
Craig <[email protected]>
Subject: [EXTERNAL] Fwd: Threats to law
enforcement
Sent from my iPhone

<[email protected]>
Date: January 24, 2021 at 4 :26:13
PM CST
<AIISherjffsOfflce@dicksoncounty net>
Subject: Threats to law
enforcement
Today we received several

phone patches through dispatch
and through the jail where
individuals are making threats
against Law Enforcement officers.
These threats are stemming from
the arrest of Joshua Garton and
the posts he had put on social
media. There is a group that calls
William R. Lord that are making
t hreats towards us. They stated
that it doesn't matter if we are in
uniform or not that we better
watch our backs and t hat they
would rather take care of us from
a distance. Be Vigila nt and wa tch
your six.
Cpl. Lashlee
and may be protected by federal laws governing d1sdosure of
private information It is intended solely
for the use of the entity to whom this email is addressed If you
are not the intended recipient,
you are hereby notified that reading, copying or distribution of
this transmission is STRICTLY PROHIBI TED,
The sender has not waived any applicable privilege by sending
the accompanying transmission.
If you have received this transmission in error.
The information contained in this email
message and any attachment(s) is the property
of Dickson County
and may be protected by federal laws
governing disclosure of private information. It
is intended solely
addressed. If you are not the intended
recipient,
you are hereby notified that reading, copying
or distribution of this transmission is STRICTLY
PROHIBITED.
The sender has not waived any applicable
privilege by sending the accompanying
transmission.
please notify the sender by returning and
deleting the message and attachment(s) from
your system.
All Email Scanned by Barracuda Spam / Virus

Filter
To: Heather Thome
Subj ect: FW; [EXTERNAL] Fwd: Tllreats to law enforcement
Date : Tuesday, February 16, 2021 7;29:51 PM

Sent: Sunday, January 24, 20215:17 PM
Cc: Brad Nealon <[email protected]>; David Rausch <[email protected]>
Thanks, Josh
Sent from my iPhone
On Jan 24, 2021, at 5;36 PM, Russ Winkler <Russ Winkler@to ~v> wrote:
FYI
From: Joe Craig <Joe.Crajg@to,eov>

To: Russ Winkler <Russ.Wlnkler@tn,goy>
You may want to forward up the chain,
Sent from my iPhone

Date: January 24, 2021 at 4:28 :22 PM CST
To: Ray Crouch <[email protected]>, Joe Craig
<Joe [email protected]>
Subject: [EXTERNAL] Fwd: Threats to law enforcement
Sent from my iPhone

<[email protected]>
<AIISheriffsOffice@d icksoncou nty. net>
Today we received several phone patches

through dispatch and through the jail where
individuals are making threats against Law
Enforcement officers. These threats are
stemming from the arrest of Joshua Garton and
the posts he had put on social media. There is a
group t hat calls themselves "The Watch Dog"
and another individual by the name of William
R. Lord that are making threats towards us.
They stated that it doesn't matter if we are in
uniform or not that we better watch our backs
and that they would rather take care of us from
a distance. Be Vigilant and watch your six.
Cpl. Lashlee
The information contained in this email message and any attachment(s) is the
property of Dickson County
and may be protected by federal laws governing disclosure of private information It
is intended solely
for the use of the entity to whom this email is addressed. If you are not the
intended recipient.
you are hereby notified that reading. copying or distribution of this transmission is
STRICTLY PROHIBITED
The sender has not waived any applicable pnvilege by sending the accompanying
transmission
p ease notify the sender by returning and deleting
and may be protected by federal laws governing disclosure
of private information . It is intended solely
for the use of the entity to whom this email is addressed. If
you are not t he intended recipien t,
you are hereby notified that reading, copying or distribut ion
of this transmission is STRICTLY PROHIBITED.
The sender has not waived any applicable privilege by
sending the accompanying transmission.
please notify the sender by returning and deleting the
message and attachment(s) from your system .
To: Heather Thorne
Subject: FW: [EXTERNAL] fwd: Threats to law enforcement
Date: Tuesday, February 16, 1021 7:2,9: 58 PM

Sent: Sunday, January 24, 20214:36 PM
To: Joshua J.Melton<[email protected]>
Subject: Fwd: [EXTERNAL] Fwd: Threats to faw enforcement
FYI
Begin forwa rded message:

You may want to forward up the chain .
Sent from my iPhone

To: Ray Crouch <[email protected]>, Joe Craig <[email protected]>
Sent from my iPhone
From: Christopher Lashlee <[email protected]>

To: All Sheriffs Office <[email protected]>
Today we received several phone patches through dispatch
and through the jail where individuals are making threats
against Law Enforcement officers. These threats are
stemming from the arrest of Joshua Garton and the posts he
had put on social media. There is a group that calls
themselves "The Watch Dog" and another individual by the
name of William R. Lord that are making t hreats towards us.
They stated that it doesn't matter if we ar e in uniform or not
that we better watch our backs and that t hey would rather
take care of us from a distance. Be Vigilant and watch your
six.
Cpl. Lashlee
Confidentiality Notice.
The information contained in this email message and any attachment(s) is the property of Dickson
County
and may be protected by federal laws governing disclosure of private informatio1c It is intended solely
for the use o f the entity to whom this email is addressed . If you are not the intended recipient,
you are hereby notified that reading. copying or distribution of this transmission is STRICTLY
PROHIBITED
The sender h as not waived any applicable privilege by sending the accompanying transmission.
please notify th e sender by returning and deleting
Confident iality Notice:

The information contained in this email message and any attachment(s) is
the property of Dickson County
an d may be protected by federal laws governing disclosure of private
information. It is in tended solely
for the use of the entity to whom this email is addressed. If you are not
the intended recipient,
you are hereby notified that reading, copying or distribut ion of t his
The sender has not waived any applicable privilege by send ing the
accompanying transmission.
please notify the sender by returning an d deleting the message and
attachment(s) from your system.
All Email Scanned by Barr acuda Spam / Virus Filter
From : Joshua J. Melton
To: Heather JbQrne
Subject: FW: TBI News Release • Dickson County - Josnua Garron
Attachments: lroqgeQOl.png
1-22-21 Pl<:Ksoo Harassment Oosbua Garton),odf
Joshua Garton PNG
From: Josh DeVine <Josh.OeVine@tn .gov>

To: Joe Craig <[email protected]>; Russ Winkler<[email protected]>
Cc: Ray Crouch (wrcrouch@ tndagc.org) <[email protected]>
Subject: TBI News Release - Dfckson County - Joshua Garton
DICKSON COUNTY - Special Agents from the Tennessee Bureau of Investigation, working alongside
investigators from the Dickson Police Department, have arrested and charged a Lyles man accused
of manufacturing and disseminating a harassing photograph on social media.
At the request of 23 rd Dist rict Attorney General Ray Crouch, TBI Agents began invest igatfng
the origin of a phot ograph that depicted individuals desecrating the grave of a deceased local
law enforcement officer, Sgt. Daniel Baker of the Dickson County Sheriff's Office. Agents
subseq uent ly v isited Baker's gravesite this morning and determined t he photograph was
digitally manufactured. Further invest igat ive efforts led to the identification of Joshua Andrew
Garton (DOB 1-31~92) as t he individual who manufactured t he image and distributed it on
social media.
This afternoon, Agent s ar rested Garton and charged him with one count of Harassment and
booked him into the Dickson County Jail where, because of this charge and other, unrelated
Josh DeVine I Communications Dfrector

Nashville, TN 37216
OFFICE: (615) 744-4295
"To unsubscribe from the TBIMEDIA list, send an email to USTSERY@l ISISERV,TN,GOV and t ype
"Unsubscribe TBIMEDIA" in t he message body. To subscribe to the TBIMEDIA list, send an email to
LISTSERV@LISTSERV,TN.GQY and type "Subscr ibe TBIMEDIA" in the message body."
MEDIA RELEASE
"tht1t guilt sh11ll 110/ escape nor innm·ence suffer"
FOR IMMEDIATE RELEASE CONTACT: JOSH DEVINE

JANUARY 221 2021 PHONE: (615) 744-4295 (OFFICE)
EMAIL: [email protected]
DICKSON COUNTY- Special Agents from the Tennessee Bureau oflnvestigation, working alongside investigators
from the Dickson Police Department, have arrested and charged a Lyles man accused of manufacturing and
disseminating a harassing photograph on social media.
At the request of 23 rd District Attorney General Ray Crouch 1 TBI Agents began investigating the origin of a
This afternoon, Agents arrested Garton and charged him w ith one count of Harassment and booked him into
$76,000 bond.
AboutTBI
Since 1980, the Tennessee Bureau of Invest igation has served as the state's independent, lead law enforcement agency. Every day,
focused on the agency's core values of truth, bravery, and integrity, the TBl's approximately 600 employees provide a variety of
advanced criminal and drug lnvestlgative, forensic, and criminal justice services to assist local, state, and federal law enforcement
partners, to fulflll the agency's promise, "Thar Guilt Sholl Not Escape Nor Innocence Suffer.'' Learn more about the TBI online at
tn.gov/tbi, and connect with the agency on Facebook, Twltter, and lnstagram at @TBlnvestigation.
Brad >
Wed, Feb 3, 3 37 PM
There was a preliminary hearing

at which time he dismissed
Fri, Feb 5, 10:52 AM
Fri, Feb 5, 1:06 PM
Busy now?
Free now
Joe >
That sounds like a perfect plan!

I appreciate it!
Wed, Feb 3, 6:09 PM
Was any media present at the

hearing today? Just curious
No
Got ya . Thanks!
You have a minute

For a call
I will I'm just a second
Russ>
We are finished.
The judge dismissed the case.

Said nobody was victimized.
Well there you have it
•
New iMessage Cancel
To : Joe Craig
what all we have and what's

corning in if you have time
Mon, Jan 25, 9:36 AM
What time is the hearing today

Joe? Sorry to interrupt 1f 1t is
now
Not sure, will let you know
Can I call you?
Yes
f.l) 1essage
Rausch >
Wednesday 4 :41 PM
Josh advised that the

harassment charge
against the person in
Dickson County was
clisn1issecl today
follow ing a prelirninary
hearing. Apparently the
Judge cited there was
no victirn in the case
Wednesday 5:43 PM
That is not good.
Wednesday 6 :48 PM
-
•
Heather Thorne
From: Brad Nealon

Sent: Friday, February 19, 2021 2:38 PM
To: Heather Thorne
Subject: Fwd: Revised Statement?
Sent from my iPhone
From: Brad Nealon <[email protected]>

Date: January 22, 2021 at 2:01:40 PM EST
To: "Joshua J. Melton" <[email protected]>
Cc: David Rausch <[email protected]>
Thank you
Sent from my iPhone
-----Original Message-----
Sent: Friday, January 22, 202111:52 AM
This morning, District Attorney General Ray Crouch requested the TBI to investigate the
origin of a troubling photograph, getting considerable attention on social media today,
that seemed to depict individuals desecrating the grave of a deceased local law
enforcement officer.
Agents visited the gravesite this morning and quickly determined the photograph is not
authentic. The TBl' s investigation, however, continues and, to that end, the Bureau
would encourage anyone with informat ion about who may be responsible for
manufacturing the image to contact the TBI at 1-800-TBI-FIND.
1
Heather Thorne
From: Larissa Picard

To: Russ Winkler; Nathan Neese
Subject: Harassment Calls Regarding Joshua Garton
Good evening,
I just wanted to pass along that friends of Joshua Garton have been harassing TIES and UOs all day long with nonsense
calls. Day shift advised that they have called all day long cussing out whoever answered the phone. We have received
numerous of the same calls so far tonight. The calls are starting to come consecutively to where they are tying up both
main line phones. I know UOs have informed Mike Frizzell. I'm not sure if y'all can even do anything in this sit uation, but
I wanted to make y'all aware . Here are the numbers that have called since Kristen and I have been on shift:
5635141904
8507488656 (9 calls)
3148521996
3057839015
Larissa (J!icarrf
Crime Information CommunicationSpecia[ist
CJJS Support Center/ <Jl'ES
'Tennessee <Bureau oflnvestioatwn
e
901 ~S. (}ass (JJ[vd:
:Nasfwifle, 7:N.37216
Office: 615.144.4600
Larissa. [email protected]
Heather Thorne
From: Leslie Earhart

To: David Rausch; Josh DeVine; Brad Nealon; Joshua J. Melton; Russ Winkler
Cc: Susan Niland; Keli McAlister
Good evening,
https://www.google.com/amp/s/lawandcrime.com/crazy/constitutionally-illiterate-tennessee-authorities-arrest-man-
for-posting-an-anti-police-meme- on-social-media/amp/
Take care,
Leslie
1
Heather Thorne
From: Michael Frizzell

Sent: Monday, January 25, 2021 8:31 AM
To: Russ Winkler
Subject: LE Sensitive
Attachments: ReportSearchExport_Garton Complaint Calls.xlsx
The attachment contains two worksheet tabs: 1) Duty Officer Ca lls; 2) System call logs.
We have received a total of 21 calls from 8 unique numbers, which began on Saturday, January 23'd•
Michael D. Frizzell
Special Agent-in-Charge
Protective Services Unit
901 R.S. Gass Blvd
Nashville, TN 37216
615. 744.4000 - Main

615.744.4088- Office
615.521.0811 - Cell
Heather Thorne
From: Russ Winkler

To: Joe Craig
Subject: Re: [EXTERNAL] Joshua Garton Intake Sheet
Got it, thank you.
On Jan 22, 2021, at 5:36 PM, Joe Craig <[email protected]> wrote:
Thanks!
Sent from my iPhone
Sent from my iPhone
From: Andrew Pentecost <[email protected]>

Subject: [EXTERNAL] Joshua Garton Intake Sheet
Here you go sir. Let me know if you need anything else.
Corporal Andrew Pentecost

Badge~
2nd Shift Corrections
Dickson County Sheriffs Department
146 County Jail Drive
Charlotte,TN 37036
Wor~
Cell:-
The information contained in this email message and any attachment(s) is the property of
Dickson County
and may be protected by federal laws governing disclosure of private information. It is intended
solely
for the use of the entity to whom this email is addressed. If you are not the intended recipient,
you are hereby notified that reading, copying or distribution of this transmission is STRICTLY
PROHIBITED.
The sender has not waived any applicable privilege by sending the accompanying transmission.
If you have received this transmission In error,
1
The information contained in this email message and any attachment(s)
is the property of Dickson County
and may be protected by federal laws governing disclosure of private
information. It is intended solely
for the use of the entity to whom this email is addressed. If you are not
the intended recipient,
you are hereby notified that reading, copying or distribution of this
The sender has not waived any applicable privilege by sending the
accompanying transmission.
please notify the sender by returning and deleting the message and
attachment(s) from your system.
<.Joshua Garton Intake Sheet.pdf>
2
Heather Thorne
From: Russ Winkler

Sent: Saturday, January 23, 202 1 6:45 PM
To: Joe Craig
Subject: Fwd: FYI - Dickso n County case
From: "Joshua J. Melton" <[email protected]>

To: Russ Winkler <Russ.W [email protected]>
Subject: Fwd: FYI - Dickson County case
Sent from my iPhone
From: Leslie Earhart <[email protected]>

Date: January 23, 2021 at 6:30:49 PM EST
To: David Rausch <[email protected]>, Josh Devine <[email protected]>, Brad
Nealon <[email protected]>, "Joshua J. Melton" <[email protected]>, Russ
Winkler <[email protected]>
Cc: Susan Niland <[email protected]>, Keli McAlister <[email protected]>
Good evening,
I just want ed to make you aware.
ht t ps://www.google.com/am p/s/law andcrime.com/crazy/constitutio nally-illiterate-

tennessee-autho rities-arrest-man-for-post ing-an-anti-police-meme-on-social-
media/amp/
Take care,
Leslie
Heather Thorne
From: Russ Winkler

To: Josh DeVine
Subject: Fwd: [EXTERNAL] Joshua Garton Intake Sheet
Attachments: Joshua Garton Intake Sheet.pdf; ATT00001 .htm

To: Russ W inkler <[email protected]>
Cc: Nathan Neese <[email protected]>
Sent from my iPhone

Subject: {EXTERNAL) Joshua Garton Intake Sheet

Badgetllllllll
Charlotte,TN 37036
Wor~
Cell:- - -
The information contained in this ema il message and any attachment(s) is the property of Dickson County
and may be protected by federal laws governing disclosure of private information. It is intended solely
for the use of the entity to whom this email is addressed. If you are not the intended recipient.
you are hereby notified that reading, copying or distribution of this transmission is STRICTLY PROHIBITED.
The information contained in this email message and any attachment(s) is the property
of Dickson County
and may be protected by federal laws governing disclosure of private information. It is
intended solely
for the use of the entity to whom this email is addressed. If you are not the intended
recipient,
you are hereby notified that reading, copying or distribution of this transmission is
STRICTLY PROHIBITED.
The sender has not waived any applicable privilege by sending the accompanying
transmission.
please notify the sender by returning and deleting the message and attachment(s) from
your system.
2
Dickson County Sheriff's Office
•
Booking Intake Details
Page 1 of 3
Inmate Details
Full Name Intake Date Release Date Booking #:2021010166
GARTON, JOSHUA ANDREW 01/22/202115:35 Jacket#: 127590
Address: 9986 ROCKY POINT RD Pod/Cell/Bed: MD-2-MD-2 •

City/State: -BON AQUA, TN 37025 Date Of Birth: 01/31/1992
Home: Cell: Age At Intake: 28
Race: WHITE Sex: MALE
Height: 511 Weight 151
Eye Color: HAZEL Hair Color: BROWN
Complexion: LIGHT Build: AVERAGE BUILD
Facial Hair: GOATEE AND MOUSTACHE Glasses: NONE
Hair Style: Hair Length: SHORT
Marital; SINGLE # Of Children: 0
Religion: NO PREFERENCE Resident: RESIDENT
Gang Name: 'NONE
Indian Tribe: Days In Jail: 1
Ethniqity: NOT HISPANIC OR LATINO Property Location: PB
Intake / Release Info

Intake By: Intake Date: 01 /22/2021 15:35 Reason: ARREST WARRANT
Searched By:
Finger Print By: Finger Print#:
Dressed Out By:
Release By: Release Date: Reason:
Released OR By: Weight Out: 0
Bonded Out By:
Inmate ID
SSN: SID#: DL#:
DOC/Prison : FBI#: ICE:
Military: NO Branch: Rank:
Local ID: Student: other ID:
Classification
Inmate Classification: PRETRIAL MISD Suicide Watch: No Violent At Intake: No
PREA Classification: Escape Risk: No Weekender: No
Registered Offender: No Tusty: No Mental Illness: No Felon No
Housing Classification: State Parolee: No Federal Prisoner: No Indigent: No
Protective Custody: No Local Parolee: No Restrict Commissary: No
Work Crew:
Place Of Birth
NCIGPOB: UNITED STATES OF AMERICA Citizen: Yes
Print Date: Jan 22 2021 - 17:27:05 Dickson County Sheriffs Office, OFFENDER: JOSHUA GARTON
Powered by iSOMS(c) Driven by Values Booking_ Details APENTECOST
Dickson County Sheriffs Office
•
Page 2 of 3
Inmate Details
GARTON, JOSHUA ANDREW 01/22/202115:35 Jacket #: 127590
Country Of Citizenship UNITED STATES Foreign Born: No
Place of Birth: NASHVILLE TN Homeless: No
lntrepreter Re quired:
Initial Arrest Information

Arrest Date: 01/221202115:47 Case#:
Arrest Location: DICKSON POLICE DEPARTMENT Mittimus#:
Vehicle Info: N/A
Arrest Agency: TENNESSEE BUREAU OF INVESTIGATION
Arrest Officer: ASAC TBI CRAIG Badge:
Bond Information
Charge Count: 1 Computed Bond: 76000.00 Override Bond:
Charge Information
Charge Code Statute Ordinance Court Court Date Dept Add On
39-17-.308 39-17-308 G 04/20/202113:00
Description: HARASSMENT (NON-VERBAL THREAT)
Detail: HARASSMENT
Arrest Dept: TBI Badge:
Arrest Officer: Bond: 76000.00
Bond: cc Bond Text: CASH/COMMERCIAL
Warrant#: NO NUMBER GIVEN Docket#:
Employer
Employer: UNEMPLOYED
Address: Length :
City/State: Phone:
Occupation: UNEMPLOYED
Emergency Contact
.:.:
N=a=m=e_ _ _ _ _ _ _ _ _ _ _ _ _R~e~la=tl~o~n=
sh~l_
p_ _ _ _ _ _ _ _ __
, NO CONTACTS
Race: SSN: Home Phone:

Sex: DL#: Work Phone:
Occupation: Cell Phone:
Print Date: Jan 22 2021 - 17:27:05 Dickson County Sheriffs Office, OFFENDER: JOSHUA GARTON
Powered by iSOMS(c) Driven by Values Booking_Details APENTECOST
Dickson County Sheriffs Office
•
Page 3 of 3
Inmate Details
GARTON, JOSHUA ANDREW 01/22/202115:35 Jacket#: 127590
Intake Phone Call

Phone#: Notes:
Education History
Level Of Education Juvenile Highest Grade Enrolled Prior To Arrest Can Read/Write Special Ed
12TH GRADE NO 12TH
Request Educational Services:
Last School Attended: KENWOOD HIGH
Inmate Signature I Date Officer Signature / Date
Print Date: Jan 22 2021 - 17:27:05 Dickson County Sheriff's Office, OFFENDER: JOSHUA GARTON
Powered by iSOMS(c) Driven by Values Booking_Details APENTECOST
Heather Thorne
From: Russ Winkler

To: Josh Devine
Subject: Fwd: [EXTERNAL) Joshua Garton Intake Photo

Subject: Fwd: [EXTERNAL] Joshua Garton Intake Photo
Sent from my iPhone

Subject: [EXTERNAL] Joshua Garton Intake Photo

Badge4IIIII
Charlotte,TN 37036
Wor~
Cell:--
The information contained in this email message and any anachment(s) is the property of Dickson County
and may be protected by federal laws governing disclosure of private information, It is intended solely
for lhe use of the entity lo whom this email is addressed If you are not the intended recipient,
you are hereby notified that reading , copying or distribution of this transmission is STRICTLY PROHIBITED.
If you have received this transmission In error,
of Dickson County
intended solely
1
recipient,
The sender has not wa ived any applicable privilege by sending the accompanying
transmission.
your system.
All Email Scanned by Barracuda Spam / Virus Filter
2
3
Heather Thorne
From: Russ Winkler

Subject: Fwd: [EXTERNAL) Fwd: Threats to law enforcement
FYI

Date: January 24, 2021 at 4 :30:32 PM CST
Subject: Fwd: (EXTERNAL] Fwd: Threats to law enforcement
Sent from my iPhone

To: Ray Crouch <[email protected]>, Joe Craig <[email protected]>
Sent from my iPhone
From: Christopher Lashlee <[email protected]>

To: All Sheriffs Office <[email protected]>
Today we received several phone patches through dispatch and

through the jail where individua ls are making threats against law
Enforcement officers. These threats are stemming from the arrest of
Joshua Garton and the posts he had put on social media. There is a
group that calls themselves "The Watch Dog" and another individual by
the name of William R. Lord that are making threats towards us. They
stated that it doesn't matter if we are in uniform or not that we better
1
watch our backs and that they would rather take care of us from a
distance. Be Vigilant and watch your six.
Cpl. Lashlee
The information contained in this email message and any attachment(s) is the property of Dickson County
for the use of the entity to whom this email is addressed. If you are not the intended recipient.
please notify lhe sender by returning and deleting
of Dickson County
intended solely
recipient,
transmission.
your system.
All Email Scanned by Barracuda Spam / Virus Filter
2
Heather Thorne
From: Russ Winkler

To: Leslie Earhart
Subject: Re: FYI - Dickson County case
10-4
On Jan 23, 2021, at 5:30 PM, Leslie Earhart <[email protected]> wrote:
Good evening,
https:Uwww.google.com/amp/s/lawandcrime.com/crazy/constitutionally-illiterate-tennessee-
authorities-arrest-man-for-posting-an-anti-police·meme-on-social-media/amp/
Take care,
Leslie
Heather Thorne
From: Joe Craig

To: Russ Winkler
Subject: Re: [EXTERNAL) Joshua Garton Intake Sheet
Thanks!
Sent from my iPhone
Sent from my iPhone


Badgetllllllll
Charlotte,TN 37036
Wor~
Cell:-
tor the use of the entity lo whom this email is addressed. If you are not the intended recipient,
you are hereby notified that reading , copying or distribution of this transmission is STRICTLY PROHIBITED.
of Dickson County
intended solely
1
recipient,
transmission.
your system.
<Joshua Garton Intake Sheet.pdf>
2
Heather Thorne
From: Josh DeVine

To: Joe Craig; Russ W inkler
Cc: Ray Crouch (w [email protected])
Subject: TBI News Release - Dickson County - Joshua Garton
Attachments: 1-22-2 1 Dickson Harassment (Joshua Garton).pdf; Joshua Garton.PNG
DICKSON COUNTY - Special Agents from the Tennessee Bureau of Investigation; working alongside investigators from the
Dickson Police Department, have arrested and charged a Lyles man accused of manufacturing and disseminating a
harassing photograph on social media .
At the request of 23rd District Attorney General Ray Crouch, TBI Agents began investigating the origin of a
This afternoon, Agents arrested Garton and charged him with one count of Harassment and booked him into
$76JOOO bond.
###
Josh DeVlne I Communications Director

Nashville, TN 37216
OFFICE: {615) 744-4295
"To unsubscribe from the TBIMEDIA list, send an email to LISTSERV@LISTSERV,TN.GOV and type "Unsubscribe
TBIMEDIA" in the message body. To subscribe to t he TBIMEDIA list, send an email to LISTSERV@ LISTSERV.TN.GOV and
type "Subscribe TBIMEDIA" in the message body."
1
Heather Thorne
From: Joe Craig

To: Russ Winkler
Cc: Nathan Neese
Attachments: Joshua Garton Intake Sheet.pdf
Sent from my iPhone


Badge#IIII
Charlotte,TN 37036
Wor~
Cell:- -
for lhe use of the entity to whom this email is addressed. If you are not the intended recipient,
The sender has not waived any applicable privilege by sending the accompanying transmission
County
PROHIBITED.
please notify the sender by returning and deleting the message and attachment(s) from your system.
1
2
Heather Thorne
From: Joe Craig

To: Russ Winkler
Subject: Fwd: [EXTERNAL] Joshua Garton Intake Photo
Sent from my iPhone

Subject: [EXTERNAL] Joshua Garton Intake Photo

Badge4IIIIIII
Dickson County Sheriff's Department
Charlotte,TN 37036
Wor~9
Cell:-
and may be protected by federal laws governing disclosure of private Information. It is intended solely
you are hereby notified that reading, copying or distribution of this transmission is STRICTLY PROHIBITED
County
PROHIBITED.
please notify the sender by returning and deleting the message and attachment(s) from your system.
All Email Scanned by Ba rracuda Spam/ Virus Filter
1
•
11 Verizon? 3 :54 AM
2 People
Thanks, Russ. Does Joe have a

8 mug, by chance.
I > ,11 tvlr 11 1 111
Thank you
,,II Verizon~ 3:55 AM I■ I•

8 mug, by chance.
Thank you
Sent you both a draft of the

release if you wouldn't mind to
take a quick look. Tried to keep
it sterile.
I added a mention of Dickson

Police, since we worked with
8 them on it.
Heather Thorne
From: Russ Winkler

Sent: Friday, January 22, 2021 10:49 AM
To: Susan Niland
Subject: Re: [EXTERNAL] NCS Question
We just got the request.
On Jan 22, 2021, at 10:48 AM, Susan Niland <[email protected]> wrote:
Hey Russ,
We've had a couple media inquiries asking whether this is anything we've been requested to get
involved in7 Not sure what that would be7
Thanks, Susan
Sent from my iPhone
From: WTVF Newsroom <[email protected]>

Date: January 22, 2021 at 10:31:49 AM CST
To: TBI Media <[email protected]>
Subject: [EXTERNAL] NCS Question
Hello,
Has the TBI been requested to investigate an image posted on Facebook of two
individuals urinating on Dickson Co. Sgt. Daniel Bakers grave?
<image.png>
Thank you,
Emerald
Assignment Desk
WTVF-TV NewsChannel 5 Network
474 James Robertson Pkwy
Nashville, TN 37201
615.248.5281
Follow us on Twitter at @NCS
Scripps Media, Inc., certifies that its advertising sales agreements do not discriminate on
the basis of race or ethnicity. All advertising sales agreements contain nondiscrimination
clauses.
., Verizon~ 3:50 AM
2 Peop.le >
,Messauc
Fri, J,m 22, ·11 4 3 AM
.Jo sh Dev irn~
Sent you a brief statement for

review. Tried to keep it no
nonsense, but if you think we
need to be more strongly
worded, let me know...
39-17-308 (4) (a)
(4) Communicates with another person by

any method described in subdivision (a)(1),
without legitimate purpose:
(A) (I) With the malicious intent to

frighten, intimidate or cause emotional
distress; or
(ii) In a manner the defendant knows,

or reasonably should know, would frighten,
intimidate or cause emotional distress to a
similarly situated person of reasonable
sensibilities; and
Thanks. Sent a revised

statement proposal to you
• I t I t ..
" Verizon? 3:51 AM L■ J,
2 People >
39-17-308 (4) (a)

any method described in subdivision (a)(1 ),
(A) (I) With the malicious intent to

distress; or

similarly situated person of reasonable
sensibilities; and
I 1, I

both. Let me know what you
G think when you have a chance.
Fri, Jan 22, 3:2 0 PM
a1II Verizon~ 3:52 AM
•
2 People >
F- ri, Jan 22, 3 20 PM
· They have identified the person

who posted that they have
interviewed him and he
confessed. They are
transporting him to booking
now and we're going to book
him in for harassment. As soon
as I get more details on his
name and his descriptors I'll get
that to you.
Ok thank you. Can I call you or

are you tied up?
.... FaceTime
Czi ll Ended
You can call
,1 Verizon? 3:54 AM
2 People

8 mug, by chance.
I , ,11 tvlr 11 1 111
Thank you
,,II Verizon~ 3:55 AM I■ I•

8 mug, by chance.
Thank you
Sent you both a draft of the

release if you wouldn't mind to
take a quick look. Tried to keep
it sterile.
I added a mention of Dickson

Police, since we worked with
8 them on it.
New iMessage
If you haven't noticed this

thing is getting crazy and I
feel tomorrow will be nuts.
Whafs getting crazy. I

haven't heard
Threats, to Leos, Ray

Facebook blown up
threats
Go to Burton Staggs
Facebook and nick beres
No kidding. He'll I haven't

heard
New iMessage
The affidavit will be

released tomorrow and I'm
sure I will be public enemy
number one
Ray is taking most today

but TBI and Sheriffs office
has been called numerous
times
Who are they threatening

and why
Law enforcement because

we violated his 1st
amendment rights
\
l. - "
New iMessage
He has a right to post.

That doesn't mean there
are no consequences
Buckle up
Ten4.
See you in the morning
I can't find the Burton

Staggs
Google Burton Staggs

Facebook
New iMessage
Reading all that, it looks

like there is a bunch of
people who support the
arrest. More support it
than not it looks like
Yes, you have to be aware

of the nuts who may show
up. Chief Lewis said FD
got a call from same group ,
that called us and SO and
threatening to burn PD the
FD
You may recall the contt011erslal case lrom last month:
A man was accused of manufacturing and
dlssemfnaling a haranlng photograph on social 1TM1dla.
The Image showed the desecration of the grave or
Dl11kson County Sheriff's Sgt. Daniel Baker who was
ldliotl In the llne of duly.
TBI agents visited the gravesite and determined the
photograph was dlgitally mani.,tactured.
Still 23rd District Attorney General Ray Crouch had
Josh~o Garton arrested and charged with a crime.
Gerton•s lawyer today argued his arrest was a clear
vlolatlon of his 1st Amendment rfght of free speech.
The G,neral Snsioos judge today heard arguments
lrom both sides and agreed.
Whlle the court conceded the image was hurlful
diAturbing and tasteless, the judge dismissed the case
as protected under Gatton's right to freedom of
expression und8f the 1st Amendment.
Garton spent ten days In tail waiting for his day in court.
And his lawyer saY5 the district attorney may now face
a federal civil rights lawsuit for wrongful arrest.
MORE TO COME ON THtS STORY.
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lt'sn,i~ 19l,,1 , t,11, , ,,,,1 :f,;htr•,l(!I ,,,,,. ! •• 1 ·• ..... , .. ,t ,,,.,.. ~" " "'l>ffl,ll'flr~
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... , ,t
New iMessage Cancel
To: Brad Nealon, David Rausch
Sat, Jan 23, 6:29 PM
David Rausch
We only investigate the

incident. Charges come from
the DA.
That's what we are doing our

best to reinforce. • -
a • (__ 1M_es_sa_ge_ _ _ _•__

----
~
• • •
·
New iMessage Cancel
David Rausch
We still need to educate

everyone on what our role is.
Although it is in our name.
David Rausch a
The trolls will do what trolls do. •
It appears they a1n d the lawyers
forget that there are surviving
family members who have
rights as well. My assessment
is these are the same folks who
called the insurrection at the
Capitol free speech.
Brad Nealon a
The world needs a little love •
SI 0) (_1M_es_sa_ge_ _ _ _
--
a_~
• • •
·
New iMessage Cancel
Although it is in our name.
David Rausch o
The trolls will do what trolls do. •
It appears they and the lawyers
forget that there are surviving
family members who have
rights as well. My assessment
is these are the same folks who
called the insurrection at the
Capitol free speech.
Brad Nealon 0
The world needs a little love •
David Rausch Q
Some Bernie Meme love!! •
Iii 0) (1Message
------
4'
• • •
·
, II Verizon ~ 2:47 PM
<
2 People >
iMessage
Fri, Jan 22, 11:43 AM
Sent you a brief statement for

review. Tried to keep it no
nonsense, but if you think we
need to be n1ore strongly
worded, let me know.. .
Russ Winkler
39-17-308 (4) (a)

any method described in subdivision (a)(1 ),
(A) (i) With the malicious intent to

distress; or

similarly situated person of r easonable
sensibilities; and
Thanks. Sent a revi sed
, Verizon~ 2:47 PM
<
2 People >

both. Let me know what you
think when you have a chance.
Fri, Jan 22, 3:20 PM

Russ Winkler
They have identified the person

who posted that they have
interviewed him and he
confessed. They are
transporting him to booking
now and we're going to book
him in for harassment. As soon
as I get more details on his
name and his descriptors I'll get
that to you.
Josh Melton
Ok thank you. Can I call you or

are you tied up?
• Russ Winkler
fJI) ____________
Message
• ,,,,
..._
·••
•• Verizon~ 2:47 PM
<
2 People >
You can call
Fri, Jan 22, 5: 04 PM

Russ Winkler
m
,1 Verizon~ 2:48 PM
<
2 People
Josh Melton
Thank you
· S~nt -you:_ both a :dra t of the

release if ;you woul n't mind to
take a quick look. T ied to keep
it sterile.
I added a mentio of Dickson

Police, since we orked with
them on it. 18-
m 0) 0_1M_a_ge_ _ _ _
•
Jan 24, 2021, 7:38 PM
https ://www.facebook.com/mike.altri
Mike
Just showing my respect to deputy Damel Baker

from the I.I C.. Wll(;OUntfp(' hc:l'd, -p-•tment
Tennessee Bureau oflnvestigation
Thanks for messaging us. We try to be as resp onsive as possible, but this account isn't monitored
24/7. We'll get back to you soon.
Mike
Fucking dun1b asses lmfao taxpayers are gonna be real happy with you in a couple of months
**
January 25, 2021 at 7:47 AM
next time instead of violating someone’s first amendment rights and instead of having to pay
them the minimum $80k he will get from your dumbass actions, maybe hire someone like me
that would tell you with rational non pork thinking that it was a bad move. now the dudes gonna
get a payout and the taxpayers will be held respond for it. clown fucking organization y’all run
January 25, 2021 at 11:20 AM
Thanks for sharing your comments.
**
Winston
https://www.facebook.com/Ottothewatchdog
A Tribute to Our Heros. https://www.youtube.com/watch?v=S_bUu009JyI
Man Arrested for Offensive Facebook Post - Otto Calls - Dickson Tennessee - The Roof is on
Fire
Well... the System isn't gonna FUCK itself...Dickson Police Department - (615) 446-
5403Tennessee cops' arrest of man over disrespectful photoshop draws wide ...
youtube.com
Thanks for messaging us. We try to be as responsive as possible, but this account isn't monitored
Thanks for sharing. Hope you have a good day. Most sincerely, TBI Public Information Office
**
Travis
come arrest me you pieces of shit, I want a settlement too
Thanks for sharing.

Sent by Leslie Earhart
Travis
Lol get a REAL job
Thanks for sharing.

Travis
https://www.facebook.com/mythiesis
The TBI is a terroristic organization that infringes on the rights on the citizens of Tennessee.
Please investigate.
**
Jan 25, 2021, 12:09 PM
Donovan
Donovan
Now come arrest me, fascist piggy. I could use the lawsuit money.
Thanks for sharing. Hope you have a good day.

Sent by Susan Rogers
**
Jan 25, 2021, 2:06 PM
Donovan
https://www.facebook.com/donovan.whitford.9
Hope you learn to read so you know what's in that Constitution you took an oath to uphold.
Thanks for sharing.

Donovan
You gonna' come arrest me now, pig?
Or not?
Is that dead cop still dead by the way?
Jan 25, 2021, 7:31 PM
Donovan
fascist pigs
'
What's the matter, piggy? Why haven't you arrested me yet? Look how many counts you have of
me breaking the law by posting the picture.
Jan 25, 2021, 10:12 PM
Thanks for sharing.

Jan 25, 2021, 11:36 PM
Donovan
Funny how you'll arrest one person and thank another for the same picture.
Jan 26, 2021, 8:48 AM
Donovan
Nazi
Jan 26, 2021, 10:31 AM
Donovan
Why won't you arrest me for the same fucking image?
I'm posting it everywhere
**
Jan 26, 2021, 9:18 AM
Michael
https://www.facebook.com/michaeljohngraz
Wow, you guys really started your own shit show by violating the meme guys rights. I hope you
lose your immunity and have to open your own wallets. The taxpayers shouldn't have to be
responsible for your blatant disregard for the constitution.
Hi Michael, thanks for your message. We are not here right now and our account isn't monitored
24/7, but we'll get back to you soon!
Jan 26, 2021, 10:55 AM
**
Jan 26, 2021, 4:42 PM
Grayson
https://www.facebook.com/grayson.mcdonald.37
Did you hapless assholes really arrest a man for a picture? I have the same picture I made of me
pissing on the same CD cover with that dead officers head on it, PLEASE come arrest me for it,
I’d like to be rich too. You guys are garbage butthurt snowflake oathbreakers. Get it together.
**
Jan 28, 2021, 10:27 AM
Michael
https://www.facebook.com/michael.masucci.96
hello is it true that you're arresting people over memes now, I saw some memes I'd like someone
arrested for
Sent by Susan Rogers
**
Feb 4, 2021, 6:30 AM
Mike
https://www.facebook.com/mike.methena
Another agency full of NAZI TYRANT THUGS. Your agents violated the Wortmans
Constitutional rights and your NAZI THUG director thinks that it’s okay.
Feb 4, 2021, 9:28 AM
Thanks for sharing. Hope you have a good day. Most sincerely, TBI Public Information Office
**

Complaint of Joshua Garton and Exhibits 1 4

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Complaint of Joshua Garton and Exhibits 1 4

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IN THE UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF TENNESSEE

Court and the Jury as follows:

1. In January 2021, Plaintiff Joshua Garton was investigated and arrested by

Deputy Daniel Baker from the #dicksonpolicedepartment.”

Case 3:21-mc-09999 Document 272 Filed 04/27/21 Page 1 of 26 PageID #: 13241

3. Internal correspondence among the Defendants obtained through a public

featured Mr. Garton’s mugshot and the fact of his arrest.

good.” Another Defendant complained—correctly—that: “We are finished.” This action

Case 3:21-mc-09999 Document 272 Filed 04/27/21 Page 2 of 26 PageID #: 13242

5. Plaintiff Joshua Garton is a transient resident of Rutherford County who

was investigated, arrested, prosecuted, and incarcerated by a joint law enforcement

taskforce for disrespecting law enforcement. He is a citizen of Tennessee and may be

contacted through his counsel.

6. Defendant W. Ray Crouch is the current District Attorney General for

was professionally obligated to comply with the Constitution, to maintain a minimum

acting in “knowing disregard of obligations” or engaging in “a systematic abuse of

prosecutorial discretion.” Upon information and belief, Defendant Crouch failed to

comply with these obligations by directing law enforcement to investigate, retaliate

37015-1613, or wherever he may be found.

7. Defendant David Rausch is the current Director of the Tennessee Bureau of

Case 3:21-mc-09999 Document 272 Filed 04/27/21 Page 3 of 26 PageID #: 13243

insurrectionists. Defendant Rausch is sued in his individual capacity regarding specified

Kingston, Tennessee, 37763-3160, or wherever he may be found.

upon information and belief, Defendant Nealon participated in the Defendants’

5252, or wherever he may be found.

information and belief, Defendant Winkler participated in the Defendants’ investigation

at his residence located at 725 Heritage Rd., Lebanon, Tennessee, 37087-6547, or

wherever he may be found.

10. Defendant Joshua Melton is the Assistant Director of the Criminal

Investigation Division of the Tennessee Bureau of Investigation. In that role, upon

information and belief, Defendant Melton participated in the Defendants’ investigation

Case 3:21-mc-09999 Document 272 Filed 04/27/21 Page 4 of 26 PageID #: 13244

11. Defendant Joseph Craig is an Assistant Special Agent in Charge at the

Greenbrier, Tennessee, 37073-5165, or wherever he may be found.

related disciplines. In that role, Defendant Vallee participated in the Defendants’

Ave. 1, Old Hickory, Tennessee, 37138-3813, or wherever he may be found.

13. Defendant Donald Arnold is a Captain in the Dickson Police Department

of the City of Dickson, to falsely arrest, maliciously prosecute, and unconstitutionally

Case 3:21-mc-09999 Document 272 Filed 04/27/21 Page 5 of 26 PageID #: 13245

37055-4068, or wherever he may be found.

14. Defendant City of Dickson, Tennessee, is a Tennessee municipality. The

established constitutional rights, as it did here. The City of Dickson is a political

East Walnut Street, Dickson, TN 37055.

III. JURISDICTION AND VENUE

action pursuant to 28 U.S.C. §§ 1331 and 1343(a).

Court pursuant to 28 U.S.C. § 1391(b)(1).

Case 3:21-mc-09999 Document 272 Filed 04/27/21 Page 6 of 26 PageID #: 13246

As a result of the Defendants’ unconstitutional and tortious misconduct, the Plaintiff

20. In January 2021, the Plaintiff pseudonymously posted the following

political message and accompanying fake photograph—otherwise known as a “meme” 2—

on Facebook, a social media website:

Case 3:21-mc-09999 Document 272 Filed 04/27/21 Page 7 of 26 PageID #: 13247

paired with the Plaintiff’s commentary regarding a matter of public concern. 3

22. Defendant Crouch was offended by the Plaintiff’s meme because it

disrespected a deceased member of local law enforcement. Accordingly, Defendant

23. Through herculean investigative work—including “TBI agents visit[ing] the

gravesite of Baker”—the Defendants “quickly determined the photograph [was] not

image in “a few seconds.”

desecrating a grave. Believing that disrespecting law enforcement still merited

“consequences,” though, the Defendants—acting in concert with one another—resolved

Case 3:21-mc-09999 Document 272 Filed 04/27/21 Page 8 of 26 PageID #: 13248

by [Defendant] Vallee identified [Plaintiff] Joshua Garton as the individual possibly