IN THE MATTER OF

THE COMPLAINT OF

RICHARD D. YOUNG

BEFORE THE
CITY OF DALLAS,
DALLAS POLICE DEPARTMENT

COMPLAINT

Pursuant to Texas Government Code Title 6, SubTitle A, Chapter 614, SubChapter B,

Section 614.021(a)(1), I, Richard D. Young, pro se, file this complaint to the Dallas Police
Department, City of Dallas, against Officer Quoc Le (10570) and Officer Justin Jacobson
(10874), and respectfully show the following:

I.

Early Summary

On Thursday, February 18, 2016, I was involved in a physical altercation with my

roommate, -Perez. -Perez admitted to me that he was depressed and suicidal, as this was not the
first time he made those comments. -Perez had a hard day at work, could not seek funds needed
for a new vehicle, and could not locate any of his w2s which were mis-delivered. All of this took
place in one day, which caused -Perez to begin consuming alcoholic beverages at 3pm at a
nearby bar. -Perez was mixing and consuming a variety of alcoholic beverages throughout the
day, and even utilizing illegal drugs, in which he admitted to me via text. -Perez continued to
consume alcohol until around midnight, and was bar-hopping with friends. -Perez then became

upset at me, as he thought I was leaving town and he feared that he may be locked out of the
house overnight, since we only had one house key. -Perez sent me a text stating that he wanted to
remove his belongings from the condo, and that he would be calling the police.
II.

Assault by Contact from Roommate

I arrived at our condo ( Inwood Rd. #, Dallas, TX, 75209) to let -Perez in the unit to get
his belongings. I told -Perez that he needed to calm down as we both walked into the bedroom.
-Perez began punching me and slapping me, and threw me into the bedroom wall. I picked up my
cell phone as I proceeded to call the police. -Perez grabbed my cell phone and car keys from me
and threw them into the bathroom. I told -Perez that he needs to quit screaming or the neighbors
will call the police, and that he needed to leave peacefully. -Perez then punched the bedroom
window, causing multiple cracks in it. He then began knocking over furniture, and throwing
items all over the bedroom. I placed -Perez in a bear hug and asked him to please stop and that it
will be okay. He pushed me on the bed, forced himself on top of me and bit my right wrist, bit
my left arm, and bit me on the chest. -Perez spit in my face and sprayed me in the face with body
spray as he had me pinned to the bed. He began to start chanting in a whispering voice, Im
Lucifer, Im Lucifer, which is common among illegal drug users. Then -Perez hit me on top of
the head with the DVD player that was in the bedroom. -Perez proceeded to leave the premises,
and knocked over the ironing board and flatscreen television in the bedroom, threw buttered
popcorn on the bedroom carpet, and knocked over the flatscreen television in the living room and
a picture off the wall. -Perez then punched the outside of the living room window as he walked
off the property. I have all of the pictures saved on my cellular phone, in which I was able to
photograph before being taken into custody.
III.

Misconduct of Officers

Officers Le and Jacobson arrived at the residence, after I dialed 911 shortly after
midnight. I explained to them everything that happened between myself and -Perez. I showed
both officers the bites that -Perez put on me. Officer Jacobson rudely told me that the bite on my
right wrist did not happen today. I explained to Jacobson that the bite did happen today. I also
tried to tell both officers that I did not want -Perez to go to jail, I just wanted him to calm down
and quit tearing my house apart. Officer Le rudely told me that I was about to piss him off. I am
not sure why Le responded that way, as I was not rude, irate, or out of control in any way. I asked
Officer Le if he had a body cam on, and he stated no. I asked both officers if I could go back into
my condo and make sure -Perez does not take any of my belongings. Officer Jacobson told me
no, and that -Perez can take anything he wanted from my condo because he was receiving mail at
the residence, despite the fact that -Perez is not listed on the lease. Officer Le explained to me
that -Perez made him aware of a sexual encounter we had almost one year ago. Office Le told me
that he thought I was just jealous. I am not sure why Le brought the sexual encounter to my
attention or brought up jealousy because the issue was not over another male, nor was there
another male involved in the physical altercation.
IV.

Negligence of Officers

I asked Officer Le if I could call my brother, whom is also a police officer in a

neighboring county. Officer Le told me no. I was actually recording both officers during the
entire time as I held my cell phone in my left hand. At one point, both Officer Le and Jacobson
walked back into the condo while I was asked to sit outside in the neighbors lawn chair. I could
hear both officers immaturely laughing and giggling, and talking in a low-tone voice to one
another. Both officers talked to -Perez and asked him for a written statement. Neither officer
asked me for a written statement, which I found odd because I was the one whom called the

police, and I was the one whom was assaulted. Not to mention it was my condo and my property
that was being destroyed. I could have easily ran away since I was unsupervised, but chose not
to. Officer Le came back outside and told me that I was going to Lew, in other words, to Lew
Sterrett jail. Le said it will be a Class C Misdemeanor which is a ticket. Officer Lee explained to
me that because the police were called, someone has to go to jail. Le also stated to me that -Perez
did not go to jail, because a friend of his arrived on the scene in time to take -Perez with him. Le
explained to me that -Perez told him that I raped him. Office Le told me that he knew -Perez was
lying; and -Perez told Office Le that he did not want to seek any medical attention. Officer Le
told me that -Perez probably will not press charges. Le walked in front of me to his police car,
never placing handcuffs on me, and never looking behind himself to see if I was still walking
behind him. Officer Le trips over a step near the condo, and falls completely on the ground.
Officer Le stands back up, and again, never looked behind himself to see if I was still walking
behind him. Any other arrestee or criminal could have easily grabbed a weapon or item off of his
belt, as Le was so negligent not to monitor an arrestee behind him. It was then, when Le
handcuffed me as I sat down in the back seat of the patrol car. I did not feel safe in the patrol car
with Officer Le, as he does not closely monitor his surroundings.
V.

Serving of Time in Jail

I was taken into custody at Lew Sterrett Jail in downtown Dallas, and was not placed in a
holding cell until fourteen hours later. The nurse who saw me did not give me a shot for any of
the three bites, nor checked my head from being hit with the DVD player. I then spent eighteen
hours in a holding cell, in which the fourteen hours of book-in did not count as my time locked
up. I was placed in a cell with no available beds, no available mats, and no available blankets.
There were no available cups for drinking water. I found myself laying on the bare floor to sleep

and also found myself sleeping in an up-right position at a picnic table inside the cell, with
uncovered rust, with my head laying down on the table. I ended up catching conjunctivitis,
commonly known as pink eye, in one eye. It then quickly spread to my other eye. While in
custody, I appeared before the judge via the computer screen in the police stations court room,
and plead Not Guilty. The time served in jail caused me to lose time related to my doctoral
course work, inter alia.
VI.

Appearance at Municipal Court

I appeared in Municipal Court no. 4 in Dallas on Monday, April 11, 2016 at 1pm before
Judge Daniel F. Solis. I made a plea agreement with prosecutor Kanesia Williams, to attend four
hours of anger management before June 20, 2016, at my own cost. Williams did explain to me
that if I successfully complete the four hours of anger management, it would not appear on my
criminal background. Williams did tell me however, to have the arrest record expunged, I would
need to get a lawyer. I was granted continuance from Judge Solis to complete the four hours of
anger management in order to have the family violence assault not be placed on my criminal
background, or otherwise plea.
VII.

Questions Raised

1)

Was I treated different and talked to inappropriately because of my race or skin color?

2)

Were either officers unprofessional or inappropriate at any time?

3)

Why did neither officer ask me for a written statement?

4)

Why was I arrested and taken into custody?

5)

Why did I have to go to court?

6)

Why did I have to attend anger management courses at my own expense?

7)

Why did the fourteen hours of book-in not count towards my time being served in jail?

8)

How come -Perez was not arrested and taken into custody?

9)

Why was I charged with a Class C Misdemeanor?

VIII. Causes of Action

a)

Racial Discrimination

b)

False Arrest and Custody

c)

Misconduct of Police Officers

d)

Negligence of Police Officers

e)

Deplorable and unsanitary conditions of holding cell

f)

Embarrassment and humiliation of arrest

IX.

Prayer of Relief

I pray and respectfully ask that the City of Dallas, and the Dallas Police Department fully
look into and investigate this matter thoroughly. I also ask that any criminal background
information or my record of being arrested and jailed be completely removed from any and all
records, including fingerprints and mugshots. I also ask that I am financially reimbursed of my
time for being falsely arrested and jailed, and to be fully reimbursed of the costs associated with
the anger management courses. And I also ask for reimbursement of my Uber ride from jail,
medication for the conjunctivitis, along with handwritten apologies from both officers with their
own signatures.

Respectfully Submitted,

Richard D. Young (pro se)

4539 Lake Ave.
Dallas, TX 75219
Cell (972)201-

FAX (214)602-1880
@yahoo.com
S.S.#
D.O.B. 11-17DL:
Incident No. 040268-2016
Log no./ORR 2016-08070
Reporting Officer 1: Le, Quoc (10570)
Reporting Officer 2: Jacobson, Justin (10874)
Date of Incident: February 19, 2016
Beat: 523