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1 COMPLAINT FOR DAMAGES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Robert S. Brown, State Bar No. 187845

ROBERT S. BROWN, APC

714 W. Olympic Blvd., Ste. 450 Los Angeles, CA 90015 Telephone: (213) 745-6300 Facsimile: (213) 261-3906 John C. Taylor, State Bar No. 78389 Louanne Masry, State Bar No. 190559

TAYLOR & RING, LLP

1230 Rosecrans Ave, Suite 360 Manhattan Beach, California 90266 Telephone: (310) 209-4100 Facsimile: (310) 208-5052 Attorneys for Plaintiff: BRIAN STATLER SR. and STACEY MEADORS UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA BRIAN STATLER SR., individually and as Successor-In-Interest to BRIAN STATLER JR and STACEY MEADORS, individually and as Successor-In-Interest to BRIAN STATLER JR. Plaintiff, vs. CITY OF INGLEWOOD, a public entity, and DOES 1 through 10, Inclusive, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CASE NO.

COMPLAINT FOR DAMAGES:

(1)

Fourth Amendment—Excessive Force (42 U.S.C. § 1983) (2)

Fourth Amendment—Detention and Arrest (42 U.S.C. § 1983) (3)

Fourteenth Amendment— Substantive Due Process (42 U.S.C. § 1983) (4)

Municipal Liability— Unconstitutional Custom or Policy (5)

Municipal Liability—Ratification (6)

Municipal Liability—Failure to Train (7)

Violation of Civil Rights—CCC § 52.1 (The Bane Act) (8)

Negligence (9)

Battery (Civil Code Section 43)

(DEMAND FOR JURY TRIAL)

Plaintiff BRIAN STATLER SR., individually and as Successor-in-Interest to BRIAN STATLER JR. and STACEY MEADORS, individually and as Successor-in-

Case 2:19-cv-10712-DMG-MRW Document 1 Filed 12/18/19 Page 1 of 22 Page ID #:1


Interest to BRIAN STATLER JR. (“PLAINTIFFS”) allege and complain against each Defendant, as follows:

JURISDICTION AND VENUE

1.

This Court has original jurisdiction over this action for damages under the laws Under 42 U.S.C. § 1983, the United States Constitution and common law principles, to redress a deprivation under color of state law of rights, privileges, and immunities secured to PLAINTIFFS and their decedent, by said status, and by the Fourth and Fourteenth Amendments of the United States Constitution. 2.

Pursuant to U.S.C. §1331, this Court has original jurisdiction under the Civil Rights Act 42 U.S.C. § 1983 and related common law claims pursuant to 28 U.S.C. §§ 1331, 1343. 3.

Venue is proper in this Court because Defendants reside in, and all incidents, events and occurrences giving rise to this action occurred in the County of Los Angeles, California 4.

PLAINTIFFS filed timely claims under Government Code § 911.2 et. al. and bring pendant actions under state law.

PARTIES AND JURISDICTION

5.

At all relevant times herein, Plaintiff BRIAN STATLER SR., individually and as Successor-in-Interest to decedent BRIAN STATLER JR., is a resident of the State of Missouri. Plaintiff BRIAN STATLER SR. is the biological father of Decedent BRIAN STATLER JR. 6. At all relevant times herein, Plaintiff STACEY MEADORS., individually and as Successor-in-Interest to decedent BRIAN STATLER JR., is a resident of the State of Pennsylvania. Plaintiff STACEY MEADORS is the biological mother of Decedent BRIAN STATLER JR. 7. Plaintiffs are informed, believe, and allege, that at all relevant times, Defendant CITY OF INGLEWOOD (hereinafter “the CITY” or “Inglewood”) was a public entity



and/or municipal corporation, duly organized and existing under and by virtue of the laws of the State of California. 8. Plaintiffs are informed, believe, and allege, that at all relevant times, Defendants DOES 1 through 10, inclusive, were sworn police officers, sworn police supervisors, managers, officials and/or employees of Defendant CITY OF INGLEWOOD. Plaintiffs are further informed, believe, and allege, that at all relevant times, Defendants DOES 1 through 10, inclusive, were acting in the course and scope or their employment with Defendant CITY OF INGLEWOOD and are liable under the doctrine of respondeat superior pursuant to Section 815.2 of the California Government Code. 9. Plaintiffs are informed, believe, and allege, that at all relevant times, Defendants, DOES 1 through 10, inclusive, were employees of Defendant CITY OF INGLEWOOD and/or DOES 1 through 10 and were responsible for implementing, promulgating, maintaining, sanctioning, condoning, and/or ratifying policies, procedures, practice, and/or customs, under which the other Defendants committed the illegal or wrongful acts complained of. Defendants DOES 1 through 10, inclusive, were acting in the course and scope or their employment with Defendant CITY OF INGLEWOOD and are liable under the doctrine of respondeat superior pursuant to Section 815.2 of the California Government Code. 10. The true names, identities or capacities, whether individual, associate, corporate or otherwise, of Defendants DOES 1 through 10, inclusive, and each of them, are unknown to Plaintiffs so said Defendants by such fictitious names. When the true names, identities or capacities of such fictitiously designated Defendants are ascertained, Plaintiffs will ask leave of Court to amend the complaint to assert the true names, identities, and capacities, together with the proper charging allegations. 11. Plaintiffs are informed, believe, and allege, that at all relevant times, that each of the Defendants designated as a DOE is responsible, in some manner, for the events
