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Case 1:16-at-00533 Document 1 Filed 07/11/16 Page 1 of 13

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GERAGOS & GERAGOS


A PROFESSIONAL CORPORATION
LAWYERS
HISTORIC ENGINE CO. NO. 28
644 South Figueroa Street
Los Angeles, California 90017-3411
Telephone (213) 625-3900
Facsimile (213) 232-3255
Geragos@Geragos.com

MARK J. GERAGOS SBN 108325


BEN J. MEISELAS
SBN 277412
Attorneys for Plaintiffs THE ESTATE OF JASON ALDERMAN, JUDY EDENS,
A.K. by and through his Guardian ad litem NENA CHAVEZ, and S.A., by and
through his Guardian ad litem STEPHANIE ELLIOT

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF CALIFORNIA

GERAGOS & GERAGOS, APC

HISTORIC ENGINE CO. NO. 28


644 South Figueroa Street
Los Angeles, California 90017-3411

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THE ESTATE OF JASON


ALDERMAN; JUDY EDENS, an
individual; A.K., by and through his
guardian ad litem NENA CHAVEZ; and
S.A., by and through his guardian ad
litem STEPHANIE ELLIOTT,
Plaintiffs,

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vs.

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CITY OF BAKERSFIELD;
BAKERSFIELD POLICE
DEPARTMENT; OFFICER CHAD
GARRETT, an individual; OFFICER
RICK WIMBISH, an individual; and
DOES 1-50,

Case No.:
COMPLAINT FOR DAMAGES:
1. VIOLATION OF CIVIL
RIGHTS 42 U.S.C. 1983
2. VIOLATION OF CIVIL
RIGHTS MONELL CLAIM
3. VIOLATION OF CIVIL
RIGHTS-FAMILIAL
RELATIONSHIP
4. VIOLATION OF CIVIL
RIGHTS FAMILIAL
RELATIONSHIP (MONELL)
5. VIOLATION OF CIVIL CODE
52.1
6. WRONGFUL DEATH NEGLIGENCE
DEMAND FOR JURY TRIAL

Defendants.

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Case 1:16-at-00533 Document 1 Filed 07/11/16 Page 2 of 13

Plaintiffs hereby allege as follows:


INTRODUCTION

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1.

On August 22, 2015, 29-year-old Jason Alderman was gunned down

execution style by Bakersfield Police Department (BDP) Officers Chad Garrett

and Rick Wimbish at a Subway restaurant while conducting an entirely separate

investigation and without engaging in any de-escalation protocol. Now, his two infant

sons and mother bring this suit against the City of Bakersfield, the Bakersfield Police

Department, and the officers named above, as a result of Mr. Aldermans wrongful

and untimely death.


THE PARTIES

GERAGOS & GERAGOS, APC

HISTORIC ENGINE CO. NO. 28


644 South Figueroa Street
Los Angeles, California 90017-3411

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2.

Plaintiff Judy Edens is the mother and heir to Decedent Jason Alderman.

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3.

Plaintiff A.K. is the son and heir to Decedent Jason Alderman. His claim

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is being brought by and through his Guardian ad litem Nena Chavez.


4.

Plaintiff S.A. is the son and heir to Decedent Jason Alderman. His claim

is being brought by and through his Guardian ad litem Stephanie Elliot.


5.

At all times herein mentioned, Defendant City of Bakersfield was a

governmental entity organized and existing under the laws of the State of California.
6.

At all times herein mentioned, the Bakersfield Police Department

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(BPD) was a governmental entity organized and existing under the laws of the State

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of California.

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7.

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Defendant Rick Wimbish, at all relevant times, was a police officer

employed by the City of Bakersfield acting under color of authority.


8.

Defendant Chad Garrett, at all relevant times, was a police officer

employed by the City of Bakersfield acting under color of authority.


9.

Plaintiff is unaware of the true names and capacities of the Defendants

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named herein as DOES 1 through 50, inclusive, and therefore sue said Defendants by

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such fictitious names. Plaintiffs will seek leave of court to amend this complaint to

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allege true names and capacities of said Defendants when the same are ascertained.
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Case 1:16-at-00533 Document 1 Filed 07/11/16 Page 3 of 13

Plaintiffs are informed and believe and thereon allege that each of the aforesaid

factiously names Defendants are responsible in some manner for the happenings and

occurrences hereinafter alleged, and the Plaintiffs damages and injuries as herein

alleged were caused by the conduct of said Defendants.


JURISDICTION, VENUE, AND NOTICE

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GERAGOS & GERAGOS, APC

HISTORIC ENGINE CO. NO. 28


644 South Figueroa Street
Los Angeles, California 90017-3411

This Court has jurisdiction over this action pursuant to 28 U.S.C. 1331

and 1343 because it is a civil rights action arising under the Constitution and laws of

the United States.

common law and state claims pursuant to 28 U.S.C. 1367. Venue is proper in this

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Court pursuant to 28 U.S.C. 1391 because a substantial part of the events giving rise

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to Plaintiffs claims occurred in the Eastern District of California.

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California Government Code section 910, Plaintiffs and each of them submitted a

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Government Tort Claim to the appropriate City of Bakersfield officials on January 8,

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2016.

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Bakersfields January 13, 2016 rejection of Plaintiffs Government Tort Claim.

This Court has supplemental jurisdiction over the remaining

The instant action is timely brought within 6 months from the City of

FACTUAL BACKGROUND

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Pursuant to

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On August 22, 2015 at approximately 11:22 p.m., Jason Alderman was

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shot in the side and back by BPD officers Rick Wimbish and Chad Garrett as he was

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attempting to exit a Subway restaurant. Mr. Alderman was in a crouching position

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with his back turned to the officers when he was struck by their gunfire.

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16.

The Subway restaurant is located at 1215 Olive Drive, Bakersfield,

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California. The entire duration of the incidentfrom when Mr. Alderman entered the

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Subway to the time he was executed inside the restaurantwas approximately 2

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minutes and 33 seconds.

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At the time of the shooting, BPD officers Garrett and Wimbish were not

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responding to a call at the Subway. Rather, the officers were conducting an entirely

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separate investigation when they suddenly arrived at the Subway and, within a 2-

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minute time period, shot and killed Mr. Alderman.


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and executioner in their interaction with Bakersfield citizens, treating the use of lethal

force as their first option during a civilian encounter and disregarding de-escalation

protocol, establishing perimeters, calling for backup, and using non-lethal force.

Non-lethal force and de-escalation are not even in BPDs vocabulary.


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Garrett and Wimbish have been involved in multiple other officer-

involved-shootings of unarmed men, including BPDs own confidential informant

Jorge Ramirez and 22-year-old James DeLarosa, whose corpse was subsequently

manipulated by another BPD officer who stated that he loved tickling the corpses of

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HISTORIC ENGINE CO. NO. 28
644 South Figueroa Street
Los Angeles, California 90017-3411

BPD officers Garrett and Wimbish have divined themselves judge, jury,

GERAGOS & GERAGOS, APC

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the people BPD killed.


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Video surveillance and the November 2015 autopsy investigation report

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contradict BPD statements made to the public that Mr. Alderman exited the subway

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and pointed a BMW carjack at the officers, which they mistook for a gun.

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The autopsy investigation report, which purports to be dated November

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2, 2015, found back-to-front entry wounds, confirming that Mr. Alderman was shot in

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the side and back.

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Initially, BPD denied the existence of video footage capturing the killing.

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Upon the discovery of functioning video surveillance capabilities at the time of the

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incident by the Alderman family attorneys, BPD acknowledged video existed but

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stated it would not be released for the dignity of the Alderman family.

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Alderman family thereafter demanded to see the video and sent an investigator to

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BPD headquarters to retrieve it. BPD again stated that it would not turn over the

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video, and reiterated that its refusal was meant to help the Alderman family.

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The

Nearly 6 months after Mr. Aldermans murder, and after multiple formal

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requests by Alderman family attorneys, BPD released the video of the shooting to the

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media before providing it to the Alderman family. The BPD eventually gave the

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Alderman family a non-functioning DVD. The video played by the media contradicts

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BPD reports that Alderman exited the Subway and presented an imminent threat to the
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lives of BPD officers. The video shows Alderman crouching with his back turned to

BPD officers when he was shot in the back and side and killed.

HISTORIC ENGINE CO. NO. 28


644 South Figueroa Street
Los Angeles, California 90017-3411

BPDs Critical Incident Review Board cleared BPD Officers Garrett and

Wimbish of misconduct on September 29, 2015.

confirming the news. However, at the time BPD cleared itself, the investigation into

the murder of Jason Alderman was far from complete. In the rush to clear itself at all

costs, BPD violated all independent investigation protocols in reaching self-serving

findings of fact before the Coroners investigation report was complete. In fact, the

Coroners investigation is dated November 2, 2015, more than a month after BPD

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GERAGOS & GERAGOS, APC

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BPD issued a press release

rendered its findings.


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The completed coroners investigation report, dated November 2, 2015,

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which had not been prepared when BPD cleared itself of wrongdoing on September

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29, 2015, clearly demonstrates the efforts by BPD to cover up the facts surrounding

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their execution of Jason Alderman. According to the autopsy investigation, BPD

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initially reported after the incident that Alderman exited the Subway, wearing a

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black mask, and raised a black colored object at the officers outside of the Subway.

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According to the initial reports from BPD officers, Alderman ran back into the

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Subway after he was shot.

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The autopsy report itself is backdated to November 2, 2015, as it

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references a communication with BPD Detective Ken Sporer which took place nearly

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a week later on November 7, 2015, further calling into question the veracity and

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authenticity of any document relating to the Alderman investigation. In any event, the

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November 2, 2015 autopsy investigation report states that on November 6, 2015, BPD

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Detective Sporer stated that he completed his investigation and for the first time

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provided the coroner with further information, that Alderman never exited the

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business. According to the Coroners report, this new information came from the

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video surveillance.

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Far from posing any threat to officers, the autopsy investigation report,
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Case 1:16-at-00533 Document 1 Filed 07/11/16 Page 6 of 13

which was completely ignored by BPDs Critical Incident Review Board, reveals what

can be seen on the video surveillance Jason Alderman was shot in the back in a non-

threatening position as he crouched to the ground.

FIRST CAUSE OF ACTION

(Violation of Civil Rights 42 U.S.C. 1983)

Plaintiffs against Defendants Wimbish, Garrett, and Does 1 through 25

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GERAGOS & GERAGOS, APC

HISTORIC ENGINE CO. NO. 28


644 South Figueroa Street
Los Angeles, California 90017-3411

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Plaintiffs reallege and incorporate by reference each and every allegation

contained in the preceding paragraphs as if fully set forth herein.


29.

Defendants were, at all relevant times, law enforcement officers with the

City of Bakersfield Police Department who were acting under color of state law.
30.

Plaintiffs bring this claim for relief in their capacities as the successors-

in- interest and personal representatives of the decedent Jason Alderman.


31.

The foregoing claim for relief arose in decedents favor, and decedent

would have been the plaintiff with respect to this claim for relief had he lived.
32.

Defendants, acting under color of state law, deprived the decedent of

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rights, privileges, and immunities secured by the Constitution and laws of the United

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States, including those enumerated in and secured by the Fourth, Fifth, and Fourteenth

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Amendments to the Constitution, by subjecting the decedent to excessive force when

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they shot and killed him.

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33.

The wrongful acts alleged herein above of Defendant police officers were

the cause of decedents death.


34.

As a proximate result of the foregoing wrongful acts of Defendants, and

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each of them, the Decedent sustained general damages, including pain and suffering,

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and a loss of the enjoyment of life and other hedonic damages, in an amount in

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accordance with proof.

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35.

In doing the foregoing wrongful acts, Defendants, and each of them,

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acted in reckless and callous disregard for the constitutional rights of Decedent. The

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wrongful acts, and each of them, were wilful, oppressive, fraudulent and malicious,
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thus warranting the award of punitive damages against each individual Defendant in

an amount adequate to punish the wrongdoers and deter future misconduct.

required to incur attorneys' fees and will continue to incur attorneys' fees, and

pursuant to 42 U.S.C. 1988 are entitled to recovery of said fees.

SECOND CAUSE OF ACTION

(Violation of Civil Rights- Monell Claim)

Plaintiffs against the City of Bakersfield and Does 26 through 50

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HISTORIC ENGINE CO. NO. 28
644 South Figueroa Street
Los Angeles, California 90017-3411

Due to the conduct of Defendants, and each of them, Plaintiffs have been

GERAGOS & GERAGOS, APC

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Plaintiffs reallege and incorporate by reference the allegations contained

in the preceding paragraphs of this complaint, as though fully set forth herein.
38.

Plaintiffs bring this claim for relief in their capacities as the successors-

in- interest and personal representatives of the Decedent Jason Alderman.


39.

Defendants, City of Bakersfield and Does 25 through 50, knowingly,

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with gross negligence, and in deliberate indifference to the Constitutional rights of

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citizens, maintain and permit an official policy and custom of permitting the

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occurrence of the types of wrongs set forth hereinabove and hereafter.

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40.

These policies and customs include, but are not limited to, the

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deliberately indifferent training of its law enforcement officers in the use of excessive

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force, the express and/or tacit encouragement of excessive force, the ratification of

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police misconduct, and the failure to conduct adequate unbiased investigations of

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police misconduct such that future violations do not occur.

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Plaintiffs are informed and believe, and thereon allege, that the customs

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and policies were the moving force behind the violations of Plaintiffs and Decedents

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rights. Based upon the principles set forth in Monell v. New York City Dept. of Social

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Services, the City of Bakersfield and Does 25 through 50 are liable for all of the

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injuries sustained by Decedent and Plaintiffs as set forth above.

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42.

As a proximate result of the foregoing wrongful acts of Defendants, and

each of them, the Decedent sustained general damages, including pain and suffering,
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and a loss of the enjoyment of life and other hedonic damages, in an amount in

accordance with proof.

HISTORIC ENGINE CO. NO. 28


644 South Figueroa Street
Los Angeles, California 90017-3411

Due to the conduct of Defendants, and each of them, Plaintiffs have been

required to incur attorneys' fees and will continue to incur attorneys' fees, and

pursuant to 42 U.S.C. 1988 are entitled to recovery of said fees.

THIRD CAUSE OF ACTION

(Violation of Civil Rights 42 U.S.C. 1983 Deprivation of the Rights of

Plaintiffs to a Familial Relationship with the Decedent)

Plaintiffs against Defendants Wimbish, Garrett, and Does 1 through 25)

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GERAGOS & GERAGOS, APC

43.

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Plaintiffs reallege and incorporate by reference the allegations contained

in the preceding paragraphs of this Complaint, as though fully set forth herein.
45.

Defendants, acting under color of state law, deprived Plaintiffs of their

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right to a familial relationship without due process of law by Defendants use of

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unjustified force, causing injuries which resulted in the Decedents death, all without

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provocation, all in violation of rights, privileges, and immunities secured by the First

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and Fourteenth Amendments to the United States Constitution.

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46.

As a result of the foregoing wrongful acts of Defendants, and each of

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them, Plaintiffs sustained general damages, including grief, emotional distress and

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pain and suffering and loss of comfort and society, and special damages, including

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loss of support, in an amount in accordance with proof.

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47.

In doing the foregoing wrongful acts, Defendants, and each of them,

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acted in reckless and callous disregard for the Constitutional rights of Plaintiffs when

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they killed the Decedent.

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oppressive, fraudulent, and malicious, thus warranting the award of punitive damages

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against each individual defendant in an amount adequate to punish the wrongdoers

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and deter future misconduct.

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48.

The wrongful acts, and each of them, were willful,

Due to the conduct of Defendants, and each of them, Plaintiffs have been

required to incur attorneys' fees and will continue to incur attorneys' fees, and
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FOURTH CAUSE OF ACTION

(Violation of Civil Rights for 42 U.S.C. 1983 Deprivation of the Rights of

Plaintiff to Familial Relationship with the DecedentMonell)

Plaintiffs against the City of Bakersfield and DOES 25 through 50)

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HISTORIC ENGINE CO. NO. 28


644 South Figueroa Street
Los Angeles, California 90017-3411

GERAGOS & GERAGOS, APC

pursuant to 42 U.S.C. 1988 are entitled to recovery of said fees.

49.

Plaintiffs reallege and incorporate by reference the allegations contained

in the preceding paragraphs of this Complaint, as though fully set forth herein.
50.

Defendants, City of Bakersfield, and DOES 25 through 50, knowingly

and with gross negligence, maintain and permit official policies and customs which

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allow the occurrence of the types of wrongs set forth hereinabove and below, all in

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deliberate indifference to the Constitutional rights of citizens.

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51.

These policies and customs include, but are not limited to, the

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deliberately indifferent training of its law enforcement officers in the use of excessive

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force, the express and/or tacit encouragement of excessive force. Further, the Citys

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ratification of police misconduct, along with the failure to conduct adequate

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investigations of misconduct leads to the violations of the Plaintiffs and the

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decedents Constitutional rights.

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52.

In spite of Plaintiffs filing of a claim, the City of Bakersfield failed to

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make an unbiased investigation, or take any action in preserving Plaintiffs or

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Decedents rights, or verify misconduct and discipline officers for the misconduct.

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Plaintiff are informed and believe, and thereon allege, that the customs and policies

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were the moving force behind the violations of Plaintiffs and decedents rights.

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Based upon the principles set forth in Monell v. New York City Dept. of Social

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Services, the City of Bakersfield is liable for all of the injuries sustained by Plaintiffs

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as set forth above.

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53.

In acting as alleged herein, Defendants, and each of them, caused Jason

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Aldermans demise and the resulting loss to Plaintiffs, thereby causing Plaintiffs to be

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damaged in an amount to be determined at the time of trial.


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required to incur attorneys' fees and will continue to incur attorneys' fees, and

pursuant to 42 U.S.C. 1988 are entitled to recovery of said fees.

FIFTH CAUSE OF ACTION

(Violation of Civil Code 52.1)

Plaintiffs against all Defendants

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HISTORIC ENGINE CO. NO. 28
644 South Figueroa Street
Los Angeles, California 90017-3411

Due to the conduct of Defendants, and each of them, Plaintiffs have been

GERAGOS & GERAGOS, APC

54.

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55.

Plaintiffs reallege and incorporate by reference the allegations contained

in the preceding paragraphs of this complaint, as though fully set forth herein.
56.

Defendants Wimbish, Garrett, and Does 1-50, acting within the scope of

their duties as City of Bakersfield employees, caused the death of Jason Alderman.
57.

Defendants City of Bakersfield and the Bakersfield Police Department

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are liable for the acts, omissions and conduct of its employees, including Defendants

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herein, whose negligent conduct was a cause in the death of the Decedent, pursuant to

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California Government Code 815.2.

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58.

Plaintiffs filed a timely claim pursuant to California Government Code

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910 et seq. As those claims having been rejected within the past six months, this

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action is timely.

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59.

Plaintiffs are the proper parties with standing as successors-in-interest

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and on behalf of the decedent pursue the claims of the decedent based on a violation

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of his rights.

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60.

The conduct of Defendants constituted interference by threats,

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intimidation, or coercion, or attempted interference, with the exercise of enjoyment by

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decedent Jason Alderman of rights secured by the Constitution of laws of the United

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States, or secured by the Constitution or laws of the State of California, including

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interference with Decedent's rights to be secure in his person and free from the use of

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excessive force under the Fourth Amendment and Cal. Const. Art. 1 sec. 13 as well as

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Cal. Civ.Code 43, and the right of protection from bodily restraint and harm.

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61.

As a direct cause of Defendants conduct, the Decedents rights pursuant


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to California Civil Code 52.1 were violated, causing injuries and damages in an

amount to be proved at the time of trial.

required to incur attorneys' fees and will continue to incur attorneys' fees, and

pursuant to California Civil Code 52.1 are entitled to recovery of said fees.

SIXTH CAUSE OF ACTION

(Negligence-Wrongful Death)

Plaintiffs against all Defendants

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HISTORIC ENGINE CO. NO. 28
644 South Figueroa Street
Los Angeles, California 90017-3411

Due to the conduct of Defendants, and each of them, Plaintiffs have been

GERAGOS & GERAGOS, APC

62.

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63.

Plaintiff realleges and incorporates by reference the allegations contained

in the preceding paragraphs of this complaint, as though fully set forth herein.
64.

Defendants Wimbish, Garrett, and Does 1-25, acting within the scope of

their duties as City of Bakersfield employees, caused the death of Jason Alderman.
65.

Defendants City of Bakersfield and the Bakersfield Police Department

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are hereby liable for the acts, omissions and conduct of their employees, including

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Defendants herein, whose negligent conduct was a cause in the death of the Decedent,

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pursuant to California Government Code 815.2.

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66.

Plaintiffs filed a timely claim pursuant to California Government Code

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910 et seq. Those claims having been rejected within the past six months, this action

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is timely.

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67.

Plaintiffs are the proper party with standing pursuant to Cal. Civ. Proc.

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Code 377.60 and hereby pursue their remedies for wrongful death against

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Defendants, and each of them, including pecuniary loss and other compensable

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injuries resulting from the loss of the society, comfort, attention, services, and support

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of the decedent.

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68.

The negligence of Defendants was also responsible in part for the death

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of Jason Alderman by acts or omissions contributing to his demise including, but not

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limited to, the deliberately indifferent training of its law enforcement officers in the

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use of excessive force, the express and/or tacit encouragement of excessive force, the
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ratification of police misconduct, and the failure to conduct adequate unbiased

investigations of police misconduct such that future violations do not occur.

69.

Decedent was a loving father and his loss has and will continue to cause

great and severe damages to his children, the Plaintiffs in this action, all in an amount

according to proof at the time of trial.

70.

As a further direct result of the acts, omissions, negligence conduct

and/or reckless disregard for the safety of decedent, Defendants, and each of them,

Plaintiffs have incurred funeral and burial expenses in an amount according to proof at

the time of trial.

GERAGOS & GERAGOS, APC

HISTORIC ENGINE CO. NO. 28


644 South Figueroa Street
Los Angeles, California 90017-3411

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WHEREFORE, Plaintiffs prays for judgment as follows:

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1.

For general damages in an amount to be determined by proof at trial;

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2.

For special damages in an amount to be determined by proof at trial;

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3.

For punitive and exemplary damages against the individual defendants


for the First and Third Causes of Action;

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4.

For costs of suit;

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5.

For reasonable attorneys fees as provided by statute; and

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6.

For such other and further relief as the Court deems just and proper.

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DATED: July 11, 2016

GERAGOS & GERAGOS, APC

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By:

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/s/ Mark J. Geragos


MARK J. GERAGOS
BEN J. MEISELAS
Attorneys for Plaintiffs

Case 1:16-at-00533 Document 1 Filed 07/11/16 Page 13 of 13

DEMAND FOR JURY TRIAL

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Plaintiffs THE ESTATE OF JASON ALDERMAN, JUDY EDENS, A.K. by

and through his Guardian ad litem NENA CHAVEZ, and S.A., by and through his

Guardian ad litem STEPHANIE ELLIOT hereby demand a jury trial.

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GERAGOS & GERAGOS, APC

DATED: July 11, 2016

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By:

/s/ Mark J. Geragos


MARK J. GERAGOS
BEN J. MEISELAS
Attorneys for Plaintiffs

GERAGOS & GERAGOS, APC

HISTORIC ENGINE CO. NO. 28


644 South Figueroa Street
Los Angeles, California 90017-3411

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