Case 5:19-cv-01017-SMH-KLH Document 1 Filed 08/06/19 Page 1 of 18 PageID #: 1

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF LOUISIANA
SHREVEPORT DIVISION

AUSTIN SULLIVAN : NO. 5:19-cv-1017

VS. :
JUDGE ____________________________
CITY OF SHREVEPORT,
SHREVEPORT POLICE CHIEF ALAN :
CRUMP, SHREVEPORT POLICE
SERGEANT MICHAEL JONES, MAGISTRATE JUDGE ______________
SHREVEPORT POLICE OFFICER B.C.
HANCOCK, AND SHREVEPORT JURY TRIAL REQUESTED
POLICE OFFICER CODY HYDE

COMPLAINT FOR DAMAGES

1.
Plaintiff brings this action to recover from the defendants compensatory damages, punitive

damages, reasonable attorney fees, judicial interest, and all costs and expenses incurred in these

proceedings, pursuant to 42 United States Code, Sections 1983 and 1988, and the Fourth and

Fourteenth Amendments to the Constitution of the United States of America, and other applicable

state and federal statutes and constitutional provisions, based upon the following:

PARTIES

2.

The Plaintiff is Austin Sullivan (hereinafter “Mr. Sullivan” or “Plaintiff”) a person of the

full age of majority who resides in Shreveport, Louisiana, and who is a resident and domiciliary

of the Western District of Louisiana.

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3.
Made Defendants herein are:

a. The City of Shreveport (hereinafter “CITY”) is a

municipality and political subdivision of the State of
Louisiana, and at all times relevant hereto, had authority
over the City of Shreveport Police Department, its policies,
procedures, customs, and practices.

b. Shreveport Police Chief Alan Crump is a person of the full

age of majority, whose actual domicile and residence are
unknown, but who is believed to be a resident and
domiciliary of the Western District of Louisiana, and is
employed by the City of Shreveport, and at all times relevant
hereto, was acting under the color of law and in the course
and scope of his employment, and had authority over the
City of Shreveport Police Department, its policies,
procedures, customs, and practices.

c. Defendant Sergeant Michael S. Jones (Badge #41)

(Hereinafter “JONES” or “Sgt. Jones”) is a person of the full
age of majority, whose actual domicile and residence are
unknown, but who is believed to be a resident and
domiciliary of the Western District of Louisiana, and is
employed by the City of Shreveport as a police sergeant, and
at all times relevant hereto, was acting under the color of law
and in the course and scope of employment.

d. Officer B.C. Hancock (hereinafter “HANCOCK”) is a

person of the full age of majority, whose actual domicile and
residence are unknown, but who is believed to be a resident
and domiciliary of the Western District of Louisiana, and is
employed by the City of Shreveport as a police officer, and
at all times relevant hereto, was acting under the color of law
and in the course and scope of employment.

e. Officer Cody Hyde (hereinafter “HYDE”) is a person of the

full age of majority, whose actual domicile and residence are
unknown, but who is believed to be a resident and
domiciliary of the Western District of Louisiana, and is
employed by the City of Shreveport as a police officer, and
at all times relevant hereto, was acting under the color of law
and in the course and scope of employment.
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JURISDICTION

4.
This is a civil action seeking monetary damages against defendants for committing, and

conspiring to commit, acts under color of law which deprived Plaintiff of rights secured under the

Constitution and laws of the United States and which deprived Plaintiff of his security, liberty, and

property without due process of law and without equal protection of the laws, as guaranteed to

Plaintiff by the Fourth and Fourteenth Amendments to the United States Constitution and other

statutes and constitutional provisions.

5.

This Court has jurisdiction pursuant to 42 United States Code, Sections 1983 and 1988,

and 28 United States Code, Sections 1331 and 1343. Jurisdiction of this Court is further invoked

pursuant to 28 United States Code, Section 1367, in its exercise of supplemental jurisdiction over

Louisiana State Law claims that are so related to claims in the action within the District Court’s

original jurisdiction that they form a part of the same case or controversy under Article III of the

United States Constitution.

FACTUAL ALLEGATIONS
6.
At approximately 2:12:36 a.m. on August 6, 2018, Plaintiff Austin Sullivan heard a short,

rapid series of knocks on the front door of his home.

7.
Approximately 15 seconds after the first series of rapid knocks, and as he made his way to

the front door wearing nothing but his underwear, Mr. Sullivan heard another short burst of three

louder, more forceful knocks on his front door.

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8.
Mr. Sullivan opened the door at approximately 2:12:57 a.m. and saw several police officers

immediately outside his front door.

9.
The officers did not greet Mr. Sullivan, identify themselves, state their business at his front

door, or ask for Mr. Sullivan’s identification.

10.
Instead, at approximately 2:13:00 a.m., one of the officers stated “step outside” to Mr.

Sullivan.

11.
Mr. Sullivan hesitated for a moment.

12.
Then, at approximately 2:13:02 a.m., one of the officers more loudly and forcefully said

“step outside!”

13.
Video and audio recording of this interaction captures one of the officers saying “[e]ither

come out or you can get drug out!” at approximately 2:13:05 a.m. as an audible physical

confrontation ensues.

14.
On the audio recording of the incident, Mr. Sullivan can be heard saying “No sir, I’m

coming out!” at approximately 2:13:06 a.m. as the officers breached the threshold of his home and

physically attacked him; Mr. Sullivan can then be heard imploring the officers to stop.
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15.
After the officers forced their way into Mr. Sullivan’s home, tackled him, punched him

repeatedly in his face and head, handcuffed him, and placed him in the back of a police car, he was

transported to the Shreveport Police Department and charged with the felony offense of “Resisting

an Officer with Force or Violence” under La. R.S. 14:108.2, and the misdemeanor charge of

“Battery of a Police Officer” under La. R.S. 14:34.2.

16.
Mr. Sullivan was booked into Caddo Correctional Center on the charges, and the aggregate

bail amount was set at $12,500.00.

17.
Mr. Sullivan posted bail and was released on August 7, 2018, and then retained an attorney

to represent him.

18.
After retaining an attorney, Mr. Sullivan appeared in Caddo Parish District Court for

arraignment on charges of Battery of a Police Officer and Resisting an Officer with Force or

Violence, and entered pleas of not guilty to all charges on October 29, 2018.

19.
All criminal charges against Mr. Sullivan were dismissed by the Caddo Parish District

Attorney in open court at Mr. Sullivan’s second court setting on January 7, 2019.

20.
On the audio recording of the incident, Mr. Sullivan can be heard yelling out for help and

loudly imploring the officers to tell him what he did wrong while he was being attacked.
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21.
According to the report prepared by Sgt. Michael Jones, the charge of Battery of a Police

Officer was based on contact between Mr. Sullivan’s front door and Sgt. Jones’ person.

22.
Mr. Sullivan’s front door opens inward rather than outward.

23.
Sgt. Jones came into contact with Mr. Sullivan’s front door because Sgt. Jones had

breached the threshold of the front door of Mr. Sullivan’s home.

FIRST CLAIM FOR RELIEF

FALSE ARREST UNDER 42 USC §§ 1983 & 1988

Plaintiff re-alleges paragraphs 1 through 23 as though fully set forth herein.

24.
Acting under color of law and pursuant to official policy or custom, Defendants JONES,

HANCOCK, and HYDE, with other Defendants, knowingly, recklessly, and with deliberate

indifference and callous disregard for Plaintiff’s rights, forcibly entered Plaintiff’s home, beat him,

arrested him, transported him to a patrol unit (and to jail) in his underwear, and charged him with

having committed a violent felony against a police officer. In so doing, Defendants detained

Plaintiff without legal authority, and in the absence of any probable cause to believe that Plaintiff

had committed any criminal offense. Defendants thereby deprived Plaintiff of his rights to due

process and equal protection of the law in violation of the Fourth and Fourteenth Amendments of

the Constitution of the United States and 42 U.S.C. §§ 1983 and 1988.
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25.
This Constitutional deprivation renders Defendants liable to Plaintiff for full compensatory

damages, attorney fees, costs of this action sufficient to remedy the damage to Plaintiff, and

punitive damages.

SECOND CLAIM FOR RELIEF

UNJUSTIFIED AND EXCESSIVE USE OF FORCE & PHYSICAL BRUTALITY
UNDER 42 USC §§ 1983 & 1988

Plaintiff re-alleges paragraphs 1 through 25 as though fully set forth herein.

26.
Acting under color of law and pursuant to official policy or custom, Defendants JONES,

HANCOCK, and HYDE, knowingly, recklessly, and with deliberate indifference to, and callous

disregard for, Plaintiff’s rights, forcibly entered Plaintiff’s home, beat him, arrested him,

transported him to a patrol unit (and to jail) in his underwear, and charged him with having

committed a violent felony against a police officer. Defendants thereby deprived Plaintiff of his

rights to due process and equal protection of the laws, in violation of the Fourth and Fourteenth

Amendments of the Constitution of the United States and 42 U.S.C. §§ 1983 and 1988.

27.
These constitutional deprivations render Defendants liable to Plaintiff for full

compensatory damages, attorney fees, and costs of this action sufficient to remedy the damage to

Plaintiff and for additional punitive damages.

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THIRD CLAIM FOR RELIEF

FEDERAL LAW LIABILITY OF THE CITY OF SHREVEPORT, LOUISIANA

Plaintiff re-alleges paragraphs 1 through 27 as though fully set forth herein.

28.
Acting under color of law and pursuant to official policy or custom, CITY, through

supervisory personnel, including but not limited to Chief of Police Crump, Sgt. Jones (the

commanding officer at the scene), as well as Internal Affairs investigators who investigated the

incident but failed to take any corrective action toward the officers involved, knowingly,

recklessly, and with deliberate indifference and callous disregard for the Plaintiff’s rights, failed

to instruct, supervise, control, and discipline the defendant police officers and those working in

concert with them on their duties relevant to “knock and talk” citizen encounters, the basic due

process rights implicated in an arrest scenario, the appropriate use of force, and truthfully and

accurately reporting facts in police reports. Those duties specifically include duties to refrain from

violating and conspiring to violate the rights, privileges, and immunities guaranteed to Plaintiff by

the Constitution and laws of the United States and the laws of the State of Louisiana in the specifics

set forth in the foregoing counts and other allegations of this Complaint and otherwise depriving

Plaintiff of his constitutional and statutory rights, privileges, and immunities. CITY had

knowledge, or had it exercised its duties to instruct, supervise, control, and discipline on a

continuing basis, should have had knowledge that the wrongs conspired to be done, as heretofore

alleged, were about to be and were being committed. CITY had the power to prevent the

commission of these wrongs, could have done so by reasonable diligence, and knowingly,

recklessly, and with deliberate indifference and callous disregard of the Plaintiff’s rights, failed or
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refused to do so. CITY, directly or indirectly, under color of law, approved or ratified the unlawful,

deliberate, malicious, reckless, and wanton conduct of the police officers heretofore described.

29.
As a direct and proximate cause of the acts of the defendants and those working in concert

with them as described above, Plaintiff has suffered personal injury, severe mental anguish, and

other losses in connection with the deprivation of his constitutional and statutory rights guaranteed

by the Fourth and Fourteenth Amendments of the Constitution of the United State of America and

protected by 42 U.S.C. §§ 1983, 1985, 1986, and 1988.

30.
These constitutional deprivations render CITY liable to Plaintiff for full compensatory

damages, attorney fees, costs of this action sufficient to remedy the damage to Plaintiff, and

punitive damages.

FOURTH CLAIM FOR RELIEF

STATE LAW CLAIM FOR INTENTIONAL TORT OF BATTERY

Plaintiff re-alleges paragraphs 1 through 30 as though fully set forth herein.

31.
Acting without Plaintiff’s consent or legal authority to arrest Plaintiff, Defendants JONES,

HANCOCK, and HYDE, intentionally, knowingly, recklessly, and with deliberate indifference

and callous disregard for Plaintiff’s rights, forcibly entered Plaintiff’s home, beat him, arrested

him, transported him to a patrol unit (and to jail) in his underwear, and charged him with having

committed violent crimes against a police officer. This physical attack was made in the absence of

any valid authority or probable cause, and thus constitutes the intentional tort of battery under the

laws of Louisiana.
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32.
Pursuant to the Court’s supplemental jurisdiction, Plaintiff shows that the action and/or

inaction of defendants, as set forth above, deprived Plaintiff of rights under State Law, including

the Louisiana Constitution of 1974, as amended, and Louisiana Civil Code Article 2315, 2317,

and 2320. These non-exclusive State Law deprivations render said defendants, along with other

unknown participants or co-conspirators, solidarily liable to Plaintiff for full compensatory

damages, including general damages and special damages (medical and legal expenses), and costs

of this action.

FIFTH CLAIM FOR RELIEF

STATE LAW CLAIM FOR INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

Plaintiff re-alleges paragraphs 1 through 32 as though fully set forth herein.

33.
By initiating the beating and false arrest of Plaintiff, Defendants engaged in conduct that

was both extreme and outrageous. As evidenced by Plaintiff’s cries for help and other exclamations

at the time of his beating and arrest, Plaintiff’s emotional distress was severe and of substantial

temporal duration. The conduct of JONES, HANCOCK, and HYDE was extreme and outrageous,

the emotional distress suffered by Mr. Sullivan was severe, and the officers desired to inflict severe

emotional distress or knew that severe emotional distress would be certain or substantially certain

to result from their conduct.

34.
Pursuant to the Court’s supplemental jurisdiction, Plaintiff shows that the action and/or

inaction of defendants, as set forth above, deprived Plaintiff of rights under State Law, including

the Louisiana Constitution of 1974, as amended, and Louisiana Civil Code Article 2315, 2317,

and 2320. These non-exclusive State Law deprivations render said defendants, along with other
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unknown participants or co-conspirators, solidarily liable to Plaintiff for full compensatory

damages, including general damages and special damages (medical and legal expenses), and costs

of this action.

SIXTH CLAIM FOR RELIEF

STATE LAW CLAIM FOR MALICIOUS PROSECUTION

Plaintiff re-alleges paragraphs 1 through 34 as though fully set forth herein.

35.
By filing false reports resulting in false charges against Mr. Sullivan, JONES and

HANCOCK commenced and caused an original criminal judicial proceeding. All of the charges

have been dismissed in favor of Mr. Sullivan, and there was no probable cause justifying the

initiation of those charges. The false police reports were made for the malicious purpose of

concealing the wrongful conduct of the officers who beat and arrested Mr. Sullivan, and for the

purpose of casting him in a negative light in order to justify the deprivation of rights that occurred.

Mr. Sullivan has suffered significant damages, including the costs of legal representation, bond

fees, medical treatment, and other general and special damages, which conform to applicable legal

standards controlling tort and civil rights remedies.

36.
Pursuant to the Court’s supplemental jurisdiction, Plaintiff shows that the action and/or

inaction of defendants, as set forth in the foregoing cited paragraphs, deprived Plaintiff of rights

under State Law, including the Louisiana Constitution of 1974, as amended, Louisiana Civil Code

Article 2315, 2317, and 2320. These non-exclusive state law deprivations render said defendants,

along with other unknown participants or co-conspirators, solidarily liable to Plaintiff for full

compensatory damages, including general damages and special damages (medical and legal

expenses), and costs of this action.

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SEVENTH CLAIM FOR RELIEF

INDEPENDENT LIABILITY OF CITY OF SHREVEPORT

Plaintiff re-alleges paragraphs 1 through 36 as though fully set forth herein.

37.
Pursuant to the Court’s supplemental jurisdiction, Plaintiff shows that the action and/or

inaction of CITY, as set forth in the foregoing cited paragraphs, deprived Plaintiff of rights under

State Law, including the Louisiana Constitution of 1974, as amended, Louisiana Civil Code Article

2315, 2317, and 2320, and including, but not limited to, theories of recovery such as abuse of

process, negligence, gross negligence, and intentional torts.

38.
These non-exclusive State Law deprivations render CITY liable to Plaintiff for full

compensatory damages, including general damages and special damages (medical and legal

expenses), and costs of this action.

EIGHTH CLAIM FOR RELIEF

VICARIOUS LIABILITY OF CITY OF SHREVEPORT
Plaintiff re-alleges paragraphs 1 through 38 as though fully set forth herein.
39.
Pursuant to the Court’s supplemental jurisdiction, Plaintiff shows that, at all times material

to this Complaint, CITY is liable for the actions of defendants Jones, Hancock, Hyde, and the other

employees of CITY, to the extent said persons were acting in the capacity as either agents or

employees of CITY, thereby placing liability upon CITY pursuant to the theories of agency,

respondeat superior, and vicarious liability for all causes and claims stated herein arising under

the law of the State of Louisiana.

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40.
These non-exclusive State Law deprivations render said defendants, along with other

unknown participants or co-conspirators, solidarily liable to Plaintiff for full compensatory

damages, including general damages and special damages (past, present, and future medical

expenses), and costs of this action.

NINTH CLAIM FOR RELIEF

CONSPIRACY TO VIOLATE CIVIL RIGHTS AND ABUSE OF PROCESS
Plaintiff re-alleges paragraphs 1 through 40 as though fully set forth herein.

41.
Defendants JONES, HANCOCK, and HYDE, conspired to bring false charges against Mr.

Sullivan in order to deprive Mr. Sullivan of due process and other constitutional rights in violation

of 42 U.S.C. § 1985. Further, JONES, HANCOCK, and HYDE’s conspiracy to bring false charges

against Mr. Sullivan constitutes abuse of process under the laws of Louisiana. Further, the

individual officers who falsely stated that Mr. Sullivan had committed a crime were aware of the

conspiracy, knew that it would serve to deprive Mr. Sullivan of his civil rights under the

Constitution, and neglected or refused to prevent that deprivation, in violation of 42 U.S.C. §§

1986.

42.
These non-exclusive deprivations and intentional acts render said defendants, along with

other unknown participants or co-conspirators, solidarily liable to Plaintiff for full compensatory

damages, including general damages and special damages (medical and legal expenses), costs of

this action, and punitive damages.

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TENTH CLAIM FOR RELIEF

LOUISIANA STATE LAW CLAIM FOR FALSE IMPRISONMENT

Plaintiff repeats and incorporates the allegations of paragraphs 1 through 42 as through

fully pled and stated herein.

43.
Defendants JONES, HANCOCK, and HYDE, and CITY, individually and together, and

jointly and severally, and by and through their agents, servants, and employees, unlawfully

restrained and/or imprisoned Plaintiff and restricted Plaintiff’s personal liberty and freedom of

locomotion.

44.
Defendant JONES, HANCOCK, and HYDE, and CITY, through its agents, servants, and

employees physically, aggressively, and unlawfully invaded the home of Plaintiff, and violently

took hold of him and restrained him with handcuffs, rendering him immobile.

45.
Defendants JONES, HANCOCK, and HYDE, and CITY, through its agents, servants,

employees, maliciously, willfully, deliberately, wantonly, intentionally, violently, negligently,

carelessly, and/or recklessly restrained Plaintiff, and restricted his movements with violence, brute

force, and the use of mechanical restraints including handcuffs.

46.
Plaintiff was falsely imprisoned, without any justification, and against his will, in his own

home, in the back of a police car, and in jail.

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47.
Defendants JONES, HANCOCK, and HYDE, and CITY, by and through their agents,

servants, and/or employees, acted without having any reasonable grounds to believe that Plaintiff

had committed a criminal offense, or that it was otherwise legally and morally necessary to restrain

him or imprison him.

48.
At no time did Plaintiff give permission, consent, or authority to be restrained or

imprisoned or confined by anyone.

49.
Plaintiff’s imprisonment and confinement were by physical force and physical barrier, and

his confinement was complete.

50.
As a direct and proximate foreseeable result of the Defendants’ false imprisonment, as set

forth above, Plaintiff suffered injuries, including physical bodily injuries, physical pain and

suffering, mental pain and suffering, emotional distress, and loss of enjoyment of life.

ELEVENTH CLAIM FOR RELIEF

VIOLATION OF 42 U.S.C. § 1983 - POLICY AND CUSTOM

Plaintiff repeats and incorporates the allegations of paragraphs 1 through 49 as though fully

pled and stated herein.

51.
At all relevant times, the employees, agents and/or officers of CITY’s Police Department,

including JONES, HANCOCK, AND HYDE, were acting under the color of state law.
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52.
At all relevant times, the employees, agents, and/or officers of Shreveport’s Police

Department, including JONES, HANCOCK, HYDE, as well internal affairs investigators, were

acting pursuant to an expressly adopted official policy or a longstanding practice or custom of the

Shreveport Police Department.

53.
Upon information and belief, Defendant City of Shreveport Police Department, including

its agents, employees, and/or officers, together with other City of Shreveport policymakers and

supervisors maintained, inter alia, the following unconstitutional customs, practices, and/or

policies:

a. Using excessive force;

b. Providing inadequate training regarding how to detain suspects and the appropriate use

of physical force;

c. Providing inadequate training regarding how to intervene to stop other officers from

using excessive force in detaining suspects;

d. Employing and/or retaining as police officers individuals who CITY knew, or

reasonably should have known, had dangerous propensities for abusing authority and for using

excessive force on suspects and other citizens;

e. Inadequately supervising, training controlling, assigning, and disciplining Shreveport

police officers and other personnel, including the individually named defendant officers, who

CITY knew, or in the exercise of reasonable care should have known, had the aforementioned

propensities and character traits; and/or

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f. Maintaining a policy of inaction and an attitude of indifference towards increasing

numbers of excessive use of police force, including by failing to discipline, retrain, investigate,

terminate, and recommend officers for criminal prosecution who participate in excessive use

of police force.

54.
CITY had actual and/or constructive knowledge of the deficient policies, practices and

customs alleged above. Despite having knowledge of the above, CITY condoned, tolerated, and

through its own actions or inactions, ratified such policies. CITY also acted with deliberate

indifference to the foreseeable effects and consequences of these policies with respect to the

constitutional rights of Plaintiff.

55.
As a direct and proximate result of the Constitutional violations caused by the employees,

agents and/or officers of the Shreveport Police Department, and the policy makers, Plaintiff

suffered violations of his Constitutional rights guaranteed to him by the Fourth, Fifth, Eighth, and

Fourteenth Amendments, as well as other provisions of the United States Constitution, and

suffered physical and emotional injuries.

56.
Moreover, as a result of the defendant Officers’ actions, including those of Officers

JONES, HANCOCK, and HYDE, Plaintiff suffered injuries and is entitled to recover all damages

allowable for constitutional violations such as 42 USC § 1983, including compensatory damages,

special damages, economic damages, all costs incurred in prosecuting this action, and attorney fees

pursuant to 42 USC § 1988.

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REQUEST FOR TRIAL BY JURY

Plaintiff desires and requests to have this case tried by a jury.
PRAYER
WHEREFORE, Plaintiff Austin Sullivan prays for judgment in his favor and against the
defendants in the following particulars:

a. For complete compensatory and special damages;

b. For judgment in favor of the Plaintiff and against defendants Sgt.

Jones, Hancock, and Hyde for appropriate punitive damages;

c. For judgment in favor of the Plaintiff and against the defendants, in

solido, for complete compensatory damages;

d. For this case to be tried by a jury;

e. For reasonable attorney’s fees as authorized by law;

f. For interest on all monetary awards from date of judicial demand

until paid;

g. For all costs of this proceeding, including expert witness fees; and,

h. Such other relief as this Court deems just and equitable.

Respectfully Submitted,
THE HATCH LAW FIRM, LLC.

/S/ CHRISTOPHER HATCH

CHRISTOPHER HATCH
LOUISIANA BAR NUMBER 32050
101 MILAM STREET, SUITE 100
SHREVEPORT, LOUISIANA 71101
318-424-1111 (TELEPHONE)
318-424-3651 (FACSIMILE)
CHRIS@FLHLAWYERS.COM
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JS 44 (Rev. 0) CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS AUSTIN SULLIVAN DEFENDANTS

CITY OF SHREVEPORT

(b) County of Residence of First Listed Plaintiff CADDO PARISH County of Residence of First Listed Defendant CADDO PARISH
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
CHRISTOPHER HATCH 318-424-1111
101 Milam Street, Suite 100, Shreveport, LA 71101

II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
u 1 U.S. Government u 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State u 1 u 1 Incorporated or Principal Place u 4 u 4
of Business In This State

u 2 U.S. Government u 4 Diversity Citizen of Another State u 2 u 2 Incorporated and Principal Place u 5 u 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a u 3 u 3 Foreign Nation u 6 u 6

Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
u 110 Insurance PERSONAL INJURY PERSONAL INJURY u 625 Drug Related Seizure u 422 Appeal 28 USC 158 u 375 False Claims Act
u 120 Marine u 310 Airplane u 365 Personal Injury - of Property 21 USC 881 u 423 Withdrawal u 376 Qui Tam (31 USC
u 130 Miller Act u 315 Airplane Product Product Liability u 690 Other 28 USC 157 3729(a))
u 140 Negotiable Instrument Liability u 367 Health Care/ u 400 State Reapportionment
u 150 Recovery of Overpayment u 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS u 410 Antitrust
& Enforcement of Judgment Slander Personal Injury u 820 Copyrights u 430 Banks and Banking
u 151 Medicare Act u 330 Federal Employers’ Product Liability u 830 Patent u 450 Commerce
u 152 Recovery of Defaulted Liability u 368 Asbestos Personal u 835 Patent - Abbreviated u 460 Deportation
Student Loans u 340 Marine Injury Product New Drug Application u 470 Racketeer Influenced and
(Excludes Veterans) u 345 Marine Product Liability u 840 Trademark Corrupt Organizations
u 153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR SOCIAL SECURITY u 480 Consumer Credit
of Veteran’s Benefits u 350 Motor Vehicle u 370 Other Fraud u 710 Fair Labor Standards u 861 HIA (1395ff) u 485 Telephone Consumer
u 160 Stockholders’ Suits u 355 Motor Vehicle u 371 Truth in Lending Act u 862 Black Lung (923) Protection Act
u 190 Other Contract Product Liability u 380 Other Personal u 720 Labor/Management u 863 DIWC/DIWW (405(g)) u 490 Cable/Sat TV
u 195 Contract Product Liability u 360 Other Personal Property Damage Relations u 864 SSID Title XVI u 850 Securities/Commodities/
u 196 Franchise Injury u 385 Property Damage u 740 Railway Labor Act u 865 RSI (405(g)) Exchange
u 362 Personal Injury - Product Liability u 751 Family and Medical u 890 Other Statutory Actions
Medical Malpractice Leave Act u 891 Agricultural Acts
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS u 790 Other Labor Litigation FEDERAL TAX SUITS u 893 Environmental Matters
u 210 Land Condemnation u 440 Other Civil Rights Habeas Corpus: u 791 Employee Retirement u 870 Taxes (U.S. Plaintiff u 895 Freedom of Information
u 220 Foreclosure u 441 Voting u 463 Alien Detainee Income Security Act or Defendant) Act
u 230 Rent Lease & Ejectment u 442 Employment u 510 Motions to Vacate u 871 IRS—Third Party u 896 Arbitration
u 240 Torts to Land u 443 Housing/ Sentence 26 USC 7609 u 899 Administrative Procedure
u 245 Tort Product Liability Accommodations u 530 General Act/Review or Appeal of
u 290 All Other Real Property u 445 Amer. w/Disabilities - u 535 Death Penalty IMMIGRATION Agency Decision
Employment Other: u 462 Naturalization Application u 950 Constitutionality of
u 446 Amer. w/Disabilities - u 540 Mandamus & Other u 465 Other Immigration State Statutes
Other u 550 Civil Rights Actions
u 448 Education u 555 Prison Condition
u 560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
u 1 Original u 2 Removed from u 3 Remanded from u 4 Reinstated or u 5 Transferred from u 6 Multidistrict u 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
42 USC Sec. 1983
VI. CAUSE OF ACTION Brief description of cause:
False Arrest/Excessive Force/Injury/Malicious Prosecution
VII. REQUESTED IN u CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. 125,000.00 JURY DEMAND: u Yes u No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD

FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE