Estate of Tamir Rice et al. v. City of Cleveland et al

8/20/2019 Estate of Tamir Rice et al. v. City of Cleveland et al.

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UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO

EASTERN DIVISION

DOUGLAS WINSTON, as administrator ofthe Estate of TAMIR RICE, SAMARIA RICEon her own behalf, T.R. by her next friend and parent, Samaria Rice,

Plaintiffs,

vs.

THE CITY OF CLEVELAND, Police OfficerTIMOTHY LOEHMANN in his individual

capacity, Police Officer FRANKGARMBACK in his individual capacity,Police Officer WILLIAM CUNNINGHAM inhis individual capacity, DispatcherCONSTANCE HOLLINGER in her individualcapacity, Dispatcher BETH MANDL in herindividual capacity, Lieutenant GAIL BINDELin her individual capacity, Sergeant EDWINSANTIAGO in his individual capacity, PoliceOfficers JOHN DOES # 1–5 in their individualcapacities,

Defendants.

CASE NO. 1:14-cv-02670

JUDGE SOLOMON OLIVER

SECOND AMENDED COMPLAINT AND JURY DEMAND BY PLAINTIFFS WINSTON, R ICE, AND T.R.

WITH JURY DEMAND

Plaintiffs Douglas Winston, as administrator of the Estate of Tamir Rice, Samaria Rice,

and minor Plaintiff T.R. by her next friend and parent Samaria Rice (collectively, “Plaintiffs”)

for their Second Amended Complaint allege as follows:

Case: 1:14-cv-02670-SO Doc #: 80 Filed: 11/03/15 1 of 38. PageID #: 624


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PRELIMINARY STATEMENT

1. This case involves the horrific, tragic, fatal shooting of a young child without any

valid excuse or legal justification. On November 22, 2014, 12-year-old Tamir Rice was playing

in the park. At approximately 3:30 pm, City of Cleveland police officers, Defendants Timothy

Loehmann and Frank Garmback, rushed their police car into the park, right up to where Tamir

was sitting. Loehmann jumped out of the car and immediately fired two shots at Tamir. Tamir

was fatally wounded and died early the next day.

2. This is a civil-rights case brought by Douglas Winston, the administrator of the

Estate of Tamir Rice, Tamir’s mother Samaria Rice, and Tamir’s sister T.R., against the City of

Cleveland and its police officers and other employees, for the shooting and wrongful death of

Tamir Rice.

JURISDICTION AND VENUE

3. This action arises under the Fourth and Fourteenth Amendments to the United

States Constitution, 42 U.S.C. §§ 1983 and 1988, and Ohio law.

4. This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 and 1343 and

42 U.S.C. § 3613. This Court has supplemental jurisdiction over the Ohio State claims under

28 U.S.C. § 1367.

5. The acts complained of occurred in the Northern District of Ohio, and venue is

lodged in this Court under 28 U.S.C. § 1391(b)(2).

JURY DEMAND

6. Plaintiffs demand trial by jury in this action.



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PARTIES

7. Tamir Rice was fatally shot by City of Cleveland police officers on November 22,

2014, while he was playing in the Cudell Recreation Center park in the City of Cleveland. Tamir

was a U.S. citizen.

8. Plaintiff Douglas Winston is a U.S. citizen with his domicile in Cuyahoga

County, Ohio. On or about December 22, 2014, Mr. Winston was appointed by the Cuyahoga

County Probate Court to be the Estate of Tamir Rice’s administrator. Mr. Winston brings this

suit in his capacity as the Estate of Tamir Rice’s administrator.

9. Plaintiff Samaria Rice is a U.S. citizen with her domicile in Cleveland, Ohio. Ms.

Rice is Tamir Rice’s mother.

10. Plaintiff T.R. is a U.S. citizen with her domicile in Cleveland, Ohio. T.R. is a

minor, Samaria Rice’s daughter, and Tamir Rice’s sister and sues hereby and through her next

friend and parent, Samaria Rice.

11. Defendant City of Cleveland (“City”) is a city organized under Ohio law and the

county seat of Cuyahoga County. The Division of Police (“CPD”) is a division of the City’s

Department of Public Safety. The CPD Communication Center is the branch of the Division of

Police that receives 911 calls and dispatches CPD officers to respond.

12. At all relevant times, Defendant Timothy Loehmann was a CPD police officer,

acting in the capacity of employee, agent, and servant of the City, within the scope of his

employment as such, and acting under color of state law. Defendant Loehmann is sued in his

individual capacity.

13. At all relevant times, Defendant Frank Garmback was a CPD police officer,




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employment as such, and acting under color of state law. Defendant Garmback is sued in his


14. At all relevant times, Defendant William Cunningham was a CPD police officer,


employment as such, and acting under color of state law. Defendant Cunningham is sued in his


15. At all relevant times, Defendant Constance Hollinger was a CPD 911 call-taker

and/or dispatcher, acting in the capacity of employee, agent, and servant of the City, within the

scope of her employment as such, and acting under color of state law. Defendant Hollinger is

sued in her individual capacity.

16. At all relevant times, Defendant Beth Mandl was a CPD 911 call-taker and/or

dispatcher, acting in the capacity of employee, agent, and servant of the City, within the scope of

her employment as such, and acting under color of state law. Defendant Mandl is sued in her


17. At all relevant times, Defendant Gail Bindel was a CPD lieutenant acting in the

capacity of employee, agent, and servant of the City, within the scope of her employment as

such, and acting under color of state law. Defendant Bindel is sued in her individual capacity.

18. At all relevant times, Defendant Edwin Santiago was a CPD sergeant acting in the

capacity of employee, agent, and servant of the City of Cleveland, within the scope of his

employment as such, and acting under color of state law. Defendant Santiago is sued in his


19. At all relevant times, Defendants John Does # 1–5 were CPD police officers

(whose complete names Plaintiffs have been unable to ascertain notwithstanding reasonable



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efforts to do so, but who are sued by the fictitious designation “John Doe”) acting in the capacity

of employees, agents, and servants of the City of Cleveland, within the scope of their

employment as such, and acting under color of state law. Defendants John Does # 1-5 are sued

in their individual capacities.

STATEMENT OF FACTS

Officer Loehmann Fatally Shoots Tamir Rice

20. In November 2014, Tamir Rice was 12 years old.

21. He lived with his mother, Samaria Rice, and his 14-year-old sister, T.R., in the

City of Cleveland.

22. Tamir and his family are African American.

23. Tamir had no criminal history and no juvenile court adjudications.

24. On Saturday, November 22, 2014, both Tamir and his sister T.R. were playing at

the Cudell Recreation Center, near their home.

25. The following paragraphs are alleged on information and belief.

26. In the afternoon of November 22, 2014, Tamir was playing in the park beside

Cudell Recreation Center.

27. Tamir was playing by himself with a plastic toy pellet gun.

28. At approximately 3:22 p.m., CPD Communication Center Dispatcher Constance

Hollinger received a 911 call from a man in Cudell Recreation Center park.

29. Defendant Hollinger was assigned that day as a CPD Communication Center call-

taker.

30. It was Hollinger’s responsibility, as 911 calls came in, to gather all pertinent

information from the caller and enter that information into the Computer Aided Dispatch system.



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After the information is entered into the computer, it is electronically transferred to the CPD

Communication Center dispatcher responsible for the geographic area from which the call

originated.

31. The 911 caller told Defendant Hollinger that there was a male outside of Cudell

Recreation Center sitting on the swings with a pistol, that the male was “probably a juvenile,”

and that the gun was “probably fake.”

32. Despite the obviously critical nature of the information that the male was

“probably a juvenile” and that the gun was “probably fake,” Defendant Hollinger recklessly

failed to include this information in her report summarizing this 911 call.

33. Hollinger coded the call as “Code 1,” the highest priority code.

34. CPD Communication Center dispatcher Beth Mandl received Hollinger’s report.

35. At approximately 3:28 p.m., Mandl dispatched the call to two CPD cars, including

the car of Defendant Officers Timothy Loehmann and Frank Garmback.

36. Mandl radioed Loehmann and Garmback that: “It’s Cudell Rec Center . . . in the

park by the youth center, there is a black male sitting on the swing . . . He keeps pulling a gun

out of his pants and pointing it at people. It’s a code one . . .”

37. Defendant Mandl recklessly did not include in her radio call the critical

information from the 911 caller that the male was “probably a juvenile” and that the gun was

“probably fake.”

38. Defendants Loehmann and Garmback proceeded towards Cudell Recreation

Center.

39. Garmback was driving and Loehmann was in the front passenger seat.



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40. In the minutes before they arrived, Tamir was sitting by himself in a gazebo in the

park.

41. When Loehmann and Garmback got to the park, Garmback drove their car over

the curb, onto the grass. Traveling at about 15 to 22 miles per hour, they drove past the

playground area and swing set.

42. Tamir was standing alone in the gazebo in the park.

43. Garmback pulled the car up right next to Tamir, so that the passenger side of the

car was only a few feet away from Tamir.

44. Loehmann immediately jumped out of the car and, within one to two seconds,

fired two shots at Tamir.

45. One of Loehmann’s bullets struck Tamir in the stomach.

46. Tamir collapsed to the ground.

47. Garmback then exited the police car.

48. For the next minute and a half, Tamir lay on the ground, while Officers

Loehmann and Garmback stood around.

49. Neither Loehmann or Garmback provided any medical care or assistance to

Tamir.

Officer Garmback Tackles T.R. To The Ground

50. T.R. was in the Cudell Recreation Center at the time Tamir was shot.

51. She heard some other children say that the police had shot Tamir outside.

52. Horrified, she ran out of the Cudell Recreation Center and towards the park.

53. Less than one minute after Loehmann shot Tamir, T.R. ran towards Tamir, who

was still lying on the ground.



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54. As she ran towards Tamir, T.R. screamed and cried out: “my baby brother, they

killed my baby brother.”

55. Defendant Garmback grabbed T.R. and tackled her, forcefully bringing her to the

ground.

56. Loehmann came over to assist Garmback.

57. T.R. tried to stand and move away from the officers.

58. But Loehmann dragged her back to the ground.

59. Defendant Officer William Cunningham, who was working at the Cudell

Recreation Center that day, arrived on the scene.

60. Loehmann and Cunningham placed T.R. face-down on the ground and handcuffed

her with her hands behind her back.

61. Loehmann and Cunningham then forced T.R. into the backseat of the police car.

62. The police car was still just a few feet away from T.R.’s brother, Tamir, where he

lay injured and dying on the ground.

63. T.R. experienced severe emotional distress as a result of the Defendants’ actions.

CPD Officers Did Not Provide Medical Care to Tamir

64. The City recklessly, wantonly, and/or intentionally does not train CPD officers to

provide first aid or any other medical care or assistance to injured people, and/or trains CPD

officers not to provide first aid or any other medical care or assistance to injured people.

65. In addition, the City recklessly, wantonly, and/or intentionally does not put first-

aid kits or any other medical equipment in CPD police cars.



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66. Neither Cunningham nor Garmback nor Loehmann, nor the other CPD officers

who later arrived on the scene (Defendants John Does # 1–5), provided Tamir with any medical

care or assistance at any time.

67. Tamir first received medical care from an FBI agent who happened to be in the

area and who arrived on the scene approximately four minutes after the shooting.

68. The FBI agent immediately noticed that Tamir was seriously injured, observing

that his intestines were eviscerated and actually coming out of the open wound in his abdomen.

69. The FBI agent spoke to Tamir, who was conscious. Tamir acknowledged the

agent and responded to his voice.

70. Tamir turned his head towards the agent and looked at him. He reached for the

agent’s hand.

71. Tamir spoke to the agent and told him his name. Tamir also said that he had been

shot and referred to a gun.

72. During this time, T.R. was still handcuffed in the police car.

73. She was screaming and crying.

74. CPD officers on the scene, including Loehmann, Garmback, Cunningham, and/or

John Does #1–5, heard T.R.’s cries.

75. Approximately twelve minutes after Loehmann shot Tamir, Emergency Medical

Services (“EMS”) arrived on the scene.

76. When EMS arrived, Tamir was still conscious. His eyes were open and blinking.

City Officers Force Samaria Rice to Choose Between Her Children

77. Samaria Rice learned that her son had been shot when some neighborhood

children knocked on her door and told her.



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78. She rushed to Cudell Recreation Center.

79. When she got there, she found Tamir laying there wounded, and T.R. handcuffed

in the back of the police car of the same officers who had shot Tamir.

80. Ms. Rice begged Loehmann, Garmback, Cunningham, and/or John Does #1-5 to

release T.R.

81. They refused.

82. Instead, Loehmann, Garmback, Cunningham, and/or John Does #1–5 forced Ms.

Rice to choose between staying with T.R., who was still handcuffed in the police car, and going

in the ambulance with Tamir.

83. Forced to make a choice no mother should ever have to make, Ms. Rice chose to

go in the ambulance with Tamir.

84. Ms. Rice and Tamir left in the ambulance.

85. T.R. was left alone, still handcuffed in the police car of the officers who had shot

her brother.

86. More than a half an hour later, City police officers took T.R. into Cudell

Recreation Center, where they questioned her without an adult present.

87. Both Ms. Rice and T.R. experienced severe emotional distress as a result of the

Defendants’ actions.

Tamir Rice Dies

88. Tamir was taken to MetroHealth Medical Center in the ambulance.

89. During this time, Tamir was conscious and responding to pain.

90. At the hospital, doctors immediately operated to try to save Tamir’s life.

91. Their efforts were unsuccessful.



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92. Tamir was pronounced dead early in the morning of November 23, 2014.

93. The Medical Examiner ruled Tamir’s death a homicide.

The City’s Reckless Hiring and Retention Of Defendants Loehmann, Garmback, Mandl, and

Hollinger

94. The CPD has a pattern and practice and a custom and policy of recklessly: hiring

officers not suitable for their positions, failing to properly train and supervise officers, and

retaining officers unfit for their positions.

95. The City recklessly hired or retained Defendants Loehmann, Garmback, Mandl,

and Hollinger, despite the fact that they were clearly unfit for their duties.

Loehmann

96. The City hired Defendant Loehmann in December 2013.

97. Prior to being hired by CPD, from July 2012 to December 2012, Loehmann

worked as a police cadet for the City of Independence, Ohio.

98. On November 28, 2012, during his gun-range examination for the State of Ohio

gun qualifications, Loehmann began crying, was distracted, and was not following instructions.

The supervising officer was forced to remove Loehmann’s gun and secure it in a safe location.

Loehmann’s personnel file documented that he “could not follow simple directions, could not

communicate clear thoughts nor recollections, and his handgun performance was dismal.”

99. When the supervising officer attempted to discuss the situation with Loehmann,

Loehmann told his supervisor “what I want is for you to just shut up.”

100. A similar incident occurred when Loehmann was in the police academy.

101. Independence Deputy Chief Jim Polak wrote in Loehmann’s file that there were

three other incidents involving Loehmann which, “taken together show a pattern of a lack of

maturity, indiscretion and not following instructions.”



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102. The past incidents involving Loehmann included two incidents of lying to his

supervisors, including one occasion in which he lied about failing to secure his gun overnight.

103. Officer Loehmann’s employment file further noted: “It just appears that he is not

mature enough in his accepting of responsibility or his understanding in the severity of his loss of

control on the range.”

104. Independence police department supervisors ultimately recommended

Loehmann’s termination.

105. Deputy Chief of Police for the City of Independence Jim Polak found: “I do not

believe time, nor training, will be able to change or correct these deficiencies,” and began the

disciplinary process of separation, including informing Loehmann of his intention to terminate

his employment. At this point, Loehmann resigned.

106. In September 2013, Defendant Loehmann failed the Cuyahoga County Sheriff

Department’s written entrance exam, earning only 46 points out of 100, on an exam with a

minimum passage requirement of 70 points.

107. Upon information and belief, before his employment with CPD, Defendant

Loehmann applied to work in five different police departments, including Akron, Euclid, and

Parma Heights, all of which refused to hire him.

108. The Euclid police department refused to hire Loehmann after reviewing his file

from Independence as part of their background check process.

109. By contrast, the City of Cleveland never checked Loehmann’s personnel file from

Independence during their background investigation.

110. The CPD police supervisors responsible for hiring Loehmann, Defendants Lt.

Gail Bindel and Sgt. Edwin Santiago, were found guilty of administrative charges, including



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neglect of duty for failing to adequately supervise and review Loehman’s application and

background investigation.

111. Defendant Bindel was suspended for two days and Defendant Santiago received a

written reprimand.

Garmback

112. The City hired Defendant Garmback in 2008.

113. During his time with the CPD, Garmback was the subject of four registered

complaints with the Office of Professional Standards and Civilian Police Review.

114. Garmback was also named as a defendant in the civil- rights lawsuit Eaton v.

Guerra, et al., No. 12 Civ. 3029 (N.D. Ohio), in which the plaintiff alleged that, in 2010,

Garmback placed her in a chokehold, tackled her to ground, twisted her wrist, and hit her, while

his partner punched her in the face multiple times.

115. In March 2014, over eight months before Garmback and Loehmann killed Tamir

Rice, the City paid $100,000 to settle the case with Ms. Eaton.

Mandl

116. The City hired Defendant Mandl in 2010.

117. Prior to being hired by the City, Mandl was employed as a dispatcher by Case

Western Reserve University police department.

118. In 2008, Mandl was fired from her dispatcher job with Case Western Reserve

University’s police department.

119. Around the same time, she was arrested and charged with bringing a gun to a bar.

120. Mandl resigned from CPD in July 16, 2015, after failing to show up for work

since April 3, 2015.



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Hollinger

121. The City hired Defendant Constance Hollinger in or about 1996.

122. In February 2014, the City issued Hollinger a letter of re-instruction on call-taking

procedures.

The City of Cleveland’s Pattern and Practice of Excessive Force

123. At the time of Tamir Rice’s death, the City of Cleveland had a long history of its

police officers using excessive force. The City knew about this pattern and practice of excessive

force by its police officers, tolerated it, and sanctioned it.

124. In 2014, the U.S. Department of Justice Civil Rights Division (“USDOJ”) issued

a news report criticizing the City of Cleveland’s failure to adequately address an ongoing pattern

and practice of police excessive force, despite a prior USDOJ investigation and agreement

between the City and USDOJ.

125. Analysis of CPD documents revealed that, between 2009 and 2011, six officers

used excessive force on 39 suspects. Only one of these suspects was armed. Out of the cases

investigated by the CPD, the CPD found all of the uses of force justified. All six of these

officers were hired since 2008. One officer in particular, Kevin Smith, had been involved in

over half of the excessive-force incidents, as he reported using force on 22 suspects.

126. On December 4, 2014, the USDOJ found that there was reasonable cause to

believe that the CPD engages in a pattern or practice of using unreasonable and unnecessary

force in violation of the Fourth Amendment of the United States Constitution.

127. The USDOJ found a custom and/or policy and pattern or practice of the use of

unnecessary and excessive deadly force, including shootings and head strikes with impact

weapons.



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128. The USDOJ further found that CPD officers fired guns at people who did not pose

an immediate threat of death or serious bodily injury to officers or others, and that officers used

guns in a careless and dangerous manner.

129. The USDOJ also noted two cases in which CPD officers engaged suspects

physically while holding a gun in their hand, and the gun inadvertently discharged in the midst of

a physical struggle.

130. The USDOJ found the following uses of force unreasonable in violation of the

Fourth Amendment. On November 29, 2012, over 100 CPD officers conducted a high-speed

police chase in violation of City policy and fatally shot Timothy Russell and Malissa Williams,

two unarmed African American civilians. Officers initiated the chase when the car drove by a

building and backfired, which some officers mistook for gunfire. During the chase, there was

confusing and contradictory radio traffic that incorrectly indicated that the car’s occupants might

be armed and firing from the car. None of the supervisors asserted control over the chase, and

some actually participated. The chase ended in a schoolyard where 13 different officers fired

over 137 shots at the car. Unarmed Timothy Russell and Malissa Williams were both shot over

20 times by CPD officers. The officers fired so many shots that officers assumed the occupants

of the car were returning fire, but evidence later showed that the only shots fired were from

fellow officers.

131. The Ohio Bureau of Criminal Investigation and Identification conducted an

investigation into the incident and issued a report which concluded that this incident “raised

serious questions about CPD’s policies, training, supervision, communication, and technology.”

132. Ohio Attorney General, Mike DeWine stated that: “Command failed.

Communications failed. The System failed. Policy, training, communications, and command



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have to be so strong and so ingrained to prevent subjective judgment from spiraling out of

control. The system has to take over and put on the brakes. On November 29, 2012, the system

failed everyone.”

133. On December 27, 2012, Cleveland’s mayor requested that the USDOJ

review the CPD’s use-of-force policies.

134. Six officers were indicted as a result of the shooting deaths of Timothy Russell

and Malissa Williams.

135. Ohio Attorney General Mike Dewine stated that in the aforementioned case,

CPD’s radio transmission network contributed to communication failures and the failure to

properly relay information. These failures included mistaking the car’s possible backfiring for a

gunshot, officers firing shots, and the wholesale absence of commands from supervisors to avoid

crossfire or spontaneous shooting, as well as their failure to communicate details to sector

supervisors, all of which contributed to the fatal shooting incident of Timothy Russell and

Malissa Williams.

136. In 2012, another CPD officer shot a man who was lawfully armed and carrying an

open container of beer. When an officer asked him to stop, he refused and walked to a porch and

sat down with his can of beer. The man then turned toward the police car and walked forward to

speak with the officers, at which point the officer saw a gun in his waistband, yelled “gun,” and

pointed his weapon at the man. The victim raised his hands above his head, and then lowered

them a bit to ear level, and the officer shot and struck him in the abdomen. The USDOJ found

the officer’s use of force unreasonable and excessive.

137. In 2013, a CPD sergeant shot at a victim as he ran from a house where he was

being held against his will by armed assailants. Before responding to the call, officers received



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information that a man was being held in his house against his will by two armed men. The

victim eventually escaped. When he ran from the house in his boxers, an officer ordered him to

stop. He continued to run toward the officers seeking safety and refuge, and the sergeant on the

scene shot at him twice. The USDOJ found the use of force unreasonable and excessive.

138. In 2010, an officer shot a man who was fleeing. The man was seated in a car with

the engine running, and the officer pointed a gun at him and told him to turn the car off. The

man sped away, brushing against the officer with the side of the car as he fled the scene. The

officer shot at him from behind as he left the scene, hitting him in the shoulder. The USDOJ

deemed the use of force unreasonable.

139. There were several incidents in which officers fired at fleeing vehicles even

though the suspect’s flight did not pose a threat of serious bodily injury or death to the officers or

others. The USDOJ stated that firing at, or from, a moving vehicle is rarely effective and

presents extreme danger to innocent persons, as it is difficult to shoot at or from a moving car

with accuracy.

140. In 2013, the Police Executive Research Forum recommended that the CPD’s

policy be changed to prohibit the discharge of firearms at, or from, a moving vehicle unless

deadly physical force is being used against the officer or another person present.

141. The USDOJ further found that the CPD had a pattern and practice and/or custom

and policy of the unnecessary, excessive, or retaliatory use of less lethal force including tasers,

chemical spray, fists, and head and body strikes; a failure to use less lethal force in proportion to

the resistance encountered, including punching people in handcuffs who were already subdued;

and the use of force as punishment for the person’s earlier verbal or physical resistance to a

command, not in response to the current threat posed by that person.



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142. In January 2011, CPD officers apprehended Edward Henderson, a mentally ill

African American man, after he fled from police in a vehicle. While Mr. Henderson lay prone on

the ground handcuffed, CPD Officers Smith and Lentz began kicking him and striking him,

breaking his orbital bone and his nose and detaching his retina. A helicopter camera captured the

entire incident, but the officers never filed a use-of-force report, despite the obvious use of force

and the severity of Henderson’s injuries. Both officers were charged with assault and the

USDOJ found the use of force unreasonable and excessive.

143. There were also several incidents in which the USDOJ found that the CPD used

unreasonable and excessive force on minor children. In one incident, an officer punched a

handcuffed 13-year-old boy in the face several times after arresting him for shoplifting. Officers

placed the minor in the back of the police cruiser. While still restrained, the 13-year-old began

kicking the door and kicked an officer in the leg. The officer sat on the boy’s legs and punched

him in the face three to four times until he was dazed and had a bloody nose. The USDOJ found

the use of force unreasonable and excessive.

144. In another incident, an officer used a taser on a juvenile twice, as two other

officers held him to the ground. Officers alleged that he matched a description for someone who

had been seen stealing from a store. The USDOJ found the use of a taser on a child otherwise

restrained unreasonable.

145. The USDOJ also found that CPD officers used excessive force against persons

who are mentally ill or in crisis, including instances in which an individual is not suspected of

having committed any crime at all.

146. In addition, the USDOJ found that officers subjected individuals to stops, frisks,

and full searches without the requisite level of suspicion, in violation of the Fourth Amendment,



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and that individuals were detained on mere suspicion of having committed a crime, but with no

record of an articulable reason for the detention.

147. The 2014 USDOJ report also stated that there was a systemic failure to file use-

of-force reports and to comply with departmental policies and protocols of investigating uses of

force that contributed to a pattern and practice and/or custom and/or policy of the use of

excessive and unreasonable force in violation of individuals’ constitutionally guaranteed rights.

148. The USDOJ found that the CPD failed to institute proper systems and policies to

provide the supervision necessary for sufficient oversight of officers’ use of force; failed to

provide consistent and clear policies and/or enforce existing policies on when and how to use

and report force; failed to implement systems to ensure that use of force is consistently reported

and investigated thoroughly and fairly to determine whether the department needs policy,

training, tactical, or other changes for officer and civilian safety; failed to address emerging

problems through the use of aggregate data to determine patterns and trends and institute

corrective measures for unlawful and dangerous behavior that places citizens at risk; and failed

to ensure that officers receive proper use-of-force training, all of which contributed to an

environment of systemic deprivation of citizens’ constitutional rights.

149. The USDOJ found a custom and policy and/or pattern and practice that

supervisors tolerated, and sometimes promoted and participated in. This included the use of

excessive force, conducting improper and biased investigations into the use of excessive force,

failing to implement constitutional policies regarding excessive force and/or failing to uphold

policies already in existence, failing to maintain the proper data regarding individual officers’

and departmental uses of force, and failing to take corrective measures when identifying

excessive use of force by individuals.



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150. The USDOJ found that, in general, there is a lack of experienced, well-supported,

well-trained supervisors, and that supervisors tolerated the use of unreasonable and excessive

force and other improper and unlawful practices, in some cases even endorsing it. Supervisors

and CPD officials and employees failed to conduct proper and objective investigations into

officers’ use of force, and failed to identify and respond to patterns of at-risk behavior or provide

officers with the support, training, supervision, and equipment to perform job functions safely

and effectively.

151. The USDOJ determined that several of the CPD’s systems for investigating and

holding officers accountable for the use of excessive force are flawed, including Internal Affairs,

the Use of Deadly Force Investigation Team, and the Tactical Review Committee. Oftentimes,

the investigations were conducted with the intent to justify the officers’ actions rather than

discern the truth. In fact, numerous investigators admitted to the USDOJ that the quality of the

investigations is compromised by investigators’ apparent bias in favor of clearing the officer

instead of objectively pursuing all of the available facts. Some investigating officers responsible

for reviewing officers’ use of deadly force admitted that they investigate with the goal of casting

the officer in the best light possible, and most officers applied the improper “beyond a reasonable

doubt” evidentiary standard when determining whether the officer used excessive and/or

unreasonable force. The USDOJ report elaborated that: “It is almost as if the goal of the chain of

command in many incidents is not to create a complete record of the incident that can be

subjected to internal and external review.”

152. The USDOJ found that the CPD also fails to adequately investigate civilian

complaints of use of excessive force, although they are required to conduct a full and complete

investigation of each civilian complaint under the Charter of the City of Cleveland. In tolerating



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supervisors’ failure to investigate uses of force, the USDOJ found that the CPD misses the

opportunity to correct dangerous behavior, and instead sends the message that there is little

oversight or concern about officers’ use of force. The admittedly biased investigations that apply

improper evidentiary standards were found to be deeply rooted and “emblematic of the type of

practice that justifies a finding under Section 14141” of the Violent Crime and Law Enforce Act

of 1994.

153. Over the span of three-and-a-half years, the USDOJ concluded that only 51 of the

1,500 CPD officers were disciplined in any fashion related to use of force. Most of the charges

were for procedural issues such as failing to file a report, or charges were deemed unfounded or

dismissed, and a finding of excessive force was “exceedingly rare.” A Cleveland Office of

Professional Standards employee stated that a deadly force incident had not been reviewed since

2012. Officers were only suspended on six occasions for their use of force.

154. The USDOJ found that the CPD does not implement appropriate corrective

measures to discipline officers and does not develop training aimed to correct improper and

unconstitutional practices, and that some supervisors actively discouraged officers from

reporting uses of force, instructing them not to complete use-of-force documents in instances

when one was required. The CPD also failed to examine and analyze use-of-force reports that

were generated to detect common patterns and trends.

155. The USDOJ found that the CPD’s failures are such that it cannot timely, properly,

and effectively determine how much force its officers are using and under what circumstances,

whether the force was reasonable, and if not, what discipline, change in policy, training, or other

action is appropriate. The CPD does not use an adequate early-intervention system to help



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identify risky and problematic trends in officer behavior before a pattern of misconduct arises—

such as the pattern or practice of excessive use of force.

156. Instead of serving the local community and adopting and enforcing appropriate

policies to implement effective community policing, the USDOJ found that the CPD has instead

fostered an “us-versus-them” mentality and created an occupying force in the city, as evidenced

by the war-zone sign hanging in the CPD vehicle bay that reads: “Forward Operating Base.”

157. The USDOJ found that the CPD has a custom and policy and/or pattern and

practice of failing to properly train officers on appropriate use of force, and that officers lack

basic support, skills, and knowledge required to safely and effectively respond to situations that

commonly arise in law-enforcement encounters. The CPD has a duty to ensure its officers are

properly trained, that training is reinforced through ongoing instruction, and that officers are

consistently held accountable for any failure to abide by their training. The failure to fulfill this

duty has contributed to the pattern and practice of excessive force identified within the CPD that

places the community in danger. The CPD does not devote enough time to training on use of

force, and fails to analyze use-of-force reports to determine what training is necessary to bring

the department into compliance. In particular, officers draw and point firearms at citizens too

often, and do not appear to know how to safely handle firearms and lack confidence in their

ability to control situations, resulting in accidentally discharging weapons or shooting the wrong

individual. Officers do not know how to effectively de-escalate situations before resorting to use

of force, and officers informed investigators that they do not receive enough training, especially

scenario-based training, and training on how to control subjects. Officers too often escalate

incidents instead of using accepted tactics to de-escalate tension, and CPD officers commit

tactical errors that endanger the Cleveland community and themselves. The employment of poor



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and dangerous tactics place officers in dangerous situations or create dangerous situations, where

use of force becomes inevitable, placing officers and civilians at unnecessary risk. The tactical

errors may result in the use of additional force and cause constitutional violations, such as firing

weapons in a manner that places bystanders in danger, sometimes accidentally firing and hitting

nothing, or shooting people and seriously injuring them. For example, officers respond to scenes

unsupervised and group together with little or no cover. As a result of these improper tactics,

officers place themselves in harm’s way and increase the likelihood that they will need to fire

shots.

158. The USDOJ found that the CPD has no idea how often its officers point guns at

civilians and that when officers point their guns with such frequency at community members,

those members can come to feel as though they are under siege.

159. The questionable tactics the CPD uses as identified by the USDOJ parallel the

same tactical errors made by the officers here, who drove the police cruiser at high speed directly

up to the table where 12-year-old Tamir Rice was seated, giving the officers little or no cover,

and immediately fired at Tamir within just one to seconds of arriving at the scene.

Plaintiffs’ Damages

160. As a direct and proximate result of the Defendants’ actions, Tamir Rice suffered

severe physical and emotional injury, pre-death terror, pain and suffering, was deprived of his

life, and lost the enjoyment of his young life.

161. As a direct and proximate result of the Defendants’ actions, Samaria Rice was

deprived forever of her son’s love, support, services, care, companionship, advice, guidance,

counsel, instruction, and society, and suffered mental anguish and extreme emotional distress.

Ms. Rice also incurred funeral and other expenses.



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162. As a direct and proximate result of the Defendants’ actions, T.R. was deprived

forever of her brother’s love, support, services, care, companionship, advice, guidance, counsel,

instruction, and society, and suffered mental anguish and extreme emotional distress. T.R. also

suffered physical emotional harm as a result of Defendants’ tackling her, dragging her,

handcuffing her, and detaining her in a police car.

163. Defendants’ acts were reckless, willful, wanton, and malicious, thus entitling

Plaintiffs to an award of punitive damages.

FIRST CLAIM FOR RELIEF

By Plaintiff Douglas Winston, as Administrator of the Estate of Tamir Rice

42 U.S.C. § 1983/ Fourth and Fourteenth Amendments Excessive Force(Against Defendants Loehmann and Garmback)

164. Plaintiffs repeat and reallege the foregoing paragraphs as if the same were fully

set forth at length herein.

165. By reason of the foregoing, using excessive force, assaulting Tamir Rice, seizing

him, and killing him, Defendants Loehmann and Garmback deprived Tamir Rice of the rights,

remedies, privileges, and immunities guaranteed to every citizen of the United States, in

violation of 42 U.S.C. § 1983, including, but not limited to, rights guaranteed by the Fourth and

Fourteenth Amendments of the United States Constitution to be free from gratuitous and

excessive force. Defendants Loehmann’s and Garmback’s conduct manifested deliberate

indifference to Tamir Rice’s constitutional rights.

166. Defendants Loehmann and Garmback acted under pretense and color of state law

and in their individual and official capacities and within the scope of their respective

employment as CPD officers. Defendants Loehmann and Garmback’s acts were beyond the

scope of their jurisdiction, without authority of law, and in abuse of their powers. Defendants

Loehmann and Garmback acted willfully, knowingly, and with the specific intent to deprive



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Tamir Rice of his constitutional rights, secured by 42 U.S.C. § 1983, and the Fourth and

Fourteenth Amendments to the United States Constitution.

167. As a direct and proximate result of the misconduct and abuse of authority detailed

above, Tamir Rice and Plaintiffs sustained the damages stated above.

SECOND CLAIM FOR RELIEF

By Plaintiff Douglas Winston, as Administrator of the Estate of Tamir Rice, and by

Plaintiff T.R., by her next friend and parent Samaria Rice

42 U.S.C. § 1983/Fourth and Fourteenth Amendment Excessive Force

(Against Defendant City)



169. Defendant City, through CPD, and acting under the pretense and color of law,

permitted, tolerated, and was deliberately indifferent to a pattern and practice of excessive force

by CPD officers at the time of Tamir Rice’s killing and the assault on T.R. This widespread

tolerance of excessive force by police officers constituted a municipal policy, practice, or custom

and led to Tamir Rice’s shooting and death and to the assault, tackling, handcuffing, and

detention of T.R.

170. By permitting, tolerating, and sanctioning a persistent and widespread policy,

practice and custom of excessive force under which Tamir Rice was killed and T.R. was

assaulted, Defendant City deprived Tamir Rice and T.R. of rights, remedies, privileges and

immunities guaranteed to every citizen of the United States, secured by 42 U.S.C. § 1983,

including, but not limited to, the right to be free from gratuitous and excessive force guaranteed

by the Fourth and Fourteenth Amendments to the United States Constitution.

171. As a direct and proximate result of the policy, practice, and custom detailed

above, Tamir Rice, T.R., and Plaintiffs sustained the damages stated above.



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THIRD CLAIM FOR RELIEF


Ohio Rev. Code § 2125/Wrongful Death

(Against All Defendants)



173. As a direct and proximate result of the reckless, wanton, and/or intentional

conduct of Defendants and their employees as described herein, Tamir Rice suffered conscious

pain and suffering until the moment of his death.

174. As a direct and proximate result of Tamir Rice’s death, his beneficiaries suffered,

and will continue to suffer, damages for the loss over his life expectancy, including loss of

companionship, consortium, care, assistance, attention, protection, advice, guidance, counsel,

instruction, training, and education.


conduct of Defendants and their employees as described herein, Tamir Rice’s beneficiaries have

suffered mental anguish and severe emotional distress and have been deprived of his love,

support, services, care, companionship, advice, guidance, counsel, instruction, and society, and

prospective inheritance, and have sustained potentially other damages as recognized under Ohio

Rev. Code § 2125.02(B) and other provisions of law. These losses are expected to be permanent

and ongoing.

176. Plaintiff Douglas Winston brings this claim in his capacity as administrator of the

Estate of Tamir Rice, for the beneficiaries of Tamir Rice.


above, Tamir Rice and Plaintiffs sustained the damages alleged above.



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FOURTH CLAIM FOR RELIEF

By Plaintiffs Douglas Winston, as Administrator of the Estate of Tamir Rice,

and Samaria Rice

Survivorship

(Against All Defendants)




conduct of Defendants and their employees as described herein, Tamir Rice was caused to suffer

severe fright, pain, suffering, and mental anguish from the moment he was shot until the moment

he lost consciousness, including knowledge of his injury and impending death.


conduct of Defendants and their employees as described herein, Plaintiff Samaria Rice and the

Estate of Tamir Rice incurred funeral and cremation expenses and other expenses.



FIFTH CLAIM FOR RELIEF


42 U.S.C. § 1983/ Fourth and Fourteenth Amendment

Deliberate Indifference to Medical Need

(Against Defendants Loehmann, Garmback, Cunningham, and John Does #1–5)



183. As alleged above, by denying medical care to Tamir Rice and by failing to

provide medical care or assistance to Tamir Rice, Defendants Loehmann, Garmback,

Cunningham, and John Does # 1–5 deprived Tamir Rice of the rights, remedies, privileges, and

immunities guaranteed to every citizen of the United States, in violation of 42 U.S.C. § 1983,



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188. By permitting, tolerating, and sanctioning a persistent and widespread policy,

practice and custom under which Tamir Rice was killed, Defendant City deprived Tamir Rice of

rights, remedies, privileges, and immunities guaranteed to every citizen of the United States,

secured by 42 U.S.C. § 1983, including, but not limited to, the right to be free from deliberate

indifference to medical needs guaranteed by the Fourth and Fourteenth Amendments to the

United States Constitution.

189. As a direct and proximate result of the policy, practice, and custom detailed


SEVENTH CLAIM FOR RELIEFBy Plaintiff Douglas Winston, as Administrator of the Estate of Tamir Rice

Assault and Battery of Tamir Rice

(Against Defendants Loehmann and Garmback and the City)



191. In physically assaulting, shooting, and killing Tamir Rice, Defendants Loehmann

and Garmback, acting in their capacity as police officers, and within the scope of their

employment, committed willful, unlawful, unwarranted, and intentional assault and battery upon

Tamir Rice.

192. The assault and battery by Defendants Loehmann and Garmback was unnecessary

and unwarranted in the performance of their duties and constituted an unreasonable and

excessive use of force.

193. Defendant City, as employer of Defendants Loehmann and Garmback, is

responsible for their wrongdoing under the doctrine of respondeat superior .





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EIGHTH CLAIM FOR RELIEF


Reckless Conduct as to Tamir Rice

(Against Defendants Hollinger and Mandl and the City)



196. As alleged above, Defendants Hollinger and Mandl failed to exercise due care and

acted in a reckless manner while engaged in police functions and activities, including by not

relaying to CPD officers the critical information from the 911 caller that the person in the park

was “probably a juvenile” and that the gun was “probably fake.”

197. This reckless conduct proximately caused the death of Tamir Rice.

198. Defendant City, as employer of Defendants Hollinger and Mandl, is responsible

for their wrongdoing under the doctrine of respondeat superior .



NINTH CLAIM FOR RELIEF

By Plaintiff T.R., by her next friend and parent Samaria Rice

42 U.S.C. § 1983/Fourth and Fourteenth Amendments Excessive Force

(Against Defendants Loehmann, Garmback, Cunningham)



201. By reason of the foregoing, using excessive force, assaulting T.R., seizing her,

and tackling her, Defendants Loehmann, Garmback, and Cunningham deprived T.R. of the

rights, remedies, privileges, and immunities guaranteed to every citizen of the United States, in

violation of 42 U.S.C. § 1983, including, but not limited to, rights guaranteed by the Fourth and

Fourteenth Amendments of the United States Constitution to be free from gratuitous and



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excessive force. Defendants Loehmann’s, Garmback’s, and Cunningham’s conduct manifested

deliberate indifference to T.R.’s constitutional rights.

202. Defendants Loehmann, Garmback, and Cunningham acted under pretense and

color of state law and in their individual and official capacities and within the scope of their

respective employment as CPD officers. These acts by Defendants Loehmann, Garmback, and

Cunningham were beyond the scope of their jurisdiction, without authority of law, and in abuse

of their powers. Defendants Loehmann, Garmback, and Cunningham acted willfully, knowingly,

and with the specific intent to deprive T.R. of her constitutional rights, secured by 42 U.S.C.

§ 1983, and the Fourth and Fourteenth Amendments of the United States Constitution.


above, T.R. sustained the damages alleged above.

TENTH CLAIM FOR RELIEF


Assault and Battery of T.R.

(Against Defendants Loehmann, Garmback, Cunningham and the City)



205. In physically assaulting, tackling, handcuffing, dragging, and forcing into a police

car minor Plaintiff T.R., Defendants Loehmann, Garmback, and Cunningham, acting in their

capacity as police officers, and within the scope of their employment, committed a willful,

unlawful, unwarranted, and intentional assault and battery upon T.R.

206. The assault and battery by Defendants Loehmann, Garmback, and Cunningham

was unnecessary and unwarranted in the performance of their duties and constituted an

unreasonable and excessive use of force.



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207. Defendant City, as employer of Defendants Loehmann, Garmback, and

Cunningham, is responsible for their wrongdoing under the doctrine of respondeat superior.



ELEVENTH CLAIM FOR RELIEF


False Imprisonment of T.R.

(Against Defendants Loehmann, Garmback, Cunningham, John Does # 1–5 and the City)



210. In physically assaulting, tackling, handcuffing, dragging, forcing into a police car,

detaining T.R. in a police car and in Cudell Recreation Center, and refusing to release minor

Plaintiff T.R., Defendants Loehmann, Garmback, Cunningham, and John Does # 1–5, acting in

their capacity as police officers, and within the scope of their employment, committed a willful,

unlawful, unwarranted, and intentional false imprisonment of T.R. without her consent and

against her will.

211. T.R.’s false imprisonment by Defendants Loehmann, Garmback, Cunningham,

and John Does # 1–5 was without probable cause and was unnecessary and unwarranted in the

performance of their duties.

212. Defendant City, as employer of Defendants Loehmann, Garmback, Cunningham,

and John Does # 1–5, is responsible for their wrongdoing under the doctrine of respondeat

superior .





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TWELFTH CLAIM FOR RELIEF


Intentional Infliction of Emotional Distress on T.R.

(Against Defendants Loehmann, Garmback, Cunningham, John Does # 1-5 and the City)



215. In physically assaulting, tackling, handcuffing, dragging, forcing into a police car,

detaining, and refusing to release minor Plaintiff T.R., and in keeping T.R. in a police car right

next to her fatally wounded brother, Defendants Loehmann, Garmback, Cunningham, and John

Does # 1–5, acting in their capacity as police officers, and within the scope of their employment,

intended to cause emotional distress to T.R., or knew or should have known that their actions

would cause T.R. serious emotional distress.

216. Defendants Loehmann’s, Garmback’s, Cunningham’s, and John Does # 1–5’s

conduct was extreme and outrageous.


conduct was the proximate cause of T.R.’s emotional injury.

218. As a result of Defendants Loehmann’s, Garmback’s, Cunningham’s, and John

Does # 1–5’s conduct, T.R. suffered serious emotional anguish.



superior .





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THIRTEENTH CLAIM FOR RELIEF

By Plaintiff Samaria Rice

Intentional Infliction of Emotional Distress on Samaria Rice

(Against Defendants Loehmann, Garmback, Cunningham, John Does # 1-5 and the City)



222. In forcing Samaria Rice to choose between going in the ambulance with her

fatally injured 12-year-old son, Tamir, and staying with her 14-year-old daughter T.R., who was

handcuffed in a police car in the custody of the officers who shot her son, Defendants Loehmann,

Garmback, Cunningham, and John Does # 1–5, acting in their capacity as police officers, and

within the scope of their employment, intended to cause emotional distress to Ms. Rice, or knew

or should have known that their actions would cause Ms. Rice serious emotional distress.


conduct was extreme and outrageous.


conduct was the proximate cause of Ms. Rice’s emotional injury.

225. As a result of Defendants Loehmann’s, Garmback’s, Cunningham’s, and John

Does # 1–5’s conduct, Ms. Rice suffered serious emotional anguish.



superior .


above, Ms. Rice sustained the damages alleged above.



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FOURTEENTH CLAIM FOR RELIEF

By Plaintiffs Douglas Winston, as Administrator of the Estate of Tamir Rice, and Plaintiff

T.R., by her next friend and parent Samaria Rice

Reckless Hiring, Training, Supervision, Discipline, Staffing, and Retention

(Against Defendant City and Defendants Bindel and Santiago)



229. Defendant City failed to exercise due care and acted in a reckless manner in

hiring, training, supervising, disciplining, staffing, and retaining Defendants Loehmann,

Garmback, Hollinger, and Mandl.

230. Defendants Bindel and Santiago failed to exercise due care and acted in a reckless

manner in hiring Defendant Loehmann.

231. Defendants Loehmann, Garmback, Hollinger, and Mandl were all unfit for their

positions and duties.

232. Defendant City’s reckless conduct in this regard proximately caused the death of

Tamir Rice and the injuries to T.R. and Samaria Rice alleged above.


above, Plaintiffs sustained the damages alleged above.

FIFTEENTH CLAIM FOR RELIEF

By Plaintiff Samaria Rice

42 U.S.C. § 1983/ Fourteenth Amendment Substantive Due Process

(Against Defendants Loehmann and Garmback)



235. Plaintiff Samaria Rice, in her individual capacity as Tamir Rice’s mother, had a

liberty interest in his familial companionship and society.



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236. Defendants Loehmann and Garmback intentionally deprived Ms. Rice of that

liberty interest without due process of law when they shot and killed Tamir.

237. As a direct and proximate result of Defendants Loehmann’s and Garmback’s

conduct, Ms. Rice experienced extreme emotional distress, mental anguish, and the loss of

Tamir’s love, support, services, care, companionship, advice, guidance, counsel, instruction, and

society.


above, Ms. Rice sustained the damages hereinbefore alleged.

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs request the Court enter judgment against Defendants and grant the

following relief:

A. Compensatory damages in an amount to be determined at trial.

B. Punitive damages against the individual Defendants only in an amount to be

determined at trial.

C. An order awarding Plaintiffs reasonable attorneys’ fees, together with the costs of

this action, under 42 U.S.C. § 1988.

D. Such other further relief as the Court may deem appropriate.



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Dated: October 15, 2015

Respectfully submitted,

EMERY CELLI BRINCKERHOFF& ABADY LLP

/s/ Jonathan S. AbadyJonathan S. AbadyEarl S. WardZoe Salzman600 Fifth Avenue, 10th Floor New York, New York 10020Phone: (212) 763-5000 Fx: (212) 763-5001 [email protected]

[email protected]@ecbalaw.com

(Admitted pro hac vice)

Attorneys for Plaintiffs Douglas Winston as

administrator of the Estate of Tamir Rice,Samaria Rice, and T.R.

THE CHANDRA LAW FIRM, LLC

/s/ Subodh ChandraSubodh Chandra (OH Bar No. 0069233)1265 W. 6th St., Suite 400Cleveland, OH 44113-1326Phone: 216.578.1700 Fx: [email protected]

FIRMEQUITY

/s/ William J. MillsWilliam J. Mills858 West Armitage Avenue, Suite 101Chicago, IL 60614(847) 207-9064 Fx: (773) 528-0013 [email protected]




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CERTIFICATE OF SERVICE

I certify that on this 15th day of October, 2015, my office served, via the Court’s

Electronic Filing System, the foregoing document on all counsel of record in the ECF system.

/s/ Zoe SalzmanZoe Salzman


One of the attorneys for Plaintiffs Douglas

Winston as administrator of the Estate of

Tamir Rice, Samaria Rice, and T.R.


Documents

Estate of Tamir Rice et al. v. City of Cleveland et al