Ryan:
Thank you for your courage and serving your country.

declare under penalty of perjury that the following is true and correct:

I am 38 years old and a retired United States Army veteran. During my military service, I survived three separate explosive blasts. As a result of those injuries, I was medically retired from the Army through the Department of Veterans Affairs disability evaluation process. I suffer from a traumatic brain injury (“TBI”), along with lasting cognitive impairments related to my military service.

I am also required to register as a sex offender under Florida law. I have made every effort to comply with all registration requirements and understand that failing to comply can result in serious criminal penalties, including felony charges.

Because of my service-connected TBI, I receive specialized treatment through the James A. Haley Veterans’ Hospital in Tampa, Florida. The James A. Haley VA is one of only a handful of VA Polytrauma Rehabilitation Centers in the United States and provides specialized treatment that is not available at most VA facilities. My treatment includes intensive cognitive rehabilitation and residential programs designed to improve my memory, executive functioning, independence, and overall quality of life.

The recent changes to Florida law have created a serious hardship for me. My understanding is that the James A. Haley Veterans’ Hospital’s residential rehabilitation program is located within 1,000 feet of Swim Academy: Tampa (University), a public swimming facility. Because of this proximity, I fear that attending the residential program could place me in violation of Florida’s residency or location restrictions under the new law. Additionally, if I remain in the residential program for three calendar days or more, I understand that I may be required to report that location as a temporary address. Because failure to comply with these requirements can result in felony prosecution, I am afraid of making an unintentional mistake while attempting to receive medically necessary treatment.

As a result, I have become reluctant to participate in the weekly residential and in-person rehabilitation programs recommended by my VA medical providers. These programs are specifically designed to treat the cognitive impairments caused by my service-connected traumatic brain injury. Instead of focusing on my recovery, I find myself worrying that seeking treatment could expose me to criminal liability.

My traumatic brain injury already affects my memory, concentration, and executive functioning. These cognitive impairments make it more difficult for me to navigate complicated legal requirements. The possibility that I could unintentionally violate a reporting requirement because of my disability makes the situation even more frightening.

I served my country honorably until I was medically retired because of injuries sustained in combat. Today, I feel as though I must choose between receiving specialized medical treatment for those service-connected injuries and risking felony prosecution under Florida law. That is a choice no disabled veteran should have to make.

I respectfully submit this declaration so the Court may understand the concrete hardship these legal changes have imposed on me. My concerns are real, immediate, and personal. They directly affect my ability to obtain medically necessary treatment, continue my rehabilitation, and improve my cognitive functioning after the injuries I suffered while serving my country.