Plaintiffs’ Original Complaint Page 1
IN THE UNITED STATES DISTRICT COURTFOR THE SOUTHERN DISTRICT OF TEXASHOUSTON DIVISIONJOHNISA TURNER Individually and §JOHNISA TURNER as Next friend of §JAKADRIEN TURNER, a Minor, §§Plaintiff, §§v. § Civil Action No.: 4-10-CV-2683§UNITED STATES OF AMERICA, §ERIC H. HOLDER, JR., JUAN P. OSUNA §JANET NAPOLITANO, JOHN T. §MORTON, JAMES T. HAYES, JR., §KENNETH LANDGREBE and ICE DOES §§Defendants. §PLAINTIFFS’ ORIGINAL COMPLAINT
NOW COMES Plaintiffs, Johnisa Turner Individually and Johnisa Turner as NextFriend of Jakadrien Turner, a Minor, filing this, their Plaintiffs’ Original Complaint, andbrings this action against The United States of America, Eric H. Holder, Jr., Juan P.Osuna, Janet Napolitano, John T. Morton, James T. Hayes, Jr., Kenneth Landgrebe andICE Does, Individually and in their Official Capacity, who, jointly and severally, havedenied Plaintiffs their rights as guaranteed by the Constitution and laws of the UnitedStates of America and the State of Texas.
1. This civil rights action seeks injunctive relief and compensatory andpunitive damages as a result of the wrongful and illegal detention and deportation of Plaintiff Jakadrien Turner, a 15-year-old minor United States citizen born and raised in
Case 4:12-cv-01570 Document 1 Filed in TXSD on 05/22/12 Page 1 of 20