Case 3:08-cv-00494-SRU Document 1 Filed 04/03/08 Page 1 of 6

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

DEMETRICE LEWIS, Plaintiff, V. BLAKE STINE, ROBERT CRISCUOLO, WILLIAM KRAUSS, MICHAEL SIEGLER, GARY DEPALMA, WILLIAM DEGOURSEY, QUINCY FREEMAN, OFFICER FLAHERTY Defendants : : : : : : : : : : : : : COMPLAINT 1. This is an action against members of the Connecticut CV_____________________

APRIL 3, 2008

State Police, New Haven Police, Meriden Police, East Haven Police, and Branford Police departments for the use of unreasonable physical force in the course of the arrest of the plaintiff. This action arises under the Fourth and Fourteenth Amendments to the United States Constitution. 2. Jurisdiction of the court is invoked under the

provisions of sections 1331, 1343(a)(3),and 1367(a)of Title 28 and sections 1983 and 1988 of Title 42 of the United States Code. 3. During all times mentioned in this complaint, the

plaintiff, Demetrius Lewis, was a resident of the City of New Haven, Connecticut.

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4.

Defendant Stine is a member of the Connecticut State

Police, and was at all times relevant to this complaint acting under the color of law. He is sued in his individual capacity only. 5. Defendant Criscuolo is a member of the Statewide

Narcotics Unit, under the control of the Connecticut State Police, and was at all times relevant to this complaint acting under the color of law. He is sued in his individual capacity only. 6. Defendant Krauss is a member of the Statewide Narcotics

Unit, under the control of the Connecticut State Police, and was at all times relevant to this complaint acting under the color of law. He is sued in his individual capacity only. 7. Defendant Siegler is a member of the Statewide

Narcotics Unit, under the control of the Connecticut State Police, and was at all times relevant to this complaint acting under color of law. He is sued in his individual capacity only. 8. Defendant Depalma is a member of the Statewide

Narcotics Unit, under the control of the Connecticut State Police, and was at all times relevant to this complaint acting under color of law. He is sued in his individual capacity only.

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9.

Defendant Degoursey is a member of the Statewide

Narcotics Unit, under the control of the Connecticut State Police, and was at all times relevant to this complaint acting under color of law. He is sued in his individual capacity only. 10. Defendant Freeman is a member of the New Haven Police

Department and was at all times relevant to this complaint acting under color of law. He is sued in his individual capacity only. 11. Defendant Flaherty is a member of the Statewide

Narcotics Unit, under the control of the Connecticut State Police, and was at all times relevant to this complaint acting under the color of law. He is sued in his individual capacity only. 12. During all times mentioned in this complaint, the

defendants as described herein were acting under color of law in that the defendants were acting in their capacity as law enforcement officers employed by their respective departments. The defendants with the exception of defendant Freeman were part of the Connecticut State Polices Statewide Narcotics Unit. 13. The defendants, each of them, had a duty to prevent

the other officers from violating the plaintiffs right to be free from unreasonable force, and each officer had the opportunity to prevent the other defendants in this case from using unreasonable force against the plaintiff.

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14.

On or about April 27, 2006, the plaintiff was arrested

and taken into custody by one or more of the defendants in the city of New Haven, Connecticut. After being arrested and while being brought to a police vehicle, the plaintiff was forcibly shoved into an outdoor gas grill, fence, and pole, and injury. 15. Once back at the police vehicles the plaintiff was causing pain

made to get inside a undercover police van. Once inside the van an unknown defendant punched the plaintiff in the face followed almost immediately by another defendants punching the plaintiff in the face a second time. 16. While in the van cables were attached to the

plaintiffs arms and he was electrically shocked by the officers. During this interrogation the officers were trying to get the plaintiff to give up some type of information. During his time in the van the plaintiff was also choked, kicked in the face and chest and punched. All of these actions caused the plaintiff pain and anguish. The plaintiff was taken to the police lockup where he was denied medical treatment and the ability to contact a lawyer. 17. At all times during his arrest and detention, the

plaintiff was in the custody of the defendants and was neither resisting them, nor attempting to flee.

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18.

In the course of the defendants assaults on the

plaintiff, the plaintiff suffered bruises, contusions, and abrasions to his face, head, chest and arms. The plaintiff also suffered from fear, terror, and emotional distress because of his treatment at the hands of the defendants. 19. The acts and omissions of each of the defendants as

herein described were inspired by malice and were intentional. 20. As a direct and proximate result of the acts and

omissions of the defendants herein described, the plaintiff suffered the loss of his right to be free from unreasonable force as guaranteed by the Fourth Amendment to the United States Constitution. 21. As a direct and proximate result of the actions of the

defendants, each of them, the plaintiff has suffered humiliation, anxiety, emotional distress, physical pain, and the loss of the Constitutional right described herein. WHEREFORE, the plaintiff claims judgment against the defendants as follows: A. Compensatory damages in an amount this Court shall consider to be just and fair; B. Punitive damages in an amount this Court shall consider to be just and fair as to the individually named defendants only; C. Attorney fees and the cost of this action;

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D.

Such other relief as this Court shall consider to be fair and equitable.

CLAIM FOR JURY TRIAL The plaintiff claims trial by jury in this case.

THE PLAINTIFF, DEMETRIUS LEWIS BY:_________________________ Norman A. Pattis Fed Bar No. Ct13120 Law Offices of Norman A. Pattis 649 Amity Road, P.O. Box 280 Bethany, CT 06524 Tel. No. 203.393.3017 Fax. No. 203.393.9745 npattis@pattislaw.com

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