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The Conley Group, Inc. and Tom Conley today announced they have filed a Federal Civil Rights Lawsuit in the United States District Court for the Southern District of Iowa. Today’s lawsuit, which is attached, was filed today by Des Moines attorney Kenneth R. Munro of the Munro Law Office, P.C. The Defendants named in this lawsuit are:

  1. The City of West Des Moines, Iowa.
  2. Russ Trimble, who is the current West Des Moines Mayor, and who was a council member of the West Des Moines City Council. He is employed by the State of Iowa as a fiscal analyst for the Iowa Legislative Services Agency.
  3. Kevin Trevillyan, who is a current West Des Moines City Council member and is retired from West Des Moines Water Works.
  4. Greg Hudson, who is a current West Des Moines City Council member, and is a Social Studies Teacher at West Des Moines Valley High School.
  5. Matthew McKinney, who is a current West Des Moines City Council member, and who is an attorney with the BrownWinick Law Firm in Des Moines.
  6. Cherry “Renee” Hardman, who is a current West Des Moines City Council member, and is the Chief Diversity, Equity and Inclusion Officer and Vice President of Human Resources at Broadlawns Medical Center in Des Moines.

The origin of this lawsuit began when an off-duty extremist reporter for a radical Des Moines area press organization was actively participating in a protest that turned into a riot at a local mall right after the George Floyd incident occurred. She and her boyfriend at the time were part of a small group that refused to leave an area after the police issued a lawful dispersal order. As a result, she and her boyfriend were exposed to OC mace as a part of that group, and they were both arrested on misdemeanor charges. In January of 2021, while that reporter was still facing criminal charges, she participated in authoring several “hit piece” stories against the Iowa law enforcement profession. These stories masqueraded as news stories, but were clearly designed to target and unfairly disparage Iowa law enforcement officers. Those hit pieces were shamefully published by that radical press organization. As a result, Mr. Conley wrote an Op-Ed in response to those hit pieces where he strongly defended the law enforcement profession and all the good law enforcement officers. He called for an immediate end to the police bashing by that radical press organization. Mr. Conley’s Op-Ed was published the following week, but with a critical section deleted that pointed out the clear conflict of interest the extremist reporter had by being involved with these hit pieces stories on law enforcement at a time when she was still facing criminal charges. Because Mr. Conley wrote and submitted that Op-Ed, he strongly believes he was then placed on that radical press organization’s internal BLACKLIST.

Fast forward from January of 2021 to July of 2021. The Conley Group (TCG) had many contracts with businesses, organizations and governmental entities in the greater Des Moines area as they had for decades. The City of Des Moines and the City of West Des Moines were two of TCG’s customers. TCG had been providing security services to those cities for some time. He was highly-passionate about providing a unique and very high level of protective services for all his clients. On July 18, 2021, the same radical press organization that had previously attacked Iowa law enforcement began publishing what would become a series of intentionally damaging articles about Mr. Conley and TCG. These articles started be published one day before the Des Moines City Council was scheduled to vote on an increased budget for the security services TCG was providing for the City of Des Moines. The same extremist reporter resurfaced as one of the primary reporters involved in the series of articles published about Mr. Conley and TCG by that radical press organization. She was joined by a fellow activist reporter. The radical press organization’s article of July 18, 2021 resulted in the Des Moines City Council stopping the security funding vote, even though Mr. Conley’s alleged comments that were reported in the radical press organization’s story, even if true, were all constitutionally protected by Mr. Conley’s First Amendment rights to freedom of speech. Part of the radical press organization’s articles were directly related to Mr. Conley calling out the criminal conduct of a small offshoot of the Black Lives Matter (BLM) organization locally as well as nationally. As Mr. Conley has repeatedly stated, he fully supports everyone’s right to peacefully protest or demonstrate. But, he does not support criminal conduct by any person or by a part of a group. Several of what Mr. Conley refers to as the radical press organization’s “Voodoo Journalism” articles were, at best, chock-full of errors, misrepresentations, mischaracterizations, omissions of relevant facts, and out-and-out lies about substantive issues. Voodoo Journalism refers to the unethical act of a press organization publishing or producing one or more targeted stories that are intended to harm one or more parties versus what the press should do which is to ethically and honestly publish or produce stories that fairly inform their audience. Those articles were clearly premeditated as a sharply-focused and targeted attack on Mr. Conley and TCG that were meant to destroy his reputation and his business.

In a previous e-mail to Des Moines Police Chief Dana Wingert, Mr. Conley made reference to a group of young adult-age males he had encountered as he was personally trying to protect several of TCG’s downtown business customers from looting, vandalism and other criminal behavior after the George Floyd incident. For 3½ weeks, a group of 11 to 12 adult-age males were throwing bricks and rocks at Mr. Conley. This occurred several times per week. Instead of responding with lawful force to stop the brick and rock attacks, as he had the legal right to do, Mr. Conley tried his best to dodge the brick and rock attacks, and took no kinetic action against the group of people that were assaulting him with deadly force. After 3½ weeks of Mr. Conley trying to dodge the bricks and rocks by this group, two members of that group approached him. They apologized to him for hitting him with bricks and rocks. The two members of this group explained to Mr. Conley that their group thought Mr. Conley was a law enforcement officer, which is why they were throwing bricks and rocks at him. However, when the group found out he was security, they stopped throwing bricks and rocks at him. At this time, one of the males informed Mr. Conley the group was from Ohio and they had been employed by BLM to come to Des Moines. Their “job” was to impersonate angry BLM protesters to harass police, destroy property and terrorize people. The two males told Mr. Conley that BLM had paid for their transportation to Des Moines as well as for their housing and food, plus their pay. That tactic made sense to Mr. Conley because he had heard BLM was hiring people to impersonate protesters that commit crimes. At the same time, he was nonetheless appalled to encounter that type of perilous behavior firsthand. As a result, he referred to this group of paid thugs as, “Little sissy bitches that could not start a lawn mower let alone a movement.” He stands by that statement and he is entitled to his opinion. What he did not do is defend himself by using deadly force, as he could have legally done, when bricks and rocks were being thrown at him. To be clear, the actions taken by this group of young adult-age males who were throwing bricks and rocks at Mr. Conley with the clear intent of hitting him, clearly constituted assault with a deadly weapon. In fact, this group’s actions also met the statutory element of terrorism as defined in the Code of Iowa in Chapter 708A.1. Given these laws, Mr. Conley would have been well within his rights to deploy defensive measures, up to and including the use deadly force, to protect himself. The fact is, Mr. Conley displayed extreme restraint by his choosing not to take kinetic action against members of that group to stop the bricks and rocks from being thrown at him.

The July 18th radical press organization’s article also caught the attention of Cherry “Renee” Hardman. Ms. Hardman had set up BLM rallies and is a self-described “Community Activist.” Ms. Hardman was and is a Councilwoman on the West Des Moines City Council. A as result of the July 18th press article, Mr. Conley was asked to come to the West Des Moines City Hall on July 22, 2021 to meet with Councilwoman Hardman and the city manager, Tom Hadden. However, when Mr. Conley arrived for that meeting, Councilwoman Hardman, City Manager Hadden and the West Des Moines City Attorney, Richard Scieszinski, were all in the meeting room. Mr. Conley was surprised to see City Attorney Scieszinski there since he had not been advised he could have chosen to be represented by his attorney. Mr. Conley even commented that he did not know he needed to have his attorney present at the meeting. Hardman, Hadden and Scieszinski all replied that he did not need his attorney present because that this was just a “conversation.” Mr. Scieszinski never offered to leave the meeting, thus leaving Mr. Conley there alone and without legal representation.

After that meeting began, Ms. Hardman explained to Mr. Conley that she had called the meeting to determine if she was going to “support” him and his company to continue providing security services to the City of West Des Moines in light of his comments as were reported by that radical Des Moines area press organization. Then, for nearly an hour, Mr. Conley answered one question after another posed to him by Ms. Hardman. Every question pertained to Mr. Conley’s constitutionally-protected First Amendment protected speech including his personal beliefs. At the end of that meeting, Ms. Hardman complimented TCG to Mr. Conley by commenting she was pleased with the services TCG has always provided at the West Des Moines City Hall and how well TCG’s security officers always treated everyone. Mr. Conley left that meeting feeling very much ambushed and was stunned that TCG’s contract with West Des Moines could be cancelled as a result of his constitutionally-protected speech and personal beliefs.

After that meeting, Ms. Hardman led an effort to cancel TCG’s security contract with the City of West Des Moines because she obviously did not agree with Mr. Conley’s constitutionally-protected First Amendment protected speech and personal beliefs. Ms. Hardman also then interfered with other TCG contracts, including TCG’s contact with the City of Des Moines. As a result of Ms. Hardman’s campaign to cancel Mr. Conley and TCG’s contracts based on Mr. Conley’s First Amendment Rights, Mr. Conley was forced to sell a large portion of his security business to a competitor in late 2021. Sadly, that was not the last time Ms. Hardman would violate the constitutionally-protected First Amendment rights of others by using her positional authority in a governmental role to do so. In her job as the Chief Diversity, Equity and Inclusion Officer and Vice President of Human Resources at Broadlawns Medical Center in Des Moines, she appeared to lead an effort to cut ties with Freedom Blend Coffee and Freedom Ministries, a Christian group that had a long-term partnership with Broadlawns and that helped troubled youth. She did that because of the Christian group’s Biblical beliefs that were posted on that group’s website. There were zero allegations of discrimination, mistreatment or any other wrongdoing against the group. But, undeterred by the Christian group’s constitutionally-protected First Amendment rights, Ms. Hardman replaced the Christian group with a black-owned business that appears to be friendly to BLM and is anti-law enforcement. The following are web links to a series of stories that were published about this matter, and in their correct order of publication:

Broadlawns severs agreement with Christian organization over religious beliefs, Hardman again at center of punishing someone for exercising First Amendment rights

August 30, 2022


PUNISHED FOR FAITH: How Broadlawns Medical Center decided to end agreement with ministry over its LGBTQ beliefs

September 17, 2022


PUNISHED FOR FAITH: Governmental entity terminates contract with ministry over religious beliefs

September 19, 2022


BROADLAWNS BIGOTRY: Des Moines media beginning to highlight government entity’s decision to punish ministry based on religious beliefs

September 22, 2022


Broadlawns DEI Chief also used West Des Moines council position to punish First Amendment exercise in 2021

September 21, 2022


LETTER: What happened to our Constitutional rights? Broadlawns is tyranny!

Letter To the editor – September 25, 2022


Mr. Conley believes Ms. Hardman has now abused her positional authority in at least two separate and distinct governmental organizations to aggressively and illegally “cancel” people and organizations that do not comport with her anti-law enforcement philosophy. Mr. Conley believes she has proven to be a bully and that she will continue to violate the Constitutional rights of others unless and until she is stopped.

Iowa has a state law that all elected governmental leaders are accountable for, among other things, ensuring that the First Amendment Rights of all people are upheld and are not violated. Part of the oath that all city council members and mayors in Iowa take, by law, is:

I, [ELECTED OFFICIAL’S NAME], do solemnly swear that I will support the Constitution of the United States and the Constitution of the State of Iowa, and that I will faithfully and impartially, to the best of my ability, discharge all the duties as City Council Member for the City of…

Instead of the elected leaders of the West Des Moines City Council ensuring Mr. Conley’s First Amendment Rights were upheld, and following their oath to protect his rights and the rights of all people, the West Des Moines City Council instead chose to deliberately and maliciously violate Mr. Conley’s First Amendment Rights. And, at least one member of the West Des Moines City Council went so far as to tortiously interfere with other TCG contracts.

Despite its challenges, the United States of America is the greatest nation on planet Earth. Part of what makes it so great and unique is the ability of people in America to express their opinions, thoughts and beliefs in a free and open way without the fear of being jailed or killed by the government as is the case in so many other nations. The First Amendment to the Constitution of the United States, “Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances.” Our First Amendment right makes free speech possible and particularly protects people from the government so those in government cannot use their power to silence anyone from expressing their opinions, thoughts and beliefs, or punish people for the same. Every one of the West Des Moines City Council members who were in that position during August of 2021 used their governmental power to punish Tom Conley for his expressing his opinions, thoughts and beliefs. That is what makes what the West Des Moines City Council members did so highly egregious, appalling as well as being morally and ethically deplorable. Every one of the West Des Moines City Council members who were in that position during August of 2021 has dishonored themselves and obliterated the public’s trust in them as individuals and as council members. No person whose word is no good can be truly trusted. Every one of the West Des Moines City Council members who were in that position during August of 2021 violated their legal oath and is a disgrace. They should all immediately resign from office in shame and never run for any position of trust in the future. With this lawsuit, Mr. Conley and TCG are merely defending themselves against unconscionable wrongdoing by the West Des Moines City Council. This entire matter all boils down to wokeness and virtue signaling wherein Mr. Conley and TCG are victims of “thought crimes” and “cancel culture” by Ms. Hardman and the other members of the West Des Moines City Council. In short, Mr. Conley and TCG were “canceled” by the West Des Moines City Council for not being woke. Rest assured, Mr. Conley is not woke and he will never be woke. Rather, he is a patriotic, law-abiding professional who is a strong and avid supporter of the law enforcement profession and all the good men and women who work in law enforcement to protect others 24 x 7 throughout the year. That will never change. Mr. Conley’s First Amendment Rights were trampled upon, and he and TCG were damaged as a result. He does not want this type of brutal attack by government to ever happen to another U.S. citizen irrespective of their protected speech and personal beliefs.

Author: Press Release


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