Document 6464834

Case :13-cv-00207-GP Document 1 Filed 01/14/13 Page 1 of 10
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IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
ROBERT WILL
S
2243 West Alleg~eny Ave., Apt. 601
Philadelphia, Pa. 19132
: CIVIL ACTION NO.
j]l $
~ ®rw
: JURY TRIAL DEMANDED
v.
CITY OF PHILADELPHIA
One Parkway
1515 Arch Street
Philadelphia, Pa. 9102
and
POLICE OPPIC R ANDRE BOYER
BADGE NO. 4815
.
One Parkway
1515 Arch Street
Philadelphia, Pa. 9102
and
POLICE OPPle; R MICHAEL VARGAS
BADGE NO. 409)7
One Parkway
1515 Arch Street
Philadelphia, Pa. 9102
,'leo
JAN 14 20\3
u\Ol'\AI:L Ii. \,UNZ, Clerk
i~...
_cap. Clerk
COMPLAINT
JURISDICTIO.
1.1S
.
action is brought pursuant to 42 U.S.C. §1983. Jurisdiction is based
upon 28 U.S.c. §1.331 and §1343, and the aforementioned statutory provisions. Plaintiff
further invokes th, supplemental jurisdiction ofthis Court under U.S.c. §1367 (a) to hear
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Case :13-cv-00207-GP Document 1 Filed 01114113 Page 2 of 10
and decide claim. arising under state law. Venue is proper in this district under 28
V.S.c. §1391 (b).
THE PARTIES
2. rntiffRobert Williams is a 25 year old African-American male who
resides at 2243 West Allegheny Avenue, Apartment No. 601, Philadelphia, Pa.. 19132.
Plaintiff Robert
1illiams is also known by his stage name, Meek Mill. He is a hip hop
recording artist lth a recent album that debuted at No.2 on the US Billboard 200
Chart, and who, LOng other things, appears and perfonns all over the world.
3. Defendant City of Philadelphia is a municipality of the Commonwealth
ofPennsylvania iliat maintains, operates, manages, directs and controls the Philadelphia
I
Police Departmedt.
4. Dlfendant Officer Andre Boyer is, and was at all times relevant hereto,
a police officer
tIl the City of Philadelphia, and acting under color of state law and
within the scope a d course of his employment. He is being sued in both his individual
and official
capaci~es.
5. ~efendant Officer Michael Vargas is, and was at all times relevant
hereto, a police OE!Cer for the City of Philadelphia, and acting under color of state law
and within the sc f pe and course of his employment. He is being sued in both his
individual and Offal capacities.
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Case' :13-cv-u0207-GP Document 1 Filed 01/14/J..:3 Page 3 of 10
FIRST CAUSE OF ACTION
(CIVIL RIGHTS VIOLATION)
6. P lio.r to Octobe.r 31,2012, the defendant City of Philadelphia, th.rough
the high commanl of the Philadelphia Police Department, implemented and enforced
a policy and pracrce of stops, frisks, se:u:ches and detenrions of persons, including
plaintiff, withOut!:.robable cause o.r .reasonable suspicion as required by the Fourth
Amendment to : e United States Constitution and Article 1, Section 8 of the
.
I
· Constitution.
I. .
Pennsylvarna
7.
±he stops, frisks, searches and detentions by Philadelphia Police
Department 0 mcts :u:e often based on constitutionally impermissible considemtions 0 f
race and/or natiodal origin in violation ofthe Equal Protection Clause of the Fourteenth
Amendment. The victims of such racial and/ ~r national origin profiling are principally
African-American and Latino.
8. TI ese constitutional abuses are directly and proximately caused by
I
policies, practices ~nd/ or customs of the defendant City of Philadelphia and members
of the high
Commissioner,
col~and of the
wr~ave
Philadelphia Police Department, including its
acted with deliberate indifference to the constitutional rights
..
I by:
·
. cItizens
o f nunO!1ty
(a)
failing to properly train, supervise and discipline
Philadelphia Police Department officers;
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Case f13-CV-00207-GP Document 1 Filed 01/14/13 Page 4 of 10
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(b)
inadequately monitoring Philadelphia Police
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Department officers and their practices related
to pedestrian and vehicle stops;
(c)
failing to properly discipline Philadelphia Police
Department
officers
who
engage
in
constitutional abuses; and
(d)
failing to rectify its unconstitutional practices of
stops, seizures, searches and detentions based
on impermissible grounds
and/ or racial
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II
9.
pro £iIing.
AsI a direct and proximate result of these policies, practices and/or
I
customs, thousands of persons, and in particular African-American and Latinos, have
I
been subjected to ~nconstitutionalseizures, frisks, searches and detentions by members
of the
PhiladelPhi~ Police Department.
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10. qn October 31, 2012, at approximately 7:30 P.M., plaintiffwas driving
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a Range Rover
sct when Philadelphia Police Officers Andre Boyer and Michael Vargas,
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without cause or jJstification, conducted a motor vehicle stop in the area of 11 th Street
[
and Girard Avenuk in Philadelphia.
11.
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IFollowing the vehicle stop, police officers Boyer and Vargas
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handcuffed plaintiff at the scene, transported him in custody to the 22nd Police District,
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Case 12:13-cv-00207-GP Document 1 Filed 01114/13 Page 5 of 10
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took photographs of plaintiff which the officers posted and published, or caused to be
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posted and published, on instagram and other social media websites depicting plaintiff
in police custody, leld plaintiff in custody against his will in a jail cell for approximately
nine (9) hours, a+r which time plaintiff was released on Novemher 1,2012, at 4:30
A.M., without beihg charged with any criminal activity and having caused plaintiff to
miss a scheduled
~romotional
appearance in Atlanta, Georgia.
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12.
Contrary to well established and accepted police standards and
practices, defendants Boyer and Vargas, intentionally, recklessly and/or with deliberate
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indifference,
caus~d plaintiff to undergo an unlawful seizure and detention by, among
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other things, fo~owing an unconstitutional stop, frisk and detention practice
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implemented by tThe high command within the Philadelphia Police Department.
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13. !Contrary to well established and accepted police standards and
;
practices, defendatts Boyer and Vargas, both individually and in complexity with other
members of the P~adelphia Police Department, intentionally, recklessly and/or with
deliberate indiffer~nce, caused the unlawful detention and imprisonment of plaintiff.
,
\
14. rpefendant City of Philadelphia, as a matter of policy and practice, has
with deliberate in1fference failed to properly sanction or discipline police officers,
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including defenda1ts Boyer and Vargas in this case, for violations of the constitutional
rights ofcitizens, tJereby causing police officers, including defendants Boyer and Vargas
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in this case, to engkge in the unlawful conduct described above.
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Case 4:13-cv-00207-GP Document 1 Filed 01114/13 Page 6 of 10
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15. tefendant City of Philadelphia, as a matter of policy, practice and/or
custom, has
wi~ deliberate indifference failed to conduct proper and balanced
i
investigations of Icomplaints of unconstitutional pedestrian and vehicle stops, and
unreasonable deftion of a citizen by police officers, thereby causing and encouraging
police officers,
in~luding defendants Boyer and Vargas in this
case, to engage in the
I
unlawful conduct idescribed above.
i
16. The acts and omissions of the City of Philadelphia, by and through
!
high ranking offi1als of the Philadelphia Police Department, constituted institutional
deliberate indiffe.~ence and led direcdy to the unlawful stop, detention, and
I.
f
.
.
f 11·
unpnsonment
0
alntlOff.
17.
}'\S a direct and proximate result of the above defendants' actions,
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plaintiff suffered tnd continued to suffer serious ,economic and non-economic losses
1
that include, but are not limited to, the following:
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(a)
j
the forfeiture ofhis deposit for the private jet that was booked to fly
plaintiff in the evening of October 31, 2012 to a promotional
appearance in Adanta, Georgia;
(b)
the cancellation of his appearance at the promotional appearance
scheduled for the evening of October 31, 2012, in Adanta, Georgia,
requiring plaintiff to refund a personal appearance fee;
(c)
the loss of numerous sponsorships and endorsements;
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Case 2:13-cv-00207-GP Document 1 Filed 01/14/13 Page 7 of 10
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(d)
the loss of plaintiffs solitude, seclusion and privacy;
(e)
the anxiety and embarrassment associated with plaintiff being placed
in a false light; and
(f)
the anxiety and embarrassment of being seized, detained, confined
and imprisoned against plaintiffs will, all to plaintiffs great financial
detriment.
,
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18. lAs a direct and proximate result of the above defendants' actions,
!
plaintiff was dep4ved of his rights, privileges and immunities secured by the United
!
I
States Constitutibn
and the laws and Constitution of the Commonwealth of
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Pennsylvania, parpcularly the right to be free from unreasonable seizure, and the right
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to be free from urpawful detention and imprisonment, in violation of 42 U.S.c. §1983,
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and the correspohding state civil rights provisions set forth in Article 1, §26 of the
I
Pennsylvania Co~stitution, all to plaintiffs great financial detriment.
WH~REFORE, plaintiff requests the following relief:
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(a)
an award of compensatory damages against the defendants, jointly
and severally;
t
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(b)
n award of punitive damages against defendants Boyer and Vargas;
and
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(c) ~n award of reasonable attorney fees and costs against defendants,
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jointly and severfY, pursuant to the lodestar provision of 42 U.S.c. §1988(b).
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Case 4:13-cv-00207-GP Document 1 Filed 01/14/13 Page 8 of 10
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SECOND CAUSE OF ACTION
(FALSE IMPRISONMENT)
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19. flaintiff realleges paragraphs 1 through 18, and incorporates the same
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herein by referen~e.
,
,
20. the acts and conduct of defendants alleged above caused confinement
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of plaintiff agains~ his will by overpowering physical force, and caused plaintiff to be
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imprisoned in a j~ cell for approximately nine (9) hours.
II
WHpREFORE, plaintiff requests the following relief:
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(a) a~ award of compensatory damages against the defendants, jointly and
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severally; and
(b) a~ award ofpunitive damages against the defendants Boyer and Vargas.
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THIRD CAUSE OF ACTION
(INVASION OF PRIVACy)
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21. rlaintiff realleges paragraphs 1 through 20, and incorporates the same
!
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herein by referen1e.
22. IBy the acts and conduct of defendants alleged above, defendants
i
[
intentionally
i
cau~ed
an unreasonable and highly offensive intrusion into plaintiff's
;
solitude, seclusioti and private affairs and/or caused publicity of a matter which placed
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him before the p~blic in a false light, knowing of the falsity of the matter or in reckless
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Case 4:13-cv-U0207-GP Document 1 Filed 01/14/10 Page 9 of 10
disregard of whe¢er it was true or false.
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WH~REFORE, plaintiff requests the following relief:
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(a) ap award of compensatory damages against the defendants, jointly and
severally;
(b) a~ award ofpunitive damages against the defendants Boyer and Vargas.
,
FOURTH CAUSE OF ACTION
(CIVIL CONSPIRACy)
23. flaintiff realleges paragraphs 1 through 22, and incorporates the same
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herein by referen4e.
24. 1rhe above actions and inactions undertaken by the defendant police
officers were the fesult of the agreement reached among and between them and other
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unnamed police p~rsonne1 to obtain the detention and imprisonment ofplaintiffwithout
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probable cause atid to violate his civil rights.
25. -f'\s a direct and proximate result of this conspiracy, combination and
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agreement of the idefendant police officers, plaintiff sustained the damages set forth
above.
WH~REFORE, plaintiff requests the following relief:
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(a) a* award of compensatory damages against the defendants, jointly and
severally;
,
(b) ap award ofpunitive damages against the defendants Boyer and Vargas.
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Case 21:13-cv-00207-GP Document 1 Filed 01/14/13 Page 10 of 10
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DENNISJ. COGAN & ASSOCIATES
DENNIS COGAN
ANTHONY J. PETRONE
2000 Market Street
Suite 2925
Philadelphia, Pa. 19103
215-545-2400
Attorneys for Plaintiff
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Case 2:13-cv-00207-GP Document 1-1 Filed 01/14/13 Page 1 of 3
CIVIL COVER SHEET
JS 44 (Rev. 12/12)
!
The JS 44 civil cover sheet and the informatipn contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by Jaw, except as
provided by local rules of court. This fonn, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. ~EE INSTRUCTIONS ON NEXI' PAGE OF THIS FORM)
I. (a) PLAINTIFFS
DEFENDANTS City of Philadelphia,
Police Officer Andre Boyer and Police
Officer Michael Vargas
County of Residence of First Listed Defendant
phi ladelphi a
Robert Williams
(b) County of Residence ofFirslListed
laintiff
phi ladelphia
(IN u.s. PLAINTIFF CASES ONLY)
IN LAND CONDEMNATION CASES, USE 1l{E LOCATION OF
(EXCEP1'IN U.S./PLAINTIFF CASES)
NOTE:
THE TRACT OF LAND INVOLVED.
(c) Allorneys (Firm Name, Address, and TLphone Number) Den n i s Cogan
2000 Market street,~suite 2925,
philadelphia, PA 1 103
215-545-2400
III. CITIZENSHIP OF PRINCIPAL PARTIES (place an "X" In One Box/or PlaIntiff
II. BASIS OF JURISDICTION/P}ace an "X" In One Box Only)
o
I
U.S. Govenunent
Plaintiff
M3
o2
U.S. Govenunent
Defendant
0 4
(For Diversity Cases Only)
PTF
Citizen of This State
tK I
Dive~sity
Citizen of Another Stale
o
2
o
2
Incorporated ond Principal Place
of Business In Another State
o
5
a
Citizen or Subject of a
Forei.n Countrv
o 3
o
3
Foreign Nation
a
6
a6
~Gl')N:J'ItA@f~ ~lIJ10R"'S
o
o
o
a
o
o
a
a
a
o
o
PERSONII.L INJURY
0 310 Ai,plf>e
0 315 Airplane Product
Liab~ity
0 320 AssauI~ Libel &
sIan1er
0 330 Federjl1 Employers'
Liabtlity
340 MariJle
345 Marnje Product
a
a
Liab~lity
a
a
a
a
28 USC 157
a
a
lWil1\RI'IIlI Rm,y
0
0 820 Copyrights
a
a 830 Patent
a
(J 840 Trademark
a
~-~.
~~lfli!I1lII'il~~.~~~~~!l!~~¥'~"~'~~''~'~'!.W'1f,,~!I!i1 a
(J 710 Fair Labor Standards
0 861 HIA (1395t1)
(J
Act
a 862 Black Lung (923)
a 720 LaborlManagemeut
a 863 D1WCIDIWW (405(g» 0
Relations
0 864 ssm Title XVI
(J
0 740 Railway Labor Act
a 865 RSI (40S(g»
a
0 625 Drug Related Seizure
of Property 21 USC 881
(J 690 Odler
a
g;~~:~~:.,~Ejectment g::; ~~:J:,ent
0 510 ~~~e':,"~to Vacate
o 245 Ton Product Liability
0 S30 General
0 535 Death Penalty
Accolru;odations
0 445 Amej. wlDisabilities·
Employment
446 Amet. wlDisabilities Other
448 Educ~lion
(J 290 All Other Real Property
a
o
I
o 3
VII. REQUESTED IN
COMPLAINT:
VIII. RELATED CASE(S)
IF ANY
01/14/2013
375 False Claims Act
400 State Reapportionment
410 Antirrust
430 Banks and Banking
450 Commerce
460 Deportation
470 Racketeerlnfluenced and
Corrupt Organizations
480 Consumer Credit
490 CablelSat TV
850 Securities/Commodities!
Exchange
890 Other StatutoI)' Actions
891 A8ricultural Acts
893 Environmental Matters
0 895 Freedom onDformation
Act
896 Arbitration
~EJjIiRWuifl'~~St!J1mS_
899 Administrative Procedure
870 Taxes (U.S. Plaintiff
ActlReview or Appeal of
or Defendant)
Agency Decision
a
a
a
a
871
~~~~;6do~arty
a
o
Actions
4 Reinstated or
Reopened
0
5 Transferred from
Another District
[} 6
Multidistrict
Litigation
CHECK YES only if demanded in complaint:
(Se /1l.ffruct/ons):
JUDG~
JURY DEMAND:
DOCKET NUMBER
l1l
~EY
OF RECORD
I
I \.J"
FOR OFFICE USE ONLY
AMOUNT
950 ~:::~:::::~a1ity of
a 462 Naturalization Application
a 465 Other lnunigration
WIDER RULE 23, F.R.Cv.P.
SIG
DATE
0 422 Appeal 28USC 158
0 423 Withdrawal
~MMlGm:\'F10N!O!!t'Ul
Other:
540 Mandamus & Other
(J 550 Civil Rights
0 SS5 Prison Condition
0 S60 Civil Detainee·
Conditions of
Confinement
a
Remanded from
Appellate Court
APPLYING IFP
5
:lBIIEOREElmURElIlEN?i'I!mYBll ~A:'NIGUmnG¥.-- ~1'I;IlJl'ER.!SiJ'h\.mmESllf.iii1jj)
•.
PERSONAL INJURY
0 365 Personal Injury •
Product Liability
367 Health CaJeJ
Pharmaceutical
Personal Injury
Product Liability
368 Asbestos Personal
Injul)' Product
Liability
PERSONAL PROPERTY
0 370 Other Fraud
0 371 Trutl1 in Lending
380 Other Personal
Property Damage
385 Property Damage
Product Liability
D 350 Motor Vehicle
a 3S5 Motor Vehicle
Proddct Liability
a
0 360 Othe, Personal
Injurx
a
0 7S1 Family and Medical
a 362 Pers;~a1llljury.
Leave Act
Medi~ Malpractice
a 790 Other Labor Litigation
§,JtWlREll1llP,ROBER'IW~ JRlI'{@IMJl!R' GHmSIllIm!illil N;p.R:JSi!lNER.~}jEiilJ'DlaSSfl.l 0 791 Employee Retirement
a 210 Land Condemnation
~ 440 Othe' Civil Rights
Habeas Corpus:
Income Security Act
220 Foreclosure
0 441 Voti~g
0 463 Alien Detainee
RECEIPT #
DEF
0 I
(Tricate Citize1l.fhtp o/Portles in Item JII)
110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovety of Overpayment
& Enforcement of Judgment
15 I Medicare Act
152 Recovel)' of Defaulted
Student Loans
(Excludes Veterans)
153 RecoveJY of Overpayment
of Vetemu's Benefits
160 Stockholders' Suits
190 Other Contract
195 Contract Product Liability
196 Franchise
and One Box/or De/endont)
PTF
DEF
Incorporated or Principal Place
0 4 Xl 4
of Business In This Stale
Fedetal Que:;tion
'S. Government Not a Party)
IV. NATURE OF SUIT (place on ,~" In One Box Only)
o
Ci ty of Philadelphia,
Law Department
Attorneys (I/Known)
JUDGE
MAG.JUDOE
iM Yes
ONo
Case 2: 3-cv-00207-GP Document 1-1 Filed 01114113
UNITED STATES DISTRICT COURT
IW
P-a~_e 2 of 3
2'0:''7
FOR THE EASTE(1SCT OF ENNSYLVANIA - DESIGNATION FORM to be used by counsel to Indicate the category of the case for the purpose of
assignment to appr
Fdar.
Address of Plaintiff:
43
AddressofDefendllDt:1515
west Allegheny Avenue, Apt.
Ardh street, Philadelphia, PA
I
Place of Accident. Incident or Transactiol:
Philadelphia, PA
601,
19132
19102
11 th street and Girard Avenue,
Philadelphia, PA
(Use Reverse Side For Additional Space)
Does this civil action involve a nongovernmental corporate party wilb any parent corporation and any publicly held corporation owning' 0% 0 more of its stock?
(Attacb two copies of the Disclosure Sktement Fonn in accordance with Fed.R.Civ.P. 7.1 (a»
YesO
J9
YesD
NolX
I
Does this case involve multidistrict litigdtion possibilities?
REUTED CASE. IF ANY:
,
Case Number:
Judge
Date Terminated:
_
Civil cases are deemed related when yes is answered 10 any oflbe following questions:
I. Is tbis case related 10 property includ d in an earlier numbered suit pending or wilbin one year previously terminated action in Ibis court?
YesO
N~
2. Does this case involve the same issue of fact or grow out of Ibe same transaction as a prior suit pending or within one year previously terminated
action in this court?
YesO
Nom:
3. Does this case involve the validity or infringement of a patent already in suit or any earlier numbered case pending or within one year previously
Yes 0
terminated action in this court?
4. Is this case a second or successive habeas corpus, social security appeal, or pro se civil rights case filed by the same individual?
I
Crvn..: (place
Yes O
NOO
No~
til in ONE CATEGOliv ONLY)
A. Federal Question Cases:
B. Diversity Jurisdicrlon Cases:
I.
D
Indemnity Contract, Mar' e Contract, and All Other Contracts
I.
[J
Insurance Contract and Other Contracts
2.
0
FELA
2.
0
Airplane Personal Injury
3.
0
4.
[J
5.
D
Jones Act-Personal Inju
3.
0
Assault, Defamation
Antitrust
4.
0
Marine Personal Injury
Patent
S.
0
Motor Vehicle Personal Injury
Labor_ManagementRelaions
6.
D
Other Personal Injury (Please specify)
@
7.!K
ivil Rights
7.
0
Products Liability
8.
abeas Corpus
8.
0
Products Liability -
9.
[J
All other Diversity Cases
D
9.
Securities Act(s) Cases
10.
D
Social Security Review
11.
[J
All other Fed eral Question Cases
(please specify)
ases
Asbestos
(please specify)
----f-I-----------­
ARBITRATION CERTIFICATION
(Check Appropriate Category)
1,--/,o<.;e~n""n:=.=i"'s"_""C..,o="'a""n........._--+
--rrJ cOUDsel of record do hereby certify:
to the best of my knowledge and belief, the damages recoverable in this civil action case exceed the sum of
D PursUllllt 10 Local Civil Rule S3.~, Section 3(c)(2),
SI 50,000.00 exclusive of interest and ~osts;
D Relief other than monetary damages is sought.
DATE:
01/14/2013
09874
Attorney-at-Law
Attorney I.D.#
. OTE: A trial de novo will be a trial by jury only if there has been compliance with F.R.C.P. 38.
I certify that, to my knOWledge, the Within c:ase Is no
e:lcept as noted above.
DATE:
01/14/2013
ated to any case now pendIng or within one year previously terminated action In this court
09874
Attorney 1.0.#
CN. 609 (512012)
Case 2 13-cv-00207-GP Document 1-1 Filed 01/14/13 Page 3 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
CASE MANAGEMENT TRACK DESIGNATION FORM
CIVIL ACTION
Robert Williams
v.
1·9
City of Philadelphia
NO.
In accordance with the Civil Justice Expense and Delay Reduction Plan of this court, counsel for
plaintiff shall complete a Case Management Track Designation Form in all civil cases at the time of
filing the complaiI}t and serve a copy on all defendants. (See § 1:03 ofthe plan set forth on the reverse
side of this form.b In the event that a defendant does not agree with the plaintiff regarding said
designation, that defendant shall, with its first appearance, submit to the clerk of court and serve on
the plaintiff and a]} other parties, a Case Management Track Designation Form specifying the track
to which that deferdant believes the case should be assigned.
SELECT ONE
or
THE FOLLOWING CASE MANAGEMENT TRACKS:
(a) Habeas COlpUr ­ Cases brought under 28 U.S.C. § 2241 through § 2255.
( )
(b) Social SecuritY - Cases requesting review of a decision of the Secretary of Health
and Human s1rvices denying plaintiff Social Security Benefits.
( )
(c) Arbitration -lases reqUIred to be deSignated for arbitratIOn under Local Civil Rule 53.2.
( )
(d) Asbestos - Cases involving claims for personal injury or property damage from
exposure to aSibestos.
( )
(e) Special Management - Cases that do not fall into tracks (a) through (d) that are
commonly re~erred to as complex and that need special or intense management by
the court. (Sef reverse side of this form for a detailed explanation of special
management aases.)
( )
(f) Standard M lagement - Cases that do not fall into anyone of the other tracks.
Dennis Cog-an
Attorney-at-law
215-988-1842
Telephone
(Civ. 660) 10/02
FAX Number
Plaintiff, Rohert Wjlliams
Attorney for
[email protected]
E-Mail Address