Clements’ brief filed today
Below is Louis Clements’ brief, filed today in the Middle District of Florida. Clements’ attorneys did a fantastic job of highlighting how Florida’s residency restrictions tip the scales, making registration tantamount to confinement. Special thanks to all who submitted declarations in this case and Professor Socia for his expert report on the residency restrictions in Florida.
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I read the entire filing and it is very well researched and written. I wish Mr. Clements well with his effort.
Does anyone doubt that if they passed a law saying DUI felons could not live within 2500 of a place at sold liquor, it would be shot down so fast. But not SO’s. lol
This should be called ‘Geographical Incarceration’ as well as residency restriction.
The state of florida is trying to banish all registrants and while I don’t believe they can successfully push all the registrants out, they can make it so onerously hard to stay within florida that you will want to move out of it.
This is really sad.
May God grant favor to Clements in this brief. Amen.
Good luck to Mr. Clements!! A win for you is a win for the rest of us. I would love to have my son come back home and not live 17 hours away!!!!!
Thanks Louis, thoughts and prayers. We are pulling for a win. And proud of those who are brave enough to have their names thrown around in the news and on lawsuits.
“In Miami-Dade County, a total of 615,840 of residential units (72.6%) are off-
limits to sex-offender registrants by virtue of the statewide residency restrictions
only. App. 15 (Socia Report 9). After applying Miami-Dade County’s own ordinance, which imposes an additional 2,500’ exclusion zone around schools, a total of
772,293 (91.1%) residential units are off limits.
In Broward County, under just the statewide restrictions, a total of 640,405
residential units (70.1%) are barred for registrants. App. 15 (Socia Report 9). Similar
to Miami-Dade, Broward County imposes an additional 2,500’ buffer zone around
schools, daycares, parks, playgrounds, and public-school bus stops. App. 16 (Socia
Report 10). When accounting for the county restrictions, a total of 881,943 residential units (96.5%) are unavailable to registrants like petitioner. App. 15 (Socia Report
9). Dr. Socia’s estimates do not include bus stops, however, because that data is not
readily available. Id. at 10. It is likely that inclusion of bus stops would increase the
percentage of restricted residential parcels and residential units.”
I wonder how much more they would find if we could of not been restrained by “For purposes of this litigation, it was infeasible for Dr. Socia to map the multi-
farious restrictions imposed by each of Florida’s 67 counties and 412 incorporated
municipalities.”
However what he did find shows what we all been staying they are systematically targeting us to force us out of the state acre by acre at a time under the guise of a civil regulatory scheme.
Sounds like we’re under house arrest to me.
Once you leave what ever residence you establish you best have a bus ticket out of the state because they are quickly closing off areas.
Great summary with sad specs and details. Why doesn’t @FAC et al decide to pay the good Dr for his time and effort to complete the study as your suggest for a complete and total FLA picture? Would it be that much more, especially if it was a study project for a few select students (grad or undergrad) for grade? I believe this needs to be seriously considered because it can pay dividends with the data analyzed and published for legal situations which could benefit from the conclusions.
these 3 are good. The two they picked show extreme restrictions, which is not gonna get any worse than that (thanks Ron Book but that another story) also the county he is in which still shows over a 50 percent restriction. The more evidence of county’s we show examples of , I believe that they could fight faults with the examples we give. Plus why waste money you don’t have.
now the state is gonna try to prove why that it’s ok to have almost all the city rope off and stay we are not under custody.
I think this is a good strategy with the resources that are available. It’s also a novel approach for our situation a lot of people are not sure how this will play out so it might be hard to raise funds. I was just happy FAC pick up the case when I saw his 11th decision come back down.
Understand. It is a good doc in the end that ought to open the court’s eyes on the matter and move it forward to opining eventually.
Doesn’t matter your name will remain on the Florida registry forever. Honestly I suggest you move out of Florida to fight the laws.
KR