Uploaded June 2026 | Updated September 2026, 2 hours ago
Pre-Suit Demand — Civil Rights Violations Arising from the September 18, 2024 Incident at Little Rock City Hall
Claimant: Jeffrey Gray
LPD Incident No. LRP2409180133; Report No. LRP24127645
Claims Asserted: 42 U.S.C. § 1983 (First and Fourth Amendments)
Dear Mr. Carpenter:
This firm represents Jeffrey Gray in connection with the violation of his clearly
established constitutional rights by officers of the Little Rock Police Department
("LRPD") at Little Rock City Hall on September 18, 2024. Mr. Gray is a United States Army Veteran and a citizen journalist who documents the exercise of First Amendment rights in public spaces. We write to present a pre-suit demand and to give the City of Little Rock the "City") the opportunity to resolve Mr. Gray's claims before suit is filed in the United States District Court for the Eastern District of Arkansas under 42 U.S.C. § 1983.
SETTLEMENT DEMAND
To resolve all of Mr. Gray's claims arising from this incident without litigation,
we demand the following:
1. Monetary payment of $19,701.00, comprising $17,910.00 in damages
made payable to St. Francis House of St. Augustine, a nonprofit organization that serves the homeless-
-including homeless Veterans, and $1,791.00 in attorneys' fees
and costs;
2. Written rescission confirming that any trespass warning or bar against Mr. Gray at City Hall is revoked and that he may engage in lawful expressive activity there on the same terms as any other citizen;
3. A commitment to provide First Amendment training to all LRPD officers and to all City Hall personnel, security staff, and agents who interact with members of the public, addressing the right to engage in expressive activity (including the solicitation of charity) in a traditional public forum and the constitutional limits on compelling a speaker to identify himself, consistent with the relief obtained in comparable matters;
4. A written acknowledgment from the involved officers of the
constitutional rights at issue and, as a good-faith gesture, an apology to Mr. Gray.
Mr. Gray offers this as a non-essential term and will not permit it to impede an
otherwise-acceptable resolution;
The monetary figures are intentionally modest and intentionally resonant:
$17,910 and $1,791 each invoke 1791, the year the Bill of Rights-including the First Amendment the City's personnel disregarded here-was ratified. They reflect that this matter concerns the vindication of a foundational liberty, not money.
This demand is about the vindication of constitutional rights and the
deterrence of future violations, not money. However, should we be forced to pursue litigation, we intend to seek all damages and remedies available, to include all incurred attorney fees and costs.
VIl. RESPONSE REQUESTED
Please have the appropriate representative respond to this demand within
thirty (30) days of the date of this letter. The figures set out above—in particular the
Page 11 of 11
reduced fee component—are extended only as part of a prompt, good-faith resolution at this pre-suit stage. Should the City decline to resolve this matter and litigation become necessary, Mr. Gray will pursue full and complete relief, including all compensatory and nominal damages and the entirety of the attorneys' fees and costs
recoverable under 42 U.S.C. § 1988, which will substantially exceed the amounts
offered here. Nothing in this letter is a complete recitation of the facts or law, and
Mr. Gray reserves all rights, claims, and remedies.
Thank you for your prompt attention to this matter.
Brandor
J. Grable
Pre-Suit Demand — Civil Rights Violations Arising from the September 18, 2024 Incident at Little Rock City Hall
Claimant: Jeffrey Gray
LPD Incident No. LRP2409180133; Report No. LRP24127645
Claims Asserted: 42 U.S.C. § 1983 (First and Fourth Amendments)
Dear Mr. Carpenter:
This firm represents Jeffrey Gray in connection with the violation of his clearly
established constitutional rights by officers of the Little Rock Police Department
("LRPD") at Little Rock City Hall on September 18, 2024. Mr. Gray is a United States Army Veteran and a citizen journalist who documents the exercise of First Amendment rights in public spaces. We write to present a pre-suit demand and to give the City of Little Rock the "City") the opportunity to resolve Mr. Gray's claims before suit is filed in the United States District Court for the Eastern District of Arkansas under 42 U.S.C. § 1983.
SETTLEMENT DEMAND
To resolve all of Mr. Gray's claims arising from this incident without litigation,
we demand the following:
1. Monetary payment of $19,701.00, comprising $17,910.00 in damages
made payable to St. Francis House of St. Augustine, a nonprofit organization that serves the homeless-
-including homeless Veterans, and $1,791.00 in attorneys' fees
and costs;
2. Written rescission confirming that any trespass warning or bar against Mr. Gray at City Hall is revoked and that he may engage in lawful expressive activity there on the same terms as any other citizen;
3. A commitment to provide First Amendment training to all LRPD officers and to all City Hall personnel, security staff, and agents who interact with members of the public, addressing the right to engage in expressive activity (including the solicitation of charity) in a traditional public forum and the constitutional limits on compelling a speaker to identify himself, consistent with the relief obtained in comparable matters;
4. A written acknowledgment from the involved officers of the
constitutional rights at issue and, as a good-faith gesture, an apology to Mr. Gray.
Mr. Gray offers this as a non-essential term and will not permit it to impede an
otherwise-acceptable resolution;
The monetary figures are intentionally modest and intentionally resonant:
$17,910 and $1,791 each invoke 1791, the year the Bill of Rights-including the First Amendment the City's personnel disregarded here-was ratified. They reflect that this matter concerns the vindication of a foundational liberty, not money.
This demand is about the vindication of constitutional rights and the
deterrence of future violations, not money. However, should we be forced to pursue litigation, we intend to seek all damages and remedies available, to include all incurred attorney fees and costs.
VIl. RESPONSE REQUESTED
Please have the appropriate representative respond to this demand within
thirty (30) days of the date of this letter. The figures set out above—in particular the
Page 11 of 11
reduced fee component—are extended only as part of a prompt, good-faith resolution at this pre-suit stage. Should the City decline to resolve this matter and litigation become necessary, Mr. Gray will pursue full and complete relief, including all compensatory and nominal damages and the entirety of the attorneys' fees and costs
recoverable under 42 U.S.C. § 1988, which will substantially exceed the amounts
offered here. Nothing in this letter is a complete recitation of the facts or law, and
Mr. Gray reserves all rights, claims, and remedies.
Thank you for your prompt attention to this matter.
Brandor
J. Grable
