Case 5:20-cv-00530-D Document 1 Filed 06/08/20 Page 1 of 7

IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF OKLAHOMA

RAMALLE MEADOWS,
ciy CaseTlo. D
Plaintiff,
CIVIL RIGHTS COMPLAINT PURSUANT
V.
TO 42 U.S.C. SECTION 1983
JURY TRIAL DEMAND
THE CITY OF THE VILLAGE, OKLAHOMA,
LT. RYAN JACOBSON, individually and in
his official capacity as City Of The Village
Police Officer, Corporal Swatzbaugh,
individually and in his official capacity as
City of the Village Police Officer,
JUN 0 8 2020
Defendants.
CLERK, COURT
by
DEPUTY
COMPLAINT

STATEMENT OF JURISDICTION

1. Plaintiff brings this action for money damages and other relief for violations of the
Fourth Amendment to the United States Constitution as made applicable to the states by the
Fourteenth Amendment to the United States Constitution to not be made subject of an
unreasonable seizure. These claims are being brought against the City of the Village,
Oklahoma. Lt Ryan Jacobson, police officer and employee of the City of the Village. Oklahoma
and the City of the Village Police Department through 42 U.S.C. Section 1983 which establishes
this court's jurisdiction. At all times material to Plaintiffs claims, the Defendants were acting
under color of state law and were state actors. Plaintiff also makes pendent claims under the
laws of Oklahoma as set forth below.

2. This Court also has jurisdiction over the claims in this lawsuit pursuant to 28
U.S.C. Sections 1331(a)(3) and 1367.
3. This action for damages is also authorized by laws of the state of Oklahoma, in
particular 12 O.S. Section 95(A)(3) and 4
4. The unlawful acts alleged herein occurred in Oklahoma County, Oklahoma.
Thus, venue is proper in this Court pursuant to 28 U.S.C. Section 1391(b).
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 The Village
Case 5:20-cv-00530-D Police1-1
Document Department
Filed 06/08/20 Page 1 of 5
A. Incident Report

Incident #: 20~1121-OF
Call #: 20-1121

Date/Time Reported: 01/23/2020 1413

Report Date/Time: 01/23/2020 1452
Occurred Between: 01/22/2020 1504-01/23/2020 1506
Status: No Crime Involved

Reporting Officer: Lieutenant RYAN JACOBSON

Assisting Officer: Patrol Officer TAYLOR HARRILL
Approving Officer: Captain RON MORROW

Signature:

Signature:

# INVOLVED SEX RACE AGE SSN PHONE

NOT AVAIL

Military Active Duty: N

HEIGHT:^ 603 WEIGHT: 212 HAIR: NOT AVAIL. EYES: BROWN
BODY: COMPLEXION: BLACK
DOB: AjMH PLACE OF BIRTH: NOT AVAIL.
LICENSE NUMBER: I ETHNICITY: NOT HISPANIC

[APPEARANCE]

GENERAL APPEARANCE: DISORDERLY

GLASSES WORN: NO

# EVENTS(S)

LOCATION TYPE: Cornmercial/Office Building Zone: District B

10400 VINEYARD BLVD
THE VILLAGE OK 73120

RECEIVE INFORMATION

# PERSON(8) PERSON TYPE SEX RACE AGE SSN PHONE

HARRILL, OFFICER T PARTICIPANT NOT AVAIL 405-751-9564

2304 MANCHESTER DR
THE VILLAGE OK 73120
DOB: NOT AVAIL

EMPLOYER: THE VILLAGE POLICE DEPT. 405-751-9569

CONTACT INFORMATION:
Home Phone [Primary) 405-751-9564
Work Phone (Primary) 405-751-9569
E-Mail Address THarrill@TheVillageOK.org
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To whom it may concern.

On the 22, day of January 2020 about 3:00 p.m.,I Ramalle Meadows was leaving Loretta's

Adult Daycare center(10404 Vineyard Blvd. suite C-D)after completing my duties for the day

as an employee. I entered my vehicle and drove about 150ft to the next building at Loretta's

Home Health Care(10400 Vineyard Blvd. suite GlOl)where I am also an employee. I arrived

there to pick up my wife, Renita Meadows who is also an employee at both facilities named

above previously. Parking is tight due to numerous businesses/office buildings surrounding,

particularly Petro Land Services located at 10400 Blvd. suite C-D directly across from our office.
90% ofemployers are owners that own big trucks, mainly fords. As I was backing my truck into

a parking space, between my mother-in-law Mercedes Mrs. Loretta Thomas, who is the owner of
Loretta's Home Health Care and Loretta's Adult Daycare. I have 28inch wheels and tires on my

truck and they tend to rub the underbody dust cover when I turn my wheels to park or turn, and it

did just that. Also, while I was backing my vehicle into the parking space,I noticed three officers

who have been identified as Lieutenant Ryan Jacobson, Officer Tailor Harrill, and Corporal

Swartzbaugh watching as I parked. They where about to leave after finishing a previous call

concerning a tenant and building owner at 10400 N. Vineyard Blvd suite B also across from our

office. As I proceeded to park, I pulled extremely close to my mother-in-law gray Mercedes

Benz to allow my wife room enough to enter my vehicle. After parking,I was approached by

three officers and asked if I had the vehicle(grey Mercedes),I then told the officers I had not hit

anything! My tires rub when I turn my wheels and that's what they heard and even ifI hit the
vehicle, it's my mother-in-law vehicle and I have insurance and It can be taken care of. They
then asked again a couple of more times if I had struck the grey Mercedes and again,I told them
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JS44 (Rev.06/17) CmL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither rralace nor supplement the filing and service ofpleading or other papers as required by law, except as
provided by local rules ofcourt This form,approved by the Judicial Conference ofthe United States in September 1974, is required for the use ofthe Clerk ofCourt for the
purpose ofinitiating the civil docket sheet. ^EEINSTRUCTIONS ON NEXTPAGE OF THIS FORM.)
I.(a) PLAINTIFFS DEFENDANTS
Ramalle Meadows The City of the Village, Oklahoma et at.

(b) Coimty ofResidence ofFirst Listed PlaintifiT Oklahoma Coimty ofResidence ofFirst Listed Defendant Oklahoma
(EXCEPTIN UB.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 (IfKnown)

unknown
16609 village Garden Dr.. Edmond Ok 73012
Ramalle Meadows Is appearing pro se

U. BASIS OF JURISDICTION (Place an "X"in OneBox Only) Ifl. CITI2<ENSIIIP OF PRINCIPAL PARTIES (P/oce on "X" in One Boxfor Plaintiff
(For Diversity Cases Only) and One Boxfor Defendant)
□ 1 U.S. Government 5^3 FederaKJuestion PTF DEF PTF DEF
Plaintiff (U.S Government Not a Party) Citizen of This State OlT 1 □ 1 Incorporated or Principal Place □ 4 I2lf4
of Business In This State

O 2 U.S. Goverrunent □ 4 Diversity Citizen of Another State 0 2 0 2 Incorporated and Principal Place 0 5 0 5
Defendant (Indicate Citizenship ofParties in Item III) of Business In Another State

Citizen or Subject of a 0 3 0 3 Foreign Nation O 6 0 6

Foreign Country

IV. NATURE OF SUIT (Place an "X" in One Box Only) CUckJiCTiybn_Natm^fSmtCo^^DesOTgtion|

CONTRACT
110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
1 SO Recovery of Overpayment □ 320 Assault, Libel &
& Enforcement of Judgment
151 Medicare Act
152 Recovery of Defaulted
Student Loans
(Excludes Veterans)
153 Recovery of Overpayment
of Veteran's Benefits
160 Stockholders' Suits
190 Other Contract
195 Contract Product Liability
196 Franchise
REAL PROPERTY
TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES "~1
PERSONAL INJURY PERSONAL INJURY □ 625 Drug Related Seizure □ 422 Appeal 28 USC 158 O 375 False Claims Act
O 310 Airplane O 365 Personal Injuiy - of Property 21 USC881 O 423 Withdrawal O 376QuiTam(31 USC
□ 315 Airplane Product Product Liability O 690 Other 28 USC 157 3729(a))
Liabili^ □ 367 Health Care/ □ 400 State Reapportionment
Pharmaceutical PROPERTY RIGHTS □ 410 Antitrust
Slander Personal Injury □ 820 Copyrights □ 430 Banks and Banking
□ 330 Federal Employers' Product Liability □ 830 Patent □ 450 Commerce
Liability □ 368 Asbestos Personal □ 835 Patent - Abbreviated □ 460 Deportation
□ 340 Marine Injury Product New Drug Application □ 470 Racketeer Influenced and
□ 345 Marine Product Liability □ 840 Trademark Corrupt Organizations
Liability PERSONAL PROPERTY fcABOR SOCIALSECURITY □ 480 Consumer Credit
□ 350 Motor Vehicle □ 370 Other Fraud □ 710 Fair Labor Standards □ 861 HlA(1395ff) □ 490 Cable/Sat TV
O 355 Motor Vehicle □ 371 Truth in Lending Act □ 862 Black Lung (923) □ 850 Securities/Commodities/
Product Liability □ 380 Other Personal □ 720 Labor/Management □ 863 DIWC/DIWW (405(g)) Exchange
□ 360 Other Personal Property Damage Relations □ 864 SSID Title XVI □ 890 Other Statutory Actions
Injury □ 385 Property Damage □ 740 Railway Labor Act □ 865 RSI (405(g)) □ 891 Agricultural Acts
□ 362 Personal Injuiy - Product Liability □ 751 Family and Medical □ 893 Environmental Matters
Medical Malpractice Leave Act □ 895 Freedom of Information
CIVIL RICBBFnS. PRISONER PETITIONS □ 790 Other Labor Litigation FEDERAL-TAXSUITS Act

□ 210 Land Condemnation ^440 Other Civil Rights
□ 220 Foreclosure O 441 Voting
□ 230 Rent Lease & Ejectment □ 442 Employment
□ 240 Torts to Land □ 443 Housing/
□ 245 Tort Product Liability Accommodations
□ 290 All Other Real Property □ 445 Amcr. w/Disabilitics ■
Employment
□ 446 Amer. w/Disabilities ■
Other
□ 448 Education
Habeas Corpus:
□ 463 Alien Detainee
□ 510 Motions to Vacate
Sentence
□ 530 General
□ 535 Death Penalty
Other:
□ 540 Mandamus & Other
□ 550 Civil Rights
□ 555 Prison Condition
□ 560 Civil Detainee-
Conditions of
Confinement
□ 791 Employee Retirement □ 870 Taxes (U.S. Plaintiff □ 896 Arbitration
Income Security Act or Defendant) □ 899 Administrative Procedure
□ 871 IRS—Third Party Act/Review or Appeal of
26 USC 7609 Agency Decision
□ 950 Constitutionality of
IMMIGRATION State Statutes
□ 462 Naturalization Application
□ 465 Other Immigration
Actions

V. ORIGIN (Place an "X" in One Box Only)

1 Original □ 2 Removed from □ 3 Remanded fiom □ 4 Reinstated or 5 Transferred from □ 6 Multidistrict □ 8 Multidistrict
Proceeding State Court Appellate Court Reopened Anodier District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not citeJuHstBciional statutes unless diversity):
42 U.S.C. Section 1983
VI. CAUSE OF ACTION Brief description of cause:
unlawful detention and unlawful investigatory detention in violation of Fourth and Fourteenth Amendments
VII. REQUESTED IN O CHECK IF THIS IS A CLASS ACTION DEMANDS CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.CV.P. JURY DEMAND: X Yes ONo
Vra. RELATED CASE(S)
(See instructions);
IF ANY JUDGE DOCKET NUMBER

DATE SIGNA OFATTO OF RECORD

FOR OFnCE USE ONLY

RECEIPT# AMOUNT APPLYING IFP JUDGE MAG. JUDGE