CAUSE NO.

2018-CV-0512

KAMERON TODD NELSON, §

Plaintiff § IN DISTRICT COURT OF
§
VS. §
§ CONWAY COUNTY, ARKANSAS
MICHAEL DALE HUCKABEE, §
Defendant §

PLAINTIFF’S ORIGINAL COMPLAINT

1. Plaintiff KAMERON TODD NELSON is a celebrated Internet personality, self-

help guru, and nationally recognized firearms expert. He is a citizen of the state of New York and
resides at 273 Bowery, New York, NY 10002.

2. Defendant MICHAEL DALE HUCKABEE is politician, Christian minister,

author, and commentator who served as the 44th governor of Arkansas from 1996 to 2007. He is
a citizen of the state of Arkansas and can be served with process through the Arkansas Secretary
of State, 500 Woodlane Street, Suite 256, Little Rock, AR 72201.

FACTUAL BACKGROUND

3. Plaintiff KAMERON TODD NELSON is a famous commentator and thought-

influencer on the Twitter website who operates the @KrangTNelson account. Plaintiff NELSON
is known for his important contributions to the public dialogue, quickly gaining wide recognition
as a vital cultural figure and internet visionary.

4. On or about February 24, 2017, Plaintiff NELSON interacted with Defendant

MICHAEL DALE HUCKABEE on the Twitter website. Plaintiff NELSON presented his
viewpoints in a public communication to Defendant HUCKABEE, consistent with the intended
purpose of the Twitter website.

5. Plaintiff NELSON’S message included an image of a custom-made trophy,

designed personally by Plaintiff NELSON, which read: “Most Obese Dog-Murdering Son –
Winner Mike Huckabee.”

6. Defendant HUCKABEE, in violation of several legal duties described more fully

below, maliciously blocked Plaintiff NELSON on the Twitter website, preventing any further
communication.

7. Defendant HUCKABEE’S callous decision to block Plaintiff NELSON even

prevents Plaintiff NELSON from merely reading Defendant HUCKABEE’S daily messages and
jokes. Defendant’s actions have harmed and will continue to harm Plaintiff NELSON.

1
 CAUSE OF ACTION:
Violation of Plaintiff’s Right to Free Speech under the First Amendment.

8. By blocking the Plaintiff on the Twitter website, Defendant HUCKABEE has

hampered and burdened Plaintiff NELSON’s participation in a vital public forum and means to
petition government redress.

9. By publicly disseminating his views accompanied by homespun jokes and folksy

puns, Defendant HUCKABEE continues to be carrying out of the constitutional, statutory, or other
official or ceremonial duties of the Governor of Arkansas.

10. Defendant HUCKABEE is also the legal sire of the Press Secretary of the President
of the United States of America, and, upon information and belief, Defendant HUCKABEE
exercises substantial control over her activities and communications.

11. As such, the @GovMikeHuckabee Twitter account operates under color of law,
and Defendant HUCKABEE has used the “block” feature of the account to unreasonably oppress
Plaintiff NELSON and prevent the exercise of his First Amendment rights.

CAUSE OF ACTION:
Intentional Infliction of Emotional Distress

12. Defendant HUCKABEE took the actions described in this lawsuit for no other
reason than to cause Plaintiff NELSON psychological anguish and mental torment.

13. Defendant HUCKABEE’S decision to block Plaintiff NELSON on the Twitter

website was outrageous and intolerable, going beyond all possible bounds of decency.

15. Moreover, at all times relevant to this lawsuit, Defendant HUCKABEE was an
ordained Southern Baptist minister.

16. Defendant HUCKABEE had certain ecclesiastical and ecumenical responsibilities,

the abdication of which has caused unjust spiritual injury to Plaintiff NELSON.

17. By blocking Plaintiff NELSON on the Twitter website, Defendant HUCKABEE

willfully engaged in a malicious action against Plaintiff NELSON’s eternal soul. This digital
excommunication was intentionally calculated to cause Plaintiff NELSON severe emotional
distress.

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 CAUSE OF ACTION:
Business Disparagement

18. Plaintiff NELSON is an international icon who has built a burgeoning online brand
based around his important public interactions on the Twitter website.

19. Actuarial market experts have estimated a future projected valuation of Plaintiff
NELSON’S brand between $15-35 million over the next five years.

20. By blocking Plaintiff NELSON on the Twitter website, Defendant HUCKABEE

has disparaged the quality, integrity, and virtue of Plaintiff NELSON’S online brand.

21. Individuals who would have otherwise followed Plaintiff NELSON on the Twitter
website or purchased his line of hand-crafted bath products will naturally hesitate to associate with
an individual who has been publicly castigated by Defendant HUCKABEE.

DAMAGES

22. Plaintiff NELSON has suffered general and special damages, including a severe
degree of mental stress and anguish. Plaintiff NELSON has also suffered damage to his reputation
and image, both up to the present and into the future.

23. Plaintiff NELSON is also entitled to punitive damages due to Defendant

HUCKABEE’S outrageous and despicable conduct.

24. Due to Defendant HUCKABEE’S conduct, Plaintiff NELSON seeks a judgment of

no less than $100,000,000.

PRAYER

WHEREFORE PREMISES CONSIDERED, Plaintiff KAMERON TODD NELSON asks

that the Court issue citation for Defendant HUCKABEE to appear and answer, and that Plaintiff
NELSON be awarded all the damages set forth above, and to grant whatever further relief to which
he is justly entitled.

Respectfully submitted,

____________________________________
KAMERON T. NELSON
(Pro Se)
273 Bowery
New York, NY 10002