Excerpt from Jeannie's motion - On November 12, 2019, I was subjected to coercive tactics, entrapment, physical duress, emotional anguish, and numerous other distressing circumstances. Due to the unlawful and unprecedented actions of the men and women holding me hostage, I did not believe they were actual or legitimate officers. I had heard Sheriff Chris Goetz tell the Nickersons they were lawfully on the property. He had not changed or altered his assurances or notified them anything had changed. I was never shown or served any writ, order, warrant, or lawful basis or authority for their actions. Previous actions had been rendered unlawful and retracted. It was never demonstrated to me they were authentic law enforcement. They were acting in a manner inconsistent and diametrically opposite to my understanding of how law enforcement should, and usually does act. I was under extreme physical and mental distress. In the light of these circumstances, which the officers were aware of, allegedly asking me any questions or to do anything was nothing short of entrapment.

Excerpt from Jeannie's motion - No harm can come to the public or justice by the vacation of this pretrial proceeding, the dismissal of my charges with prejudice, or the disqualification of the Clearwater County Prosecutor's Office. No owner, alleged owner, person in possession, or person occupying the property filed a complaint asking that I be arrested or criminally charged for being on the property. No warrant was issued prior to my arrest. Admissible and factual probable cause based on personal knowledge has not been established. I have no criminal record. All charges brought against me represent non-violent crimes with no injury to property or persons. I did no harm... To be clear, I was arrested for being on a property I was lawfully occupying and my personal belongings were seized when no owner, authority, or law requested or granted permission for them to be taken or for me to be arrested.

Excerpt from Jeannie's motion - The public prosecutor 'is the representative not of any ordinary party to a controversy, but of a sovereignty whose obligation to govern impartially is as compelling as its obligation to govern at all; and whose interest, therefore, in a criminal prosecution is not that it shall win a case, but that justice shall be done...'

Excerpt from Jeannie's reply brief - The Clearwater County Prosecutors Office has concealed exculpatory evidence, ignored defects in the complaint and proceedings, exhibited prejudicial actions and attitudes toward my defense, violated the rules of Professional Conduct and other applicable professional guidelines and standards, demonstrated they have an axe to grind against the Nickersons through me, firmly convinced me I cannot receive a fair trial with their office representing the 'State,' and displayed dishonesty in the production of evidence and their dealings with the public. There are no alternative solutions to disqualification which would allow me to obtain a fair trial and the risk of public suspicion and lack of confidence far outweigh any alleged benefits from continuing the present representation.

Click here or see below for Jeannie's Affidavit that supports of this Motion.

Excerpt from Jeannie's motion - [I] move this Court to dismiss the erroneous charges brought against me because this Court, the Clearwater County prosecuting attorney, Sheriff Chris Goetz, and the arresting officers violated the United States Constitution, the Idaho State Constitution, Idaho Code, and Idaho Criminal Rules and other procedures during the unlawful arrest, detainment and seizure on November 12, 2019, and the prosecution of this case.

Excerpt from Jeannie's motion - The 'State' failed to follow procedure and violated numerous laws and rules in my arrest, incarceration, and prosecution. The 'State' violated the clear written instructions of the court and bank thereby nullifying their authority as an alleged agent. The 'State' seeks to prosecute me based on inadmissible evidence illegally obtained by questioning me while in handcuffs and in custody without first advising me of my Miranda Rights. Defects in the complaint, prosecution, and prior proceedings in this case are good faith arguments that demonstrate good cause for dismissal of my case. Therefore, justice, judicial efficiency, and good stewardship of county funds and resources move this Court to dismiss the charges against me. Further, truth compels this Court to investigate the horrendous reasons why I was falsely charged and maliciously prosecuted on November 12, 2019, in the first place.

Click here or see below for Jeannie's Affidavit that supports of this Motion.

Excerpt from Jeannie's response - The assertion that 'all matters involving the right to possess or occupy that property were fully and finally litigated' is inaccurate, misleading, and factually untrue. Clearwater County Case CV18-18-0408 was currently in appeal on November 12, 2019, regarding new claims of fraud and the right to occupy the property. Issues of ownership and possession were still undecided on November 12, 2019. ..The 'State' fails to communicate why it would be insufficient to object to this evidence at trial should I seek to introduce it. According to my limited research, this is an essential element of a Motion in Limine…The 'State' fails to identify any specific evidence or 'speculative arguments' they want excluded. Requesting this court make a ruling without specificity is unfairly vague and violates my equal access to justice and a proper defense in this matter.

Excerpt from Jeannie's affidavit - I was never served or shown any warrant, writ, or any document granting the sheriff deputies or state police authority to break and enter the property, confiscate belongings and/or arrest me… I was never lawfully asked to leave the property that I had the express and implied permission of all possible owners to be on. As far as I knew, could know, or had reason to know, I was lawfully on 3165/139 Neff Road, Orofino, ID, on November 12, 2019, and no law enforcement officer, bank employee, agent of the bank, or any other individual or entity showed or served me any document to the contrary that contradicted my clear understanding.

Note: This affidavit supports the Motion To Continue Final Pre-Trial Conference and Trial Setting, Motion To Dismiss, and Motion To Disqualify Clearwater County Prosecutor's Office.

Exhibit D - A Letter From Nick Nickerson As A Friend of Law And Justice
Jeannie's constitutional rights to be secure in her person, houses, papers and effects against unreasonable searches and seizures were violated. She was never served or shown a writ or warrant. She was not informed of any intention to arrest her, the cause of her arrest, or any authority to arrest her, prior to being arrested. She was falsely arrested before she even allegedly committed a crime. Although she did not resist in any way or attempt to flee, she was double handcuffed, made to sit out in the cold and rain for hours, never advised of her rights, and forced to post excessive bail. She did not obstruct any officer and complied with every lawful order they gave. She did not, nor was she capable of committing the crimes for which she was accused per I.C. § 18-114, I.C. § 18-201, I.C. § 18-705, I.C. § 18-7008(2)(a), I.C. § 18-7008(6)(a)(i), and the legal definitions of these terms. However, the Clearwater County Sheriff's Office, the Clearwater County Prosecutor's Office, the Idaho State Police and this Court have violated, at a minimum, I.C. § 18-703; I.C. § 18-704; I.C. § 18-2901; I.C. § 19-602; I.C. § 19-603; I.C. § 19-608; I.C.R. 5(b); I.C.R. 10(a); I.C.R. 10(b); I.C.R. 10(c); I.C.R. 10(d)(2); fourth and eighth amendments of the Constitution of the United States; Constitution of the State of Idaho, Article I, Section 6 and 17; the Miranda Rule; and the Idaho Civil Sheriffs Manual, 1.3.9...

Jeannie is currently representing herself pro se because she has been unable to identify any Constitutional criminal defense lawyers in Idaho. We have not been able to locate any either. The American Bar Association told us Idaho has none. Pretty sad...

UPDATE: In June 2021, Clearwater County Magistrate Judge David Judd appointed Attorney Joanna McFarland of Lewiston, Idaho, to represent Jeannie. After reviewing facts and evidence and spending time discussing details of the events surrounding the Idaho Ranch Raid with Jeannie, Joanna determined the charges brought against Jeannie should be dropped. When Prosecutor Clayne Tyler refused to do so, Joanna determined to take this case to trial so Clearwater County and the community of Orofino can hear what really happened on November 12, 2019. In response, the Clearwater County Commissioners terminated Joanna's contract and appointed local Orofino attorney Allison Brandt in October 2021. After hearing more about the case and reviewing facts surrounding the case, Allison decided it was ridiculous Jeannie had ever been given a citation in the first place and agreed that the charges against Jeannie should most certainly be dropped. When Allison approached Clayne Tyler about the case to request he immediately drop the charges, Clayne Tyler refused and disclosed for the first time that Clearwater County Sheriff Chris Goetz is the one pushing the charges. Is acting Sheriff Chris Goetz forcing these charges in hopes of justifying his criminal actions against our family? We think so. Jeannie is still awaiting trial.