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1 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 1 of 28 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF INDIANA, INDIANAPOLIS DIVISION RACHEL LONG, as Administrator for the ESTATE OF DONTE LAMONT SOWELL and on behalf of herself, Plaintiff, v. CITY OF INDIANAPOLIS, INDIANAPOLIS METROPOLITAN POLICE DEPARMTENT OFFICER JAVED RICHARDS, AS-YET UNKNOWN METROPOLITAN POLICE DEPARTMENT OFFICERS, AMBER WOODS COOPERATIVE, FLAHERTY & COLLINS PROPERTIES, SPECIAL TASK FORCE PROTECTION AGENCY LLC (A.K.A. CRIME PREVENTION TASK FORCE SPECIAL SERVICES, INC., STEPFON SEYMOUR, and AS-YET UNKNOWN SECURITY GUARD EMPLOYEES OF THE SPECIAL TASK FORCE PROTECTION AGENCY LLC, Defendants. Case No. 15 C 252 JURY TRIAL DEMANDED COMPLAINT Plaintiff Rachel Long, as Administrator for the Estate of Donte Lamont Sowell, by and through her attorneys, Loevy & Loevy, complains of Defendants City of Indianapolis; Indianapolis Metropolitan Police Department ( IMPD Officer Javed Richards and other unknown Indianapolis Metropolitan Police Department Officers (collectively, Defendant Officers ; Amber Woods Cooperative; Flaherty & Collins Properties; Special Task Force Protection Agency LLC (also known as Crime Prevention Task Force Special Services, Inc.; and Stepfon Seymour and other as-yet unknown Security Guards employed by Special Task Force Protection Agency LLC (collectively, Defendant Security Guards, stating:

2 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 2 of 28 Introduction 1. Donte Lamont Sowell was shot in the back and killed without justification by one or more of the Defendant Officers and Defendant Security Guards. At the time the Defendants killed Mr. Sowell, he had surrendered, was unarmed, and presented no threat to Defendants or anyone else. 2. To cover up their misconduct, the Defendants falsely claimed that Mr. Sowell had shot at them. In actuality, all of the shooting was perpetrated by various Defendants, who were each shooting at Mr. Sowell. 3. The Defendants unlawful conduct is the product of the policies and practices of the Indianapolis Metropolitan Police Department ( IMPD, which has for years permitted its officers and agents to shoot at Indianapolis residents without any meaningful training, supervision, post-incident review, or discipline. 4. Mr. Sowell s death has proven no exception to this rule. Within hours of the shooting, IMPD spokespersons relayed Defendants false account to the media, thus deeming it justified before a proper investigation could take place. 5. Not only has Indianapolis failed to hold anyone accountable for Mr. Sowell s death, but it has also refused to disclose any meaningful information about the shooting including any video recordings of the shooting to Mr. Sowell s family. 6. Ms. Long brings this action pursuant to 42 U.S.C and Indiana law to hold Defendants accountable for their actions; to redress the devastating injuries to Mr. Sowell s Estate caused by the unjustified shooting; and to require IMPD to release any existing video of Mr. Sowell s shooting. 2

3 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 3 of 28 Jurisdiction and Venue 7. This Court has jurisdiction pursuant to 28 U.S.C & Venue is proper pursuant to 28 U.S.C. 1391(b. The events giving rise to the claims asserted herein all occurred within the district, Defendant City of Indianapolis is a municipal corporation located here, and, on information and belief, all or most of the parties reside in this judicial district. Parties 9. Before he was shot and killed by the Defendants, Donte Lamont Sowell was a 27-year-old lifelong resident of Indianapolis, a much beloved member of his closeknit community, and a father to three young children. At the time of his death, Mr. Sowell lived with his fiancée, Rachel Long, who was pregnant with Mr. Sowell s fourth child, a daughter born in August Rachel Long is the administrator of Mr. Sowell s estate and was Mr. Sowell s fiancée at the time of his death. 11. Defendant City of Indianapolis is a municipal corporation under the laws of the State of Indiana. 12. Defendant Javed Richards is an IMPD police officer. At all times relevant to this Complaint, Defendant Richards and as-yet unknown City of Indianapolis police officers acted under color of law and within the scope of their employment as police officers for the City of Indianapolis. 13. Defendant Amber Woods Cooperative is the housing development where Mr. Sowell was shot and killed. Defendant Amber Woods Cooperative is owned and managed by Flaherty & Collins Properties. 3

4 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 4 of Defendant Flaherty & Collins Properties develops, owns, and manages residential apartments including the Amber Woods Cooperative housing development where Mr. Sowell was shot and killed. At all times relevant to this Complaint, Defendant Flaherty & Collins Properties employed Defendant Special Task Force Protection Services Agency LLC to provide police services at the Amber Woods Cooperative despite having previously received notice of a myriad of complaints from residents that security guards employed by Special Task Force Protection Services Agency LLC routinely harassed residents and overstepped their authority at the Amber Woods Cooperative. 15. Defendant Special Task Force Protection Agency LLC (a.k.a. Crime Prevention Task Force Special Services, Inc. is a security company located in Indianapolis, Indiana that employed the Defendant Security Guard(s who shot Mr. Sowell. At all times relevant to this Complaint, Defendant Special Task Force Protection Agency LLC provided police services in the Amber Woods Cooperative; hired current or former police officers; acted in concert with, as agents for, and with the approval of IMPD; patrolled a low-income housing development funded by state money; and acted with police powers granted by a state licensing body. Special Task Force Protection Agency LLC continued to employ Defendant Stephfon Seymour and the other Defendant Security Guards despite having received notice of a myriad of complaints from residents that security guards employed by Special Task Force Protection Services Agency LLC routinely harassed residents and overstepped their authority at the Amber Woods Cooperative. 4

5 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 5 of Defendant Stephfon Seymour is a security guard employed by Special Task Force Protection Services Agency LLC. At all times relevant to this Complaint, Defendant Seymour and other as-yet unknown security guards employed by Special Task Force Protection Services Agency LLC to provide security at the Amber Woods Cooperative acted as state actors. They were current and/or former law enforcement officers themselves; they acted in concert with and as agents for IMPD; their conduct was facilitated, condoned, and approved of by IMPD; they acted with police powers granted by a state licensing body; and they patrolled a low-income housing development funded by state money. The Shooting of Mr. Sowell 17. On the evening of January 15, 2015, Donte Sowell and his brother left the Amber Woods Cooperative in Indianapolis by car. 18. Within just two blocks of his departure from the Amber Woods apartments, Mr. Sowell s brother, who was driving, was pulled over for a traffic stop by a female Defendant Officer in a marked police car. 19. The traffic stop was unlawful. The female Defendant Officer lacked any reasonable basis to believe that Mr. Sowell s brother had done anything illegal or improper. In fact, Mr. Sowell s brother had not violated any law or ordinance while driving. 20. Nonetheless, Mr. Sowell s brother promptly pulled into the gas station at the corner of 38th Street and Mitthoefer Road and stopped the car. 21. Mr. Sowell, alarmed by the unjustified stop, exited the car and ran south in the direction of the Amber Woods Apartments. 5

6 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 6 of The female Defendant Officer searched Mr. Sowell s brother and the car. She found no weapons or contraband of any sort and did not charge Mr. Sowell s brother with any traffic or criminal violations. 23. The female Defendant Officer radioed a description of Mr. Sowell s appearance and location on a publicly available frequency. 24. As Mr. Sowell ran into Amber Woods, one or more Defendant Officers and one or more Defendant Security Guards began shooting at Mr. Sowell, who had done nothing to justify this use of deadly force. 25. Mr. Sowell surrendered, but the Defendant Officer(s and Defendant Security Guard(s continued to shoot at him, coordinating their efforts. 26. As Defendants were well aware, Mr. Sowell was unarmed and posed no threat to anyone at the time Defendants shot him. 27. The Defendant Officer(s and Defendant Security Guard(s fired many bullets at Mr. Sowell, at least two of which hit him in the back. 28. Additional Defendant Officers and Defendant Security Guards who were present had a reasonable opportunity to prevent the violation of Mr. Sowell s constitutional rights, but failed to do so. 29. Defendant Officers were the first people to reach Mr. Sowell after the shooting and recovered no weapon from him or the surrounding area. 30. The Defendant Officers handcuffed Mr. Sowell, who was lying on the ground gravely wounded. They did not perform cardiopulmonary resuscitation ( CPR or provide any other medical assistance in the time it took for an ambulance to arrive. 6

7 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 7 of Mr. Sowell remained alive and experienced excruciating pain and suffering from the time he was first shot by the Defendant Officer(s and Defendant Security Guard(s until he died handcuffed to a hospital bed several hours later. 32. The fatal shooting of Mr. Sowell was entirely unjustified and unnecessary. Mr. Sowell had done nothing which could have justified the use of deadly force. 33. After the shooting, the Defendant Officers falsely claimed that Mr. Sowell had fired at them, to conceal their misconduct. 34. Those statements were fabricated. As is explained above, Mr. Sowell presented no threat to anyone and was not carrying a gun let alone shooting one when Defendants killed him. 35. On the night of the shooting, IMPD spokespersons relayed to the media that Mr. Sowell had shot at police officers, thus justifying the Defendant Officers conduct within hours of its occurrence. That justification was patently false. 36. In addition to falsely deeming the Defendant Officers shooting justified, the City of Indianapolis failed to investigate or prosecute the Defendant Security Guard(s for shooting at Mr. Sowell without cause and conspired with them to conceal the unjustified nature of the shooting. 37. As a result of Defendants misconduct, the Estate of Donte Sowell suffered devastating injuries that included physical harm from at least six gunshot wounds; death; loss of liberty, property, and companionship; great mental anguish; humiliation; degradation; anxiety; and financial loss. 7

8 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 8 of 28 The City of Indianapolis s Policies and Practices 38. The Defendant Officer and Security Guards unlawful conduct was directly caused by the City of Indianapolis and IMPD s deficient policies and practices regarding police shootings of civilians. These policies and practices include the failure to provide meaningful training and supervision regarding the use of deadly force, such as against people fleeing from police officers; inadequate post-incident review; and a lack of meaningful discipline for excessive force, including the use of unjustified deadly force. 39. IMPD, which was created in 2007 through a merger of the Indianapolis Police Department and the Marion County Sheriff s Department, has a long history of unjustified police shootings and other use of force violations. As but a few examples: a. In 1996, a jury found that Indianapolis police officers Charles F. Penniston and Edwin M. Aurs had killed 16-year-old Michael Taylor while he was handcuffed in the back of a squad car. The police initially claimed that Taylor had shot himself in the head, while handcuffed, with a gun hidden in his shoe. A jury rejected that version of events, awarding Taylor s family over $3 million dollars in damages. Penniston and Aurs, however, were permitted to remain on duty. b. In 2001, Officer Ronald Shelnutt of the Marion County Sheriff s Department awoke, shot, and killed a sleeping stockbroker who had broken into his own home because he did not have his keys. Although the City settled the case for nearly a million dollars, the Indianapolis Firearms Review Board exonerated Shelnutt of all misconduct. Not only did Indianapolis fail to fire Shelnett at that time, but it continued to employ him after he was involved in a 2005 high speed chase that ended in 8

9 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 9 of 28 two deaths, prompting a second wrongful death lawsuit; after he was accused in two separate cases of releasing K-9 dogs on suspects who had surrendered, both of which resulted in confidential settlements; and after he initiated a high-speed chase in 2008 that caused yet another two fatalities. Shelnutt remains on the IMPD force today. c. In May 2010, Indianapolis police officer Jerry Piland subjected 15- year-old Brandon Johnson to an unjustified beating that was documented in horrific photographs. Although the advisory Indianapolis Citizens Police Complaint Board recommended disciplinary action and Indianapolis settled the resulting lawsuit for $150,000, IMPD s Internal Affairs Division exonerated Piland of any wrongdoing and placed him back on duty. d. In May 2014, IMPD officers Justin Beaton and Jennifer Gabel kicked and repeatedly deployed their stun guns on 29-year-old Marcus Jackson. A portion of Jackson s arrest was captured on video, showing Beaton brutalizing Jackson as he lay limp and face-down. Despite public outcry, Indianapolis failed to discipline the officers and placed them back on duty, until Beaton was arrested earlier this year for beating and attempting to murder his girlfriend. 40. The City of Indianapolis s rate of police shootings of civilians is staggeringly high. In 2013, for example, IMPD officers shot and killed nearly as many civilians as police in New York City, whose population is nearly ten times greater than that of Indianapolis. See Killed by Police 2013, This year alone, Indianapolis Municipal Police Department officers have fatally shot and killed at least seven people, including Mr. Sowell. See Killed by Police 9

10 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 10 of , As high-ranking police leaders acknowledge, inadequate training, supervision, and review of police officers sharply increases of the frequency of police shootings. For example, Police Commissioner Raymond Kelly credits New York s success in reducing police shootings to its improvement in training procedures and a more thorough shooting-review process. See Sean Gardner, NYPD Marks All Time Low In Shootings, Wall Street Journal, Jan. 11, Likewise, Police Chief Gary McCarthy credits better training and supervision as well as restraint by officers for reductions in shootings in Chicago. See Jeremy Gorner, Police-Involved Shootings Down Sharply in Chicago So Far This Year, Chicago Tribune, May 20, Unlike some of their counterparts, however, Indianapolis and IMPD have failed to adopt reforms to reduce unnecessary and unjustified police shootings despite notice of their occurrence at disturbing rates. 44. When excessive force incidents occur, IMPD rarely undertakes a meaningful review and almost never disciplines any officers. A 2012 external audit of IMPD s Professional Standards Division concluded that the current system of managing and ensuring police accountability in the IMPD is significantly flawed, if not broken. See Audit: IMPD's Issues Significant, Problematic : Consulting Group Reviews Department's Internal Investigation Process, The Indy Channel, March 26, Recognizing the scope of IMPD officer misconduct, former Indianapolis Public Safety Director Frank Straub stated in 2010: We have ignored people, and 10

11 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 11 of 28 trouble has followed. Inaction by supervisors or someone else led to unnecessary incidents. See It s gotten out of control, IndyStar.com, Aug. 29, Indianapolis and IMPD s failures to train, supervise, review, and discipline police officers with regard to unjustified police shootings in the face of widespread de facto policies permitting the use of excessive deadly force reflect deliberate indifference to Indianapolis residents and were the moving force behind Mr. Sowell s tragic and unnecessary death. IMPD s Refusal to Release Video of Mr. Sowell s Shooting 47. Due to the ubiquitous nature of recording devices, the deadly encounter between Defendants and Mr. Sowell may well have been captured on video. Many police squad cars are equipped with recording devices; many buildings and city buses record surveillance video; many members of the public use cell phones to record suspicious police interactions; and, at the time of Mr. Sowell s shooting, certain IMPD officers were equipped with body cameras. 48. Following the Defendants killing of Mr. Sowell, Plaintiff requested from IMPD a copy of any video recordings depicting Defendants shooting of Mr. Sowell. Specifically, Plaintiff requested: A copy of all video recordings depicting any events that transpired during the interaction between Donte Sowell and members of IMPD on January 15, This request includes but is not limited to recordings from dashboard cameras, body cameras, police car cameras, security cameras, cameras on buses, and cameras on city buildings. 49. IMPD refused to produce the requested video recordings, in violation of the First Amendment of the United States Constitution and the common law. 11

12 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 12 of In response, IMPD initially contended that Plaintiff s request was insufficiently particular, even after Plaintiff enclosed a copy of the police report describing the shooting. 51. IMPD also refused to confirm whether or not it had responsive records, despite Plaintiff s repeated requests for such information. 52. When IMPD finally considered the merits of Plaintiff s request, it claimed an entitlement to withhold responsive recordings pursuant to the investigatory records exemption in the Indiana Access to Public Records Act, see Indiana Code (b( In making this claim, IMPD failed to disclose whether it had any responsive video recordings, and if so, from what source; failed to offer any justification for the withholding other than the mere exercise of its discretion; and withheld responsive records even though it had just released video of IMPD officers April 2015 shooting of Mack Long, which post-dated the shooting of Mr. Sowell by nearly three months. 54. Plaintiff has filed a formal complaint seeking an advisory opinion from the Office of the Public Access Counsel that declares IMPD s conduct to be a violation of Plaintiff s rights, but has not yet received a response to that complaint. 55. The public s right to information about the workings of government is a cornerstone of the democratic form of government, and of particular importance when police officers shoot and kill civilians. 56. Police departments may not selectively disclose video recordings of police shootings when such recordings serve their interests, and withhold them when they do 12

13 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 13 of 28 not. Instead, the public, to fulfill its role of holding police departments accountable, is entitled to access all video recordings that depict police officers shooting and killing civilians, such as Mr. Sowell, during the course of performing official police duties in public places. Count U.S.C Excessive Force 57. Each Paragraph of this Complaint is incorporated herein. 58. In the manner described above, the conduct of one or more of the Defendant Officers and Defendant Security Guards constituted excessive force in violation of the Fourth and Fourteenth Amendments to the United States Constitution. 59. The misconduct described in this Count was objectively unreasonable and was undertaken intentionally with willful indifference to Mr. Sowell s constitutional rights. 60. The misconduct described in this Count was undertaken with malice, willfulness, and reckless indifference to the rights of others. 61. The Individual Defendants misconduct described in this Count was undertaken pursuant to the policy and practice of the City of Indianapolis in that: a. As a matter of both policy and practice, the IMPD directly encourages, and is thereby the moving force behind, the very type of misconduct at issue here by failing to adequately train and supervise its officers regarding the use of deadly force on fleeing suspects, such that its failure to do so manifests deliberate indifference; b. As a matter of both policy and practice, the City facilitates the very type of misconduct at issue here by failing to adequately review and discipline prior 13

14 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 14 of 28 instances of similar misconduct, thereby leading Indianapolis Police Officers to believe their actions will never be scrutinized and, in that way, directly encouraging future abuses such as those affecting Mr. Sowell. Specifically, Indianapolis Police Officers accused of excessive force can be confident that those accusations will not be investigated in earnest by the IMPD, and that the IMPD will decline to recommend discipline even where the officer has engaged in excessive force; c. Generally, as a matter of widespread practice so prevalent as to comprise municipal policy, IMPD officers abuse citizens in a manner similar to that alleged by Plaintiff in this Count on a frequent basis, yet the IMPD makes findings of wrongdoing in a disproportionately small number of cases; d. City policy-makers are aware of, and condone and facilitate by their inaction, a code of silence in the IMPD. Police officers routinely fail to report instances of police misconduct and lie to protect each other from punishment, and go un-disciplined for doing so; and, e. The City of Indianapolis has failed to act to remedy the patterns of abuse, despite actual knowledge of the same, thereby causing the types of injuries alleged here. f. The City of Indianapolis fails to utilize records of allegations of excessive force against its officers to identify and respond to patterns of misconduct by its officers. 62. As a result of the Defendants misconduct described in this Count, the Estate of Donte Sowell has suffered injury, including physical harm, mental distress, and death. 14

15 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 15 of 28 Count U.S.C False Arrest 63. Each Paragraph of this Complaint is incorporated herein. 64. As is described more fully above, one or more of the Defendant Officers and Defendant Security Guards falsely arrested and unlawfully detained Mr. Sowell without justification and without probable cause in violation of the Fourth and Fourteenth Amendments to the United States Constitution. 65. The misconduct described in this Count was undertaken with malice, willfulness, and reckless indifference to Mr. Sowell s constitutional rights. 66. The misconduct described in this Count was objectively unreasonable and was undertaken intentionally with willful indifference to Mr. Sowell s constitutional rights. 67. The Individual Defendants misconduct described in this Count was undertaken pursuant to the custom, policy, and/or practice of Defendant City of Indianapolis, such that Defendant City of Indianapolis is also liable, as described above. 68. As a result of the Defendants misconduct described in this Count, the Estate of Donte Sowell has suffered injury, including physical harm, mental distress, and death. Count U.S.C Unlawful Search and Seizure 69. Each of the Paragraphs of this Complaint is incorporated herein. 70. In the manner described above, one or more of the Defendant Officers and Defendant Security Guards violated Mr. Sowell s Fourth Amendment right to be free 15

16 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 16 of 28 from unreasonable search and seizure by seizing Mr. Sowell without justification and without probable cause. 71. The misconduct described in this Count was objectively unreasonable and undertaken with malice, willfulness, and reckless indifference to the rights of others. 72. The Individual Defendants misconduct described in this Count was undertaken pursuant to the custom, policy, and/or practice of Defendant City of Indianapolis, such that Defendant City of Indianapolis is also liable, as described above. 73. As a result of the Defendants misconduct described in this Count, the Estate of Donte Sowell has suffered injury, including physical harm, mental distress, and death. Count U.S.C Failure to Intervene 74. Each Paragraph of this Complaint is incorporated herein. 75. In the manner described above, one or more of the Defendant Officers and Defendant Security Guards had a reasonable opportunity to prevent the violation of Mr. Sowell s constitutional rights as set forth above, but failed to do so. 76. The Individual Defendants actions were undertaken intentionally, with malice and reckless indifference to Mr. Sowell s rights. 77. The Individual Defendants misconduct described in this Count was undertaken pursuant to the custom, policy, and/or practice of Defendant City of Indianapolis, such that Defendant City of Indianapolis is also liable, as described above. 78. As a result of the Defendants misconduct described in this Count, the Estate of Donte Sowell has suffered injury, including physical harm, mental distress, and death. 16

17 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 17 of 28 Count U.S.C Conspiracy to Deprive Constitutional Rights 79. Each Paragraph of this Complaint is incorporated herein. 80. In the manner described above, there was an agreement between two or more of the Defendant Officer(s and Defendant Security Guard(s to deprive Mr. Sowell of his constitutional rights. 81. Specifically, the Defendants conspired by concerted action to accomplish an unlawful purpose by an unlawful means. In furtherance of the conspiracy, each of the co-conspirators committed overt acts and was an otherwise willful participant in joint activity. 82. The conspiring Defendants actions were undertaken intentionally, with malice and reckless indifference to Mr. Sowell s rights. 83. The Individual Defendants misconduct described in this Count was undertaken pursuant to the custom, policy, and/or practice of Defendant City of Indianapolis, such that Defendant City of Indianapolis is also liable, as described above. 84. As a result of the Defendants misconduct described in this Count, the Estate of Donte Sowell has suffered injury, including physical harm, mental distress, and death. Count U.S.C Denial of Medical Attention 85. Each Paragraph of this Complaint is incorporated herein. 86. As described more fully above, while Mr. Sowell was falsely imprisoned by Defendant Officers and Defendant Security Guards, he was denied necessary medical attention. 17

18 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 18 of The conduct of the Defendant Officers and Defendant Security Guards was objectively unreasonable and they were deliberately indifferent to Mr. Sowell s objectively serious medical needs. 88. As a result of the Individual Defendants objectively unreasonable conduct and deliberate indifference to Mr. Sowell s necessary medical needs, the Estate of Donte Sowell suffered damages, including but not limited to pain and suffering and mental distress. Count 7 -- State Law Claim Assault and Battery 89. Each Paragraph of this Complaint is incorporated herein. 90. In the manner described above, the conduct of one or more Defendant Officers and Defendant Security Guards, acting under color of law and within the scope of his employment, constituted unjustified and offensive physical contact, undertaken willfully and wantonly, proximately causing Mr. Sowell s bodily injuries. 91. The misconduct described in this Count was objectively unreasonable and was undertaken intentionally with willful indifference to Mr. Sowell s constitutional rights. 92. The misconduct described in this Count was undertaken with malice, willfulness, and reckless indifference to the rights of others. 93. As a result of the Defendants misconduct described in this Count, the Estate of Donte Sowell sustained bodily and other injuries, including but not limited to great bodily harm and a reasonable apprehension of great bodily harm. 18

19 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 19 of 28 Count 8 -- State Law Claim False Arrest and False Imprisonment 94. Each Paragraph of this Complaint is incorporated herein. 95. Mr. Sowell was imprisoned by Defendant Officer(s and Defendant Security Guard(s, and thereby had his liberty to move about unlawfully restrained, despite Defendants knowledge that there was no probable cause for the imprisonment. 96. The actions of the Defendants were undertaken intentionally, with malice and reckless indifference to Mr. Sowell s rights. 97. As a result of the Defendants misconduct described in this Count, the Estate of Donte Sowell has suffered injury, including physical harm, mental distress, and death. Count 9 -- State Law Claim Conspiracy 98. Each of the Paragraphs of this Complaint is incorporated herein. 99. In the manner described above, the Defendant Officer(s and Defendant Security Guard(s, acting in concert, reached an agreement among themselves to shoot Mr. Sowell without justification and conspired by concerted action to accomplish an unlawful purpose by an unlawful means. In addition, these co-conspirators agreed among themselves to protect one another from liability for depriving Mr. Sowell of these rights In furtherance of their conspiracy, each of these co-conspirators committed overt acts and were otherwise willful participants in joint activity. 19

20 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 20 of The misconduct described in this Count was objectively unreasonable and was undertaken intentionally, with malice, with reckless indifference to the rights of others, and in total disregard of the truth and Mr. Sowell s innocence of their claims As a result of the Defendants misconduct described in this Count, the Estate of Donte Sowell suffered injury, including physical harm, mental distress, and death. Count State Law Claim Intentional Infliction of Emotional Distress 103. Each Paragraph of this Complaint is incorporated herein The actions, omissions, and conduct of the Defendant Officer(s and Defendant Security Guard(s as set forth above were extreme and outrageous. These actions were rooted in an abuse of power and authority and were undertaken with the intent to cause, or were in reckless disregard of the probability that their conduct would cause, severe emotional distress to Mr. Sowell, as is more fully alleged above As a direct and proximate result of the Defendants misconduct described in this Count, the Estate of Donte Sowell suffered injury, including severe emotional distress. Count State Law Claim Respondeat Superior against Defendant City of Indianapolis 106. Each Paragraph of this Complaint is incorporated herein In committing the acts alleged in the preceding paragraphs, the Defendant Officers were agents of the IMPD acting at all relevant times within the scope of their employment. 20

21 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 21 of In committing the acts alleged in the preceding paragraphs, the Defendant Security Guards were agents of the IMPD acting at all relevant times within the scope of their employment Defendant City of Indianapolis is liable as principal for all torts committed by its agents. Count State Law Claim Respondeat Superior against Defendant Special Task Force Protection Agency LLP 110. Each Paragraph of this Complaint is incorporated herein In committing the acts alleged in the preceding paragraphs, the Defendant Security Guard(s were employees and agents of Special Task Force Protection Agency acting at all relevant times within the scope of their employment Defendant Special Task Force Protection Agency is liable as principal for all torts committed by its agents. Count State Law Claim Respondeat Superior against Defendants Amber Woods Cooperative and Flaherty & Collins Properties 113. Each Paragraph of this Complaint is incorporated herein In committing the acts alleged in the preceding paragraphs, the Defendant Security Guard(s were employees and agents of Defendant Amber Woods Cooperative and Defendant Flaherty & Collins Properties, acting at all relevant times within the scope of their employment Defendant Amber Woods Cooperative and Defendant Flaherty & Collins Properties are liable as principals for all torts committed by their agents. 21

22 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 22 of 28 Count 14 State Law Claims Negligent Hiring, Entrustment, Supervision, and Training Against Defendants Flaherty & Collins Properties and Amber Woods Cooperative 116. The Defendant Security Guard(s and Defendant Special Task Force Protection Agency LLP provided police and security services at the Amber Woods Cooperative only at the direction of Defendant Flaherty & Collins Properties and Defendant Amber Woods Cooperative Defendants Flaherty & Collins Properties and Amber Woods Cooperative had a duty to exercise reasonable care so as to control their agents, the Defendant Security Guard(s and Defendant Special Task Force Protection Agency LLP, to prevent them from harming others Defendants Flaherty & Collins Properties and Amber Woods Cooperative knew or had reason to know that they maintained the ability to control the Defendant Security Guard(s and Defendant Special Task Force Protection Agency LLP Defendants Flaherty & Collins Properties and Amber Woods Cooperative knew or had reason to know of the necessity of exercising control over the Defendant Security Guard(s and Defendant Special Task Force Protection Agency LLP, and their opportunity to do so Defendants Flaherty & Collins Properties and Amber Woods Cooperative breached their duty of reasonable care to hire, retain, supervise, and train competent employees The Defendant Security Guard(s and Defendant Special Task Force Protection Agency LLP were unfit and incompetent to provide security services at the Amber Woods Cooperative and lacked adequate supervision and training. 22

23 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 23 of Defendants Flaherty & Collins Properties and Amber Woods Cooperative knew or, by the exercise of reasonable care, should have known that the Defendant Security Guard(s and Defendant Special Task Force Protection Agency LLP were unfit and incompetent to provide security services at the Amber Woods Cooperative and lacked adequate supervision and training The above-described breach of duty by Defendants Flaherty & Collins Properties and Amber Woods Cooperative proximately caused damages to the Estate of Donte Sowell. Count 15 State Law Claims Negligent Entrustment, Hiring, Supervision, and Training Against Defendant Special Task Force Protection Agency LLP 124. The Defendant Security Guard(s provided police and security services at the Amber Woods Cooperative only at the direction of Defendant Special Task Force Protection Agency LLP Defendant Special Task Force Protection Agency LLP had a duty to exercise reasonable care so as to control its agents, the Defendant Security Guard(s, to prevent them from harming others Defendant Special Task Force Protection Agency LLP knew or had reason to know that it maintained the ability to control the Defendant Security Guard(s Defendant Special Task Force Protection Agency LLP knew or had reason to know of the necessity of exercising control over the Defendant Security Guard(s and and its opportunity to do so Defendant Special Task Force Protection Agency LLP breached its duty of reasonable care to hire, retain, supervise, and train competent employees. 23

24 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 24 of The Defendant Security Guard(s were unfit and incompetent to provide security services at the Amber Woods Cooperative and lacked adequate supervision and training Defendant Special Task Force Protection Agency LLP knew or, by the exercise of reasonable care, should have known that the Defendant Security Guard(s were unfit and incompetent to provide security services at the Amber Woods Cooperative and lacked adequate supervision and training Defendant Special Task Force Protection Agency LLP s breach of duty proximately caused damages to the Estate of Donte Sowell. Count State Law Claim Indemnification 132. Each Paragraph of this Complaint is incorporated herein Indiana law requires public entities to pay any tort judgment for compensatory damages for which employees are liable within the scope of their employment activities The Defendant Officers are or were employees of the IMPD who acted within the scope of their employment in committing the misconduct described above. Count 17 - State Law Claim Wrongful Death: Intentional or Reckless Battery 135. Each Paragraph of this Complaint is incorporated herein As described more fully in the preceding paragraphs, the actions of the Defendant Officer(s and Defendant Security Guard(s constituted offensive physical contact made without the consent of the Decedent. 24

25 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 25 of The Individual Defendants actions were undertaken willfully and wantonly and either intentionally or with reckless indifference or conscious disregard for the safety of others The Individual Defendants actions were the proximate cause of Decedent's great bodily harm and death, as well as Decedent s great pain and suffering As a result, the Estate of Donte Sowell has incurred medical, funeral, burial, and other expenses, and suffered other injuries, including loss of society and companionship. Count 18 - State Law Claim Survival Action: Intentional or Reckless Battery 140. Each Paragraph of this Complaint is incorporated herein As described more fully in the preceding paragraphs, the actions of the Defendant Officer(s and Defendant Security Guard(s constituted offensive physical contact made without the consent of the Decedent The Individual Defendant actions were undertaken willfully and wantonly and either intentionally or with reckless indifference or conscious disregard for the safety of others The Individual Defendants actions were the proximate cause of Mr. Sowell s great bodily harm and death, as well as Mr. Sowell s great pain and suffering The misconduct described in this Count was undertaken with intentional disregard for Mr. Sowell s rights As a result of these actions, Mr. Sowell experienced injuries including conscious pain and suffering. 25

26 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 26 of 28 Count 19 - Federal Law Claim First Amendment Violation 146. Each Paragraph of this Complaint is incorporated herein The First Amendment of the United States Constitution affords the public a qualified right of access to certain government activities, processes, and information to ensure that citizens can effectively participate in and contribute to our republican system of self-government Pursuant to this right, Plaintiff has a First Amendment right of access to video recordings depicting interactions between police officers and civilians in which police officers shoot and kill a civilian during the course of performing their official duties in public Defendants Indianapolis and IMPD denied Plaintiff access to any video recordings depicting the interaction between Mr. Sowell and Defendants that culminated in Mr. Sowell s death The encounter between Mr. Sowell and government agents took place on public streets open to the press and general public Public access to video of police shootings plays a significant positive role in the functioning of police departments by ensuring accountability and transparency Police officers performing their public duties in public places have no reasonable expectation that their conduct is private and will not be recorded, published, and disseminated By denying Plaintiff any existing video recordings of the police shooting of Mr. Sowell, Indianapolis and IMPD violated Plaintiff s rights as secured by the First Amendment of the United States Constitution. 26

27 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 27 of As a result of these actions, Plaintiff suffered damages. Count 20 Federal and State Law Claim Violation of Common Law Right to Information 155. Each Paragraph of this Complaint is incorporated herein Pursuant to the common law, Plaintiff has a right to inspect and copy records within the possession of the government As set forth in further detail above, Indianapolis and IMPD wrongfully denied Plaintiff an opportunity to inspect any available video depicting the interaction in public between Defendants and Mr. Sowell on January 15, 2015 that culminated in Mr. Sowell s death As the administrator of Mr. Sowell s estate, Plaintiff has a direct and tangible interest such video recordings Plaintiff seeks the recordings for a legitimate purpose: to challenge Defendants claims about the circumstances of their shooting of Mr. Sowell and to bring transparency and accountability to shootings of civilians by IMPD officers Indianapolis and IMPD have no legitimate countervailing interest in withholding any existing recordings Immediately after shooting Mr. Sowell, the Defendants told the press their account of what had happened, and so there was never a legitimate investigation into Mr. Sowell s death. WHEREFORE, Plaintiff Rachel Long respectfully requests that this Court enter judgment in her favor and against Defendants City of Indianapolis, Defendant Officers, Special Task Force Security LLC, and Defendant Security Guards, awarding compensatory damages, punitive damages, and attorney s fees and costs; declaring that 27

28 USDC IN/ND case 1:15-cv document 1 filed 09/10/15 page 28 of 28 IMPD and Indianapolis have violated the First Amendment and the common law right to information; ordering the release of any video recordings of the interaction between Mr. Sowell and Defendants on the night of Mr. Sowell s death; and ordering any other relief this Court deems just and appropriate. JURY DEMAND Plaintiff Rachel Long hereby demands a trial by jury pursuant to Federal Rule of Civil Procedure 38(b on all issues so triable. Dated: September 10, 2015 RESPECTFULLY SUBMITTED, /s/_ruth Z. Brown Attorneys for Plaintiff Arthur Loevy Jon Loevy Russell Ainsworth Matthew Topic Ruth Z. Brown LOEVY & LOEVY 312 North May St., Suite 100 Chicago, IL (

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