Veterans Defending Veterans

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Veterans defending Veterans

The Law Offices of Randy Reep prevails in a sex offender residency restriction constitutional challenge with national implications.

Recently the Law Offices of Randy Reep won a constitutional challenge to the Nassau County Sex Offender Residency Restriction. The county ordinance increased the standoff distance of the state’s 1000 feet restriction by 250 percent and increased the number of places tenfold to over forty different types of locations.

The Law Offices of Randy Reep proved through constitutional argument and expert state of the art geo-spatial mapping that at least 99.1 percent of all Nassau county’s residential properties would be prohibited outright. For over twenty years, incredibly punishing sex offender residency restrictions drove this ostracized class to homelessness and the forests.

A disabled Vietnam War combat veteran and retired federal employee was charged with violating the Nassau County ordinance in 2018 shortly after moving to a quiet waterfront community with his wife of over forty years near Fernandina Beach, Florida. Despite having no registry violations whatsoever, the veteran faced the very real prospect of being forced to move out of Nassau county entirely, at great financial loss, shamed to banishment.

After months of legal battle, countless hours of research and analysis, Judge Wesley Poole (also a veteran himself) heard argument on the matter in April.

After considering the arguments, Judge Poole noted the following in GRANTING the Defendant’s Motion to Dismiss:


There is the “clearest proof of punishment in the County’s ordinance.” As noted above, the Commission evinces both civil and penal intent. But the penal effects are unambiguous: (1) Like many other sexual offenders in Nassau County, (Defendant) will be restrained from living virtually anywhere in the county; (2) at best, the County ordinance resembles probation and parole; at worst, outright banishment and public shaming; (3) while the Commission invokes deterrence, its focus on unpunished crimes, both past and future, betrays a retributive animus; (4) the sole basis for the restriction is a criminal conviction; (5) most of the enumerated crimes require scienter; (6) there is no rational connection between the ordinance, which regulates only where sexual offenders stay at night, and forces them into the streets or out of the county, thereby increasing the risk of recidivism, and defeats the goal of child protection, and (7) even if there were a rational connection, the ordinance is excessive in banishing (Defendant) to less than one percent of available housing in Nassau County without any regard to his individual risk, or lack thereof’


The Constitution protects us all, and the Law Offices of Randy Reep is honored to have served a warrior who himself defended the nation in a time of war, paid his debt to society, and has earned the right to live in peace.

Attorney John Holzbaur, a retired multiple combat tour veteran naval flight officer, served as lead counsel in this matter. Interested parties are invited to reach out to the Law Offices of Randy Reep for information on the continuously evolving matter of sex offender residency restrictions.





If you would like to learn more about The Law Offices of Randy Reep or to schedule a consultation, you can call us 904-830-4444 or email