HomeMy WebLinkAbout2022-cv-1983 - Townley v. Fort Collins, et al - 020.1 - Redlined First Amended Complaint And Jury DemandIN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 1:22-cv-01983-SKC
MICHAEL PIPER TOWNLEY, ANNA KRUGER, and JOSHUA DeLEON;
Plaintiffs,
v.
FORT COLLINS,a municipal entity;
BRIAN MALLORY,in his individual capacity;
ETHAN VANSICKLE,in his individual capacity;
DANIEL NETZLENETZEL,in his individual capacity;
JARED ROBERTSON,in his individual capacity;
JOE SCHILZ,in his individual capacity;
JASON HAFERMAN,in his individual capacity;
CHRISTOPHER YOUNG,in his individual capacity; and
JOHN DOES 1-100, in their individual capacities.
Defendants.
FIRST AMENDED COMPLAINT AND DEMAND FOR A JURY TRIAL
For their First Amended Complaint, Plaintiffs state and allege as follows:
INTRODUCTION
In Fort Collins, there are two sets of laws - one that applies to those who protest police
brutality and racism, and another for those who support the police. Plaintiffs bring this action to
protect their rights to protest police brutality free of retaliation, to be free from arrest based on
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the content of their message, and to be free from coordinated political violence sanctioned by the
police.
THE PARTIES
1.Plaintiff Michael Piper Townley is a citizen of the United States and was a resident of
the state of Colorado during the relevant times described herein.
2.Plaintiff Anna Kruger is a citizen of the United States and was a resident of the state
of Colorado during the relevant times described herein.
3.Plaintiff Joshua DeLeon is a citizen of the United States and was a resident of the
state of Colorado during the relevant times described herein.
4.Defendant City of Fort Collins is a municipality in the state of Colorado.The Fort
Collins Police Department (FCPD) is a subdivision of the City of Fort Collins.
5.Defendant Brian Mallory is a citizen of the United States and was a resident of the
state of Colorado during the relevant times described herein.Defendant Mallory is
sued in his individual capacity as a police officer in the Fort Collins Police
Department.
6.Defendant Ethan VanSickle is a citizen of the United States and was a resident of the
state of Colorado during the relevant times described herein.Defendant VanSickle is
sued in his individual capacity as a police officer in the Fort Collins Police
Department.
7.Defendant Daniel Netzle Netzel is a citizen of the United States and was a resident of
the state of Colorado during the relevant times described herein.Defendant Netzle
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Netzel is sued in his individual capacity as a police officer in the Fort Collins Police
Department.
8.Defendant Jared Robertson is a citizen of the United States and was a resident of the
state of Colorado during the relevant times described herein.Defendant Robertson is
sued in his individual capacity as a police officer in the Fort Collins Police
Department.
9.Defendant Joe Schilz is a citizen of the United States and was a resident of the state
of Colorado during the relevant times described herein.Defendant Schilz is sued in
his individual capacity as a police officer in the Fort Collins Police Department.
10.Defendant Jason Haferman is a citizen of the United States and was a resident of the
state of Colorado during the relevant times described herein.Defendant Haferman is
sued in his individual capacity as a police officer in the Fort Collins Police
Department.
11.Defendant Christopher Young is a citizen of the United States and was a resident of
the state of Colorado during the relevant times described herein.Defendant Young is
sued in his individual capacity as a police officer in the Fort Collins Police
Department.
12.John Does 1-100 are individual police officers of the City of Fort Collins who
engaged in conduct meant to deprive Plaintiffs of their rights to Free Speech and to be
free from political violence issue in this case.Their identities are currently unknown
to Plaintiffs,but are known to the City of Fort Collins.They are each public
employees of Fort Collins who were operating under the color of state law.When
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their identities are determined,this Complaint will be amended to name each
individual officer to the extent that they violated the rights contemplated in this suit.
JURISDICTION AND VENUE
13.This is a civil rights action brought pursuant to 42 U.S.C. § 1983. Therefore, this
Court has jurisdiction over the subject matter of this action pursuant to 28 U.S.C. §§
1331(a) and 1343, the First, Fifth and Eighth Amendments United States Constitution
and over the parties pursuant to 28 U.S.C. § 1391(b) because this action arises from
the commission of tortious acts within the State of Colorado, by residents of the State
of Colorado.
14.Pursuant to 28 U.S.C. § 1391(b), venue is proper in the District Court in and for the
District of Colorado because the conduct complained of occurred within the City of
Fort Collins which is within the District of Colorado.
ALLEGATIONS
15.On August 8, 2020, the City of Fort Collins was the site of a Black Lives Matter
protest.
16.In response, a counter-protest was organized by various right-wing groups and
individuals, including Three Percenters and the Proud Boys -a right-wing and white
nationalist militia organizations.
17.These counter-protesters showed up to confront those calling for an end to police
violence.
18.The Three Percenters and others engaged in militia activities were organized, much
like the January 6, 2021 insurrectionists.
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19.Indeed these organizations played an important role in the January 6 insurrection five
months later.
20.They coordinated over encrypted radio communications with earpieces and a
command structure.
21.Many were armed with firearms.
22.These proto-January 6, 2021 insurrectionists engaged in much of the conduct that we
would witness in Washington D.C. only five months later.
23.When they arrived, they quickly coordinated with Fort Collins police officers.
24.Throughout the day, Fort Collins police officers associated with these
proto-insurrectionists.
25.The police officers thanked the militiamen for their presence and support.
26.They joked together.
27.At other times, the police would deliberately mute their body cameras when talking
and planning with the proto-insurrectionists.
28.And throughout, the Fort Collins police officers remained in areas with the
proto-insurrectionists, never interacting with the Black Lives Matter protesters.
29.At one point, the Three Percenters were aggressively confronting Black Lives Matter
protesters.
30.Defendant Mallory turned to the other Defendants and told them that they should
retreat because so long as the police were present, the groups would not engage in a
fight.
31.He then told the other Defendants that “if we break up a fight, then Antifa wins.”
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32.Defendant Mallory would later describe the Black Lives Matter protesters as
“domestic terrorists.”in his official police reports.
33.As the police officers retreat, a woman comes up to her to complain that one of the
Three Percenters had assaulted her.
34.The officers told her to file an online complaint.
35.They then turned to each other and talked about how people who protest police
violence should not expect to be protected by the police.
36.Within ten minutes of Defendant Mallory instructing his officers to retreat so that the
proto-insurrectionists would feel more secure in fighting, three proto-insurrectionists
attacked Joshua DeLeon.
37.Police were deliberately slow to respond to the assault of a Black Lives Matter
protester by three proto-insurrectionists.
38.In fact, Defendant Mallory instructed his officers to “take it slow” so that the Black
Lives Matter protesters would suffer greater injury.
39.For the individual Defendants, people who protest police brutality were less deserving
of protection and should learn that if they express criticism of police conduct, then the
police will withhold their services in kind.
40.Over the course of the protests, the police surveilled and targeted Black Lives Matter
protestors for arrest and made clear that they were only considering Black Lives
Matter protesters for arrest.
41.Over the course of the rest of the day, the FCPD officers would carry out this plan.
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42.In an attempt to give the proto-insurrectionists space to carry out their political
violence, the FCPD officers left the area of the protest.
43.Shortly thereafter, three proto-insurrectionists confronted and surrounded Joshua
DeLeon.
44.They pushed, punched and verbally assailed until they provoked him into a fight.
45.One of the proto-insurrectionists stabbed him with a cattle prod.
46.Another stabbed him with a flagpole with a United States flag while he lay on the
ground.
47.When Defendants Mallory, Netzel, Robertson, VanSickle,and Schilz the police
finally decided to intervene, they pulled the three proto-insurrectionists off of Joshua
DeLeon and arrested Mr. DeLeon.
48.Daniel Netzel and Jared Robertson are two of the first officers to approach these three
proto-insurrectionists who are beating Mr. DeLeon.
49.Both Defendants Netzel and Robertson were aware that these three
proto-insurrectionists had been engaged in fighting, including stabbing Mr. DeLeon.
50.Defendants Brian Mallory, Ethan VanSickle, and Joseph Schilz were involved in
pulling the three proto-insurrectionists off of Mr. DeLeon, but as part of their
common scheme to side with the proto-insurrectionists, they let those violent
individuals go.
51.Defendants Brian Mallory, Ethan VanSickle, and Joseph Schilz spoke with no one and
questioned no one about how the fight had begun, why there had been fighting, who
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had been involved, nor whether those individuals that they had seen hitting Mr.
DeLeon had also committed a crime.
52.For each of these five Defendants, Mr. DeLeon was the opposition and they intended
to punish him for his speech and viewpoint.
53.For each of these five Defendants, the proto-insurrectionists were their allies and
should be relieved of any responsibility for their actions if they were punishing the
Black Lives Matter protesters.
54.These officers encountered four people fighting and only arrested one based entirely
on the different viewpoints that were being expressed.
55.The three proto-insurrectionists were commended and were given free passage to the
protest to effect more violence.
56.None were arrested nor given tickets for their brutal attack, even though the police
saw them engaged in political violence.
57.They were never even questioned.
58.But Mr. DeLeon was immediately arrested because the FCPD officers, including
Defendant Netzle,were seeking to punish only those who called out police brutality.
59.However, the message the Defendants were giving to the proto-insurrectionists was
clear: they were free to exact punishment on behalf of the police without fear of
punishment. Their violence against Black Lives Matter protesters would be condoned.
60.Mr. DeLeon’s charges were later dismissed.
61.Thirty minutes later, the proto-insurrectionists began their second campaign of
violence and threats against the Black Lives Matter protesters.
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62.Over the course of several minutes, the proto-insurrectionists aggressively pushed the
Black Lives Matter protesters away from the protest area and into a residential
neighborhood.
63.Throughout, the Black Lives Matter protesters backed up while the
proto-insurrectionists pursued them.
64.The proto-insurrectionists lobbed threats while the Black Lives Matter protesters tried
to calm the situation.
65.Meanwhile, the police, consistent with their plan to allow political violence made no
attempt to pursue or separate the groups.
66.Having already seen the first fight that they had earlier predicted resulting from their
absence, the Defendants decided to leave the scene altogether and return to police
headquarters.
67.Presumably, they did this to enable further violence from their allies, the
proto-insurrectionists.
68.At some point, the two groups found themselves near a large ditch.
69.Black Lives Matter protesters are were attempting to leave the area and seek safety.
70.The proto-insurrectionists then pushed the Black Lives Matter protesters into the
ditch and began their assault.
71.One proto-insurrectionist chambered a round in his handgun near the Black Lives
Matter protesters.
72.Other proto-insurrectionists used their fists and other instruments of violence.
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73.The proto-insurrectionist who had stabbed Mr. DeLeon with a flagpole beats a Black
Lives Matter protester with a flagpole affixed with the flag of the United State of
America.
74.One member of the Three Percent militia straddled Michael Piper Townley and beat s
them repeatedly in the face and head.
75.Another proto-insurrectionist used a large rock on protesters’ head s and placeds
another in a choke-hold.
76.A proto-insurrectionist can be heard telling members to “Everyone keep your hands
off your weapons. Keep punching each other in the face, just don’t shoot anyone.”
77.When the FCPD finally arrived, the fight was over.
78.The Police then conversed with several of the proto-insurrectionists. These were their
partners.
79.When Defendant Mallory or another FCPD officer sees saw Michael Piper Townley
bleeding profusely from the head and receiving medical treatment, he lookeds around
for his supporters.
80.Although Mx. Townley, Ms. Kruger, and several others were telling all Defendants
that they had been attacked and had been trying to leave - that the
proto-insurrectionists had punched them, the Defendants did not care.
81.They were only looking for statements from the proto-insurrectionists which would
support their efforts to punish the Black Lives Matter protesters and protect the
proto-insurrectionists who were doing the violence against Black Lives Matter that
they could not accomplish themselves.
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82.The man with the flag and the person who had repeatedly punched Mx. Townley in
the face wasere asked if Mx. Townley had been fighting,to which they responded
yes.
83.With no other information or investigation and knowledge that the
proto-insurrectionists were the aggressors,the FCPD officers Defendant VanSickle
pushed Ms. Kruger away without basis and grabbed Mx.Townley and arrested them
for fighting.
84.Defendants VanSickle and Schilz then placed Mx. Townley under arrest.
85.Defendants had no probable cause to arrest Mx. Townley. The police were simply
looking to use the force of the state to punish those who called for an end to police
brutality.
86.The police officers knew that the proto-insurrectionists they spoke with had been the
aggressors, but they never considered arresting them. These were their colleagues.
87.When Ms. Townley points out to Defendants VanSickle and Schilz that it is wrong
that they are arresting those getting beat up and not the violent people, Defendant
VanSickle threatens further charges for resisting arrest.
88.As Defendants VanSickle and Schilz walk Mx. Townley away, the
proto-insurrectionists taunt Mx. Townley, saying, “I’ll bet you wish the cops would
have got there quicker.”
89.Defendants VanSickle and Schilz ignored this - that clearly Mx. Townley had been
the one beaten by these individuals and was the one in need of police protection from
these violent proto-insurrectionists.
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90.Of course, the Defendants responded in this manner because they had gotten what
they wanted by removing themselves from the situation - violence to be perpetrated
against those who protested police misconduct by the proto-insurrectionists.
91.Once the District Attorney reviewed the police video, all charges against Mx.
Townley were dismissed.
92.One of the medics tending to Mx. Townley was Anna Kruger.
93.Upon Defendants’arresting of Mx. Townley, Defendant Robertson threw Ms. Kruger
to the ground with excessive force.
94.Upon seeing this use of excessive force, officer Netzle When Ms. Kruger stood back
up, Defendants Netzel and Mallory threw her to the ground jumped onto Ms. Kruger,
again without any basis.
95.No officer had any belief that Ms. Kruger had committed any crime, that she was
about to commit a crime, that she was a danger to any person, or that she was
resisting arrest.
96.The officersDefendants Robertson, Mallory, and Netzel simply did not like her
because she was protesting police violence.
97.When she was dragged to her feet in pain, she asked what she was being arrested for.
The police Defendant Mallory responded with resisting arrest.
98.Defendant Mallory knew that no order had been given to Ms. Kruger to support
resisting arrest, nor had Defendants intended to arrest her.
99.Robertson, and Mallory placed Ms. Kruger under arrest, knowing that they had no
probable cause to arrest her and that she had committed no crime.
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100.Ms. Kruger correctly pointed out that they needed a basis to arrest her before she
could resist arrest.
101.The officersDefendants Robertson and Netzel, realizing that they had committed
excessive force and had seized Ms. Kruger without cause,then manufactured lies in
their statements and probable cause statements.
102.Defendant Robertson wrote in his incident report that Ms. Kruger had interfered in an
arrest even though he knew that she had not engaged in any action of interference. He
needed a basis for arresting her so he lied.
103.Defendant Netzle Netzel wrote in his statement that Ms. Kruger had engaged in
fighting. Defendant Netzle Netzel knew this to be a lie, but wrote it anyway.Netzle
Netzel knew that there was no probable cause for arresting her, so he lied about her
conduct so that she would be arrested.
104.These charges were soon dismissed.
105.Defendant Christopher Young then prepared charges against Mx. Townley for the
criminal offense of disorderly conduct without any basis.
106.Defendant Young then affirmed under oath that Mx. Townley “was observed by
officers engaging in a physical fight with other protesters.”
107.This was plainly untrue as Mx. Townley had not been fighting, but more importantly,
the officers had intentionally removed themselves from the protests so that the
proto-insurrectionists could exact their mob justice without police intervention.
108.By the time that any officer approached the scene where this violent mob had beaten
Mx. Townley, Mx. Townley was off to the side being treated for a head injury.
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109.Defendant Young lied in his sworn statement about the circumstances of Mx.
Townley’s arrest to support criminal charges.
110.Defendant Jason Haferman then prepared charges against Ms. Kruger for the criminal
offenses of disorderly conduct and resisting arrest.
111.Defendant Haferman then affirmed under oath that “Anna Kruger was observed by
multiple officers fighting in public. Kruger resisted arrest when she was contacted by
police.”
112.As with Defendant Young’s sworn statement, Defendant Haferman lied about the
circumstances of Ms. Kruger ’s arrest to support criminal charges.
113.Jason Haferman has since been suspended by the Fort Collins Police Department
lying in probable cause statements for years.
114.At least twelve people have been charged by Defendant Haferman for driving under
the influence when there was no evidence that they had consumed any alcohol.
115.Apparently, Defendant Haferman has made a practice of trumping up charges or
simply lying in probable cause statements to effect more arrests.
116.Defendants Mallory, Robertson, Schilz, VanSickle, or Netzel told Defendants
Haferman and Young that Plaintiffs Townley and Kruger had been engaged in
fighting when they had no probable cause or knowledge to believe this.
117.No Defendant nor any other officer in the Fort Collins Police Department had
conducted any interviews, done any research, nor engaged in any investigating of the
incident before arresting or charging Plaintiffs DeLeon, Townley, or Kruger.
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118.Defendants lacked any basis for charging Townley or Kruger, but did so because they
believed that people who protest police brutality are their opponents and were
inherently violent while disregarding the known violence of the Three Percenters and
Proud Boys.
119.After each incident in which they knew that the proto-insurrectionists had engaged in
violence, not a single Defendant questioned any proto-insurrectionist on their
violence.
120.No Defendants sought the identities of people who were stabbing people with flag
poles.
121.Defendants simply allowed their compatriots to leave with impunity.
CAUSES OF ACTION
COUNT I:
42 U.S.C. 1983 - Fourth Amendment - Excessive Force
(ANNA KRUGER AGAINST JARED ROBERTSON, DANIEL NETZLENETZEL,AND BRIAN MALLORYJOHN DOES
1-100)
122.Plaintiff incorporates by reference the allegations contained in the foregoing
paragraphs, as though fully set forth herein.
123.Defendants acted under color of state law,and within the course and scope of their
employment,in their capacities as law enforcement officers for the FCPD at all times
relevant to the allegations in this Complaint.
124.Defendants are “persons” under 42 U.S.C. § 1983.
125.Plaintiff had a protected Fourth Amendment interest against being victimized by the
use of excessive force at the hands of law enforcement personnel.
126.Defendants did not have, at any time, a legally valid basis to seize Plaintiff.
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127.Defendants unlawfully seized Plaintiff by means of excessive physical force.
128.Defendants had no warrant authorizing any seizure of Plaintiff.
129.Each Defendant failed to intervene to prevent the other Defendants from violating
Plaintiff ’s constitutional rights and is thereby liable for such failure to intervene.
130.Defendants’actions were objectively unreasonable in light of the circumstances
confronting them.
131.Plaintiff had committed no crime (nor could any of the Defendants have reasonably
believed they had committed any crime)that would legally justify arrest or detention,
Plaintiff gave the officers no reason to fear for their safety,Plaintiff was obviously
unarmed, and Plaintiff was not resisting arrest or fleeing.
132.Defendants did not have a legally valid basis to seize Plaintiff in the manner and with
the level of force used under the circumstances presented.
133.Defendants’actions,as described herein,were objectively unreasonable in light of the
facts and circumstances confronting them.
134.At the time when Defendants used excessive force against Plaintiff,Plaintiff had a
clearly established constitutional right under the Fourth Amendment to the United
States Constitution to be secure from unreasonable seizure through excessive force.
Any reasonable law enforcement officer knew or should have known of this clearly
established right.
135.Defendants engaged in these actions intentionally,willfully,and wantonly,
demonstrating deliberate indifference to,and a reckless disregard for,Plaintiff ’s
constitutionally protected rights.
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136.As a direct and proximate cause and consequence of Defendants’unconstitutional
acts and omissions, described herein, Plaintiff suffered injuries, damages, and losses.
137.Defendants’herein described acts or omissions were the moving force and the legal,
direct,and proximate cause of Plaintiff ’s injuries and losses,including but not limited
to non-economic damages,economic damages,the physical and mental pain and
anguish Plaintiff suffered during and after the vigil,and other compensatory and
special damages.
138.Defendants’intentional actions or inactions as described herein intentionally deprived
Plaintiff of due process and of rights,privileges,liberties,and immunities secured by
the Constitution of the United States of America.
COUNT II:
C.R.S. 13-21-131 - Fourth Amendment - Excessive Force
(ANNA KRUGER AGAINST JARED ROBERTSON, DANIEL NETZLENETZEL,AND BRIAN MALLORY,AND
JOHN DOES 1-100)
139.Plaintiff incorporates by reference the allegations contained in the foregoing
paragraphs, as though fully set forth herein.
140.Defendants acted under color of state law,and within the course and scope of their
employment,in their capacities as law enforcement officers for the FCPD at all times
relevant to the allegations in this Complaint.
141.Plaintiff had a protected interest against being victimized by the use of excessive
force at the hands of law enforcement personnel.
142.Defendants did not have, at any time, a legally valid basis to seize Plaintiff.
143.Defendants unlawfully seized Plaintiff by means of excessive physical force.
144.Defendants had no warrant authorizing any seizure of Plaintiff.
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145.Each Defendant failed to intervene to prevent the other Defendants from violating
Plaintiff ’s constitutional rights and is thereby liable for such failure to intervene.
146.Defendants’actions were objectively unreasonable in light of the circumstances
confronting them.
147.Plaintiff had committed no crime (nor could any of the Defendants have reasonably
believed they had committed any crime)that would legally justify arrest or detention,
Plaintiff gave the officers no reason to fear for their safety,Plaintiff was obviously
unarmed, and Plaintiff was not resisting arrest or fleeing.
148.Defendants did not have a legally valid basis to seize Plaintiff in the manner and with
the level of force used under the circumstances presented.
149.Defendants’actions,as described herein,were objectively unreasonable in light of the
facts and circumstances confronting them.
150.At the time when Defendants used excessive force against Plaintiff,Plaintiff had a
clearly established constitutional right under the Colorado Constitution to be secure
from unreasonable seizure through excessive force.Any reasonable law enforcement
officer knew or should have known of this clearly established right.
151.Defendants engaged in these actions intentionally,willfully,and wantonly,
demonstrating deliberate indifference to,and a reckless disregard for,Plaintiff ’s
constitutionally protected rights.
152.As a direct and proximate cause and consequence of Defendants’unconstitutional
acts and omissions, described herein, Plaintiff suffered injuries, damages, and losses.
153.Defendants’herein described acts or omissions were the moving force and the legal,
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direct,and proximate cause of Plaintiff ’s injuries and losses,including but not limited
to non-economic damages,economic damages,the physical and mental pain and
anguish Plaintiff suffered during and after the vigil,and other compensatory and
special damages.
154.Defendants’intentional actions or inactions as described herein intentionally deprived
Plaintiff of due process and of rights,privileges,liberties,and immunities secured by
the Constitution of the United States of America and the Constitution of the state of
Colorado.
COUNT III:
42 U.S.C. 1983 - Malicious Prosecution
(ANNA KRUGER AGAINST JARED ROBERTSON, DANIEL NETZLENETZEL,BRIAN MALLORY, JOE
SCHILZ,AND ETHAN VANSICKLE AND JASON HAFERMANJOHN DOES 1-100)
155.Plaintiff incorporates by reference the allegations contained in the foregoing
paragraphs, as though fully set forth herein.
156.Defendants acted under color of state law,and within the course and scope of their
employment,in their capacities as law enforcement officers for the FCPD at all times
relevant to the allegations in this Complaint.
157.Defendants initiated and continued the case without proper purpose and based on
fabrication.
158.Defendants played important roles in the filing of charges against Ms. Kruger.
159.The case was ultimately dismissed in Ms. Kruger ’s favor.
160.Ms. Kruger suffered injuries as a direct and proximate result of Defendants’ conduct.
COUNT IV:
C.R.S. 13-21-131 - Malicious Prosecution
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(ANNA KRUGER AGAINST JASON HAFERMAN, JARED ROBERTSON, DANIEL NETZLENETZEL, BRIAN
MALLORY, JOE SCHILZ,AND ETHAN VANSICKLEJOHN DOES 1-100)
161.Plaintiff incorporates by reference the allegations contained in the foregoing
paragraphs, as though fully set forth herein.
162.Defendants acted under color of state law,and within the course and scope of their
employment,in their capacities as law enforcement officers for the FCPD at all times
relevant to the allegations in this Complaint.
163.Defendants initiated and continued the case without proper purpose and based on
fabrication.
164.Defendants played important roles in the filing of charges against Ms. Kruger.
165.The case was ultimately dismissed in Ms. Kruger ’s favor.
166.Ms. Kruger suffered injuries as a direct and proximate result of Defendants’ conduct.
COUNT V:
42 U.S.C. 1983 - False Arrest
(ANNA KRUGER AGAINST JASON HAFERMAN,JARED ROBERTSON,DANIEL NETZLENETZEL,AND
BRIAN MALLORY AND JOHN DOES 1-100)
167.Plaintiff incorporates by reference the allegations contained in the foregoing
paragraphs, as though fully set forth herein.
168.Defendants knew that Ms. Kruger had not resisted arrest.
169.Defendants manufactured a basis for arresting Ms. Kruger instead.
170.Owing to this, Defendants knew that they lacked probable cause to arrest Ms. Kruger.
171.Nonetheless, Defendants arrested Ms. Kruger.
172.Ms. Kruger suffered injuries as a direct and proximate result of Defendants’ conduct.
COUNT VI:
C.R.S. 13-21-131 - False Arrest
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(ANNA KRUGER AGAINST JARED ROBERTSON, DANIEL NETZLENETZEL,AND BRIAN MALLORYJOHN
DOES 1-100)
173.Plaintiff incorporates by reference the allegations contained in the foregoing
paragraphs, as though fully set forth herein.
174.Defendants knew that Ms. Kruger had not resisted arrest.
175.Defendants manufactured a basis for arresting Ms. Kruger instead.
176.Owing to this, Defendants knew that they lacked probable cause to arrest Ms. Kruger.
177.Nonetheless, Defendants arrested Ms. Kruger.
178.Ms. Kruger suffered injuries as a direct and proximate result of Defendants’ conduct.
COUNT VII:
42 U.S.C. 1983 - Malicious Prosecution
(MICHAEL PIPER TOWNLEY AGAINST BRIAN MALLORY, CHRISTOPHER YOUNG, JOE SCHILZ, ETHAN
VANSICKLE, DANIEL NETZEL,AND JARED ROBERTSONJOHN DOES 1-100)
179.Plaintiff incorporates by reference the allegations contained in the foregoing
paragraphs, as though fully set forth herein.
180.Defendants acted under color of state law,and within the course and scope of their
employment,in their capacities as law enforcement officers for the FCPD at all times
relevant to the allegations in this Complaint.
181.Defendants initiated and continued the case without proper purpose and based on
fabrication.
182.Defendants played important roles in the filing of charges against Mx. Townley.
183.The case was ultimately dismissed in Mx. Townley’s favor.
184.Mx.Townley suffered injuries as a direct and proximate result of Defendants’
conduct.
COUNT VIII:
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C.R.S. 13-21-131 - Malicious Prosecution
(ANNA KRUGERMICHAEL PIPER TOWNLEY AGAINST BRIAN MALLORY,CHRISTOPHER YOUNG,JOE
SCHILZ, ETHAN VANSICKLE, DANIEL NETZEL,AND JARED ROBERTSONJOHN DOES 1-100)
185.Plaintiff incorporates by reference the allegations contained in the foregoing
paragraphs, as though fully set forth herein.
186.Defendants acted under color of state law,and within the course and scope of their
employment,in their capacities as law enforcement officers for the FCPD at all times
relevant to the allegations in this Complaint.
187.Defendants initiated and continued the case without proper purpose and based on
fabrication.
188.Defendants played important roles in the filing of charges against Mx. Townley.
189.The case was ultimately dismissed in Mx. Townley’s favor.
190.Mx.Townley suffered injuries as a direct and proximate result of Defendants’
conduct.
COUNT IX:
42 U.S.C. 1983 - False Arrest
(MICHAEL PIPER TOWNLEY AGAINST BRIAN MALLORY,JOE SCHILZ,AND ETHAN VANSICKLEJOHN
DOES 1-100)
191.Plaintiff incorporates by reference the allegations contained in the foregoing
paragraphs, as though fully set forth herein.
192.Defendants had no probable cause to believe that Mx.Townley had engaged in
fighting.
193.Owing to this,Defendants knew that they lacked probable cause to arrest Mx.
Townley.
194.Nonetheless, Defendants arrested Mx. Townley.
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195.Mx.Townley suffered injuries as a direct and proximate result of Defendants’
conduct.
COUNT X:
C.R.S. 13-21-131 - False Arrest
(MICHAEL PIPER TOWNLEY AGAINST BRIAN MALLORY,JOE SCHILZ,AND ETHAN VANSICKLEAND
JOHN DOES 1-100)
196.Plaintiff incorporates by reference the allegations contained in the foregoing
paragraphs, as though fully set forth herein.
197.Defendants had no probable cause to believe that Mx.Townley had engaged in
fighting.
198.Owing to this,Defendants knew that they lacked probable cause to arrest Mx.
Townley.
199.Nonetheless, Defendants arrested Mx. Townley.
200.Mx.Townley suffered injuries as a direct and proximate result of Defendants’
conduct.
COUNT XI:
42 U.S. C. 1983
First Amendment Violation — Freedom of Speech and Assembly
(All Plaintiffs against All Defendants )
201.Plaintiffs incorporate by reference the allegations contained in the foregoing
paragraphs, as though fully set forth herein.
202.Defendants,acted under color of state law,and within the course and scope of their
employment,in their capacities as officers of the FCPD at all times relevant to the
allegations in this Complaint.
203.Defendants are “persons” under 42 U.S.C. § 1983.
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204.Plaintiffs were engaged in First Amendment-protected expression by gathering to
protest police brutality.
205.The actions of Defendants would chill a reasonable person from engaging in activity
protected by the First Amendment.
206.Plaintiffs’ expressions were on a matter of public concern and did not violate any law.
207.Plaintiffs’ expressions occurred in a traditional public forum.
208.Defendants’actions were a content-based and/or viewpoint-based restriction of
Plaintiffs’ expression.
209.Defendants’actions were not a reasonable time,place,and manner restriction on
speech.
210.Defendants,collectively,failed to intervene to prevent each Defendant from violating
Plaintiff ’s constitutional rights.
211.At the time when Defendants stopped Plaintiffs from speaking and gathering,Plaintiff
had a clearly established constitutional right under the First Amendment to the United
States Constitution to gather,express himself,and speak freely.Any reasonable law
enforcement officer knew or should have known of this clearly established right.
212.Defendants engaged in their conduct intentionally,knowingly,willfully,wantonly,
maliciously, and in reckless disregard of Plaintiffs’ constitutional rights.
213.As a direct and proximate cause and consequence of Defendants’unconstitutional
acts and omissions, described above, Plaintiffs suffered injuries, damages, and losses.
214.Defendants’herein described acts or omissions were the moving force and the legal,
direct,and proximate cause of Plaintiff ’s injuries and losses,including but not limited
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to non-economic damages,economic damages,the physical and mental pain,and
anguish Plaintiff suffered during and after the protest,and other compensatory and
special damages.
215.Defendants’intentional actions or inactions as described herein intentionally deprived
Plaintiff of due process and of rights,privileges,liberties,and immunities secured by
the Constitution of the United States of America.
COUNT XII:
C.R.S. 13-21-131 — Freedom of Speech and Assembly
(All Plaintiffs against All Defendants )
216.Plaintiffs incorporate by reference the allegations contained in the foregoing
paragraphs, as though fully set forth herein.
217.Defendants,acted under color of state law,and within the course and scope of their
employment,in their capacities as officers of the FCPD at all times relevant to the
allegations in this Complaint.
218.Plaintiffs were engaged in protected expression by gathering to protest police
brutality.
219.The actions of Defendants would chill a reasonable person from engaging in activity
protected by the Colorado Bill of Rights.
220.Plaintiffs’ expressions were on a matter of public concern and did not violate any law.
221.Plaintiffs’ expressions occurred in a traditional public forum.
222.Defendants’actions were a content-based and/or viewpoint-based restriction of
Plaintiffs’ expression.
223.Defendants’actions were not a reasonable time,place,and manner restriction on
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speech.
224.Defendants,collectively,failed to intervene to prevent each Defendant from violating
Plaintiff ’s constitutional rights.
225.At the time when Defendants stopped Plaintiffs from speaking and gathering,Plaintiff
had a clearly established constitutional right under the Constitution of Colorado to
gather,express himself,and speak freely.Any reasonable law enforcement officer
knew or should have known of this clearly established right.
226.Defendants engaged in their conduct intentionally,knowingly,willfully,wantonly,
maliciously, and in reckless disregard of Plaintiffs’ constitutional rights.
227.As a direct and proximate cause and consequence of Defendants’unconstitutional
acts and omissions, described above, Plaintiffs suffered injuries, damages, and losses.
228.Defendants’herein described acts or omissions were the moving force and the legal,
direct,and proximate cause of Plaintiff ’s injuries and losses,including but not limited
to non-economic damages,economic damages,the physical and mental pain,and
anguish Plaintiff suffered during and after the protest,and other compensatory and
special damages.
229.Defendants’intentional actions or inactions as described herein intentionally deprived
Plaintiff of due process and of rights,privileges,liberties,and immunities secured by
the Constitution of the United States of America.
CLAIM XIII
42 U.S.C. § 1983
First Amendment Violation — Retaliation
(All Plaintiff against All Defendants )
230.Plaintiffs incorporate by reference the allegations contained in the foregoing
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paragraphs, as though fully set forth herein.
231.Defendants acted under color of state law,and within the course and scope of their
employment,in their capacities as law enforcement officers for the FCPD at all times
relevant to the allegations in this Complaint.
232.Defendants are “persons” under 42 U.S.C. § 1983.
233.Plaintiffs’were engaged in First Amendment-protected expression by gathering to
protest police brutality.
234.The actions of Defendants would chill a reasonable person from engaging in activity
protected by the First Amendment.
235.Plaintiffs’ expression was on a matter of public concern and did not violate any law.
236.Plaintiffs’ expression occurred in a traditional public forum.
237.Defendants jointly and on their own accord responded to Plaintiff ’s First Amendment
protected activity with retaliation.
238.Defendants sought to punish Plaintiffs for exercising his First Amendment rights,to
silence them,and to deter them from gathering and speaking in the future.
Defendants’retaliatory actions would chill a person of ordinary firmness from
engaging in such First Amendment protected activity.
239.Defendants’retaliatory actions were substantially motivated by Plaintiffs’exercise of
their First Amendment rights.
240.At the time when Defendants retaliated against Plaintiffs for exercising their First
Amendment rights,Plaintiffs had a clearly established constitutional right under the
First Amendment to the United States Constitution to be free from retaliation.Any
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reasonable law enforcement officer knew or should have known of this clearly
established right.
241.Defendants,collectively,failed to intervene to prevent each Defendant from violating
Plaintiffs’ constitutional rights.
242.Defendants engaged in their conduct intentionally,knowingly,willfully,wantonly,
maliciously, and in reckless disregard of Plaintiffs’ constitutional rights.
243.Defendants stopped Plaintiffs from engaging in expressive activity.
244.As a direct and proximate cause and consequence of Defendants’unconstitutional
acts and omissions, described above, Plaintiff suffered injuries, damages, and losses.
245.Defendants’herein described acts or omissions were the moving force and the legal,
direct,and proximate cause of Plaintiff ’s injuries and losses,including but not limited
to non-economic damages,economic damages,the physical and mental pain and
anguish Plaintiff suffered during and after the protest,and other compensatory and
special damages.
246.Defendants’intentional actions or inactions as described herein intentionally deprived
Plaintiff of due process and of rights,privileges,liberties,and immunities secured by
the Constitution of the United States of America.
CLAIM XIV
C.R.S. 13-21-131 Free Speech Retaliation
(All Plaintiff against All Defendants )
247.Plaintiffs incorporate by reference the allegations contained in the foregoing
paragraphs, as though fully set forth herein.
248.Defendants acted under color of state law,and within the course and scope of their
employment,in their capacities as law enforcement officers for the FCPD at all times
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relevant to the allegations in this Complaint.
249.Plaintiffs’were engaged in protected expression by gathering to protest police
brutality.
250.The actions of Defendants would chill a reasonable person from engaging in activity
protected by the Colorado Constitution.
251.Plaintiffs’ expression was on a matter of public concern and did not violate any law.
252.Plaintiffs’ expression occurred in a traditional public forum.
253.Defendants jointly and on their own accord responded to Plaintiff ’s free speech
protected activity with retaliation.
254.Defendants sought to punish Plaintiffs for exercising their free speech rights,to
silence them,and to deter them from gathering and speaking in the future.
Defendants’retaliatory actions would chill a person of ordinary firmness from
engaging in such First Amendment protected activity.
255.Defendants’retaliatory actions were substantially motivated by Plaintiffs’exercise of
their free speech rights.
256.At the time when Defendants retaliated against Plaintiffs for exercising their
Constitutional rights,Plaintiffs had a clearly established constitutional right under the
Constitution of the state of Colorado to be free from retaliation.Any reasonable law
enforcement officer knew or should have known of this clearly established right.
257.Defendants,collectively,failed to intervene to prevent each Defendant from violating
Plaintiffs’ constitutional rights.
258.Defendants engaged in their conduct intentionally,knowingly,willfully,wantonly,
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maliciously, and in reckless disregard of Plaintiffs’ constitutional rights.
259.Defendants stopped Plaintiffs from engaging in expressive activity.
260.As a direct and proximate cause and consequence of Defendants’unconstitutional
acts and omissions, described above, Plaintiff suffered injuries, damages, and losses.
261.Defendants’herein described acts or omissions were the moving force and the legal,
direct,and proximate cause of Plaintiff ’s injuries and losses,including but not limited
to non-economic damages,economic damages,the physical and mental pain and
anguish Plaintiff suffered during and after the protest,and other compensatory and
special damages.
262.Defendants’intentional actions or inactions as described herein intentionally deprived
Plaintiff of due process and of rights,privileges,liberties,and immunities secured by
the Constitution of the United States of America.
CLAIM XV
42 U.S.C. § 1983
Equal Protection - Selective Enforcement
(All Plaintiff against All Defendants )
263.Plaintiffs incorporate by reference the allegations contained in the foregoing
paragraphs, as though fully set forth herein.
264.Defendants were operating under color of state law.
265.Plaintiffs and the right-wing protesters were similarly situated individuals.
266.Plaintiffs were arrested for conduct engaged in by those who Defendants perceived to
be supportive of police while Defendants perceived Plaintiffs as oppositional to
police.
267.Defendants discriminated against Plaintiffs and arrested them for conduct that the
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right wing agitators were also engaged in.
268.Defendants did this on the basis of Plaintiffs’ protected constitutional rights.
269.As a direct and proximate cause and consequence of Defendants’unconstitutional
acts and omissions, described above, Plaintiff suffered injuries, damages, and losses.
270.Defendants’herein described acts or omissions were the moving force and the legal,
direct,and proximate cause of Plaintiff ’s injuries and losses,including but not limited
to non-economic damages,economic damages,the physical and mental pain and
anguish Plaintiff suffered during and after the protest,and other compensatory and
special damages.
271.Defendants’intentional actions or inactions as described herein intentionally deprived
Plaintiff of due process and of rights,privileges,liberties,and immunities secured by
the Constitution of the United States of America.
CLAIM XVI
C.R.S. 13-21-131
Equal Protection - Selective Enforcement
(All Plaintiff against All Defendants )
272.Plaintiffs incorporate by reference the allegations contained in the foregoing
paragraphs, as though fully set forth herein.
273.Plaintiffs and the right-wing protesters were similarly situated individuals.
274.Plaintiffs were arrested for conduct engaged in by those who Defendants perceived to
be supportive of police while Defendants perceived Plaintiffs as oppositional to
police.
275.Defendants discriminated against Plaintiffs and arrested them for conduct that the
right wing agitators were also engaged in.
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276.Defendants did this on the basis of Plaintiffs’ protected constitutional rights.
277.As a direct and proximate cause and consequence of Defendants’unconstitutional
acts and omissions, described above, Plaintiff suffered injuries, damages, and losses.
278.Defendants’herein described acts or omissions were the moving force and the legal,
direct,and proximate cause of Plaintiff ’s injuries and losses,including but not limited
to non-economic damages,economic damages,the physical and mental pain and
anguish Plaintiff suffered during and after the protest,and other compensatory and
special damages.
279.Defendants’intentional actions or inactions as described herein intentionally deprived
Plaintiff of due process and of rights,privileges,liberties,and immunities secured by
the Constitution of the United States of America.
CLAIM XVII
42 U.S.C. §1985(3)
CONSPIRACY TO OBSTRUCT JUSTICE BASED ON INVIDIOUS
DISCRIMINATION
(All Plaintiff against All Defendants )
280.Plaintiffs incorporate by reference the allegations contained in the foregoing
paragraphs, as though fully set forth herein.
281.Defendants are “persons” as that term is used in 42 U.S.C. §1985.
282.Defendants,acting in concert with each other and other co-conspirators—including
members of the Three Percenters and other non-party armed individuals—reached an
agreement among themselves to deprive Plaintiffs of their constitutional rights and
equal protection of the laws,all as described in the various paragraphs of this
Complaint.
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283.In so doing,these co-conspirators conspired to accomplish an unlawful purpose by an
unlawful means.In addition,these co-conspirators agreed among themselves to
protect one another from liability for depriving Plaintiffs of these rights.
284.In furtherance of the conspiracy,each of the co-conspirators committed overt acts and
was an otherwise willful participant in joint activity.
285.The conspiracy between Defendants and the other co-conspirators set forth above,
and the actions taken in furtherance thereof, were motivated by racial animus.
286.Specifically,working in concert with these others,Defendants targeted individuals of
color and individuals allied with them in protest against racial discrimination,
including Defendants,by creating a dangerous environment in which injury to
Plaintiffs and others was highly likely.They did this by permitting the all-white
armed individuals—many of whom had openly espoused racist and violent
intentions—to taunt,threaten and monitor the diverse group of protestors,by
permitting the all-White armed individuals to patrol the streets like deputized police
officers,by offering the all-White armed individuals assistance and praise while
simultaneously ordering protestors to disperse,and by ultimately corralling the
protestors and funneling them toward the all-white armed individuals to “deal with
them.”
287.The misconduct described in this Count was objectively unreasonable and was
undertaken intentionally,with malice,willfulness,and reckless indifference to the
rights of Plaintiffs and others.
288.As a direct and proximate cause and consequence of Defendants’unconstitutional
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acts and omissions, described above, Plaintiff suffered injuries, damages, and losses.
289.Defendants’herein described acts or omissions were the moving force and the legal,
direct,and proximate cause of Plaintiff ’s injuries and losses,including but not limited
to non-economic damages,economic damages,the physical and mental pain and
anguish Plaintiff suffered during and after the protest,and other compensatory and
special damages.
290.Defendants’intentional actions or inactions as described herein intentionally deprived
Plaintiff of due process and of rights,privileges,liberties,and immunities secured by
the Constitution of the United States of America.
CLAIM XVIII
42 U.S.C. §1983
CONSPIRACY TO DEPRIVE CONSTITUTIONAL RIGHTS
(All Plaintiff against All Defendants )
291.Plaintiffs incorporate by reference the allegations contained in the foregoing
paragraphs, as though fully set forth herein.
292.Defendants are “persons” as that term is used in 42 U.S.C. §1985.
293.Defendants acting in concert with each other and other co-conspirators including
members of the Three Percenters and other non-party armed individuals—reached an
agreement among themselves to deprive Plaintiffs of their constitutional rights,all as
described in the various paragraphs of this Complaint.
294.In so doing,these co-conspirators conspired to accomplish an unlawful purpose by an
unlawful means.In addition,these co-conspirators agreed among themselves to
protect one another from liability for depriving Plaintiffs of these rights.
295.In furtherance of the conspiracy,each of the co-conspirators committed overt acts and
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was an otherwise willful participant in joint activity.
296.The misconduct described in this Count was objectively unreasonable and was
undertaken intentionally,with malice,willfulness,and reckless indifference to the
rights of Plaintiffs and others.
297.As a direct and proximate cause and consequence of Defendants’unconstitutional
acts and omissions, described above, Plaintiff suffered injuries, damages, and losses.
298.Defendants’herein described acts or omissions were the moving force and the legal,
direct,and proximate cause of Plaintiff ’s injuries and losses,including but not limited
to non-economic damages,economic damages,the physical and mental pain and
anguish Plaintiff suffered during and after the protest,and other compensatory and
special damages.
299.Defendants’intentional actions or inactions as described herein intentionally deprived
Plaintiff of due process and of rights,privileges,liberties,and immunities secured by
the Constitution of the United States of America.
WHEREFORE, Plaintiffs pray for relief as follows:
1.Declaratory relief and other appropriate equitable relief;
2.Economic losses on all claims as allowed by law;
3.Compensatory and consequential damages,including damages for emotional distress,
humiliation,loss of enjoyment of life,and other pain and suffering on all claims
allowed by law in an amount to be determined at trial;
4.Punitive damages on all claims allowed by law and in an amount to be determined at
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trial;
5.Attorneys’fees and the costs associated with this action under 42 U.S.C.§1988,
including expert witness fees, on all claims allowed by law;
6.Pre-and post-judgment interest at the lawful rate; and
7.Any other appropriate relief at law and equity that this Court deems just and proper.
JURY DEMAND
Plaintiffs demand a trial by jury of all issues triable.
Respectfully submitted this 28th day of August November 2022.
E. Milo Schwab
E. Milo Schwab
2401 S Downing
Denver, CO 80210
(303) 888-4407
milo@ascendcounsel.co
ATTORNEY FOR PLAINTIFFS
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