The Greeley Police Department had been to Ms. Griego’s home at 2423 East 18
Street, Greeley, Colorado twice in the past year to inquire about Angela, and Ms. Griegorepeatedly told officers that the woman no longer lived at that address. Nevertheless, the officersstill entered her home on June 15, 2010 without probable cause to believe that Angela was livingthere.9.
Defendants relied on an address listing for Angela that had been current on February12, 2008, but at the time of the June 15, 2010 raid was over two years old.10.
Upon arriving at Ms. Griego’s residence, Defendants banged on the front door; notreceiving an answer, they broke down the door to gain entry. Defendants then entered Ms.Griego’s home with their weapons drawn and pointed towards Ms. Griego and her young son,Colby Frias. The officers detained Ms. Griego and continued to threaten her and her son.11.
When the officers arrived, Ms. Griego was in the shower and her nine-year-old sonwas sleeping in his bedroom. Ms. Griego dressed and approached the front door. When she gotto the door to unlock it, the officers burst inside, breaking the door in the process.12.
Ms. Griego was placed in handcuffs in the presence of her young son until she wasable to convince Defendants that she was not Angela.13.
During this incident and to date, despite numerous requests, Ms. Griego has not beenpresented with a warrant authorizing Defendants to enter Ms. Griego’s home or to detain her.14.
Ms. Griego and her son were severely traumatized by the event. Her son continues tosuffer nightmares as a result and will no longer sleep in his bedroom or answer the door.
FIRST CLAIM FOR RELIEF
(§ 1983 Fourth Amendment Violation – Unlawful Entry)15.
Plaintiffs incorporate all other paragraphs of this Complaint for purposes of thisclaim.3
Case 1:12-cv-01392-RBJ Document 1 Filed 05/29/12 USDC Colorado Page 3 of 6