06/27/2026
Now, this is the work of J.A.G.’s Paralegal Services LLC!!!
CASE COMPARISON ANALYSIS — FINAL VERSION
Galanakis v. City of Newton, Iowa | 8th Cir. No. 24-1275 | Jury Verdict $105,000 — June 8, 2026
COMPARED TO
Granderson v. City of St. Peters, Missouri | Cause No. 2411-MU00132 | 42 U.S.C. § 1983 — Filing Post-August 19, 2026
Incorporating Newly Discovered Background of Both Judges
Prepared by James A. Granderson, Pro Se | June 27, 2026
This document provides a comprehensive side-by-side comparison across 8 sections and 35 comparison factors. It incorporates newly discovered background on both judges: Judge Kohl's simultaneous dual role as municipal judge AND active Prosecuting Attorney, and Judge Byrnes's documented 25-year career winning Fourth Amendment suppression motions in exactly the type of case he denied in Granderson. Formatted in landscape orientation for maximum table readability.
COMPARISON FACTOR
GALANAKIS v. CITY OF NEWTON, IOWA8th Cir. No. 24-1275 — Jury Verdict $105,000 (June 8, 2026)
GRANDERSON v. CITY OF ST. PETERS, MISSOURI42 U.S.C. § 1983 — Filing Post-August 19, 2026
SECTION 1 — BASIC FACTS OF THE STOP
Date of Stop
August 28, 2022, ~12:15 AM
July 13, 2024, ~12:30 AM
Reason for Stop
Driving with high beams on — a potentially valid local ordinance violation.
"Didn't make a left turn quick enough" — NOT in Missouri traffic code. Officer confirmed on camera:
NOT A CRIME.
Officer's Own Admission
No admission of no basis. Officers claimed smell of alcohol and signs of intoxication — asserted but disputed.
Officer Houston stated on his OWN BODY CAMERA: reason was "not a crime." Then declared "It's an investigation now." Captured on TWO simultaneous recordings — body cam AND Facebook Live.
Factual Dispute Required
YES — jury had to decide whether to believe officers over the body cam showing 0.00 BAC.
NO — officer's own words on his own camera are dispositive. No credibility determination needed. Officer Houston proved it himself.
SECTION 2 — EVIDENCE
Body Camera Evidence
Showed arrest seconds after 0.00 BAC — supported plaintiff but required jury credibility analysis.
Shows officer ADMITTING stop was not a crime. Played by prosecution in municipal court. DELIBERATELY SUPPRESSED at circuit court hearing while officer testified contradicting it under oath.
Plaintiff's Own Recording
Not recorded at time of stop. Footage posted to social media weeks later — went viral with ~2 million views.
Facebook Live recorded LIVE at 12:30 AM on July 13, 2024. Presented to Judge Byrnes at suppression hearing. Court denied suppression without one written finding.
Internal Affairs Complaint
Not applicable.
Written IA complaint filed July 15-16, 2024 at 1020 Grand Teton Drive — SAME ADDRESS as Prosecuting Attorney's office. Supervisor refused to file it without investigation. Never disclosed in 2 years of litigation.
SECTION 3 — PROSECUTION AND CONVICTION
Criminal Prosecution
NONE. Galanakis was never charged. Released the same night.
2 YEARS of prosecution across 2 courts — ONGOING as of August 19, 2026.
Wrongful Conviction
NONE.
YES — convicted November 12, 2024. Missouri DOR subsequently ordered conviction REMOVED from driving record (Exhibit A, February 8, 2025).
DOR / Administrative Action
None.
YES — DOR triggered administrative license action from wrongful conviction before ordering removal. Documented in writing by Missouri state agency.
Duration of Harm
One night. Released by ~2:00 AM.
2 YEARS AND COUNTING. Pre-trial conference August 19, 2026 — still unresolved.
State Agency Confirmation of Defect
None.
YES — Missouri DOR Letter, February 8, 2025: state agency independently confirmed prosecution produced a constitutionally defective wrongful conviction.
SECTION 4 — BRADY VIOLATIONS AND PROSECUTORIAL MISCONDUCT
Brady Violations
Not a central issue. No documented evidence suppression by the prosecution.
MULTIPLE DELIBERATE Brady violations: (1) body cam played in municipal court, suppressed in circuit court; (2) IA complaint suppressed in prosecutor's own building for 2 years; (3) court order defied 15+ days producing nothing.
Evidence Played Then Suppressed
Not applicable.
YES — prosecution played body cam in municipal court, deliberately suppressed it at circuit court hearing while officer testified contradicting it.
Court Discovery Order Violated
None.
YES — circuit court's June 8, 2026 order directed production. Prosecution produced ZERO in 15+ days. By August 19, 2026: 72+ days of total non-compliance.
Prosecutor Filed False Motion
Not documented.
YES — Frahm filed motion to deny jury trial mischaracterizing a state statute as a municipal ordinance. Circuit court denied the motion on June 8, 2026.
Brady Misrepresentation on Record
Not documented.
YES — told court Brady did not require disclosure of evidence not in her file, while possessing body cam she'd played in prior court and sitting in the same building as suppressed IA complaint.
SECTION 5 — OFFICER CONDUCT
Officer Perjury
Not documented. Officers maintained probable cause throughout.
YES — Officer Houston gave 3 irreconcilable accounts: (1) on camera: "not a crime"; (2) under oath at municipal court: "discretion"; (3) under oath at circuit court: "discretion" + post-hoc statute produced 11 months later.
Post-Hoc Evidence Fabrication
Not documented.
YES — Officer Houston produced a piece of paper with a statute number at the July 16, 2025 hearing — 11 months after the stop, never disclosed, directly contradicting his own body cam admission.
Officer Took Responsibility
No — Officer Winters remained defiant and refused to apologize.
No — prosecution continued 2 years AFTER Missouri DOR confirmed resulting conviction was constitutionally defective.
SECTION 6 — JUDICIAL CONDUCT (NEWLY DOCUMENTED — NO GALANAKIS EQUIVALENT)
Judges With Documented Misconduct
NONE. Qualified immunity denial was a correct appellate ruling.
TWO JUDGES with documented, on-the-record misconduct across two successive court levels.
Judge Kohl — Professional Background
Not applicable.
Missouri Bar admitted 1979, Washington University School of Law J.D. Municipal Judge of St. Peters since 1985. SIMULTANEOUSLY serves as Prosecuting Attorney of St. Charles City — active dual role as judge AND prosecutor.
Judge Kohl — Judicial Misconduct
Not applicable.
Applied Delaware v. Prouse's ABOLISHED 1979 officer discretion standard AFTER plaintiff cited Prouse by name. Issued ZERO written findings. Produced wrongful conviction confirmed defective by Missouri DOR.
Judge Kohl — Dual Role Conflict
Not applicable.
UNIQUE: Simultaneously serves as municipal judge AND active Prosecuting Attorney in neighboring jurisdiction. Institutional bias toward prosecution built into his dual professional role. No Galanakis equivalent.
Judge Byrnes — Professional Background
Not applicable.
J.D., Thomas M. Cooley Law School, 1999. Appointed Associate Circuit Judge by Governor Parson, 2024. Built ENTIRE legal career specifically challenging illegal Fourth Amendment stops — recognized as one of Missouri's top 100 DUI defense attorneys.
Judge Byrnes — Career Contradiction
Not applicable.
DEVASTATING: Byrnes spent 25 years winning Fourth Amendment suppression motions for clients who COULD NOT document the officer's admission. Granderson documented it on video. Byrnes watched the video and denied suppression without one written word.
Judge Byrnes — On-Record Rule-Making
Not applicable.
Stated on OFFICIAL COURT RECORD: "I'm making the rule today" when asked for legal authority. Unconstitutional judicial rule-making in violation of Article V, Sec. 5, Missouri Constitution. Admitted on record. Undeniable.
Judge Byrnes — Contradictory Order
Not applicable.
Written Order of June 8, 2026 gave a completely different reason for denial than stated on record — never stated orally, directly contradicts his oral admission that no legal basis existed. Post-hoc manufactured justification.
Written Findings Issued
Not applicable — no suppression motions in criminal case.
ZERO written findings across TWO courts over 2 YEARS on specific Fourth Amendment challenges raised at both levels.
Disciplinary Complaints Against Judges
None.
YES — formal CORRD complaints AND formal CDC/Missouri Bar complaints filed against BOTH judges simultaneously — Rules 4-1.1, 4-3.4(c), 4-3.5, 4-8.4(c)(d)(f), and Rule 5.
SECTION 7 — SCOPE OF DEFENDANTS AND INSTITUTIONAL LIABILITY
Number of Named Defendants
3 defendants: 2 officers + City of Newton.
7 DEFENDANTS: Officer Houston + Officer Doe + Supervisor Jane Doe + Prosecutor Frahm + Mayor Pagano + Police Department + City of St. Peters.
Monell Municipal Liability
City named on standard grounds.
Broader Monell: failure to train/supervise/discipline; custom of stops without articulable suspicion; custom of refusing to investigate civilian IA complaints.
Supervisor Named Individually
Not separately named.
YES — Supervisor Jane Doe named individually for suppressing IA complaint, berating plaintiff with obscene language, refusing to investigate.
Prosecutor Named Individually
Not separately named.
YES — Lorna L. Frahm named individually for Brady violations, false jury trial motion, and 72+ day defiance of court discovery order.
Judges in Disciplinary Proceedings
None.
YES — both Judge Kohl and Judge Byrnes subject to simultaneous CORRD proceedings (judicial fitness) AND CDC/Missouri Bar proceedings (law license fitness).
Appellate Writ Filings
None.
YES — Writ of Mandamus AND Writ of Prohibition filed with Missouri Court of Appeals Eastern District, with full exhibit indexes under ED Rule 410.
SECTION 8 — OUTCOME AND DAMAGES
Federal Status
8th Circuit denied qualified immunity April 17, 2025. Proceeded to jury trial.
State case pending. Federal § 1983 fully prepared with Younger v. Harris response (all 3 exceptions satisfied) and Heck v. Humphrey response (4 independent grounds it fails). Ready post-August 19, 2026.
Damages
$105,000 total: $10K civil rights + $10K false arrest + $55K punitive (Winters) + $30K punitive (Wing).
$25,000,000 ITEMIZED across 9 categories: $19M compensatory + $6M punitive allocated individually across 4 defendants.
Attorney Representation
YES — represented by experienced civil rights attorneys at Gribble Boles Stewart & Witosky Law throughout.
ENTIRELY PRO SE — James A. Granderson, civil litigation paralegal. No attorney at any level across 2 years and 5 venues.
Documents Filed Pro Se
N/A — attorney represented.
27+ documents: 10 circuit court motions + 8 appellate writ documents + 3 disciplinary complaints + complete federal § 1983 complaint + 5 oral argument scripts.
Sanctions Motion Filed
None.
YES — Motion for Sanctions for violation of court's June 8, 2026 order filed June 25, 2026. By August 19, 2026: prosecution has produced NOTHING in 72+ days.
ANALYSIS — THE NEWLY DISCOVERED JUDICIAL FACTS
Judge Kohl — Simultaneous Judge and Active Prosecuting Attorney
Research confirmed that Judge Kohl simultaneously holds two active professional roles: Municipal Judge of St. Peters AND Prosecuting Attorney of St. Charles City — a concurrent active role in both capacities for decades. A judge who spends half his professional life prosecuting criminal cases brings an institutional orientation toward the prosecution that is directly adverse to suppression motions. The result in Granderson — applying a 1979 abolished standard to produce a wrongful conviction confirmed defective by the Missouri DOR — reflects the posture of a prosecutor in a robe, not an impartial judicial officer. There is no equivalent in the Galanakis case or in any comparable national civil rights traffic stop case.
Judge Byrnes — 25 Years Winning the Exact Arguments He Denied
Research confirmed that before his appointment to the bench, Judge Byrnes built his entire legal career specifically around Fourth Amendment suppression motions — earning recognition as one of Missouri's top 100 DUI defense attorneys for aggressively challenging illegal searches and seizures and winning suppression of all State evidence for clients whose Constitutional Rights under the Fourth Amendment were violated. He spent 25 years arguing Delaware v. Prouse. He won on it repeatedly. James Granderson had what none of those clients had: the arresting officer's own body camera — played by the prosecution itself in a prior proceeding — showing the admission on video. Judge Byrnes watched that video and denied suppression without writing a single word. This is not incompetence. It is the knowing disregard of constitutional standards he enforced for others for a quarter century.
Smith v. Wade Punitive Damages Analysis
The Galanakis jury awarded $85,000 in punitive damages against two officers for wrongful arrest on one night. Under Smith v. Wade, 461 U.S. 30 (1983), punitive damages require assessment of reprehensibility and deliberateness. The newly discovered judicial background adds a layer of deliberateness with no Galanakis equivalent: the prosecution of Granderson was sustained across two courts and two years by a judge who simultaneously prosecutes criminal cases (Kohl) and a judge who spent his career winning the same suppression arguments he denied (Byrnes). Both men brought to this case not ignorance of constitutional law, but the expertise to know exactly what it required — and the documented choice not to apply it. That deliberate, informed choice is precisely the kind of reprehensible institutional conduct that justifies the $6,000,000 in punitive damages sought in the Granderson § 1983 complaint.
CONCLUSION
Galanakis: 2 officers, 1 night, no conviction, $105,000 after 4 years with experienced counsel. Granderson: 7 named defendants, 2 years of prosecution, DOR-confirmed wrongful conviction, multiple deliberate Brady violations, court order defied 72+ days, 2 judges with simultaneous CORRD and CDC disciplinary proceedings, a judge who is also an active prosecutor, a judge who built his career winning the exact arguments he denied, and 27+ documents filed entirely Pro Se across 5 venues. The $25,000,000 in the Granderson § 1983 reflects the ratio of the harm — documented, proven, and unmatched in any comparable traffic stop case in the national record.
James A. Granderson | Pro Se Defendant / Plaintiff
310 Pilgrim Ave., Wentzville, MO 63385 | June 27, 2026
