To the FBI, Illinois State Police, and Christian County officials reading this:

You’ve visited this site. You know the truth. You’ve seen the documents. You’ve read the timeline. You’ve had every opportunity to correct course—and instead, you’ve doubled down.

This is your notice: I will not be silenced. I will not be intimidated. And I will not stop until justice is done.



********

Todd E. Daugherty
800 West Main Cross Street
Taylorville, IL 62568
[XXXXXXXXXXXXX]
[XXXXXXXXXXXXXXXX]

[July 4th, 2025]

VIA CERTIFIED MAIL – RETURN RECEIPT REQUESTED

To:
Christian County State’s Attorney’s Office
101 S. Main Street
Taylorville, IL 62568

Taylorville Police Department
108 W. Vine Street
Taylorville, IL 62568

Illinois State Police
801 South 7th Street, Suite 1000-S
Springfield, IL 62703

RE: NOTICE OF CLAIM PURSUANT TO 745 ILCS 10/8-102

Dear Sir or Madam:

Please take notice that pursuant to 745 ILCS 10/8-102 of the Illinois Local Governmental and Governmental Employees Tort Immunity Act, I, Todd E. Daugherty, hereby provide formal notice of my intent to bring a civil action against the following entities and individuals:

- The City of Taylorville and the Taylorville Police Department
- Christian County and the Christian County State’s Attorney’s Office
- The Illinois State Police
- Individual officers and agents including but not limited to Officer Christian Nelson, Officer Dorwart, and others to be named

Nature of the Claim:

This claim arises from a series of unlawful and unconstitutional actions taken against me beginning in March 2018 and continuing through the present. These include, but are not limited to:

- False arrest without probable cause
- Execution of a search warrant that was later quashed
- Unlawful search and seizure of personal property
- Malicious prosecution
- Withholding of exculpatory evidence in violation of *Brady v. Maryland*
- Intentional infliction of emotional distress
- Abuse of process
- Denial of due process and right to counsel

Date and Location of Occurrence:

- Initial arrest: March 17, 2018, Taylorville, IL
- Search and seizure: March 21, 2018, at 800 W. Main Cross, Taylorville, IL
- Continued prosecution and re-arrest: September 14, 2022, and ongoing

### Damages:

I am seeking damages in the amount of $35,000,000 for the harm suffered, including but not limited to:

- Loss of liberty
- Emotional distress
- Reputational damage
- Legal expenses
- Property loss
- Punitive damages for egregious misconduct

Please preserve all records, communications, and evidence related to this matter, including internal communications, search warrants, affidavits, discovery logs, and correspondence with federal agencies.

Sincerely,
Todd E. Daugherty
[Signature]
July 4th, 2025

I was stripped of my public defender over my objection, and now the court expects me to retain private counsel with $6,250—an amount that is categorically insufficient for a case of this complexity. Once that money is gone, I’m expected to go into debt to defend myself against a prosecution built on a general search warrant—a type of warrant that has been unconstitutional since at least Marron v. United States, 275 U.S. 192 (1927) and reaffirmed in countless rulings since.

I am being forced to choose between liberty and legal representation. This is not justice—it is a constructive denial of my Sixth Amendment right to counsel, a violation of my Fourth and Fourteenth Amendment rights, and a direct affront to Article I, Sections 2, 6, 8, and 12 of the Illinois Constitution.

The State of Illinois is not just prosecuting me—they are defending a warrant that never should have existed and doing so while denying me the means to fight back. That is not due process. That is systemic abuse.

Quote:ASA/LD; DEFENDANT WITH PD SENGER; OVER OBJECTION OF DEFENDANT, PD SENGER ALLOWED TO WITHDRAW DUE TO IRRECONCILABLE DIFFERENCES WITH DEFENDANT; STATE DOES NOT OBJECT; HOWEVER, STATE OBJECTS TO APPT OF "NEW APPOINTED COUNSEL" SINCE DEFENDANT HAS $12,500 IN BOND PENDING (COURT APPROVES A BOND ASSIGNMENT OF AT LEAST 1/2); DEFENDANT ORDERED TO ATTEMPT TO FIND NEW, PRIVATELY RETAINED COUNSEL; FAWC/COUNSEL STATUS SET FOR JULY 24, 2025 AT 8:30 A.M.

“The State's continued use of illegally obtained evidence, the withdrawal of appointed counsel under suspicious timing, the denial of substitute public defense, and the de facto unavailability of private counsel combine to create a systemic violation of Defendant’s Sixth and Fourteenth Amendment rights. This has resulted in a constructive denial of counsel, access to justice, and a fundamentally fair proceeding.”

Todd Daugherty ~ June 2025

People of the State of Illinois v JOHN T. McCAVITT 2019 (Illinois Court of Appeals)

http://160.32.227.211/3170830.pdf


All property seized must be returned to its rightful owner once the criminal proceedings have terminated. Cooper v. City of Greenwood , 904 F.2d 302, 304 (5th Cir. 1990) ; United States v. Farrell , 606 F.2d 1341, 1343 (D.C. Cir. 1979) ; United States v. LaFatch , 565 F.2d 81, 83 (6th Cir. 1977). When no charges are pending against an individual, any of the individual's property in the possession of the State should be immediately returned to him. See People v. Jaudon , 307 Ill. App. 3d 427, 447, 241 Ill.Dec. 76, 718 N.E.2d 647 (1999) (citing 725 ILCS 5/108-2 (West 1996) ); People v. Jackson , 26 Ill. App. 3d 845, 848-49, 326 N.E.2d 138 (1975). After criminal proceedings conclude, the government has no right to retain a defendant's property.  United States v. Rodriguez-Aguirre , 264 F.3d 1195, 1213 (10th Cir. 2001). "t is fundamental to the integrity of the criminal justice process that property involved in the proceeding, against which no Government claim lies, be returned promptly to its rightful owner." United States v. Wilson , 540 F.2d 1100, 1103 (D.C. Cir. 1976).

People v. McCavitt, 438 Ill. Dec. 102, 109 (Ill. App. Ct. 2019)

“The major, overriding problem with the description of the object of the search—“any or all files”—is that the police did not have probable cause to believe that everything on the phone was evidence of the crime of public indecency.” United States v. Winn, 79 F. Supp. 3d 904, 919 (S.D. Ill. 2015)

The Supreme Court put the scope of such a wholesale seizure in perspective by explaining that it “would typically expose the government to far more than the most exhaustive search of a house.” Riley v. California, ––– U.S. ––––, 134 S.Ct. 2473, 2491, 189 L.Ed.2d 430 (2014) (emphasis in original).

United States v. Winn, 79 F. Supp. 3d 904, 919 (S.D. Ill. 2015)

"I can't see a court allow a general search warrant, after all they are unconstitutional, and it's been well established by the courts that they are unconstitutional. (Marron v. United States, 275 U.S. 192 (1927) all the way to (Groh v. Ramirez, 540 U.S. 551 (2004)" (Daugherty 2024)

“At the same time, the warrant authorized the wholesale seizure of all electronic devices discovered in the apartment, including items owned by third parties. In those circumstances, we conclude that the warrant was unsupported by probable cause and unduly broad in its reach.” United States v. Griffith, 867 F.3d 1265, 1270-71 (D.C. Cir. 2017)


“Although we pay "great deference" to the judge's initial determination of probable cause, a warrant application cannot rely merely on "conclusory statement[s]." Id. at 236, 239, 103 S.Ct. 2317 (citing Nathanson v. United States , 290 U.S. 41, 54 S.Ct. 11, 78 L.Ed. 159 (1933) ).” United States v. Griffith, 867 F.3d 1265, 1271 (D.C. Cir. 2017)


The Supreme Court has long distinguished between arrest warrants and search warrants. See Steagald v. United States , 451 U.S. 204, 212-13, 101 S.Ct. 1642, 68 L.Ed.2d 38 (1981). An arrest warrant rests on probable cause to believe that the suspect committed an offense; it thus primarily serves to protect an individual's liberty interest against an unreasonable seizure of his person. Id. at 213, 101 S.Ct. 1642. A search warrant, by contrast, is grounded in "probable cause to believe that the legitimate object of a search is located in a particular place." Id. Rather than protect an individual's person, a search warrant "safeguards an individual's interest in the privacy of his home and possessions against the unjustified intrusion of the police."
United States v. Griffith, 867 F.3d 1265, 1271 (D.C. Cir. 2017)

Regardless of whether an individual is validly suspected of committing a crime, an application for a search warrant concerning his property or possessions must demonstrate cause to believe that "evidence is likely to be found at the place to be searched." Groh v. Ramirez , 540 U.S. 551, 568, 124 S.Ct. 1284, 157 L.Ed.2d 1068 (2004). Moreover, "[t]here must, of course, be a nexus ... between the item to be seized and criminal behavior." Warden, Md. Penitentiary v. Hayden , 387 U.S. 294, 307, 87 S.Ct. 1642, 18 L.Ed.2d 782 (1967).
United States v. Griffith, 867 F.3d 1265, 1271 (D.C. Cir. 2017)


The Fourth Amendment requires that warrants "particularly describe" the "things to be seized." U.S. Const. amend. IV. That condition "ensures that the search will be carefully tailored to its justifications, and will not take on the character of the wide-ranging exploratory searches the Framers intended to prohibit." Garrison , 480 U.S. at 84, 107 S.Ct. 1013. Consequently, a warrant with an "indiscriminate sweep" is "constitutionally intolerable." Stanford v. Texas , 379 U.S. 476, 486, 85 S.Ct. 506, 13 L.Ed.2d 431 (1965). We will hold a warrant invalid when "overly broad." United States v. Maxwell , 920 F.2d 1028, 1033-34 (D.C. Cir. 1990).
United States v. Griffith, 867 F.3d 1265, 1275 (D.C. Cir. 2017)


The warrant's overbreadth is particularly notable because police sought to seize otherwise lawful objects: electronic devices. Courts have allowed more latitude in connection with searches for contraband items like "weapons [or] narcotics." Stanford , 379 U.S. at 486, 85 S.Ct. 506 (internal quotation marks omitted). But the understanding is different when police seize "innocuous" objects. See Andresen v. Maryland , 427 U.S. 463, 482 n.11, 96 S.Ct. 2737, 49 L.Ed.2d 627 (1976). Those circumstances call for special "care to assure [the search is] conducted in a manner that minimizes unwarranted intrusions upon privacy." Id. ; see also 2 LaFave, Search & Seizure § 4.6(d).
United States v. Griffith, 867 F.3d 1265, 1276 (D.C. Cir. 2017)

Anything on the internet could be considered social media (Packingham v North Carolina - US Supreme Court 2017)

The Court held that social media—defined broadly to include Facebook, Amazon.com, The Washington Post, and WebMD—is a "protected space" under the First Amendment for lawful speech (Packingham v North Carolina - US Supreme Court 2017)

42 U.S. Code § 1983 - Civil action for deprivation of rights

Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory or the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress, except that in any action brought against a judicial officer for an act or omission taken in such officer’s judicial capacity, injunctive relief shall not be granted unless a declaratory decree was violated or declaratory relief was unavailable. For the purposes of this section, any Act of Congress applicable exclusively to the District of Columbia shall be considered to be a statute of the District of Columbia.


(R.S. § 1979; Pub. L. 96–170, § 1, Dec. 29, 1979, 93 Stat. 1284; Pub. L. 104–317, title III, § 309©, Oct. 19, 1996, 110 Stat. 3853.)


"the Court held that social media—defined broadly to include Facebook, Amazon.com, The Washington Post, and WebMD—is a "protected space" under the First Amendment for lawful speech.

Justice Anthony Kennedy explained the decision: "A fundamental principle of the First Amendment is that all persons have access to places where they can speak and listen, and then, after reflection, speak and listen once more."

"... sources for knowing current events, checking ads for employment, speaking and listening in the modern public square, and otherwise exploring the vast realms of human thought and knowledge."

"It is well established that, as a general rule, the Government 'may not suppress lawful speech as the means to suppress unlawful speech'."

The Fourth Amendment prohibits general search warrants and requires that a warrant describe, with particularity, the place to be searched and the persons or things to be seized. U.S. Const. amend. IV. The purpose of the particularity requirement is to “protect persons against the government's indiscriminate rummaging through their property” and to “[prevent] the searching for and seizure of items that there is no probable cause to believe are either contraband or evidence of a crime” United States v. Jones, 54 F.3d 1285, 1289–90 (7th Cir.1995) (citing Coolidge v. New Hampshire, 403 U.S. 443, 467, 91 S.Ct. 2022, 29 L.Ed.2d 564 (1971)); United States v. Sims, 553 F.3d 580, 582 (7th Cir.2009) (citing Maryland v. Garrison, 480 U.S. 79, 84–85, 107 S.Ct. 1013, 94 L.Ed.2d 72 (1987)). “By limiting the authorization to search to the specific areas and things for which there is probable cause to search, the requirement ensures that the search will be carefully tailored to its justifications, and will not take on the character of the wide-ranging exploratory searches the Framers intended to prohibit.” Garrison, 480 U.S. at 84, 107 S.Ct. 1013; United States v. Vitek Supply Corp., 144 F.3d 476, 481 (7th Cir.1998) (“This requirement ... ensures that the scope of a search will be confined to evidence relating to a specific crime that is supported by probable cause.”)

To satisfy the particularity requirement, a warrant “must describe the objects of the search with reasonable specificity, but need not be elaborately detailed.” Vitek Supply Corp., 144 F.3d at 481. “In practice, courts have ... demanded that the executing officers be able to identify the things to be seized with reasonable certainty and that the warrant description must be as particular as circumstances permit.” Jones, 54 F.3d at 1290 (citing United States v. Brown, 832 F.2d 991, 996 (7th Cir.1987)). Accord United States v. Yusuf, 461 F.3d 374, 395 (3d Cir.2006) (“The breadth of items to be searched depends upon the particular factual context of each case and also the information available to the investigating agent that could limit the search at the time the warrant application is given to the magistrate.”) Furthermore, when the search involves digital media, the Seventh Circuit has instructed police officers “to exercise caution to ensure that warrants describe with particularity the things to be seized and that searches are narrowly tailored to uncover only those things described.” United States v. Mann, 592 F.3d 779, 786 (7th Cir.2010).

United States v. Winn, 79 F. Supp. 3d 904, 918-19 (S.D. Ill. 2015)

Stuff like this.. (and several dozen more, including your threat to kill people in the courthouse and burn it down) The judge will read it in court, and "you're have a chance to explain yourself". My "friend" is emailing her now. And she'll have to disclose it all.

I hope you spend the summer in that unair-conditioned jail while it takes a few months for new council to get up to speed on your case.