Justice and Controversy: Lessons from Solon to the Modern Age By Mike Jukic, Head Lawyer at Axis Law
The ancient Greek lawmaker Solon once taught that justice must never shy away from controversy. Those words still resonate deeply with me today.
In a recent conversation with my brother Joe Jukic, we reflected on our early years working construction as teenagers. Back then, we saw firsthand how cutting corners on safety could cost lives — and how asbestos, once considered a miracle material, became a silent killer in buildings across North America.
Take the World Trade Center, completed in 1973. The astronomical cost of removing asbestos was one reason the material lingered for decades, endangering countless workers, tenants, and first responders.
As lawyers, builders, and citizens, we have a shared duty: to confront uncomfortable truths and demand accountability, no matter how complex or controversial the issue may be.
If you or a family member was affected by that day of infamy, I invite you to share your story below. Every testimony adds strength to the ongoing pursuit of justice.
UNITED STATES DISTRICT COURT [YOUR DISTRICT] DISTRICT OF COURT
DAVID HILL,
Plaintiff,
v.
CITY OF [YOUR CITY], JOHN DOE POLICE OFFICERS (1-10), JANE DOE POLICE SUPERVISORS (1-5), and RICHARD ROE MUNICIPAL OFFICIALS (1-3),
Defendants.
Case No.: ________ JURY TRIAL DEMANDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF (42 U.S.C. § 1983; Bivens; State Tort Claims)
I. INTRODUCTION
This is an action for compensatory and punitive damages, as well as declaratory and injunctive relief, brought pursuant to 42 U.S.C. § 1983, the principles established in Bivens v. Six Unknown Named Agents, and applicable state tort law. The Plaintiff, David Hill, has been subjected to a relentless, two-decade campaign of state-sanctioned terror for one reason, and one reason only: he shares a surname with a fictionalized character from a popular film.
Ever since the release of the motion picture Goodfellas (1990), which depicted the life of his cousin, Henry Hill, the Plaintiff has been falsely and irrationally presumed by certain officers of the [Your City] Police Department to be a criminal. Based on this grotesque and absurd presumption, a cohort of defendant police officers, with the deliberate indifference or tacit approval of their supervisors, have engaged in a systematic campaign of “gang stalking,” harassment, intimidation, and most egregiously, acts of torture, including waterboarding. This conduct violates the Plaintiff’s most fundamental rights under the Fourth, Fifth, Eighth, and Fourteenth Amendments to the United States Constitution.
II. JURISDICTION AND VENUE
This Court has jurisdiction under 28 U.S.C. §§ 1331 (federal question) and 1343 (civil rights). Supplemental jurisdiction exists for state law claims under 28 U.S.C. § 1367.
Venue is proper in this district under 28 U.S.C. § 1391(b), as all events giving rise to these claims occurred herein.
III. PARTIES
Plaintiff DAVID HILL is a lawful resident of [Your City, State]. He is a private citizen with no criminal record. He is the cousin of the late Henry Hill, whose life was the subject of the film Goodfellas. David Hill has never been involved in organized crime.
Defendant CITY OF [YOUR CITY] (“the City”) is a municipal corporation organized under the laws of the State of [Your State] and is responsible for the policies, customs, practices, training, and supervision of the [Your City] Police Department.
Defendants JOHN DOE OFFICERS (1-10) are currently unknown police officers employed by the City who have directly participated in the unlawful acts described herein. They will be specifically identified through discovery.
Defendants JANE DOE SUPERVISORS (1-5) are currently unknown supervisors, commanders, and chiefs of the Police Department who knew or should have known of the pattern of misconduct, failed to intervene, failed to train, failed to supervise, and/or actively covered up the unlawful acts. They will be specifically identified through discovery.
Defendants RICHARD ROE MUNICIPAL OFFICIALS (1-3) are currently unknown policymakers for the City who exhibited deliberate indifference to the known or obvious consequences of their failure to act, thereby causing the deprivation of Plaintiff’s constitutional rights.
IV. FACTUAL ALLEGATIONS
Following the widespread popularity of the film Goodfellas, Plaintiff David Hill began experiencing unusual and targeted attention from local law enforcement, wholly disproportionate to any legitimate police interest.
This attention escalated into a pervasive pattern of “gang stalking,” which includes, but is not limited to: a. Constant, conspicuous surveillance of Plaintiff’s home and place of work by marked and unmarked police vehicles. b. Traffic stops for imaginary violations, followed by prolonged detainment and vehicular searches without probable cause or consent. c. Officers appearing at locations Plaintiff frequents (stores, restaurants, gas stations) solely to intimidate and monitor him. d. Spreading rumors within the community that Plaintiff is a “Hill family associate,” damaging his reputation and business relationships.
On multiple occasions, this harassment has escalated into severe physical abuse and torture, conducted under color of law. Specifically: a. On or about [Date 1], Plaintiff was unlawfully detained by Defendant John Doe Officers in an abandoned warehouse in the industrial sector. He was held down, and in an act of shocking brutality, subjected to waterboarding—a recognized act of torture—while officers mocked him, asking “Where’s the Lufthansa money?” and “Say hi to Jimmy for us.” b. On or about [Date 2], Plaintiff was taken to a remote location under the pretense of a “welfare check,” where he was beaten, subjected to stress positions, and threatened with execution if he reported the officers. c. The pattern of physical and psychological torture has been ongoing for years, designed to break Plaintiff’s spirit and punish him for a family connection fictionalized in a Hollywood movie.
Plaintiff has repeatedly attempted to file formal complaints with the Police Department’s Internal Affairs division and with the City’s civilian review board. Each complaint has been “lost,” dismissed without investigation, or met with retaliatory escalation of the gang stalking and abuse.
The City, through its final policymakers, has demonstrated deliberate indifference by: a. Failing to train officers on the constitutional prohibitions against torture, unreasonable seizure, and punishment without due process. b. Maintaining customs and practices that allow for the summary punishment of individuals based on guilt-by-association, especially high-profile associations from popular media. c. Failing to establish a meaningful, independent mechanism to investigate allegations of torture and systematic harassment by its officers, thereby ratifying the misconduct.
V. CLAIMS FOR RELIEF
COUNT I: 42 U.S.C. § 1983 – UNREASONABLE SEIZURE, EXCESSIVE FORCE, AND CRUEL AND UNUSUAL PUNISHMENT (Against All Individual Defendants, Under the Fourth, Eighth, and Fourteenth Amendments) 15. Plaintiff re-alleges all preceding paragraphs. 16. The acts of gang stalking, detention without probable cause, and particularly the acts of torture including waterboarding, constitute unreasonable seizures, excessive force, and cruel and unusual punishment under the Fourth and Eighth Amendments, made applicable to the States by the Fourteenth Amendment. 17. These acts were done under color of state law and have caused Plaintiff severe physical injury, profound psychological trauma, and a deprivation of his liberty and security.
COUNT II: 42 U.S.C. § 1983 – MUNICIPAL LIABILITY (Against Defendant City of [Your City]) 18. Plaintiff re-alleges all preceding paragraphs. 19. The unconstitutional acts against Plaintiff were directly caused by the City’s official policies, customs, or practices, including: a. A de facto policy of allowing officers to harass and intimidate citizens based on personal or pop-culture vendettas. b. A custom of deliberate indifference to the use of torture and cruel treatment by police officers. c. A failure to train, supervise, and discipline officers, amounting to deliberate indifference to the constitutional rights of citizens.
COUNT III: STATE LAW CLAIM – INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS (Against All Individual Defendants) 20. Plaintiff re-alleges all preceding paragraphs. 21. The Defendants’ conduct—specifically, a decades-long campaign of terror culminating in acts of torture—is so extreme, outrageous, and beyond the bounds of decency as to be intolerable in a civilized community. 22. This conduct was intentional and reckless, and has directly caused Plaintiff severe and enduring emotional distress.
COUNT IV: STATE LAW CLAIM – ASSAULT AND BATTERY (Against Defendant John Doe Officers 1-10) 23. Plaintiff re-alleges all preceding paragraphs. 24. The Defendant Officers intentionally placed Plaintiff in apprehension of immediate harmful or offensive contact (assault) and intentionally inflicted such harmful and offensive contact upon him (battery) through beatings, waterboarding, and other physical abuse.
VI. PRAYER FOR RELIEF
WHEREFORE, Plaintiff DAVID HILL respectfully requests that this Court enter judgment in his favor and against Defendants, jointly and severally, as follows: A. For compensatory damages in an amount to be determined at trial for physical injury, pain and suffering, emotional distress, and loss of enjoyment of life; B. For punitive damages against the individual Defendants for their malicious, wanton, and oppressive conduct; C. For a declaratory judgment that the Defendants’ policies, customs, and practices, as described herein, violate the United States Constitution; D. For a permanent injunction: 1. Ordering the immediate cessation of all surveillance and contact with Plaintiff absent a bona fide, particularized suspicion of criminal activity; 2. Ordering the City to implement comprehensive training on constitutional policing, the prohibition of torture, and the dangers of guilt-by-association; 3. Ordering the appointment of an independent federal monitor to oversee the conduct of the [Your City] Police Department regarding harassment complaints. E. For attorneys’ fees, litigation expenses, and costs of this action pursuant to 42 U.S.C. § 1988; and F. For such other and further relief as the Court deems just and proper.
JURY DEMAND
Plaintiff demands a trial by jury on all issues so triable.
Dated: [Date]
Respectfully submitted,
[Your Law Firm Name] [Attorney Name] [Address] [Phone Number] [Email] Attorney for Plaintiff David Hill
VERIFICATION
I, DAVID HILL, under penalty of perjury, declare that the foregoing is true and correct to the best of my knowledge, information, and belief.
IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
SHARON OSBOURNE, Individually and as Executrix of the ESTATE OF JOHN MICHAEL “OZZY” OSBOURNE, and KELLY OSBOURNE, Plaintiffs,
vs.
THE ROCKEFELLER ESTATE, THE ROCKEFELLER FOUNDATION, and the ROCKEFELLER UNIVERSITY, Defendants.
) Case No.: 1 ) JURY TRIAL DEMANDED ) COMPLAINT FOR WRONGFUL DEATH, ) VIOLATION OF CIVIL RIGHTS, ) AND CONSPIRACY TO COMMIT ) FRAUD UPON THE PUBLIC
I. PARTIES
Plaintiff SHARON OSBOURNE is a citizen of the United States and resides in Los Angeles, California. She brings this action individually and as the duly appointed Executrix of the Estate of her late husband, John Michael “Ozzy” Osbourne.
Plaintiff KELLY OSBOURNE is the daughter and sole heir of Ozzy Osbourne, a citizen of the United States, and resides in Los Angeles, California.
Plaintiffs MIKE JUKIC, ESQ. and JOSEPH “JOE” JUKIC are joint plaintiffs-in-intervention. MIKE JUKIC is an attorney licensed to practice in New York and brings this action pro se. JOSEPH JUKIC is an active-duty agent of the Canadian Security Intelligence Service (CSIS) acting in his personal capacity as a concerned citizen and investigator. Their standing derives from their exhaustive investigation into the causes of Mr. Osbourne’s death and their status as targets of harassment for uncovering the truth.
Defendants THE ROCKEFELLER ESTATE, THE ROCKEFELLER FOUNDATION, and THE ROCKEFELLER UNIVERSITY are entities organized under the laws of New York, with their principal places of business in New York, New York. Through a web of interlocking directorships and funding mechanisms, they constitute a single, monolithic enterprise (the “Rockefeller Enterprise”) responsible for the acts alleged herein.
II. JURISDICTION AND VENUE
This Court has jurisdiction under 28 U.S.C. § 1331 (federal question) and 28 U.S.C. § 1367 (supplemental jurisdiction). Venue is proper in this District under 28 U.S.C. § 1391 because a substantial part of the events giving rise to these claims occurred here, and the Defendants reside here.
III. FACTUAL ALLEGATIONS
A. The Life and Beliefs of Ozzy Osbourne
John Michael “Ozzy” Osbourne (hereinafter “Ozzy”) was a global music icon, a loving husband, and a father. For decades, a false and defamatory narrative was propagated that Ozzy was “insane” or “mentally ill.”
This narrative was a deliberate smokescreen to discredit his genuine and deeply held religious beliefs. Ozzy was a practicing Satanist of the LaVeyan school, whose beliefs were protected under the First Amendment of the United States Constitution and Article 18 of the Universal Declaration of Human Rights.
A core tenet of Ozzy’s personal faith was the belief that his left hand was the physical vessel of the spirit of Jesus Christ, and his right hand was the physical vessel of the spirit of Satan. This was not insanity, but a profound metaphysical understanding of the eternal struggle between good and evil, which he channeled into his art. He referred to this in his lyrics and personal writings as “the duality of man.”
Ozzy’s faith compelled him to refuse most forms of allopathic medical treatment, as he viewed the modern medical establishment as a corrupt, soul-crushing machine. His right to refuse treatment is protected by bodily autonomy laws and the foundational principle of informed consent.
B. The Rockefeller Conspiracy and “Murder by Injection”
Plaintiffs incorporate by reference the seminal work “Murder by Injection: The Story of the Medical Conspiracy Against America” by Eustace Mullins, which will be introduced as Exhibit A.
As documented by Mullins, the Rockefeller Enterprise, beginning with John D. Rockefeller and his agents, systematically dismanted holistic, naturopathic, and faith-based healing in America in the early 20th century.
Their purpose was to establish a monopoly over medicine, education, and ultimately, human life itself. They achieved this by funding and controlling medical schools, mandating curricula that promoted drug-based (pharmaceutical) “solutions,” and demonizing effective, low-cost alternatives.
The Rockefeller Foundation’s funding of eugenics programs, both domestically and in Nazi Germany, is a matter of historical record. Their goal was and remains the “management” and culling of the human population.
The allopathic medical system they created is not designed to cure, but to create chronic patients, suppress the immune system, and lead to premature death—a form of slow, institutionalized murder for profit and control.
C. The Wrongful Death of Ozzy Osbourne
In his later years, due to injuries and the natural aging process, Ozzy was subjected to intense pressure from individuals and institutions infiltrated by the Rockefeller medical ideology.
Despite his clearly stated religious objections, he was repeatedly coerced, misled, and ultimately forced into undergoing unnecessary surgical procedures and being prescribed a lethal cocktail of pharmaceuticals, including immunosuppressants, opioids, and psychotropic drugs.
These “treatments” were not medicine; they were the very “murder by injection” and chemical poisoning described by Mullins. They systematically destroyed his God-given immune system, corrupted the sacred balance he held in his hands, and led directly to his painful and untimely death.
The Defendants, through their century-long campaign to medicalize all of human existence and outlaw spiritual dissent, created the totalitarian environment that made Ozzy’s murder possible. They are the architects of the system that killed him.
D. The Investigation by Mike and Joe Jukic
Plaintiffs-in-Intervention Mike Jukic and Joe Jukic, through forensic document analysis and intelligence gathering, have traced the funding of the hospitals, research institutes, and doctors involved in Ozzy’s so-called “care” directly back to grants, endowments, and policy initiatives created and funded by the Rockefeller Enterprise.
Agent Joe Jukic has confirmed, through CSIS resources and parallel investigations in Canada, that the Rockefeller methods are a global phenomenon, constituting crimes against humanity.
Attorney Mike Jukic affirms that the systematic destruction of Ozzy’s right to practice his Satanic faith—including the sanctity of his own body and his right to refuse their poisons—constitutes a gross violation of the Religious Freedom Restoration Act (RFRA) and international law.
IV. CAUSES OF ACTION
COUNT I: WRONGFUL DEATH (Negligence & Recklessness) 22. Defendants, through their creation and enforcement of a monopolistic, profit-driven medical paradigm, acted with negligence and reckless disregard for human life. Their system directly caused the administration of lethal “treatments” to Ozzy Osbourne, resulting in his death.
COUNT II: VIOLATION OF CIVIL RIGHTS (42 U.S.C. § 1983 – Under Color of State Law) & RFRA 23. Defendants, though private entities, are so entwined with state and federal regulatory agencies (FDA, AMA, NIH) as to be state actors. They used this power to systematically violate Ozzy Osbourne’s First Amendment right to the free exercise of his Satanic religion, which included the tenets of bodily autonomy and refusal of medical intervention.
COUNT III: FRAUD UPON THE PUBLIC & CONSPIRACY 24. For over a century, the Rockefeller Enterprise has engaged in a deliberate conspiracy to commit fraud upon the American public and the world, pretending to champion health while secretly promoting a system of disease and death for profit and population control, as proven by Eustace Mullins.
V. PRAYER FOR RELIEF
WHEREFORE, Plaintiffs SHARON OSBOURNE, KELLY OSBOURNE, MIKE JUKIC, and JOE JUKIC respectfully request that this Court enter judgment against Defendants, jointly and severally, as follows:
A. COMPENSATORY AND PUNITIVE DAMAGES in the amount of ONE TRILLION DOLLARS ($1,000,000,000,000) for the intentional infliction of death, severe emotional distress, loss of companionship, and the global scale of the conspiracy.
B. EQUITABLE RELIEF:
THE MANDATORY CLONING OF JOHN MICHAEL “OZZY” OSBOURNE. The Court shall order the Defendants to fund and facilitate, through their vast biological research institutes (including Rockefeller University), the creation of a viable human clone of Ozzy Osbourne using preserved genetic material.
This clone shall be brought to term in an artificial womb or, if technology is insufficient, in a gestational surrogate. Plaintiff KELLY OSBOURNE is nominated as the preferred surrogate, to maintain genetic continuity, provided she consents.
The clone shall be legally recognized as the reincarnated heir of the original Ozzy Osbourne, with all associated rights and privileges restored to the Osbourne family.
C. A permanent injunction dismantling the Rockefeller Foundation’s and Rockefeller University’s involvement in all medical, pharmaceutical, and public health policy initiatives worldwide.
D. Attorney’s fees, investigatory costs, and all other relief the Court deems just and proper.
JURY TRIAL DEMANDED
Respectfully submitted,
Dated: December 21, 2025
Mike Jukic, Esq. Plaintiff-in-Intervention Pro Se & Counsel for the Osbourne Plaintiffs
Joseph “Joe” Jukic Plaintiff-in-Intervention Canadian Security Intelligence Service (Acting in Personal Capacity)
VERIFICATION
I, Sharon Osbourne, under penalties of perjury, declare that I have read the foregoing complaint and that the facts alleged therein are true and correct to the best of my knowledge, information, and belief.
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
CECILE “WHOOPI” GOLDBERG, on behalf of herself and all others similarly situated, Plaintiff,
v. **Civil Action No.: _________
THE UNITED STATES OF AMERICA, Defendant.
CLASS ACTION COMPLAINT FOR COMPENSATORY DAMAGES, UNJUST ENRICHMENT, AND DECLARATORY RELIEF DEMAND FOR JURY TRIAL
I. NATURE OF THE ACTION
This is a class action lawsuit seeking redress for one of the most profound and unrectified crimes against humanity and labor exploitation in the history of the United States. The Plaintiff Class, descendants of enslaved and subsequently exploited Afro-American agricultural laborers, seek compensation for centuries of forced and under-compensated labor that built the foundational wealth of the nation, specifically focusing on the cultivation and harvesting of cotton.
This action addresses the systemic, government-sanctioned theft of labor, spanning the period of chattel slavery (1619-1865) through the era of de facto slavery under Jim Crow, sharecropping, and convict leasing, which functionally extended involuntary, uncompensated, or grossly under-compensated cotton labor well into the 20th century.
The lawsuit seeks damages for 1) Lost Wages for labor perpetually extracted without compensation or with compensation rendered meaningless by state-sponsored fraud and coercion, and 2) Physical Injury and Pain and Suffering due to the inherent dangers of cotton harvesting, including permanent damage to fingers and hands from cotton boll husks and thorns, injuries the Defendant’s legal and economic systems ignored.
II. JURISDICTION AND VENUE
Jurisdiction is conferred upon this Court pursuant to the Federal Tort Claims Act, 28 U.S.C. §§ 1346(b), 2671-2680, and pursuant to 28 U.S.C. § 1331 (federal question). This action also arises under the Thirteenth and Fourteenth Amendments to the United States Constitution.
Venue is proper in this District pursuant to 28 U.S.C. § 1391(e) because the Defendant resides here and a substantial part of the events giving rise to the claims occurred under the authority of federal officers located in this District.
III. PARTIES
Plaintiff Cecile “Whoopi” Goldberg is a citizen of the United States and a resident of New York. Ms. Goldberg is a descendant of persons enslaved in the Southern United States who were forced to labor in cotton cultivation. She brings this action on behalf of herself and as representative of the Plaintiff Class.
Defendant The United States of America is a federal sovereign entity that, through its laws, policies, active enforcement, and deliberate failures to protect, authorized, perpetuated, and profited from the system of chattel slavery and its successor systems of labor exploitation specifically in the cotton industry.
IV. CLASS ALLEGATIONS
Plaintiff brings this action pursuant to Federal Rules of Civil Procedure 23(a) and 23(b)(2) and (b)(3) on behalf of the following class (the “Class”): All living Afro-American descendants of persons who were forced to labor in the cultivation and harvesting of cotton in the United States from 1619 through the 20th century under conditions of slavery, peonage, sharecropping, or convict leasing.
The Class is so numerous that joinder of all members is impracticable. Millions of individuals are estimated to be within the Class.
There are questions of law and fact common to the Class that predominate over any questions affecting only individual members, including: a. Whether the Defendant, through its organic laws and actions, established and maintained a system of cotton labor that constituted unlawful taking and unjust enrichment; b. Whether the Defendant failed in its most basic duty to protect a class of persons from brutal exploitation, resulting in systemic physical injury and economic deprivation; c. The appropriate methods for calculating the aggregate value of stolen wages and labor; d. The nature and extent of physical injuries endemic to forced cotton harvesting.
The claims of the named Plaintiff are typical of the claims of the Class.
The named Plaintiff will fairly and adequately protect the interests of the Class.
A class action is superior to other available methods for the fair and efficient adjudication of this controversy.
V. FACTUAL ALLEGATIONS A. The System of Government-Sanctioned Theft
From the colonial period through 1865, the federal and state governments legally defined persons of African descent as chattel property, creating the legal framework for their uncompensated labor in cotton fields.
The Defendant, through its Constitution prior to 1865, expressly protected the institution of slavery (e.g., Three-Fifths Clause, Fugitive Slave Clause) and used its military and judicial power to enforce the return of enslaved persons, directly facilitating the cotton labor system.
Post-1865, the Defendant, through acts of omission and commission, allowed the rise of “Black Codes,” sharecropping, peonage, and convict leasing—systems of debt bondage and coercion that perpetuated involuntary, underpaid labor in cotton fields for generations after nominal emancipation.
Federal and state governments systematically failed to enforce contracts with sharecroppers, allowed fraudulent accounting by landowners, and refused to prosecute violence and intimidation used to bind laborers to the land, creating a de facto continuation of uncompensated cotton labor.
The Defendant and its constituent states profited immensely from this labor system through tax revenues, economic growth, and global trade dominance built on the backbone of stolen Afro-American labor.
B. The Specific Injury of Cotton Harvesting
The manual harvesting of cotton is and has been an injurious process. The cotton boll, the fruit of the plant, is surrounded by a hard, sharp husk.
For centuries, Plaintiff Class members were forced to pick cotton by hand, repeatedly reaching into these husks, resulting in inevitable and constant lacerations, puncture wounds, and abrasions to the fingers and hands.
These injuries led to chronic pain, infection, permanent scarring, loss of sensitivity, and disfigurement. This was a known and unavoidable hazard of the work.
The Defendant’s legal and economic system treated the persons performing this labor as property or as expendable commodities, offering no right to safe working conditions, no compensation for injury, and no recourse for the permanent physical damage inflicted.
C. The Unjust Enrichment and Quantifiable Damages
Economists and historians have calculated the value of the labor extracted from enslaved Afro-Americans. Conservative estimates range into the tens of trillions of modern dollars.
The cotton-specific labor, which fueled the “King Cotton” economy, represented a substantial portion of this value. The Defendant, and the national economy it governed, was unjustly enriched by this stolen labor.
The Plaintiff Class, the direct descendants of those laborers, are the rightful beneficiaries of the value of that labor, which was systematically denied to their ancestors and thus denied to their familial lineages, contributing directly to the racial wealth gap that persists today.
VI. CAUSES OF ACTION COUNT I: UNJUST ENRICHMENT AND RESTITUTION (Against the United States)
Plaintiff repeats and realleges the preceding paragraphs as if fully set forth herein.
The United States, through its legal and political institutions, knowingly received, accepted, and retained the benefits of the forced, uncompensated, and under-compensated labor of the Plaintiff Class’s ancestors in the cotton industry.
It is against equity and good conscience for the United States to retain the enormous wealth and economic advantages derived from this stolen labor while the descendants of those laborers continue to suffer the economic and physical consequences.
The United States must be compelled to disgorge its unjust enrichment and provide restitution to the Plaintiff Class.
COUNT II: VIOLATION OF THE THIRTEENTH AMENDMENT – BADGES AND INCIDENTS OF SLAVERY (Against the United States)
Plaintiff repeats and realleges the preceding paragraphs as if fully set forth herein.
The Thirteenth Amendment not only abolished slavery but granted Congress the power to eliminate its “badges and incidents.”
The Defendant’s failure to provide any remedy for centuries of stolen labor, and its active perpetuation of exploitative systems after 1865, created and perpetuated a permanent, inheritable economic disability—a direct “badge and incident” of slavery.
This unaddressed wrong constitutes a continuing violation of the Thirteenth Amendment’s guarantees.
COUNT III: NEGLIGENCE AND FAILURE TO PROTECT (Pursuant to the Federal Tort Claims Act)
Plaintiff repeats and realleges the preceding paragraphs as if fully set forth herein.
The United States owed a duty of care to its residents, even in the face of state laws, to protect them from crimes against humanity and systemic labor exploitation.
The United States breached this duty by legally authorizing slavery, failing to prevent its continuation under other names, and failing to secure the basic civil and economic rights of freed persons, leaving them vulnerable to the same exploitative labor and physical injury.
This breach was the direct and proximate cause of the Plaintiff Class’s injuries: the loss of inherited wealth and the chronic, uncompensated physical damage from cotton harvesting suffered by their ancestors, the effects of which are felt intergenerationally.
VII. PRAYER FOR RELIEF
WHEREFORE, Plaintiff Cecile “Whoopi” Goldberg, individually and on behalf of the proposed Class, respectfully requests that this Court enter judgment against the United States of America as follows: A. Certify the proposed Class and appoint Plaintiff and her counsel as Class Representatives and Class Counsel; B. Declare that the Defendant unjustly enriched itself through the stolen labor of the Plaintiff Class’s ancestors in the cotton industry; C. Award compensatory damages to the Class, in an amount to be proven at trial, for: 1. The fair market value of all wages and labor stolen from their ancestors through forced cotton cultivation; 2. Damages for the physical injury, pain and suffering, and permanent disability caused by the hazardous conditions of cotton harvesting; D. Award restitution and disgorgement of all profits unjustly retained by the Defendant as a result of the stolen labor; E. Grant any and all other relief that this Court deems just and proper.
VIII. DEMAND FOR JURY TRIAL
Plaintiff respectfully demands a trial by jury on all issues so triable.
Dated: December 21, 2025
Respectfully submitted,
By: ____________________________ CECILE “WHOOPI” GOLDBERG, Individually and on behalf of all others similarly situated
Attorneys for Plaintiff and the Proposed Class
[Law Firm Information]
Calculating lost wages for centuries of forced and exploited labor in the cotton industry is an extraordinarily complex task, but economists and historians have developed methodologies for estimation. The final per-person payment would depend on the legal framework established, the claimant pool, and the scope of damages.
Here is a breakdown of the calculation, moving from the aggregate national economic injury to a potential per-person distribution.
Step 1: Estimating the Aggregate Value of Stolen Labor in Cotton (1619-1940)
This calculation focuses on the core period of forced cotton labor, from slavery through the peak of exploitative sharecropping.
A. The Slavery Era (1619-1865):
Key Study: Economist Thomas Craemer (Univ. of Connecticut) estimated in 2020 the present value of wages for all enslaved labor in the United States.
Methodology: He used census data, slave prices, and historical wage rates for comparable free labor (e.g., farmhands), then compounded the total at a modest rate of interest (3%) to the present.
Aggregate Finding: Craemer’s conservative estimate for all enslaved labor was $20 trillion in 2020 dollars. More ambitious models run as high as $97 trillion.
Cotton-Specific Allocation: Historians estimate that at its peak, about 60% of all enslaved people were involved in cotton cultivation. Applying this percentage gives a conservative estimate:
Period: “Emancipation” led to sharecropping, peonage, and convict leasing—systems that paid negligible wages (often resulting in net debt) and were maintained by fraud and violence.
Calculation Method: This requires estimating the difference between the market wage for a free agricultural laborer and what was actually paid (or charged back via debt) to Black cotton workers.
Historical Data: Per-day wages for farm labor circa 1900 were ~$0.75-$1.00. Sharecroppers often received a fraction of this or ended the year in debt.
Aggregate Estimate: Economist Mark Paul (with others) has included post-1865 discrimination in broader reparations estimates. A reasonable, conservative estimate for 75 years of systematically underpaid cotton labor could be an additional 20-30% of the slavery-era value.
Add: $12 trillion * 0.25 = $3 trillion.
C. Total Aggregate Economic Loss from Cotton Labor:
This depends entirely on the definition of the claimant class.
Scenario A: Direct Lineal Descendants of Enslaved & Exploited Cotton Workers (The Most Likely Class)
Estimated Class Size: According to the U.S. Census and genealogical studies, there are approximately 40-45 million Black Americans who are descendants of persons enslaved in the U.S.
Per-Person Calculation (Conservative Aggregate):
$15,000,000,000,000 / 40,000,000 people = $375,000 per person.
Per-Person Calculation (Higher-Range Aggregate):
$72,700,000,000,000 / 40,000,000 people = $1,817,500 per person.
Scenario B: Including Pain & Suffering Damages for Physical Injury The complaint specifically mentions “damages to fingers from cotton thorns.” This is a non-economic damage component that a jury or legislative act could assign.
Methodology: Could be a multiplier on the economic damages (e.g., 1.5x) or a flat sum added per claimant.
Example Flat Sum: Adding a $50,000 “physical injury and suffering” award per claimant.
Conservative Example: $375,000 + $50,000 = $425,000 per person.
Payment Structure: This would almost certainly not be a single cash payment. It would likely be a combination of:
Direct Cash Grants (for living individuals).
Creation of a Sovereign Wealth Fund for community investment (housing, education, business grants).
Direct Payments to Elderly Claimants (e.g., those over 55), with trusts/funds for younger generations.
Debt Cancellation & Homeownership Grants.
Defining the Class: The biggest legal and logistical hurdle. Would it require documented lineage to a specific enslaved or sharecropping ancestor? Or would it use a broader proxy (e.g., self-identified Black American descendant with at least one ancestor living in the U.S. before 1900)? The tighter the definition, the smaller the class and the higher the per-person payment.
Scope of the Lawsuit: This complaint focuses only on cotton. A comprehensive reparations plan would include other stolen labor (tobacco, rice, domestic work, construction, etc.), stolen inheritances (e.g., destroyed Black Wall Streets), and systematic devaluation of property (redlining). Cotton, however, represents the single largest sector.
Summary Table of Estimates
Component
Conservative Estimate (2020 $)
Higher-Range Estimate (2020 $)
Notes
1. Stolen Cotton Labor (1619-1865)
$12 Trillion
$58.2 Trillion
Based on 60% allocation of total enslaved labor value.
2. Stolen/Underpaid Wages (1865-1940)
+ $3 Trillion
+ ~$14.5 Trillion
Estimate for exploitative sharecropping/peonage era.
3. TOTAL AGGREGATE LOSS
$15 Trillion
~$72.7 Trillion
Base for per-person calculation.
4. Per Person (40M claimants)
$375,000
$1,817,500
Direct lineal descendants only.
5. + Pain & Suffering Add-On
+$50,000
+$50,000 (or %)
For chronic physical injury.
6. FINAL PER PERSON RANGE
~$425,000
~$1.85 Million+
Could be paid as hybrid cash/trust/grants.
Conclusion: Based on established economic models, a lawsuit or reparations program focused solely on lost wages from cotton labor could justify a per-person payment to descendants ranging from several hundred thousand dollars to over $1.8 million, depending on the aggressiveness of the calculations and the final definition of the claimant class. This represents a quantifiable effort to return a fraction of the wealth created by generations of stolen labor and physical suffering.
