Exhibit C-10 (7/1/25) [LAWSUIT] California Attorney General Rob Bonta Violates Equal Protection of Defendant Michael Taylor (The Vernon Patterson Dossier)

📘 Exhibit C-10: Strategic Equal Protection Framing in Light of State of California et al. v. U.S. Department of Health and Human Services (Case No. 3:25-cv-05536)

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I. Procedural Context and Civilian Engagement

On July 1, 2025, the California Attorney General Rob Bonta, along with a coalition of other states, filed State of California et al. v. U.S. Department of Health and Human Services et al. in the Northern District of California, alleging unlawful disclosure of protected Medicaid data by the federal government. The plaintiffs argued that this breach violated HIPAA privacy standards and the Equal Protection Clause of the Fourteenth Amendment, citing disproportionate impacts on Medicaid recipients and state regulatory authority.

On the same date, Michael Bernard Taylor submitted a documented civilian implication notice directly to Attorney General Bonta and the other coalition plaintiffs. This public engagement referenced and built upon the state’s own claims by asserting that:

> "The facts in my case meet and exceed those asserted in your own federal litigation."

The notice identified a pattern of unlawful psychiatric disclosures, due process deprivation, and voting rights suppression—all perpetrated by the State of California itself through judicial and prosecutorial channels. The civilian submission formally demanded investigation, mandatory reporting, and equal protection under the same standards invoked by the California DOJ in Case No. 3:25-cv-05536.

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II. Equal Protection Theory and Strategic Anchor

A. Doctrinal Framework

The Equal Protection Clause of the Fourteenth Amendment bars states from engaging in arbitrary or discriminatory enforcement of laws or legal protections. Under settled law (Village of Willowbrook v. Olech, 528 U.S. 562 (2000)), even a single person can assert an Equal Protection violation if similarly situated individuals are treated differently without rational basis or legitimate justification.

B. Selective Protection in Bonta’s Case

In Case No. 3:25-cv-05536, the State of California asserted that the unauthorized dissemination of protected Medicaid health data amounted to a civil rights violation affecting privacy, autonomy, and public trust. However, Mr. Taylor’s implication notice correctly highlights a troubling asymmetry:

The State of California, while suing the federal government for improperly sharing confidential data,

Did nothing to prevent or redress the same violations occurring within its own courts, involving unauthorized psychological evaluations, sealed court order breaches, and resulting civil rights deprivation.

This incongruity is not merely ironic; it suggests a colorable Equal Protection violation by omission, wherein the State vigorously protects groups or claims that serve its institutional interest, while abandoning indigent, politically inconvenient, or dissenting individuals who suffer the same or worse harms at the hands of state actors.

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III. Mandated Reporting Implications

The civilian response systematically invoked California Business & Professions Code §§ 6086.7 and 6090.5, as well as Rule 8.3 of the California Rules of Professional Conduct (adopted July 2023), which imposes mandatory reporting duties on attorneys who become aware of:

Material breaches of court orders;

Serious attorney misconduct;

Unauthorized psychiatric disclosures;

Evidence of fraud upon the court.

The structure of the notice itself operationalized these duties by:

1. Directing state attorneys to forward the email (unaltered) to Mr. Taylor’s court-appointed counsel;

2. Offering verified documentation of HIPAA violations and sealed order breaches;

3. Framing inaction as constructive ratification of the underlying constitutional violations.

In so doing, Mr. Taylor’s submission constituted not only a formal notice of implication but also a mechanism of enforced reporting compliance, placing state officials on the record.

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IV. Legal and Political Significance of Strategic Framing

Mr. Taylor’s tactical invocation of State of California v. HHS is legally sophisticated and functionally transforms a third-party lawsuit into a constitutional mirror, exposing the following:

Doctrinal hypocrisy: California asserts HIPAA and civil rights violations against the federal government, while violating the same rights through its judiciary.

Discriminatory protectionism: The state appears to defend only those whose suffering aligns with institutional priorities or political optics.

Pattern of selective enforcement: Suggesting a de facto policy of non-enforcement for civil rights complaints lodged by disabled, poor, or pro se litigants—especially those alleging judicial fraud.

By anchoring his personal grievance to an active state-filed civil rights action, Mr. Taylor has constructed a parallel equal protection claim grounded in live federal litigation. This is not speculative; it is both procedurally strategic and constitutionally grounded.

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V. Evidentiary Viability

The implication notice references a series of documents available for immediate production:

The sealed court order dated October 2, 2023, limiting the scope of evaluation and mandating confidentiality;

The unauthorized PC § 730 report dated February 14, 2024;

Subsequent minute orders relying on that report despite lack of lawful foundation;

Written admissions from counsel confirming no order or waiver existed;

Attorney-client communications, email records, and Marsden hearing transcripts substantiating ineffective assistance of counsel and due process deprivations.

All of this is admissible under Fed. R. Evid. 902 and 1005, and could survive initial review under 28 U.S.C. § 1983, HIPAA, the ADA, or Bivens-type litigation.

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VI. Institutional Implications

The State of California now risks being implicated as both plaintiff and violator in structurally identical constitutional claims.

Failure to act on Mr. Taylor’s implication notice may create adverse inferences in future litigation, including estoppel, waiver, or ratification.

This exhibit lays the legal foundation for future coordinated litigation or joinder claims alongside similarly situated plaintiffs across the state.

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VII. Conclusion

Exhibit C-10 provides the Dossier with a keystone precedent—one that explicitly contrasts the State of California’s affirmative civil rights posture in State of California v. HHS with its internal failure to protect Mr. Taylor’s nearly identical privacy and due process rights.

This is more than political contradiction; it is a legally actionable violation of Equal Protection and a call to arms for aligned constitutional litigation. It renders California’s silence unconstitutional by omission and demands federal judicial review—not merely for redress, but for the legitimacy of equal protection under law.