RerafagersisJeMLN Donen Fledosoue4 Page 1 oBgenRt 116 TY Us osiacrcoxn | wady eet osu WAR O 1 ata UNEED stares pistRICE couRT ame aa te WESTERN DISTRICT OF LOUISIANA, nl SHREVEPORT DIVISION TONYA MANN CIVIL ACTION NO. (AKA TONYA MANN-OLIVER), on behalf of her SECTION ‘Minor daughters, K.M. and A.M, supor VERSUS MAGISTRATE JUDGE ity of Bossier through its Mayor, TRIAL BY JURY DEMANDID ‘Thomas H, Chaney, in bis ofa) capacity, Sheriff Jalian Whitington, Sri at she Rosser Parvh Sheriff Office ‘in ooh is individual and otal eapaiy, Police Chie€ Dane Haagen, as Tolle Chie of Bosier City Police Department ‘in bo his individual and oficial capacty, BCPD Officer Dion Hunt, both individually and in his: cial capacity, BPSO Deputy Richard Sih, both individually andi sofia pac, BED Officer Chad Hollins, both iaivially and ibs oficial capacity, BED Sergeant "Tony Vandagrfy, bs invidually an in his ‘offal cupasty, BRSO Deputy Mareus Hays, toh odivhiily and in his oial capacity, [BCED Ofer nyo Holland, bot individually aud in his oficial eapacity, BCPD Officer BBarey Walsh, both inivvaly adi ie ‘ficial capacity, BCPD Officer Keith Campbel, ‘oth individually and in is ofa pacity, BPSO Deputy Jason! Sowet, both individ ‘nis oficinl capacity, BESO Deputy Dylan ‘Dison, both individually and in his official eapaicy, BCPD Offices Richard Polit, bok indidally ad J socal capacity, BESO. Deputy Bryan Sprankle, both ndvially nd i his ofl capacity, BCD Sergeant Michael Lonbardino, Je, both individually ana in is ffs eapacity, RCRD Sergeant Steven ‘Boothe, both individually and nhs offal capacity, ‘BCPD Ofticer Grogory Russel, oth individually adi his ofa emooty, REPD Offer Jeremy Watson, ‘bth individually and in soil expat, ‘Case 5:24-cv-00318-JE-MLH DocumentS Filed 03/01/24 Page 2 of 25 PagelD #: 117 BCED Ofticee Matthew Boyd, both individally ‘and in his official expacity, BCRD Officer ‘Mares Green, both individually and in his official eapscity, Polis C ‘Todd Gibson as Police Chief of Haughton Polles Department both in his individual ‘and official capacity, MPD Officer Putriek mond, Jr, both individually und i his ‘official capaci, HPD Sergeant Michnel ‘Freeman, both individually and in his official capacity, HPD Officer Steven Kenn ‘oth individually andi his official expacity, HPD Olicer Jesse Cutrer PLAINTIEE'S 101 chs NOW INTO COURT, comes Maintif, Tonya Mann, appearing on behalf of her mivor fila, KLM. and A.M, who with respectfully submits this Pro Se Petition for Damages as iallaws: YRELIMINARY STATEMENT 1 ‘This 1 a civil rights action Srooght puisunat fo 42 USC. § 1983 and faisig supplemental state-law clalins concemning thedctions of Detendanis the City of Bassler through, {ts Mayor, Thomas If, Chandier, in his offieial capacity, Sheriff Julian Whitington, Sheriff ‘ofthe Hosslor Parish Sheriff Otfiee in both his individual and official capacity, Police Chief Danicl Haugen, Police Chief af Rossier City Police Department in both hts dividual and official capaciy, BCPD Officer Dion Hunt, both individully- aud in his oficial capacity, ESO Depoty Richard Smith, both individually and in his oMicial capacity, BEPD Officer Chad Hollins, both Sidividaully od in his oficial capacity, BCPD Sergeant Tony Vandagrif both bndividually and in his official capacity, BPSO Deputy Marcus Hays, both individually ‘nd in bis official capacity, BCPD Officer Hugo Holland, both individually avd ia his officalCase 5:24-cv-00318JE-MLH Document Filed 03/03/24 Page 3 of 25 PagelD #: 118 opacity, BCRD Officer Barry Watsh, both individually and in his offical capacity, BCPD ‘fticer Ketth Cainphel, both individually and in his offical capacity, BESO Deputy Jason ouett, both individually and in his official capacity, BPSO Deputy Dylan Dison, both individually din his oficial capacity, BCRD Ofcer Richare Polit, bot individually and in his official capacity, BPSO Deputy ryan Sprankle, both individually and in his offical ‘capacity, BCPD Sergeant Michvel Lombarding, J. both individally and in his fii capacity, CPD Sergeant Steve Boothe, bith individually and in his oficial capacity, BCPD: Ofcce Gregory Russell, both idividestly and in his official capacity, BCPD Officer Jeremy ‘Watson, both individonlly nid inhi official capacity, BCRD Officer Matthew Boyd, both individually and in his officia capacity, BCPD Officer Miareus Green, both individually and in his officiat copicty, Police Chief Todd Gibson #4 Pollee Chlct of Haughton Police Departineat bot in his ntividual aod official capacity, HPD Ofteer Patrick Edmonds, Jr both: individualy and in his official capacity, HPD Sergeant Michael: Freeman, both ‘nividuelly and i his official capacity, HPD Oiicer Steven Kennon, both individually and in ‘ia oficial capacity, HPD Offer Jesse Cutver, bot individually and in his oficial capacity, for fling ta tain, filing to supervise, using excessive foie to shoot Jason Michael Matingly, dy by officers lien Natingly Jt. raised his hands to pesowably surrender according to Jndependcat witnesses interviewed. (Soe Fxbibiss FE both Ellis and Bossier interviews) All officer defeedans mistkenly fied on Mattingly: when ier officers fired falsely thinking Mattingly fied. Mattingly did not have firearm, so this was imposible, Due to lack of traning ofall officer defendants, Matigly was shot 85 or nore times with excessive force. 2Case 5:24-cv-00318-JE-MLH Document Filed 03/01/24 Page 4 of 25 PagelD #: 119 Defendants were negligent in ther ets of patefpation in the brutal mid scavetes killing ‘of Jon Michael Miatingly, Jt, do to lack of trining, lack of supervision, flare to follow policies and procedures ofthe Bossier Parish Sheriff Orie, Bossier Cty Police Department and Haughton Poli 18 Departinent, aid fine Yo uphold the sights entitled to Jason Michact Matting, 3. der the United States Constitation. 3 ‘Bétsiee City Police Depertment (“BCPD"), Bossier Paish Sheriff Office (*APSO") and ‘Hauighton Police Dupartinent (“HPD") had a custom and practice of using excessive forve on civitions. Unitnmed offices carry miitiple flams of equipment which employ a leer ube of ‘ores, such as Tasers, pepper spray, mace anc batons, which give poliee lesser farve options to poroach cine ina afte manner, fo the proteton ofthe ctzens a forte cers, Ista, the officers only ize etl meas f ove (90 round ro 233 fe dA ede sine sucrate gum) most from sea ltaess where the officers were no in dang form Mitoaly 4 ng infer thi ce Ripped i sde, Tins, this teagedy of the shooting of civilians wit continue to oeeur duc tothe dangerous castom and prntces ofthe Bossier Parish Police Department. son Mating, was severely injured, disabled, and incapable of alsin cor soli «Crosman aot pit gun ieee a to ran fem Bons, at is ight arm. vas flared. (es Bxbibit CG Awtopry Repoit) Thus, he could not Have raised an ARIS Crows sf pele arte, Alo, tivo witness jrvided ved lates that 1) they dil not se Jase Maing, have an ARS fle and 2) son Matinly Je, raed hi nd inthe air ag if signatig to surrender whew shot. (See Exhibit D video staiomens). Addloral, most ofCase 5:24-cv-00318-JE-MLH DocumentS Filed 03/01/24 Page 5 of 25 PagelD #: 120 Deflideas OMicrs and Deputies BCID Officer Dion Hunt, APSO Deputy Richard Sovih, BCPD Officer Chad Hollins, CRD Sergeant Tony Vandigetf, BESO Deputy Marcus Heys, BCPD Offer Hugo Holland, BCPD Officer Burry Walsh, BCED Officer Keith Campa, BPSO Depaty Jason Jouett, BPSO Deputy Dylan Disoo, BCPD Officer Richard ont, BESO Depoty Bryan Spranke, BCPD Sergeant Michael Lombaraine Jr, BCRD Sergemit Steven Boothe, BCPD Otcer Gregory Russel, BCPD Officer Jeremy Watson, BCD Officer Muithew Boyd, BCPD Officer Marcus Green, HPD Officer Patrick amonds; Sry HPD Sergeant Mlehaet Freeman, HPD Oiticer Sioven Kanon, and IPD OicerJease Cuter’ ied excessive toon by fring 0 caliber pistols and especially AR-S 233 in he vehicle fom gre ditance when they cold wot se any weapon ia Jason Matingly ‘e's bands. Despite these fs, Defendant Offless shot over 83 rounds in two bursts afer de several bullets struck Jason Mattingly Joely Becguse and oie a Ne was moving ad til living. Shooting 90 rounds at Jason Mattingly, Js. was clearly excessive, ‘The Defendant Deis and Ofer were not proply tunel, The number of sots fue, pectilly dhe 233 ‘ARCS ile sounds wer cleat exestive force. One ofthe Deputies resigned after he altered ‘the erie seen, switche tho anni he had in his ile ep, and gave false statements tothe police iavestigators (Exhibit) Detuant Officers and Deputies infeatonally unin violation ‘of poly, never tumed on tir body eumeras including. BPSO Deputy Bryan Sprinkle who fale (o tu onthe body eas. Yet no diseiplinaryseton was ak against BPSO Deputy ‘Bryan Sprankle ad the other Defendant OFcors, who were the fis officers to uppoaeh and soot Jason Mattingly, Je eaxpyng their lips of hair 40 caliber sen-dtomatshandgues JURISDICTION 4Case 5:24-cv-00318-JE-MLH Documents Filed 03/01/24 Page 6 of 25 PagelD #: 121 Petitioner brings this action in this Couré pursuant to 28 US.C. § 139%(b), ax the transitional vets constituting the alleged tortious behavior arose aid occurred within Bossier Parish, and ja comtorinity with Fad. Rules Civ. P, An: A(ds the cause is further grounded in 28 US. § 1331 oF sog, and 1343(0}3), 13434094), and 1367(0) 6 this suit tives questions of fad civ sigs tow apd is also brought pursoan wo 42 USC. § 1989 ot sey. wel her weld provisions. This action is authorizad by 42 U.S.C, $1981, ot seq, especialy $1989, 10 redress the doprivation under color of lai, statis, onan, regulatan; custom, andlor usage of sgh ‘guaranteed to the Plainly the Fi States Poort, and Fourteenth Armendinets to the Constitution, Pein aloo sack all iG afforded understate In and neluding La, ivi Cade Antile 2315, 25151, 23152, wrongful death end survival actions PARTHES 5 ‘Tonya Mann, aka Tonya MannOliver, oppesting isdvidilly and on Babul of her rior children, KLM. and A.M, is a resident of B ‘Parish, Louisiana, Tonya Mani aka ‘Tonya Mann-Olivier fy also the Court appointed tur of her minor children K.M. and ‘who ate the biologie chiken of Jason Michael Mattingly, Jr (Exhibit A, Tutorship Order) 6 Defeadant, Sheriff Julian Whittington, Sheriff of the Bossier City Police Departeicut, in his individual and official capacity fr filing to supervise; filing to tain his officers of the Bossier Parish Sheriff Office and having custom and practice of officers ‘approsching citizens nsing excessive oxwe,Case 5:24-cv-00318-JE-MLH Documents Filed 03/01/24 Page 7 of 25 PagelD #: 122 Defendant Police Chief Daniel Haugen, Police Chiet of Bossier City Potice Départnient, in his individual and oficial capacity for filing to supervise, filing to train his officers of the Bossier City Potice Department and having a custom, and prictice of officers anprovchiny ctizens using excessive fer. s Defendant, ity of Bossier, Louisina, is a monicipalty orgonized under the laws of the State of Louisa with cxpacity to sue and be sued, Defendant City of Bossier and is ageney the ossier City Police Depariment and Bossier Parish Shesif Office Js « municipality which ovis, operates, manages, diréos, and ‘controls the Bossier City Police Depuinedt abd Bossier Patish Sheriff Office hich: employed Mayor Thomas 1, Chandler, and Police Officers BCPD Officer Dion Hunt, BOPD Deputy Richard Smith, CPD Officer Chad Hollins, BCPD Sergeant ‘Tony Vandagrff, BCPD Depuly Marcus Hays, BCPD Officer Hugo Holland, CPD Officer Barry Walsh, BPD Officer Keith Camphell, BCPD Deputy Jason Jowett, CPD Depaty Dylan Dison, BCPD Officer Richard Polit, BCPD Deputy Bryan Sprankle, BEPD Seryednt Michiel Lomburdino, Jr; BCPD Sergeant Stoven Boothe, BCPD Officer Greyory Russell, BCPD Officer Jeremy Watson, end BCPD Officer Matihew Boyd, BCPD Oiticer Marcus Green, Bach of the above listed officers used excessive Fores and together fred ‘over 90 rounds of 233 rounds trom great distances. and 40 caliber vouids in two bursts wen Matigly was clearly not a threat and disabled. (See ExhibicF cell phone vidoo und Exhibit G shooting video)Case 5:24-cv-00318-JE-MLH DocumentS Filed 03/01/24 Page 8 of 25 PagelD 123 Deeendant, Mayor Thomas H, Chandler, is « person of the full age of majority, @ resident of Bostier Pars, and i a previoas Mayor of the City of Bosier chief executive officer ofthe Cty of Bossier at the time of death of fason Michael Mattingly, 19. etiam, Police Cher Todd Gibson ak Fotlee Chlet of Haughton Pollee Department, in his individual and official capacity for failing ¥ supervise, filing to train his olfests of the Haughton Police Department and having « eustors und practice of offivers approaching eittins using excessive fore. Mm Defendant, Ciy of Bossier; Lousiana, i « municipaity organized under the laws of the ‘tute of Louisiana with capacity to sue wd be sued, Defendant City of Bossier and its agency the ‘Haughton Police Department is & municipality which owns, operates, manages, directs, and contiols the Haughton Police Departimett which employed Mayor Thomas H. Chandler, and m Oftiers HPD Ofer Pairek Kadmonds, Jr, TPB Sergeint Michael Freeman, HPD fier Seven Kenindn, and HD Officer deste Cutrr. 1 BERD Officer Dion Hunt, both individually and in his offal capacity, for Ki rtcpation in the excessive fxce use yas Jason Mating, J, using Sym semiautomatic itl sid i ed widh 288 anaiton ke iity Defendant Offeen ad Depuliee cxuldnot soe Jason Maithili his vehi, hey were poiioed at great istance. [BCPD Omicer Dion Hunt ate in concert with all oher Defendant Ofces nd Depts in tbs shooting and kiting of Jason Mating, J. This use of excessive force was in violation of the 4th Amendment oF the U.S, Constittion,Case §:24-cv-00318-JE-MLH Document Filed 03/01/24 Page 9 of 25 PagelD #: 124 a BPSO Deputy Richard Smith, both individually and in his ofl capacity, for his participation inthe excessive force wie against Jason Mating, Jey using 8 rounds of Suu sexnnatomae pista and also ils wih 239 amnion whan any Defendant Oces and Depuligt could aa 86 Jo Mang, Jr. His vee, as hey were positioned & great tit 2. BESO Doputy Richard Smith acted in concert with all ober Defendant Offers ahd ‘Deputies inthe shooting dnd killing of Jasin Mattingly, Js: This ue of exeessive force was in violation of the 4th Amendaect of the U.S. Constitution, Deputy Smith vod other deputies nitty hoight, do Sk of ining, hat Mating Yeas Sing Fc a i wh fie wa jing Wo surond M4, CPD Oftieer Chad His, oth ftviually and fn is oficial capacity, for bis participa In ihe excessive force used against Jason Mattingly, Jr, ing rifles with 283 anumunition when many Defendant Officers én Deputies could not see Jason Mattingly, Je in his vobiole, as they were positioned ai a great distance. BCPD Otticer Chad Hollins acted in concert with all other Defendant Offices and Deputies in the shooting and kiling of Javon, Matiigly, Jr. This ase of excessive force was i violation of the 4th Amendarent of the U. Constitution, Deputy Hollins and other deputies mistakenly hough, due to luck of wining, dt Matty waa Gri « rear at them when in the was trying fo sender, 15, BCPD Sergeant Tony Vandagriff, both individually and in bis oficial capacity, for his pticipation in the excessive force wsed agaist Jason Mattingly, Jr using rifles with 233Case §:24-cv-00818-JE-MLH Document Filed 03/01/24 Page 10 of 25 PagelD #: 125 tunoanition when inaay Defendant Officers snd Deputies eo not soe Jason Mattingly, Jr. in hia ohio, as they were positioned ata yyeatdistanes. BCPD Sergeant Tony Vandageiffacied {in concert with all other Delendant Oificers and Deputies in the shooting and killing of Jason Mattingly, Jp. This use of excessive force was in violation of the tl: Amendment of the U.S ‘Constittion: Dejuty Vanidagsil! and olhicrdsputics saatakenly though, dus to Ick of traning, ‘that Mattingly was feng firearm at then whe in fet he was tying Wo sarrd, 16 [BRSO Deputy Marcus Hays, both inivdlly and in is ficial capacity, for his parpaon inthe excessive foie uss agaist Jason Mating, J, wing fos with £233 smu, whew imany Defeat Officers anid Deut coud not season Mating, his vet, as they were psoned a a grit dance, BESO Deputy Maren Hays asd in onoort ith all other Defendant Offices aod Depuie in the shocking an King of Jason Matingly, J. Tit wie of sxcesive force wasn vilton of the 4th Amendment ofthe US. Constistion, Deputy Hays sud olor depuis mistakenly thought de a Tack of tfsng, bat ‘Mat nly was living a ie w thei when in fst he was eying to surender, Mn CED Officer Hogo Holland, both iividally and in his ofc capacity, for his partition in the exoesive fee ed saint Jason Mating, Jk, using sllen with 233 ammunition when sy Defendant Offices and Depts could wot se Tsou Mating, J. bis vehi as they were postoned ata great distance. BCPD Officer Hig Holland acted in concert with all othee Defendant Offiests and Deputies in the shooting aid Killing of Jason 10Case §:24-cv-00318-JE-MLH Documents Filed 03/01/24 Page 11 of 25 PagelD #: 126, ‘Mattingly, Je. This wse of excessive foree wos in violation of the 4th Amendment of the U.S, Constitution. Deputy Holland and other deputgs mistakenly thought, du to Ik of tsning, tht ‘Mawingly was fring a Sean at them when infact be was trying fo surrender, 1% BCPD Officer Barry Walsh, both individolly. and in his oficial capacity, for his Participation in. the ekeosive force wed against Jason Mattingly, Jc, wig rifles with .233 ‘xmuniton when many Defendant Olfcers and Deputies coud not see Jason Mattingly, Jr io tis vale, a they were positioned at a pret distance. BCPD Oftleer Barry Walsh ate in cnet with all ofher Defendant Offers and’ Depotcs inthe shooking and Killing of Jason Maitngly, te ‘Tis vse of excessive force was in violotion of the 4th Amendment of the U.S. Constitution, Depity Walsh atid other deputies mistakenly tought, die to Ink of trang, that ‘Malingly eu fring a firearm a them whes infact he was fying to surender: 19. BCPD Officer Keith Campbell, bot individually und in bis official capacity, for his participation in the excessive foroo used against Jason Mattingly, Jr, using rifles with 233 sunmunition when many Defendant Officers and Deputies vould not see Jason Mattingly, J in is Webiele a they were positioned ata great distinee, BCPD Offer Keith Campbell scted in concert with all ther Defendant Ofte sand Deputies in ibe shooting and killing of Jason Mattingly, Je. This use of excessive force was in violation of the 4th Amendment of the US. Constitution. Deputy Cabell and othor deputies mistakenly thought, due to ack of tnining, hat Matting was ising fear a theme whe in et he was trying to Surender, aCase 5:24-cv-00318-JE-MLH DocumentS Filed 03/01/24 Page 12 of 25 PagelD # 127 20. ‘BPSO Deputy Jusen Jouett, both individually and jn his oficial capacity, for his prticiption in the eiceisive foros used agains Jason Matogly, 3, sing rifles with 233 uoaition when ininy Defeadast Oceana Deputies cout not se san Maing, Ea his veil, as they were positioned at » great distance, WSO Deputy Jason owe acted ia conoer with sl other Deferdast Officers and Depots in the shooting and Killing OF Jason Maitngly, J Ths use of excessive force was in volo of the 4th Amendment af the US. Consittion, Duty Jett aed othr deputies mistakenly thigh us to ck of tsining, tat ‘Mating wa firing frearoy at thom whie in Fat he was trying fo surrender, 24 BPSO Deputy Dylan Dison, both individually and in his official capacity, for his panicipation ia the excessive free used against Jason) Mating, Je ammunition when many Defendant Officers snd Deputies could not see Jason Mattingly, Jr, in his vebiele, as they were positioned at a gat Kstavee, BPSO Deputy Dylan Dison ected in covoeet With all other Deftndant Oficess and Deputies fi the shooting and killing of Jason Mating, Je. This use of excessive force was in violation of the Att Amendment of the US. Caistittion, Deputy Dison and cider deputies mistakenly thought, det lack of training, hit “Maigly wa fing fromm a hem when infact he was tying to surrenderCase 5:24-cv-00318-JE-MLH Document Filed 03/01/24 Page 13 of 25 PagelD #: 128, BCPD Officer Richnrd Pollitt, both individuelly and in his officiel capacity, for his participation in the excessive foree-usedl against Jason Mattingly, Jt, using ifles with Sm sud 23 ammunition when many Defendant Officers and Deputies could not see Jason Matty, J in hie lial a thoy were positioned at great distance: BCPD OMMcer KRtehard Poli acted Jn concert with all other Defendant Officers and Deputies in the shooting and King of Jason, Mating, Jt This ate of excessive force was in Violation of the 4th Ariendhoent of the US. Constitution, Deputy Polit and other deputies mistakenly thought, due to lack of taining, dat ‘Mauingly was firing a freer at theo wire i fact he was trying to suscender, a. BPSO Depaty Bryan Sprankle, both individually snd in official capacity, for hig participation in the exeeasive force used against Jason, Maitingly, Jr, using, rifles with 233, ‘ammunition when many Defendant Officers and Deputies could not se Jason Mastingly, Je in dis voile, as they: were positioned at @ great disunce, BPSO Deputy Bryan Sprankle veted in ‘concert with all ther Defeadait Oftieets ond Deputies io the shooting ail Killing of Jason Matinglys Je This uve Of excessive force was i violation of tho 4th Ameridment of the US, ‘Consiuution, Depuly Spranile and other deputies mistskenly thought, dve wo Tack of taining, at Mattingly wos fing a Farm af hens when in act he was tying to surrender, and he sie him raise his hands, Sprankle also called for other olficers fo shoot more. “shouting he is aiving und aftr he was shoot mumierous times causing other deputies ro fre again a total of BS rons ito Mattingly’s vetted vehicle which was immobilized and nota threat to anyone ‘Sprankle als filed intentionally not to nti his body camo video the fist rounds be fired snd eae prt when ordered not to pursue Mating.Case 5:24-cv-00318-JE-MLH Documents Filed 03/01/24 Page 14 of 25 PagelD #: 129 w BCPD Sergeant. Michael Lombardino, Je, both individually wed in his feist ‘capacity, for his participation in the excossve foto used against Jason Mattingly Jn usng fet writ, 239 acoanmition ton ewmny Detinlont Orfcers od Depiles caikt mal wee Hawn ‘Matingly, Ji: in is vobicle, az they wore positioned at a greit distnce. BCRD Sergeant Michiel Lamardino, J. seted in ennrt vith ll ter Detevtant Officers and Deputies in hie shooting and killing Joon Malingly, Je This we of enessve force was invitation ofthe 4th Amendonént of the US. Constitution, BCPD Sergeant Michael Lomba Fr ahd other Aepues mistakenly thought, due wo lack of raining, that Mtingly was fring a Trea al hem when ia athe was trying to surrender, 23. CED Sergeant Steven Bouthe; both individially and in ie foal capacity for hi ‘ateipstion inthe excessive feo use agains Jason Mating, using ile wih 9mm and 233 amonnition when niany Defeadant Offices and Deputis eld nt see Jason Mating, ‘nis vebicte, as they wore potions ata grat distance. BCD Sergeant Steven Boothe acted in concert wih al other Defndant fiers mnt Deputi a he shooting and Kling of Jason Mattingly, Jr. This wie of excessive foece was in violation of the lk Amendment of the US. stituGon. BCPD Sergeant Steven Boothe and other deputies mistakenty thought, duc to lv of taining, tht Mattingly sa firing a firearm adhere wen in fot he was trying to surender 6,Case §:24-cv-00218-JE-MLH Document Filed 03/01/24 Page 15 of 25 PagelD #: 130 BCPD Oiicer Gropory Russell, both indvidolly and in his ofl espociy, for hia tcp inthe coos foroe ied against Jason Mating, Je, using rifles with dm and 233 arumuniion whoa many Dein Officers ond Deputies could not see an Matty, in ic vehol, as they wete positioned ata grea distance. BCP Offer Gregory Russell acted Jn convert with si other Del int OMcer and Bepatos i he shout ling UF Sosun Matingly This we of excosive fore was in Violin Othe Ath Aviendment of the US, Consition, BERD OMtcer Gregory Rail abd other depuis sakenly though, due ko lack of taining, that Multingly wat Bring a ream. at them when fa fact he was tying vo 2 BCPD Officer Jeremy Watsoi, both individually and in his official eapacity, for his participation in the excessive force used against Jason Matingy, Jn, sing ith Sin and 283 acini when inany Defendant Ofices aid Dep coil uo 86 Jason Mating, Je fn his vba, as they were positioned i areata, BCID Oar Jeremy Watson cto in concedt with al ote Deteant Ofiers and Deputies inthe shooting and King of fson Matingly, This use of exessive force was in violation of the 4th Amendment of te US. Constiutlon, BCPD Officer Jeremy Watson 1d other deputies mistakenly thought, doe to feck of ttning, that Mattingly was firing a fem al them whon in fact he was frying to surrender. 28 18Case §:24-cv-00318-JE-MLH Document 5 Filed 03/01/24 Page 16 of 25 Pagel #: 131, CPD Onleer Matthew Hoya, bat individually and in his oii capacity, tor hs paitcpation in ho excessive foe used ais Jason Maltinaly, J, using Sm sonautomatic isis. sites with 239 ammunition whea many Defendant Oicer and Deputies coil not sos Jason Matingly, his vehi, a they wore positioned ta peat dstates, BCPD Ofiebe Matthew Hoya acted in concert with ll oher efenant Oia and Deputies in he doting ‘and kaling oF Jason Mattingly, J. ‘This ise Of excessive force was in violation OF the 4th Ammendmeit of the US, ‘Constintion. BCPD Officer Matthew Boyd, and other deputies mistakenly shought, due to lack of teining, that Mattingly was firing a fener at them shen in {ct he wos eying tu Suede. 2. CPD Officer Maréus Green, both individually and jn his ofivial capacity, for his ticipation in the excessive foce xed agaist son Mating, J, using ills wid. Sam and 233 nani wn many Defeat OMe sind Dep ould ait se Japon Mattingly, inhis veil, a hey were positioned ata reat distance. BCPD Officer Marcus Green acted in conceit with al other Defiant Offices wid Depts i the shooting and ili of Sion Matingly, Je: This use of excessive free was in vilation ofthe 4th Amendment of the US. Constitution, BERD Offer Mareus Green ant oder depts mistakenly thought, dae to lek ting, ht Maing wa ring rar thn han in act he wes tying to surender 30 [HPD Office Patrick Raimond, Je, both individually and i hs ofa capacity, for his partite the excessive fee se gaint Jan Mattingly, Je using rifles wit 9mm nd 233 ammunition when many Defendant Office's ahd Deputies could. sot see JasonCase 5:24-cv-00318-JE-MLH Document§ Filed 03/01/24 Page 17 of 25 PagelD #: 132 Mottngly, Jin his veil, as they were positioned ata great distance, HPD Oficer Patrick ‘dmondl, Je acod in conse wit il other Dafa Offices and Deputies i tho shooting and falling of ison Matingly, 3 This use of excensive fores wat in vielaton of the 4th ‘Arsendxent ofthe US. Constitution. HPD Officer Patrick Edmonds, J, and otbr deputies mistaeoty ought, due ko task oF waning, ea Minaya Reng rete a Hem wien in fuothe wi trying to suvender. 3 [HPD Sergeant Michae! Freeman, both individually and in his official capacity, for paticipation inthe eneusive fares used aginst Jaxon Moiingly, Fe otng ills with oun sod 23 aoanunition when many Defindant Officers and Deputies could not se Jason Matingly, i bis vehi a they wore poston ata gest distace. MPD Sergeant Michael Freeman seid in voncert with all oiber Defeadaat Officers and Depuis in the shooting ap Kling of Jason Mattingly, I. This use of exoestive fru vins fa Villon of the Ath Amadmsat of ths ‘US. Constution, HPD Sergeant Michael Freeman andl othr depuis mistaksalythoogh, due 1 ek of trining, that Mattingly was firing a fit a tiem shen in fet he was tg to surrendet. 2 HPD Ofticer Steven Kennon, both individually and in his officio capi, for his pitcpation fo the excessive free usb agin eon Matigy,S, sing ils wth Sih and .239 ammunition wen many Dsfeadant Officer and Deputies could notte Jason Mattingly, in his wohict, as they were positioned ata eat discunce. HPD Officer Steven Kemion acted in 0Case 5:24-cv-00318-JE-MLH Document 5 Filed 03/01/24 Page 18 of 25 PagelD #: 133 ‘concert with all othér Defendant Officers and Deputies in the shooting end killing of Jason Mattingly, Je: ‘This wie of execasive fegoe wat in violation of the 4th Aniendinant of tie U.S ‘Constitution, acted in concert wil all other Defendant Micon ad Deputies in the shooting nd Ailing of Jason Mattingly, J: This se of excessive free wa in voltion ofthe te Amodinent Fhe US. Conkition: IPD Offlwr Steven Kennan ard thor depuces mistakenly though de lick of taining, hat Matingly was Fring firearm at them when int he was eng eo sunrider 3 HPD Oticr Jesse Cutror, both indvidvlly and in i oficial capacity, foe ie paripatin nthe extsive foro wo again ason Mattingly, uting ifs wth Sim and 233 ammunition when many Defendant Ofcers and Depts could not ee Jason Mating, sin hi vi they weie postonod at a gretdistmce, HPD OMflse Jesse Cudrer eta in ‘oucert wih all otter Defiant Officers end Deputies inthe shooting and Killing of Jason Matingly, J, Thiv use of excxssive force wos in violation of the 4th Amendnent Of te U.S, Covstuton, MPD Officer Jesse Culver and othcr deputies mistakinly tool, de o lack of ‘raining, dhat Mattingly was firing fcearm at dhean when infact be was trying to surrender FACTUAL ALLEGATIONS m4, 8Case 5:24-cv-00318-JE-MLH Document S Filed 03/01/24 Page 19 of 25 PagelD #: 134 (a or about Saturday, March 4, 2023 at 2:38 a, officers from the Highton Police Departinent (“HPD") responded to a domestic ineident between Georgia Thurman and Jason Matingly Jt (Exhibit B, Louisiana State Police Report) Late that same day at upproximately 11:00 aan, HPD followed vp WhITMG;"Thosiman ahd bused on Ber socount of the incidast ‘between her ane! ME, Mtinghy,aerst warrant was wriuen for Mr, Mautigly, J. signed by Honwrable Judge Michiel Neren. (RxhibitB, Louisiana State Police Report) 45 Av approximately 5:05 po this same day, HPD initiated a trafic stop on Mr Mattingly, Jn grace at LAIST and Alford Roadl jn Haughton, Lousiana, (Exhibit B, Louisnis State Police Report) Win Me. Maing, Jr did not sop his vehicle, HPD officees pursed him in theie polige Vehicles. (Exhibit B, Louisiana State Police Report) Mr: Matingly, 4 drove Nort ot LA-IS7 to US Hy-80, and then headed west on US Hwy-80; Bossier Parish: Sheri’ Office plod! Mattingly, 3s track on US Hsy+80 wear the Tull Tirsbers neighborliond, (Exhibit B, Louisina Stale Police Repod) Mr; Mattingly, Se continned west until erahing info « vehicle on ‘US Hwy-80 at Aistive Drive, Me, Mating, Jr. continued west on US Hiwy-80 unit erasing into. pole. (Exhibit B, Louisa State Police Report) 36 ‘Mr. Maitingly, J's truck came to rest on its passenger side in the font parking lot of Sicll Stuffing of Shrevepoit-Bossiet ry facing US Hiwy-80, BCPD, BPSO, RD dps fore were apndacing Mi, Matty, stick with thor frre. (Exhibit By Loui Stat Pie Report) Mr, Ming, J. was potion pie dain inhi vehicle a BESO Deputy Bryan Sprankle opened fe on Mr: Maingly, J. st, followed by Defendant Bossier City Police Department (BCPD) oie, on (1) Bose Patsh Shi Office (APSO) 19Case §:24-cv-00318JE-MLH Documents Filed 03/01/24 Page 20 of 25 PagelD #: 135 deputy, and one (1) HPD officer who all shirged their depaitinent issued weapons approximately 45 times at Me, Mattingly, 1, striking him moltple ties, (Exhibit 8, Louisiana State Police Report) After beifsot multiple times, ope of the officers ai the seene showed, “he’s sill moving”, at which point Defendint OMioers fired another 48 plus rounds at Mr; Matthys I roan in hi dest 31 PSO Deputy Bryan Sprankle falsely claimed Mr. Mattingly, Jt. pointed «rife (later determined to be an AR style BB air rll) t In enforcement which gave vive tothe use and discharge their weapons, Exhibit B, Loisiana State Police Report) However, this is unlikely as Mr, Maltingly, Jt. was upside down in his vehicle with broken femurs and right arm boues Additionally several witnesses athe sene provided recorded statement that rir fo beng st by CPD, BPSO, and HPD officers dnd deputies, Mt, Mattingly, had both of his hands in the sir and was surenderiog. Some ofthe officers that fired their 233 rifle weapons were over 800 et sivay from Me: Matingly, Jr's vebile, and eould ot have reasonably considered! Mr Moitingly, J «threat as he was injured and positioned upsice dow in his ovestumed vehicle Yet these ofticers procetld to fire their weopons repeatedly and excessively to ensure Mr, Mattingly k's demise, Deputy Bryan Sprinkle filed to setvate this body camera doving the inal eovounter yet was no dscplied, No reais or inspection of aay officers cameras ware lever done to cover up the exeossve forvo and violations of polloy. Spraukle intentionally did ‘ot setvate his body camera when initial fing nd Mattingly was tying to weve his hands surrender to officers, Sprankle also tuselystted Mattingly was stil a threat and aid, hei till moving” and Sprankle eaused the other offcats to fire another 45 rounds into Mattingly who 9Case 5:24-cv-00318JE-MLH Document’ Filed 03/01/24 Page 21 of 25 PagelD #: 136 was suspended in the overtamed vehicle and not a threat Yo anyone and unarmed with ay ‘roar. 38, ‘As 8 rasult of being shot by BPSO, PCPD, and HPD officers and deputies, both of Mi. Mitaingly, Jee fers a hls Tees were broke, as Wel as hls right arm wearing his muscles. Mr, Miatingly, Je. die after suffering for some time after sustaining these iniial injuries Hom excessive fore fom 85 plus rounds of 9 mm and 239 bullet fred into his overiutned tuoi and his body. »”. in effrt to conceal the extent of the Defendant Officers noglizence, several Defendant Oificers Sprankle and #dmonds intentionally did not activate their body eumeras. No inspections ot pairs wert made. The body cameras were repeated not tamed on by these two defendant ofcers Sprane ané Edmonds, CAUSES OF ACTION Count éderit Constitutional Clams 40, ‘The aotions of all Defendants, named hercin, violated dosedunt’s rights under the Fourth snd Fourtecith Amendments wo the United Stater Constitution to be free ftom the unlawful use of fore, Count ‘Fedora Constitutional Claims ai, aCase $:24-cv-00318-JE-MLH Document Filed 03/01/24 Page 22 of 25 PagelD #: 137 “The violations of docede's ighls uid the Pout axd Route Anda 10 the United Stas Constintion, Plains damages, and the conduct ofthe individual Defendann were dietly and prosimately eqs by the actions andor instions ofthe Defendant City of Bossier, which has tolerate, ratified and has eon delibestely indore to the following fii, palo, prction, nd-cont, ae te the nee for more oF ifevend tang supervision, investigution, nd disipline in the areas of 1 Tho use of free by polio officers. b. ‘The proper exerise of police powers, including but not limited to the making of an arrest, engagement with civilian, and the use of free ©. Tho monitoring and disciplining of officer misconduct. 1, ‘The Titre to ide aid ake rene or disciptinary action against pice officers who “wer the subject of pei evilian or intemal complaints of misoonduck, ©. Police ets use of thei stats as police officers to eploy the use of Foes, The falure of police officers to follow established policies, procedures, directives, and instruotions regarding aress, engagement with civilians, and the use of force under such circumstances as presented by this ease; lad out above, & Defendant, Sheriff Julian Whittington, Sheriff of the Bossier City Police Department, in his individns! and official capacity for filing to supervise, filing to ‘tain his officers of the Bowser Cit y Police Department. | ‘The failure to have a writen, communicated, fully implemented polley tha tain and ‘have Focuet taining ofl inthe above procedures in (@) and (s) above 4. allure to be tind to detect when a suspects fring and not to fie excessively 2Case 5:24-cv-00318-JE-MLH DocumentS Filed 03/01/24 Page 23 of 25 PagelD #: 138 jj Paitie to adequately investigate the defoadants offices failure to use body eams and the excossiveriess of 85 plus rounds of Oinis snd 233 soonds fired into an immobilized ‘Mattingly in a overturned vehicle Count mt State Lavy Clatms cm “The actions of Defendant Offices names herein constitaa tho torts of asslt and battery Lndor tbe laws of tho State of Louisiana. Petitioner claims damages under La, C.C. 2315, La. CC: 2881. suv ation, La: .C. 2315.2 wrong death, Potiioner Forder aver that esl of tho wnlawfol conduct af Defendants named hess, due solely to the nesligence, ful, andlor inleatlanut ols Of way ofall the Defends, Peioner and her minor eid ae ened a survival damages for the physical pin and suing and forthe violation of his civil gh, in Adit to wrong deat dae For losk of constum an econdme Toss net past and fitace spousal end parent support eines list their damoges as follows: 1, amas or wrong! death under Ca. C.C, 28152 for KM. und AM, cildeen of so Mice Mattingly, 2 Damages for survival under La: C.C, 231541 foe KML and A.M, bilan of Son ‘Michael Mattingly, J. 3, Past pin and suffering of decedent Jason Michael Mattingly, J. 4, Pastel angus of decedent sason Michael Magy, 5, Pastmenal anguish KM. ond A.M, children of ason Michact Matiogly Jr 6, Futite mental anguish of K.M: and A.M, children of Faton Michael Mattingly, Jt. 2Case 5:24-cv-00318-JE-MLH Document Filed 03/01/24 Page 24 of 25 PagelD # 139 7, ost of guidance and ennotional support to K.M, end A.ML de tothe det of their ther Jon Michael Mattingly, 4 ‘Loss of love end affection of KM, nd A.M, due to the death of hs father Jason Michael Mattingly, 9 Loss of finan suppor das tothe death of Sais Mihnct Matingly, i 10 K aM 10, Damages for exoess free and acting under color af state nw ia ioiton of 42 S.C. Section 1989 11. Dainagis for exes fice we the Fis, Fourth, ad Roost Amine Lo the United Sates Contintion 1B, Punitive damagis agains the named police officer fort elon which vealed in he ling ofan Mich! Mating, J 6 Plaintiff hereby repeats its detnatid fora tial by jury ato all clams, 2%Case 5:24-cv-00318-JE-MLH Document S Filed 03/01/24 Page 25 of 25 PagelD #: 140 EERE EEEE IEEE Cerlifieation nd Closing ‘ner Federal Rule of Civil Prose 1, ysgnig belo cet th st of my knowledge, information, si bel tha this compat (1) sot boing presented ora inipreper purpose, such a a ras, se unsceneary delay, or edlesly increase tho cst of gation: 2) is support by exiting law or by a onfrvolsanment fr extending, modifying, or eversing exiting las (3) th fan ententons have vida supporto, it special so identied, wil ikely have evidentiary soppot flr a reasonabie ‘pportiy fx fri nvestgton or discovery; ad (4 the complaint thers complies th th reiretnents of Rae I A, Ror Partos Without Attorney: {age to provide the Clerk's Office with any changes to my addres. where case-rlaed papers way be served. Tunderstay that my falar to Keep a carrent address on fle withthe Clerk's Office may rest inthe dismiss of my cass viet 7 /y J roe Avy, Hen 0 . Print NamooF Paint PROSE. ogy. M800.. Orde... Pao- Se. 1O@ ode packde, Std, Ly 79460