Sara Wolosek v. Jaime L. Johnson

OFFICE OF THE CLERK
WISCONSIN COURT OF APPEALS
110 EAST MAIN STREET, SUITE 215
P.O. BOX 1688
MADISON, WISCONSIN 53701-1688
Telephone (608) 266-1880
TTY: (800) 947-3529
Facsimile (608) 267-0640
Web Site: www.wicourts.gov
DISTRICT III
September 29, 2026
To:
Hon. Mary M. Sowinski
Circuit Court Judge
Electronic Notice
Brenda Behrle
Clerk of Circuit Court
Oneida County Courthouse
Electronic Notice
Alexandra Nicole Francois
Electronic Notice
Jaime L. Johnson
Electronic Notice
You are hereby notified that the Court has entered the following opinion and order:
2024AP2516 Sara Wolosek v. Jaime L. Johnson (L. C. No. 2024CV231)
Before Stark, P.J., Hruz, and Gill, JJ.
Summary disposition orders may not be cited in any court of this state as precedent or
authority, except for the limited purposes specified in WIS. STAT. RULE 809.23(3).
Jaime Johnson, pro se, appeals from a harassment injunction issued against him pursuant
to WIS. STAT. § 813.125 (2023-24).1 The injunction bars Johnson from contacting or harassing
Oneida County Sheriff’s Deputy Sara Wolosek for a period of four years. It also requires him to
avoid her residence or any premises that she is temporarily occupying (which would include the
Oneida County Sheriff’s Office where she works) and orders him to surrender any firearms.
Johnson contends: (1) there is insufficient evidence to support the injunction; (2) the injunction is
1 All references to the Wisconsin Statutes are to the 2023-24 version.

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improperly based upon speculative fears and constitutionally protected expression; and (3) the
injunction violates Johnson’s rights to petition the government and have access to public
services. Based upon our review of the briefs and record,2 we conclude at conference that this
case is appropriate for summary disposition. See WIS. STAT. RULE 809.21. Although Johnson
has failed to file a reply brief and his claims are largely undeveloped, we will reach the merits of
his appeal and briefly explain why we reject Johnson’s arguments and affirm.
Our review of a harassment injunction involves mixed standards of review. We will
uphold the circuit court’s factual findings—including determinations about intent—unless they
are clearly erroneous. Board of Regents—UW Sys. v. Decker, 2014 WI 68, ¶20, 355 Wis. 2d
800, 850 N.W.2d 112; Welytok v. Ziolkowski, 2008 WI App 67, ¶¶26-27, 30, 312 Wis. 2d 435,
752 N.W.2d 359. We will independently determine, as a question of law, whether the
established facts provide adequate grounds for an injunction. Decker, 355 Wis. 2d 800, ¶20.
Assuming grounds have been established, the decision whether to grant an injunction, as well as
the scope of the injunction, lie within the court’s discretion. Id., ¶19. However, we also will
independently determine whether an injunction violates the subject’s constitutional rights.
Kindschy v. Aish, 2024 WI 27, ¶9, 412 Wis. 2d 319, 8 N.W.3d 1.
Regarding the sufficiency of the evidence, Wolosek needed to show reasonable grounds
to believe that Johnson “engaged in harassment with intent to harass or intimidate” Wolosek,
with clear and convincing evidence that Johnson might use a firearm to cause physical harm to
2 Throughout the response brief, Attorney Alexandra Francois has repeatedly violated WIS.
STAT. RULES 809.19(1)(i) and (3)(a)2., which require parties to be referred to by name rather than by
party designation in briefs. We admonish counsel to follow the rules in future filings with this court.

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another or to endanger public safety. WIS. STAT. § 813.125(4)(a)3, (4m)(a). The injunction
statute defines “harassment” as “[e]ngaging in a course of conduct or repeatedly committing acts
which harass or intimidate another person and which serve no legitimate purpose.”
Sec. 813.125(1)(am)4.b. Case law further adopts the common dictionary definitions that
“[h]arass” means “to worry and impede by repeated attacks, to vex, trouble or annoy continually
or chronically, to plague, bedevil or badger,” while “[i]ntimidate” means “to make timid or
fearful.” Bachowski v. Salamone, 139 Wis. 2d 397, 407, 407 N.W.2d 533 (1987) (citation
omitted).
The analogous criminal harassment statute defines a “[c]ourse of conduct” as a “pattern
of conduct composed of a series of acts over a period of time, however short, evidencing a
continuity of purpose.” WIS. STAT. § 947.013(1)(a); Welytok, 312 Wis. 2d 435, ¶25 (applying
the definition in § 947.013(1)(a) to a predecessor injunction statute). A course of conduct or
repetitive acts that are intended, even in part, to harass or intimidate do not serve a legitimate
purpose. Decker, 355 Wis. 2d 800, ¶38.
At the injunction hearing, Wolosek testified that she was involved in the investigation of
a domestic violence incident on May 23, 2023, that resulted in Johnson’s arrest. During the
incident, Johnson displayed erratic and violent behavior that Wolosek thought suggested he was
under the influence of drugs. Among other things, Johnson lunged at another deputy and tried to
head butt that deputy; gouged his own face with the handcuffs around his wrists; put a large dent
into Wolosek’s squad car with his head; and vacillated between extreme emotions, from crying
to yelling. Wolosek had also observed Johnson “go from crying to angry in a matter of seconds”
during prior contacts with him. Wolosek subsequently testified at a revocation hearing for
Johnson that was triggered by the May 23 incident.

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Following his arrest, Johnson lodged both a Prison Rape Elimination Act (PREA)
complaint and a citizen’s complaint against Wolosek. Both complaints were based upon the
facts that: (1) Wolosek had admittedly threatened, while transporting Johnson to the hospital
following his arrest, to give Johnson “the biggest dick punch of his life” if he attempted to hurt
anyone in the hospital, and (2) Wolosek remained present while Johnson was strip searched by
jail staff during his subsequent booking at the jail. Both incidents were recorded, but both
complaints were ultimately deemed to be unfounded, and no discipline was imposed on
Wolosek. The PREA coordinator informed Johnson by email that the PREA complaint had been
determined to be unfounded but did not provide a “close-out letter” or other written explanation
of the reasons for the decision. Johnson also filed two John Doe complaints against Wolosek
related to his arrest that were dismissed.
While incarcerated at the Oneida County Jail, Johnson sent Wolosek a series of messages
through the jail’s kiosk messaging system, continuing to complain about the manner of his arrest.
In one of the messages, Johnson wrote:
Did you learn the dick punching technique while you were logging
training hours cheating on your family? Ive done some dumb shit
in my day but havent had a newspaper article written about me.…
Do you dick punch with an open mouth? Cause you told my judge
that you use yor mouth and words to control suspects? Just curios.
In another message, Johnson called Wolosek a “POS,” which he acknowledged meant piece of
shit.
After his PREA complaint had already been determined to be unfounded, Johnson also
sent expletive-filled jail kiosk messages making derogatory and personal comments about
Wolosek to Wolosek’s boss, Sheriff Gardy Hartman; Johnson’s former probation officer, Wendy

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McCormack; and several other people. These comments included referring to a negative news
article about Wolosek; asserting that Wolosek had stripped Johnson naked in front of another
female deputy; characterizing Wolosek’s conduct during the arrest and strip search as sexual
assault or excessive force; and calling Wolosek a “useless ass” and a “lesbian looking friend,
mother and wife of the year.” One of the messages to the probation agent stated: “dont go
retiring on me.. I’ll be back.. I checked the game-score card…. Your up 2 revocations and im
on board with an extortion win. My move.” Inmates were advised in the jail rule book that
messages sent by inmates through the jail’s kiosk messaging system were reviewed by jail
personnel.
After Johnson was transferred to the Wisconsin prison system, he sent a series of letters
to other inmates discussing his ongoing campaign against Wolosek and the Oneida County
Sheriff’s Office. In one, Johnson wrote, “Fuck Oneida County. Make sure you tell them, Sheriff
included, that I’m coming for them.” He continued: “If you see Sara Wolosek, tell her I can’t
wait to get dick punched by her when I get out. All her coworkers wanted to cover up her
misdeeds. Now it’s gonna be her fault they all unemployed. (I love that they read all this.
Bahahahah … Fuck ‘em!” In another, Johnson wrote: “So this is what I’m on right
now … Bringing down the Office of the Sheriff. I’m putting together an investigation, and I’m
good with paperwork. And they are fucked for what they did to me.” In a third, he wrote:
I cant wait til they get what I got coming for them. At least this
gives me an oppertunity to passive aggresivley talk shit indirectly.
Like for instence, that Mark Neuman shouldv’e just done the job
the tax payers paid him to do instead of trying to cover for Sera
Wolosek, cause now it’s gonna cost him his pension…. If Yor
reading this … Yor all Fucked.

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He went on: “I swear, I’m gonna name a park after me w/ the money they pay me. I hope they
reading this and laughing … ‘What an idiot’ cause I’m the Perfect Inmate for them to fuck.” He
continued:
Bitch went out of her way to fuck me over. Sat up and laughed
with the DA while I was testifying. Ha ha ha ha ha … We see who
laughing. Then they charge me criminaly … okay—GAME ON!
She can come dick punch me when I win her pension too.
Finally, Johnson wrote, “Is Dick Punching an authorized use of force. Hope she enjoys those
sergeant stripes while she has them. Bahahahahahaha. So Fucking Funny now heh? I bet her ex
husband think it’s funny!!!”
Wolosek testified that Johnson’s “continuous messaging and not letting it go” led her to
believe that Johnson was obsessed with her. Although Wolosek had encountered other
defendants who had made threats against her in the past, she said this was the first time in her 24
years of working at the Oneida County Sheriff’s Office that she had become genuinely
concerned for the safety of herself and her family.
One of Wolosek’s coworkers also testified that he observed Wolosek make changes in
her personal life to protect herself and her family from Johnson following Johnson’s release from
incarceration. The coworker had never seen anyone send the amount of correspondence that
Johnson did in support of his complaints.
Johnson testified that he was having a mental health episode during the time of his arrest
and was not on drugs. He stated that the reason he kept sending correspondence to officials was
that his complaints had been ignored rather than acted upon. Johnson asserted that he was
seeking accountability through legal means, not revenge. He characterized his statements to

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other inmates as “venting.” He denied that he had ever made any threats and asserted that he did
not own any firearms.
The circuit court made factual findings that Johnson began sending messages to Wolosek
on July 7, 2023, after he was blocked from having contact with the victim of the domestic
violence incident. After September 25, Johnson’s messages were sent to other people rather than
directly to Wolosek. The court noted that many of Johnson’s messages included references to
Wolosek’s personal life and derogatory comments about her, indicating that he had a “personal
grudge” against her and held her personally responsible for some of his troubles. The court also
observed that many of Johnson’s comments were misogynistic, showing that he appeared to have
a problem with women. The court construed Johnson’s comment to his probation agent that he
would “be back” as a threat. The court further noted that Johnson’s statement that he would be
“coming for” Oneida County staff would include Wolosek. The court concluded that Johnson’s
intent was to “freak people out,” that he had no legitimate reason for making vulgar and
derogatory personal statements to and about Wolosek, and that Johnson’s conduct demonstrated
the possibility that he might use a firearm to harm Wolosek or others. The court granted the
injunction and also ordered Johnson to surrender any firearms.
Johnson first argues that the evidence was insufficient to support the injunction because
he had not directly communicated with Wolosek for over a year and that none of his
correspondence contained any threats of physical harm against her, making her fears for her
safety merely speculative. However, as discussed above, the definition of harassment does not
require either direct communication or threats. Johnson’s ongoing conduct of making derogatory
comments about Wolosek in correspondence to her supervisors, other professionals, and fellow
inmates (which he knew would be seen by jail staff) constituted harassment because it

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continually annoyed and badgered Wolosek. Wolosek’s fear for her safety was no more
speculative than any future event must necessarily be to some degree. That fear was reasonable
based upon the combination of the incessant nature of Johnson’s correspondence, Johnson’s
history of violence and mood swings, and the vague threat he made against another person who
Johnson had perceived to have harmed him.
Johnson’s next argument that he had a legitimate—and constitutionally protected—
reason for filing complaints against Wolosek is unpersuasive because he fails to acknowledge the
distinction between filing complaints and making personal and derogatory comments within
those complaints. Although he does acknowledge that First Amendment rights are not absolute
and do not protect harassment, Johnson also fails to understand that conduct may constitute
harassment when it is motivated even in part by an illegitimate purpose. The record here
supports the circuit court’s determination that Johnson’s ongoing personal attacks against
Wolosek in his correspondence were motivated in part by misogyny and anger at Wolosek’s role
in his revocation, even if Johnson also genuinely believed that he had been mistreated during his
arrest. The constitution does not protect speech that is motivated by illegitimate purposes. See
Welytok, 312 Wis. 2d 435, ¶¶16, 31 (explaining that a course of conduct that included
disseminating true negative information about a competing attorney’s past disciplinary
proceeding formed part of the valid basis for a harassment determination when motivated by a
desire for revenge rather than consumer protection).
Finally, Johnson’s assertion that the injunction denies him the right to file complaints and
have access to the sheriff’s office ignores the fact that the circuit court explicitly stated at the
hearing that Johnson is still allowed to write to people in the sheriff’s office, to publicly discuss
his complaints about his arrest and strip search using generic references to an Oneida County

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deputy, and to make legal filings. In short, the limitations imposed on the manner in which
Johnson pursues redress are properly tailored to address the form of harassment he has been
engaging in, and they are not overly broad.
Upon the foregoing,
IT IS ORDERED that the order is summarily affirmed. WIS. STAT. RULE 809.21.
IT IS FURTHER ORDERED that this summary disposition order will not be published.
Samuel A. Christensen
Clerk of Court of Appeals