Adamson v. City of San Francisco et al

Filing 1

COMPLAINT against City of San Francisco, Daniel Dudley, Christopher O'Brien, Brian Stansbury, Greg Suhr ( Filing fee $ 400, receipt number 0971-8151803.). Filed byLorenzo Adamson. (Burris, John) (Filed on 11/12/2013)

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JOHN L. BURRIS, Esq., (SBN 69888)
DEWITT LACY, Esq., (SBN 258789)
THE LAW OFFICES OF JOHN L. BURRIS
Airport Corporate Center
7677 Oakport Street, Suite 1120
Oakland, California 94621
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiff
LORENZO ADAMSON

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UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA

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LORENZO ADAMSON, an individual

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Plaintiff,
v.

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CITY OF SAN FRANCISCO, a municipal
corporation; GREG SUHR, individually and
in his official capacity as Chief of Police for
the CITY OF SAN FRANCISCO;
CHRISTOPHER O’BRIEN, individually and
in his official capacity as a Police Officer for
the CITY OF SAN FRANCISCO; DANIEL
DUDLEY, individually and in his official
capacity as a Police Officer for the CITY OF
SAN FRANCISCO; BRIAN STANSBURY,
individually and in his official capacity as a
Police Officer for the CITY OF SAN
FRANCISCO and DOES 1-50, inclusive; in
their individual and/or official capacities as
police officers for the CITY OF SAN
FRANCISCO,

Case No.:
COMPLAINT FOR DAMAGES
(42 U.S.C. Section 1983 and pendent
tort claims)
JURY TRIAL DEMANDED

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Defendants.
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INTRODUCTION

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1. These claims arise out of the unlawful use of force choking and arrest of

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an off-duty, African-American Police Officer, LORENZO ADAMSON, by fellow

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CITY OF SAN FRANCISCO Police Officers, on May 30, 2013. CITY OF SAN
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FRANCISCO Police Officers stopped Mr. ADAMSON for a traffic violation.

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CITY OF SAN FRANCISCO Police Officer BRIAN STANSBURY came up to

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Mr. ADAMSON’s window and immediately asked him if he was on parole,

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without bothering to ask for his license and insurance. CITY OF SAN

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FRANCISCO Police Officer DANIEL DUDLEY told Mr. ADAMSON to get out

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of the car and inexplicably lead him to the curb. Mr. ADAMSON identified
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himself as a San Francisco Police Officer. Despite identifying himself as a

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Police Officer, Officer DUDLEY came up from behind Mr. ADAMSON and

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began applying a carotid chokehold. Mr. ADAMSON attempted to show the

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officers his San Francisco Police Department issued badge. Mr. ADAMSON was

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unable to breathe and feared for his life as he fell to the ground with Officer
DUDLEY choking him. Finally, another patrol car arrived and identified Mr.

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ADAMSON as a San Francisco Police Officer. Mr. ADAMSON was
subsequently treated for his injuries and cited for resisting arrest.
JURISDICTION
2. This action arises under Title 42 of the United States Code, Section 1983.
Title 28 of the United States Code, Sections 1331 and 1343 confers jurisdiction
upon this Court. The unlawful acts and practices alleged herein occurred in the

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City of San Francisco, San Francisco County, California, which is within this

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judicial district.

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PARTIES
3. Plaintiff, LORENZO ADAMSON, is now and at all times mentioned

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herein a United States Citizen.
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4. Defendant CITY OF SAN FRANCISCO (hereinafter “CITY”) is, and at all

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times herein mentioned, a municipal entity duly organized and existing under the

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laws of the State of California. Under its authority, CITY OF SAN FRANCISCO

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operates the San Francisco Police Department.

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5. Defendant, GREG SUHR (hereinafter “CHIEF”) is and at all times herein

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mentioned, a United States citizen and a resident of California, and employed as
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the Chief of Police for CITY. He is sued in his individual and official
capacities.

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6. Defendant, DANIEL DUDLEY, (hereinafter “DUDLEY”) is and at all

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times herein mentioned, a United States citizen and a resident of California. He

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is sued individually and in his official capacity as Police Officer for the CITY.
7. Defendant, CHRISTOPHER O’BRIEN, (hereinafter “O”BRIEN”) is and at

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all times herein mentioned, a United States citizen and a resident of California.

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He is sued individually and in his official capacity as Police Officer for the

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CITY.

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8. Defendant, BRIAN STANSBURY, (hereinafter “STANSBURY”) is and at
all times herein mentioned, a United States citizen and a resident of California.
He is sued individually and in his official capacity as Police Officer for the

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CITY.

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9. Plaintiff is ignorant of the true names and/or capacities of Defendants

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sued herein as DOES 1 through 50, inclusive, and therefore sues said defendants

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by such fictitious names. Plaintiff will amend this complaint to allege their true

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names and capacities when ascertained. Plaintiff believes and alleges that each
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of the DOE defendants is legally responsible and liable for the incident, injuries

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and damages hereinafter set forth. Each defendant proximately caused injuries

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and damages because of their negligence, breach of duty, negligent supervision,

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management or control, violation of public policy and unlawful use of force.

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Each defendant is liable for his/her personal conduct, vicarious or imputed

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negligence, fault, or breach of duty, whether severally or jointly, or whether
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based upon agency, employment, ownership, entrustment, custody, care or

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control or upon any other act or omission. Plaintiff will ask leave to amend this

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complaint subject to further discovery.

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10. In doing the acts alleged herein, Defendants, and each of them acted
within the course and scope of their employment.
11. In doing the acts and/or omissions alleged herein, Defendants, and each of

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them, acted under color of authority and/or under color of law.
12. Due to the acts and/or omissions alleged herein, Defendants, and each of

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them, acted as the agent, servant, and employee and/or in concert with each of

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said other Defendants herein.

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13. For State causes of action related to Federal claims, Plaintiff is required
to comply with an administrative claim requirement under California law.

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Plaintiff has complied with all applicable requirements.

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FACTS

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14. On May 30, 2013, at 8:17 p.m., Plaintiff LORENZO ADAMSON was driving
northbound on Lane Street, in San Francisco, California. Mr. Adamson is a San Francisco

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Police Officer who is currently on disability leave.
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15. Mr. Adamson saw a CITY Police Department patrol car make a U-turn and pull up

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behind him with its lights flashing. Mr. Adamson pulled-over near the intersection of

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Third and Newcomb Streets. Three CITY Police officers were in the patrol car. CITY

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Police Officer STANSBURY was working as a Field Training Officer. CITY Police

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Officers DUDLEY and O’BRIEN were participating in field training, under the

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supervision of Defendant STANSBURY. Defendant STANSBURY walked up to the car
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and told Mr. Adamson, “I pulled you over because there is no license plate on your car.”
16. Defendant STANSBURY asked Mr. Adamson, “Are you on parole or probation?”

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Mr. Adamson knew that this was not what he practiced when enacting a traffic stop and

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noted the officer’s name on his name badge. The name badge said ‘STANSBURY.’ Mr.

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Adamson asked Defendant STANSBURY, “Officer Stansbury, why are you asking if I am
on parole or probation?” Defendant STANSBURY replied, “Because you don’t have a

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license plate on your car.” Mr. Adamson asked Defendant STANSBURY, “What does not

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having a plate on my car have to do with being on parole or probation? Shouldn’t you be

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asking for my license, registration and insurance?” Defendant STANSBURY replied,

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“That’s what we do out here.”

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17. Defendant STANSBURY told Mr. Adamson to take his keys out of the ignition and
Mr. Adamson complied. Defendant STANSBURY then told Mr. Adamson, “If you don’t

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answer my question I am going to take you out of the car.” Mr. Adamson did not respond

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to Defendant STANSBURY’s unwarranted question. Then Defendant STANSBURY

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ordered Defendant DUDLEY to get Mr. Adamson out of the car.

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18. Defendant DUDLEY opened Mr. Adamson’s driver side door and told him to get

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out of the car. Mr. Adamson immediately complied, got out of the car with his hands
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extended up in the air and asked, “Officer, what do you want me to do?” The officers lead

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Mr. Adamson to the curb. Mr. Adamson’s concern for his safety grew when he realized

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that the officers were deviating from what he understood as standard police practice and

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procedures. Mr. Adamson asked the officers, “Why are you taking me out of the car on a

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traffic stop?” One of the officers told Mr. Adamson, “Sit on the curb.” Mr. Adamson told

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the officers, “I can’t, I’m on DP for a low back injury.” ‘DP’ is police jargon for disability
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leave.

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19. One of the officers forcefully grabbed Mr. Adamson’s wrist and said, “Sit

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down.” Mr. Adamson then explained to the defendant officers, “Before this goes

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any further, I’m an officer and I work out of Bayview Station.” At this point,

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the officers knew that Mr. Adamson was an officer and that he was on leave for a
back injury; however, Defendant DUDLEY escalated the incident when he

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inexplicably jumped onto Mr. Adamson’s back and began applying a carotid

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restraint hold to Mr. Adamson. The defendant officer unsuccessfully applied the

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carotid restraint hold on Mr. Adamson and consequently began choking Mr.

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Adamson. Mr. Adamson frantically repeated, “I’m a cop, I’m a cop,” as he was

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being choked and gasping for air. Mr. Adamson and Defendant DUDLEY then
fell to the ground with DUDLEY landing on top of Mr. Adamson.

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20. Mr. Adamson lifted his shirt to display his San Francisco Police badge and gun to

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the Defendant officers. Defendant O’BRIEN then grabbed Mr. Adamson’s gun from his

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waistband while Defendant DUDLEY lay on top of Mr. Adamson. Mr. Adamson told the

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officers, “Hurry up and cuff me.” The Defendant officers placed Mr. Adamson in

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handcuffs, and laid him facedown on the ground until backup officers arrived.
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21. Thereafter, CITY police officers, Michael Ellis and Reginald Scott arrived and

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confirmed that Mr. Adamson was indeed a CITY police officer. Then the Defendant

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officers picked Mr. Adamson up off the ground and removed his handcuffs.

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22. Mr. Adamson was in severe pain and asked for an ambulance, but the Defendant
officers did not call an ambulance. Instead, Defendant officers took Mr. Adamson to the

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Bayview CITY Police Department station in an unmarked patrol car while another officer
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drove Mr. Adamson’s car to the station. Sometime later, paramedics were called and they

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transported Mr. Adamson from the Bayview station to a Kaiser medical facility in San

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Francisco. The incident aggravated Mr. Adamson’s back injuries. Then, adding insult to

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injury, the Defendant officers cited Mr. Adamson for resisting arrest and vehicle code

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violations.
23. All criminal charges against Mr. Adamson were later discharged by CITY District

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Attorney’s office.

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DAMAGES

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24. The battery of LORENZO ADAMSON as described herein was brutal, malicious

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and done without any just provocation or cause, proximately causing Plaintiff’s injuries
and resulting damages.
25. As a proximate result of Defendants’ conduct, Plaintiff suffered pain and physical

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injuries from being choked and tackled to the ground. As a further proximate result of

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Defendants’ conduct, Plaintiff suffered severe and extreme emotional distress, fear, terror,

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anxiety, humiliation, and loss of his sense of security, dignity, and pride as a United States

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citizen.

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26. The conduct of Defendants STANSBURY, O’BRIEN, DUDLEY and DOES 1-25
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was malicious, wanton, and oppressive. Plaintiff is therefore entitled to an award of
punitive damages against said Defendant Police Officers for CITY.
27. Plaintiff found it necessary to engage the services of private counsel to vindicate
his rights under the law. Plaintiff is therefore entitled to an award of all attorneys’ fees
incurred in relation to this action for violation of his civil rights.

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FIRST CAUSE OF ACTION
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(42 U.S.C. Section 1983)

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(Against Defendant Officers STANSBURY, DUDLEY, O’BRIEN and DOES 1-25)

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28. Plaintiff hereby re-alleges and incorporates by reference herein paragraphs 1

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through 27 of this Complaint.
29. In doing the acts complained of herein, Defendant STANSBURY, DUDLEY,
O’BRIEN and DOES 1-25, inclusive, and/or each of them, acted under color of law to

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deprive Plaintiff of certain constitutionally protected rights, including, but not limited to:
a. The right to be free from unreasonable searches and seizures, as guaranteed
by the Fourth and Fourteenth Amendments to the United States Constitution;
b. The right not to be deprived of life or liberty without due process of law, as
guaranteed by the Fourteenth Amendments to the United States Constitution;
c. The right to be free from the use of excessive force by police officers,

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which is guaranteed by the Fourth and Fourteenth Amendments to the United

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States Constitution;
d. The right to equal protection of the laws, as guaranteed by the Fourteenth
Amendment to the United States Constitution;

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30. Said rights are substantive guarantees under the Fourth and/or Fourteenth
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Amendments to the United States Constitution.
WHEREFORE, Plaintiff prays for relief as hereinafter set forth.

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SECOND CAUSE OF ACTION

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(Monell)

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(42 U.S.C. §1983)

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(Against CITY, CHIEF and DOES 26-50)
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31. Plaintiff hereby re-alleges and incorporates by reference herein paragraphs 1
through 30 of this Complaint.
32. As against Defendants CITY, CHIEF and/or DOES 26-50 and/or each of them,
individually and/or in their capacities as official policy-maker(s) for CITY, the Plaintiff
further alleges that the acts and/or omissions alleged in the Complaint herein are indicative

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and representative of a repeated course of conduct by members of Defendant CITY
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tantamount to a custom, policy or repeated practice of condoning and tacitly encouraging

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the abuse of police authority, and disregard for the constitutional rights of citizens, such as

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decedent and Plaintiff.

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33. Plaintiff is informed and believes and thereon alleges that the acts and/or omissions
alleged herein are the proximate result of a custom, policy, pattern or practice of deliberate
indifference by Defendants CITY, CHIEF and DOES 26-50 and/or each of them, to the

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repeated violations of the constitutional rights of citizens by CITY police officers, which

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have included, but are not limited to, repeated acts of: making false reports, using

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excessive and/or arbitrary force, deadly force and/or engaging in similar acts of

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misconduct on a repeated basis and failure to institute and enforce a consistent disciplinary

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policy.
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34. Plaintiff is further informed, believes and thereon alleges that these abuses of

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authority, including excessive force, racial profiling and racial discrimination are part of

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department training and practice, as indicated by Field Training Officer STANSBURY’s

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actions of asking about Plaintiff’s parole status which is contrary to known San Francisco

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Police Department policy and then excusing his conduct by saying ‘that’s what we do out

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here.’ Plaintiff is further informed, believes and thereon alleges the CITY has not
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disciplined or retrained any of the officers that have engaged in excessive use of force.

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Plaintiff is further informed, believes and thereon alleges the CITY has ratified, approved

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and condoned the aforementioned uses of deadly force and loss of life.

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35. Plaintiff is further informed and believes and thereon alleges the damages sustained
as alleged herein were the proximate result of customs, policies and/or practices which
included, but were not limited to, the failure to adequately or appropriately hold officers

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accountable for their misconduct, the failure to properly and fairly investigate complaints

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about officers’ misconduct, the failure to enact or adopt policies to ensure adequate and/or

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appropriate oversight of officers to prevent continuing violations of the rights of citizens.

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36. Plaintiff is further informed and believes and thereon alleges that the damages

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sustained as alleged herein were the proximate result of customs, policies and/or practices,
which included, but were not limited to, the failure to adequately or appropriately train

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officers in making detentions and/or arrests.

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a. The aforementioned deliberate indifference, customs, policies or practices of

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defendants CITY, CHIEF and DOES 26-50, and/or each of them, resulted in

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the deprivation of the constitutional rights of the Plaintiff, including, but not

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limited to, the following: the right not to be deprived of life, liberty or
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property without Due Process of Law;

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b. the right to be free from unreasonable searches and/or seizures; and/or,

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c. the right to enjoy civil and statutory rights.

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37. Said rights are substantive guarantees under the Fourth and/or Fourteenth
Amendments to the United States Constitution.

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38. As a result of the violation of their constitutional rights by Defendants CITY,
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CHIEF and/or DOES 26-50 and/or each of them, Plaintiff sustained the injuries and/or
damages as alleged heretofore in this Complaint.
WHEREFORE, Plaintiff prays for relief as hereinafter set forth.

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THIRD CAUSE OF ACTION

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(Violation of State Statutory Rights)

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(Violation of CALIFORNIA CIVIL CODE §51.7)
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(Against Defendants STANSBURY, DUDLEY, OBRIEN and DOES 1 – 25)
39. Plaintiff re-alleges and incorporates by reference herein paragraphs 1 through 38 of
this Complaint.
40. Plaintiff is informed, believes and thereon alleges that the conduct of Defendant
STANSBURY, DUDLEY, O’BRIEN and DOES 1-25, inclusive, as described herein, was
motivated by racial prejudice against LORENZO ADAMSON. Plaintiff is and was readily

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recognizable as African-American. When Plaintiff asked why he was being questioned

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about his status as a parolee, Defendant STANSBURY replied “that’s what we do out

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here.” CITY’S Bayview District is one of the few areas in CITY with a sizeable African

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American population. Accordingly, Plaintiff is informed and believes Defendant

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STANSBURY’S asked about Plaintiff’s status as a parolee because Plaintiff is an African5
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American. In engaging in such conduct, Defendants violated Plaintiff’s rights under

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California Civil Code §51.7 to be free from violence, or intimidation by threat of violence

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committed against Plaintiff because of his race.

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41. Under the provisions of California Civil Code §52(b), Defendants are liable for
punitive damages for each violation of Civil Code §51.7, reasonable attorney’s fees and an

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additional $25,000.00.
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42. As a proximate result of Defendants’ wrongful conduct, Plaintiff suffered damages
as hereinafter set forth.
WHEREFORE, Plaintiff prays for relief as hereinafter set forth.

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FOURTH CAUSE OF ACTION

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(Violation of Civil Code Section 52.1)
(Plaintiff against Defendants STANSBURY, DUDLEY, O’BRIEN and DOES 1-25)

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43. Plaintiff re-alleges and incorporates by reference herein paragraphs 1 through 42 of
this Complaint.
44. The conduct of Defendants STANSBURY, DUDLEY, O’BRIEN and DOES 1-25,
inclusive, as described herein, acting in the course and scope of their employment for
CITY, violated California Civil Code Section 52.1, in that they interfered with Plaintiff’s
exercise and enjoyment of his civil rights, through use of wrongful and excessive force and

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failure to make a proper or reasonable arrest of Plaintiff, all accomplished through force,

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threats, intimidation, and coercion.
45. As a direct and proximate result of Defendants’ violation of Civil Code Section
52.1 Plaintiff suffered violation of his constitutional rights, and suffered damages as set

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forth herein.
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46. Since this conduct occurred in the course and scope of their employment, CITY is
therefore liable to Plaintiff pursuant to respondeat superior.
47. Plaintiff is entitled to injunctive relief and an award of his reasonable attorney’s
fees pursuant to Civil Code Section 52.1(h).
WHEREFORE, Plaintiff prays for relief, as hereinafter set forth.

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FIFTH CAUSE OF ACTION
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(Assault and Battery)

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(Against Defendants STANSBURY, DUDLEY, O’BRIEN and DOES 1-25)
48. Plaintiff re-alleges and incorporates by reference herein paragraphs 1 through 47 of
this Complaint.
49. Defendants STANSBURY, DUDLEY, O’BRIEN and DOES 1-25, inclusive,
placed Plaintiff in immediate fear of death and severe bodily harm by deviating from

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department policy; forcing him out of his car; leading him out of public view and choking
him, without any just provocation or cause.
50. These Defendants’ conduct was neither privileged nor justified under statute or
common law.
51. As a proximate result of defendants’ conduct, Plaintiff suffered damages as
hereinafter set forth.

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WHEREFORE, Plaintiff prays for relief as hereinafter set forth.

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SIXTH CAUSE OF ACTION

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(Intentional Infliction of Emotional Distress)

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(Against Defendant STANSBURY, DUDLEY, O’BRIEN and DOES 1-25)

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52. Plaintiff re-alleges and incorporates by reference herein paragraphs 1 through 51 of
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this Complaint.
53. The conduct of Defendants STANSBURY, DUDLEY, O’BRIEN and DOES 1-25,

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inclusive, as set forth herein, were extreme and outrageous and beyond the scope of

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conduct which should be tolerated by citizens in a democratic and civilized society.

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Defendants committed these extreme and outrageous acts with the intent to inflict severe

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mental and emotional distress upon Plaintiff.
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54. As a proximate result of Defendants’ willful, intentional and malicious conduct,

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plaintiff suffered severe and extreme mental and emotional distress. Therefore, Plaintiff is

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entitled to an award of punitive damages as against said defendants. Plaintiff has suffered

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damages as hereinafter set forth.

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WHEREFORE, Plaintiff prays for relief as hereinafter set forth.

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SEVENTH CAUSE OF ACTION
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(Negligence)

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(Against Defendants STANSBURY, DUDLEY, O’BRIEN and DOES 1-25)
55. Plaintiff re-alleges and incorporates by reference herein paragraphs 1 through 54 of
this complaint, except for any and all allegations of intentional, malicious, extreme,
outrageous, wanton, and oppressive conduct by defendants, and any and all allegations
requesting punitive damages.

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56. At all times herein mentioned, Defendants STANSBURY, DUDLEY, O’BRIEN

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and DOES 1-25, inclusive, were subject to a duty of care to avoid causing unnecessary

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physical harm and distress to persons through their use of force and making of arrests. The

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wrongful conduct of Defendants, as set forth herein, did not comply with the standard of

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care to be exercised by reasonable persons, proximately causing plaintiff to suffer injuries
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and damages as set forth herein. Pursuant to Government Code Section 815.2(a), CITY is

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vicariously liable to Plaintiff for his injuries and damages suffered as alleged herein,

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incurred as a proximate result of the aforementioned wrongful conduct of Defendants.

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57. As a proximate result of Defendants’ negligent conduct, Plaintiff suffered severe
physical injury, severe emotional and mental distress, injury having a traumatic effect on

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Plaintiff’s emotional tranquility, and suffered damages.
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WHEREFORE, Plaintiff prays for relief as hereinafter set forth.
JURY DEMAND

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58. Plaintiff hereby demands a jury trial in this action.

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PRAYER
WHEREFORE, Plaintiff prays for relief, as follows:

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1. For general damages in a sum to be determined according to proof;
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2. For special damages, including but not limited to, past, present and/or future

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wage loss, income and support, medical expenses and other special damages in a sum to be

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determined according to proof;

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3. For funeral and burial expenses according to proof;
4. For punitive damages and exemplary damages in amounts to be determined
according to proof as to defendants and/or DOES 1 through 25 and/or each of them;

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5. For reasonable attorney’s fees pursuant to 42 U.S.C. §1988 and U.S.C. Section

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794a;
7. For violation of California Civil Code Sections 51.7 and 52.1, statutory
damages, and reasonable attorney’s fees;

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8. For cost of suit herein incurred;
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T HE L AW O FFICES

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Dated: November 12, 2013

OF

J OHN L. B URRIS

____/s/ John L. Burris____________
John L. Burris, Esq.

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