Professional Documents
Culture Documents
Plaintiff, COMPLAINT
vs.
Defendant.
Count 1
Count 2
Count 3
bruising to his ear in Cedar Rapids, Linn County, Iowa. The child reported that he was
13 years-old when this happened.
Count 4
Count 5
Count 6
Count 7
creating a substantial risk to his son’s physical, mental or emotional health or safety,
by trying to choke him out and put a cigarette out on his head in Toddville, Linn County,
Iowa. The child reported this happened during the summer of 2021 when he was 13
years-old.
Count 8
knowingly acted in a manner creating a substantial risk to his son, H.L.’s, physical,
mental or emotional health or safety, by repeatedly calling him names like “retard” or
“stupid” or the “n” word or “bitch” repeatedly and verbally berating him while in
Toddville, Linn County, Iowa.
Count 9
knowingly acted in a manner creating a substantial risk to his son, K.L.’s, physical,
mental or emotional health or safety, by repeatedly calling him names like “retard” or
“stupid” or the “n” word or “bitch” repeatedly and verbally berating him while in
Toddville, Linn County, Iowa.
Count 10
knowingly acted in a manner creating a substantial risk to his son, L.L.’s, physical,
mental or emotional health or safety, by repeatedly calling him names like “retard” or
“stupid” or the “n” word or “bitch” repeatedly and verbally berating him while in
Toddville, Linn County, Iowa.
I, the undersigned, being duly sworn, state that all facts contained in this Complaint and
Affidavit, told to me by other reliable persons, form the basis for a finding of probable
cause by the court that the defendant committed this crime.
The defendant is the biological father who had care, custody and control of his three
sons: H.L., K.L. and L.L. between and including all of the above dates. As detailed
E-FILED 2022 MAR 23 3:41 PM LINN - CLERK OF DISTRICT COURT
above, the defendant reportedly physically abused H.L., now 13 years-old, by slamming
his head into a window sill causing a laceration, throwing a bottle at the back of his
head causing a laceration, punching him in the ear causing bruising and choking him
while trying to put a cigarette out on his head. The defendant reportedly physically
abused K.L., now 8 years-old, and L.L., now six years-old, by punching them both in the
head causing a red mark to his face on January 11, 2022, during the same incident.
The children reported that the defendant is mean to them and was always calling them
names like "retard", "bitch", "stupid" or the "n" word. This verbal abuse has created a
risk to their mental and emotional health. They reported he would drink alcohol and be
drunk when these incidents happened. The defendant admitted having an alcohol
problem and not remembering many of these incidents but did admit it was possible he
did them, and that he would box with his children and "that's called training" and to
using the above words to "joke" around with them.