UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TENNESSEE

SPENCER RENCK and ALYSSA JENNETTE, )

Individually and as Next Friend of KNOX )
JENNETTE, )
)
Plaintiffs, )
)
v. ) No.:
)
BRADLEY COUNTY, TENNESSEE, ) JURY DEMANDED
)
Defendant. )

COMPLAINT

Come now Plaintiffs Spencer Renck, Alyssa Jennette, individually and as next friends of

Knox Jennette, by and through counsel, and sue Defendant Bradley County, Tennessee, as

follows:

PARTIES, JURISDICTION, AND VENUE

1. This case arises under 42 U.S.C. § 1983 for Defendant’s deprivation of Plaintiffs’

rights under the Fourth Amendment to the United States Constitution.

2. The Court has subject matter jurisdiction pursuant to 28 U.S.C. § 1331 (federal

question) and 28 U.S.C. § 1343 (civil rights).

3. Venue lies in this judicial district pursuant to 28 U.S.C. § 1391.

4. Plaintiff Spencer Renck is an adult citizen and resident of Cleveland, Bradley

County, Tennessee.

5. Plaintiff Alyssa Jennette is an adult citizen and resident of Cleveland, Bradley

County, Tennessee.

Case 1:19-cv-00151-HSM-SKL Document 1 Filed 05/20/19 Page 1 of 11 PageID #: 1

 6. Plaintiffs Renck and Jennette, a married couple, are the natural parents of Plaintiff

Knox Jennette, a minor child. Renck and Jennette bring this action individually and as next friend

of their son Knox Jennette.

7. Defendant Bradley County, Tennessee, (“the County”) is a local governmental

entity located in Southeast Tennessee and is a person for purposes of 42 U.S.C. § 1983.

8. The actions taken by the County against Plaintiffs as set forth herein were carried

out principally by Lieutenant John Stone, Detective Jerry Rogers, and Detective Daniel Marlow

(collectively, “the Actors”), with the assistance and involvement of Detective David Michaels,

Detective Rusty Bryant, Detective Chad Ownby, Detective Brandon Coffel, Detective Brent Myers,

Deputy Ken Ritenour, Lieutenant Mario Santos, Detective Dave Jones, Lieut. Douglas Towne,

Deputy Paul Singleton, Deputy Eduardo Choate, Deputy Chad Nave, and Sgt. Doug Graham.

9. The above-identified Actors were acting as agents of the County pursuant to

customs, policies, and procedures intended or reasonably foreseeable to deny each plaintiff his

or her rights under the Fourth Amendment to the U.S. Constitution. Each of the Actors was acting

under color of state law and was a final policy- and decision-maker with respect to the actions

set forth below.

10. Additionally, as to the claims set forth below pertaining to the County’s failure to

implement appropriate policies, procedures, and safeguards and to ensure appropriate training

to prevent these foreseeable and inevitable violations of citizens’ Fourth Amendment

protections, Sheriff Eric Watson was the final policy-and decision-maker with respect to those

decisions.

Case 1:19-cv-00151-HSM-SKL Document 1 Filed 05/20/19 Page 2 of 11 PageID #: 2

 FACTUAL BASIS

11. On May 22, 2018, Plaintiffs Renck and Jennette were asleep in their residence

located at 4040 Lynncrest Dr. NE, Cleveland, Tennessee, along with their four minor children.

12. At approximately 6:00 AM, Plaintiffs were jolted awake by the sounds of loud

explosions and crashes inside their residence, along with unintelligible shouting and cursing.

The source of these explosions was the Bradley County SWAT team which, at this predawn hour,

had used a battering ram to crash into Plaintiffs’ front door, ripping it from its frame, and then

proceeded to intentionally detonate at least three explosive devices designed to cause temporary

deafness and disorientation to the residents inside. Not only did the devices start small fires or

other heat-related damage where they exploded, their explosive force caused damage to nearby

areas of the house.

13. Mr. Renck immediately felt his family was being attacked and under siege from

unknown intruders, so he grabbed his pistol and proceeded to move upstairs from his basement

bedroom. As he reached the basement stairs, the upstairs door opened and a flash bang grenade

was lobbed towards him. As he proceeded to raise his gun toward the source of the grenade, he

came to believe the person at the top of the stairs might be a member of law enforcement; most

fortunately, the officer at the top of the stairs likely did not see Mr. Renck’s firearm or else the

officer would have likely killed Mr. Renck instantly.

14. Mr. Renck immediately put his gun in his pants and proceeded to lie on the floor

while advising the officers handcuffing him that they were in the wrong house and that children

were present.

15. At the same time these events were occurring to Mr. Renck, his wife and kids were

awakened by the same explosions and by men appearing in their bedrooms carrying automatic

weapons.

Case 1:19-cv-00151-HSM-SKL Document 1 Filed 05/20/19 Page 3 of 11 PageID #: 3

 16. The SWAT team soon discovered that the felony arrest warrant they were

attempting to serve was supposed to be executed at a home next door, having an address of 4030

Lynncrest Drive. Rather than Plaintiffs, the subjects of the arrest warrant were Monte Brewer

and Dennis Moore, both of whom are purported gang members who were wanted for first-

degree murder (Brewer) and multiple drug offenses (both).

17. The intended house is unobstructed from the street, and the numerical address is

displayed prominently in white numbers affixed to a black mailbox positioned at the street.

18. Bradley County’s involvement in the raid was requested by the U.S. Drug

Enforcement Agency (“DEA”) following a months-long investigation into these individuals. Upon

information and belief, none of the employees of the Bradley County SWAT team had been

personally involved in the investigations or in procuring the arrest warrants.

19. Upon information and belief, the affidavit used to secure the warrants was

submitted by Tennessee Bureau of Investigation (“TBI”) agent, Rodd Watters.

20. Plaintiffs reasonably believe and therefore affirmatively aver that Bradley County

SWAT created the raid’s action plan the previous evening without anyone with personal

knowledge of the investigation – that is, DEA agents or Agent Watters – being present.

21. Plaintiffs further aver that no one from the DEA or Agent Watters was involved in

the raid such that they could reasonably direct the precise location for the SWAT Team’s assault

on the residence.

22. Plaintiffs reasonably believe and affirmatively aver that Lieut. Stone, (one of) the

highest-ranking member of the County’s Sheriff’s Department on the scene, decided at the last

minute that another member, Detective Daniel Marlow, would drive the deployment vehicle

whereas the action plan called for Lieutenant Stone to be the driver. The newly chosen driver

Case 1:19-cv-00151-HSM-SKL Document 1 Filed 05/20/19 Page 4 of 11 PageID #: 4

had never driven by the intended residence for the purpose of identifying its precise location or

characteristics.

23. Upon information and belief, there was no new risk or circumstances leading to

this change but rather Detective Marlow simply asked if he could drive. Although Lieut. Stone

purportedly asked Marlow if he knew what house they were planning to raid, the change of plans

placed Lieut. Stone further behind several other SWAT Team members where he could not see

the house at which Marlow stopped.

24. Additionally, upon information and belief, there was confusion as the deployment

vehicle approached a house. Marlow stopped in front of one house (believed to be the correct

one – i.e. 4030 Lynncrest) when someone from the rear of the vehicle yelled “keep going!,” which

resulted in the deployment vehicle proceeding to Plaintiffs’ residence.

25. Plaintiffs aver that the SWAT team was acting pursuant to a no-knock warrant.

Pleading in the alternative, even if the warrant was a traditional “knock and announce” warrant,

Defendant’s SWAT team did not adequately announce their identity or allow a reasonable time

for Plaintiffs’ to respond.

26. As a result of the events of the predawn hours of May 22, 2018, Plaintiffs Renck

and Jennette began experiencing extreme fear, difficulty sleeping, anxiety, nervousness, and

related mental and emotional harm. Their young child Knox Jennette, who was almost seven

years-old, began experiencing nightmares, was scared to fall asleep, and showed ongoing signs

of anxiety and fear.

Case 1:19-cv-00151-HSM-SKL Document 1 Filed 05/20/19 Page 5 of 11 PageID #: 5

 CAUSES OF ACTION

42 U.S.C. § 1983; Violations of the Fourth Amendment to the U.S. Constitution

27. The Fourth Amendment to the U.S. Constitution affords Plaintiffs protection and

security in their own homes against unreasonable searches and seizures by the government.

28. The County engaged in a predawn military-like assault on Plaintiffs and their

residence, breaching the front door and utilizing flash grenades, as well as seizing each plaintiff

by handcuffing Renck face down on the floor and pointing multiple guns at each of them.

29. Defendant had no warrant, probable cause, or other exigent circumstance to enter

and search Plaintiffs’ home or to seize them.

30. Defendant did not properly knock and announce their presence before storming

the house, which was unreasonable and not supported by probable cause or exigent

circumstances. This amounts to an independent violation of Plaintiffs’ Fourth Amendment

rights. See, e.g., Dickerson v. McClellan, 101 F.3d 1151, 1162 (6th Cir. 1996).

31. The Actors, all of whom were acting under color of state law, violated each

Plaintiff’s constitutional rights pursuant to the County’s customs, policies, and procedures.

Additionally, Sheriff Watson, failed to provide appropriate training to his department’s part-time

SWAT team officers, displaying a deliberate indifference to the likelihood that the precise

mistakes leading to the violations of Plaintiffs’ Fourth Amendment rights were certain to occur.

32. Mistaken raids by law enforcement officers have persisted for decades, and

numerous media outlets and court opinions have brought awareness to these circumstances.

The mistakes underlying these constitutional violations are often nearly identical. Therefore,

Defendant could foresee the precise sources and errors that could lead to a mistaken raid, as well

as the types of harms that could flow from such a mistake.

Case 1:19-cv-00151-HSM-SKL Document 1 Filed 05/20/19 Page 6 of 11 PageID #: 6

 33. Plaintiffs reasonably believe and affirmatively aver that the following customs,

policies, and/or procedures were in effect and proximately caused the foreseeable violations of

Plaintiffs’ Fourth Amendment rights and the resulting harms:

a. Conducting raids without taking appropriate steps to ensure the proper person

and/or property was being searched or seized;

b. Using unreliable methods for identifying houses listed on warrants;

c. Identifying persons and property by using vague, subjective, and/or temporary

characteristics (such as “white car in the driveway”) when more reliable and

definitive sources of information are available for raids that can be scheduled in

advance;

d. Agreeing to activate their SWAT team without requiring senior SWAT leadership

to verify information that is readily identifiable, such as the correct location of a

house based on its address;

e. Ignoring constitutional requirements that officers knock and announce their

presence and wait a reasonable amount of time before storming a house; and/or

f. Using aggressive, vulgar, and coarse language when conducting an operation,

which is likely to cause unnecessary fear and intimidation.

34. Additionally, Plaintiffs aver that Sheriff Watson failed to provide adequate

training and instruction to SWAT officers who serve in that capacity only part-time.

35. SWAT members are responsible for displaying and utilizing law enforcement’s

most aggressive tactics, equipment, and weaponry, so the failure to provide adequate training

demonstrates a deliberate indifference to the same foreseeable risks that proximately caused

Plaintiffs’ harm. Among the training Defendant could have provided its SWAT officers but did

Case 1:19-cv-00151-HSM-SKL Document 1 Filed 05/20/19 Page 7 of 11 PageID #: 7

not – and which training is reasonable considering the insignificant time, cost, personnel, and

resources required – include but is not limited to:

a. Training in appropriate navigation and identification techniques in dark or

limited visibility situations;

b. Developing action plans that unequivocally identify each member’s

responsibilities, as well as account for various contingencies;

c. Utilizing multiple methods and sources for verifying addresses, property

descriptions, owners’ identities, etc., and recognizing each source’s limitations

and potential for error; and/or

d. Teaching members to recognize obstacles, risks, and conditions that increase the

likelihood of mistaking houses, cars, and people;

36. Plaintiffs aver that Defendant’s failure to implement appropriate policies and

procedures about executing scheduled SWAT raids was itself a policy and custom that

demonstrated a deliberate indifference to the foreseeable harm Plaintiffs suffered. Among the

policies Defendant should have implemented but recklessly or deliberately did not, and which

proximately caused Plaintiffs’ harm, include but are not limited to:

a. Having photographs of the residence, and ensuring each member has sufficient

opportunity to inspect them;

b. Identifying landmarks, utility poles, and similar fixed objects as they relate to the

residence’s location;

c. Prohibiting last-minute alterations to the execution plan unless case-specific and

articulable facts justify the change;

d. Designating at least two people to independently confirm the address or other

definitive characteristic of the property to be raided;

Case 1:19-cv-00151-HSM-SKL Document 1 Filed 05/20/19 Page 8 of 11 PageID #: 8

 e. Ensuring the person chosen to drive the team to the property has independent

knowledge of the home’s address or permanent characteristics;

f. Implementing redundant systems to ensure proper identification of the property.

For example, the driver and passenger of the deployment vehicle could each be

required to verbally affirm certain identifying information, such as, “The subject

house is on Oak Street. I see the road sign showing we are turning on Oak Street,”

etc.

g. Requiring that the officer in charge or other senior team leader verify as close as

possible to the time of deployment the location, condition, occupancy, etc., of the

property to be raided;

h. Discontinuing a raid if any team member expresses doubt about the property’s

identity;

i. For no-knock raids, requiring a heightened level of identification and verification

of the raid’s location, which must be demonstrated to a Lieutenant or other

superior officer; and/or

j. For nighttime assaults and/or raids where the most aggressive type of entry will

be utilized (i.e. flash-bang grenades, etc.), requiring a heightened level of

identification and verification of the property, which must be demonstrated to a

Lieutenant or other superior officer.

37. As to the creation and implementation of Defendant’s policies and training

protocols – necessarily including the failure to create such policies and training – Sheriff Watson

was the final policy- and decision-maker. As to the other operational policies, procedures, and

customs of the SWAT team addressed herein (such as, the custom or policy of not properly

Case 1:19-cv-00151-HSM-SKL Document 1 Filed 05/20/19 Page 9 of 11 PageID #: 9

 knocking and announcing the team’s presence before entering homes), the Actors were the final

policy- and decision-makers with respect to them

DAMAGES

38. Defendant proximately caused Plaintiffs’ harms and losses via its existing policies

and customs, as well as through its deliberate failure to implement policies, procedures, and

training protocols that would have eliminated the County’s foreseeable violations of the

Plaintiffs’ constitutional rights.

39. Among Plaintiffs’ harms and losses are the physical damage to their property,

physical pain and suffering (Plaintiff Renck only), mental anguish, emotional suffering, loss of

enjoyment of life, severe fright, and embarrassment and humiliation.

PRAYER FOR RELIEF

WHEREFORE, based on the foregoing, Plaintiffs Spencer Renck and Alyssa Jennette,

individually and as next friend of Knox Jennette, respectfully pray for the following relief:

40. A declaratory judgment that Defendant violated their constitutional rights under

the Fourth Amendment to the United States Constitution;

41. A jury be empaneled to serve as the trier of fact;

42. Compensatory damages for their property damage;

43. Non-pecuniary damages attributable to their physical pain and suffering (Plaintiff

Renck only), mental anguish, emotional suffering, loss of enjoyment of life, severe fright, and

embarrassment and humiliation;

44. Pre- and post-judgment interest;

45. An award of reasonable attorney fees and costs; and

10

Case 1:19-cv-00151-HSM-SKL Document 1 Filed 05/20/19 Page 10 of 11 PageID #: 10

 46. An award of such other and further legal and equitable relief to which any of them

may be entitled under the facts and law of this case.

RESPECTFULLY SUBMITTED,

s/ Jesse D. Nelson
JESSE D. NELSON (BPR # 025602)
NELSON LAW GROUP, PLLC
10263 Kingston Pike
Knoxville, TN 37922
(865) 383-1053
jesse@NLGattorneys.com

11

Case 1:19-cv-00151-HSM-SKL Document 1 Filed 05/20/19 Page 11 of 11 PageID #: 11

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