On June 12, DOJ attorney Joseph Finarelli—counsel for the North Carolina Human Relations Commission—filed an unsolicited memorandum opposing my Rule 60(b) motion, not to defend the agency’s conduct but to justify the Tribunal’s legal reasoning. This filing was never ordered and exceeded DOJ’s scope under N.C. Gen. Stat. § 150B-23(a), which authorizes representation of agencies—not administrative judges. It was clear from the timing and content that the memorandum was intended to retroactively justify a denial already in the works. DOJ had failed to file a required memorandum in March when ordered by the Tribunal but was now permitted to submit one voluntarily, revealing a selective enforcement of procedural rules and an unequal playing field.
In response, I filed a Motion to Strike on June 13, pointing out that DOJ had no standing to defend the ALJ’s logic and that their filing only reinforced concerns of improper coordination and retaliation against me as a pro se, neurodivergent litigant. I highlighted how this filing circumvented fair process, misrepresented my arguments, and further demonstrated that the Tribunal and DOJ were acting in concert to discredit my legal position rather than address my due process claims. I made clear that if the Tribunal relied on this unauthorized defense to justify its denial, it would only strengthen my ongoing § 1983 claim for due process violations and retaliatory adjudication.
On June 16, DOJ responded again—this time characterizing my motion to strike as “threatening” and “bad faith,” attempting to paint my legal objections as emotional outbursts. Their filing failed to address the central point: that DOJ cannot legally act as counsel for the Tribunal.
By continuing to minimize valid procedural challenges and reframing them as personal attacks, DOJ only confirmed the exact pattern of distortion, deflection, and bias I’ve documented throughout this case. This has not been a case based in proper law and merit, but a targeted campaign to distract from NCHRC’s misconduct.