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Complaint For Violation of Civil Rights/Jury Trial Demanded
Complaint For Violation of Civil Rights/Jury Trial Demanded
PLAINTIFF
Cause No. 1:15cv82-SA-DAS
v.
THE UNITED STATES OF AMERICA
JOHN DOES 1-15
DEFENDANT
filing his Notice of Claim under the Federal Tort Claim Act. More than six months have passed
since the administrative claim was made. As of this date no response has been received and
Plaintiff elects to proceed via litigation.
PARTIES
Plaintiff:
Mississippi.
Defendant:
The acts and omissions alleged against the United States of America were
performed by employees of the United States. Those employees were, to plaintiffs knowledge
and belief, employees of the Federal Bureau of Investigation, the Department of Homeland
Security and/or the Department of Justice. John Does 1-15 are individuals whose names are
suspected, but not fully known, and who will be identified during the course of the litigation.
STATEMENT OF FACTS
Background
1.
entertainer who was living in Corinth, Alcorn County, Mississippi, in April 2013. Kevin
received Social Security disability payments and supplemented his income through live vocal
performances as well as the sell of his music CDs. Kevin frequently used social media to
advocate various causes and concerns. During his use of social media Kevin used certain
phrases, such as I am KC and I approve this message as well as the quote To see a wrong and
not expose it, is to become a silent partner to its continuance. Kevin often closed his postings
with either or both of these phrases. A simple internet search reveals Kevin had used these
quotes as far back as 2003. In fact, the government states as much in its affidavit for the arrest of
Dutschke: This statement is found frequently in Curtis's online postings, as any visitor to
Curtis's Facebook page would know. (USA v. Dutschke USDC No. 3:13MJ0020, Document
#1).
2.
On April 16, 2013, the Jackson Division of the FBI was advised that the United
States Senate Mall Facility in Landover, Maryland had identified an envelope which contained a
type-written letter and a suspicious granular substance. The letter was addressed to "Snator
(sic) Roger Wicker, 555 Dirksen Senate Bldng, Washington DC 20510". Senator Wicker is an
elected official representing the State of Mississippi whose primary residence is in the Northern
District of Mississippi. No return address was identified on the envelope and it was
postmarked in Memphis, Tennessee, on April 8, 2013. Contained in the envelope was a letter
containing the following language: No one wanted to listen to me before. There are
still/Missing Pieces' Maybe I have your attention now Even if that means someone must die.
This must stop. To see a wrong and not expose it, is to become a silent partner to its
continuance I am KC and I approve this message.
3.
According to the United States government, law enforcement sought information from
Senator Wickers office about constituents or complainants who might have the initials KC.
The government claims that Senator Wickers office provided the name Paul Kevin Curtis.
The
government further claimed that Kevin Curtis sent multiple mailings to Senator Wicker and other
political officers, all containing the phrases that appeared in the Ricin letters. The government
also learned from local authorities that Kevin had been investigated and that many years before
his ex-wife described him as delusional.
4.
Based on those speculations and accusations, the United States government, by and
through the full force of its law enforcement agencies, destroyed the life of Kevin Curtis.
The Arrest
5.
On April 17, 2013, Kevin Curtis was living his life quietly while honing his entertaining
skills and caring for his children. A father of four, Kevin played an active role in the lives of his
children from their birth forward. On the afternoon of April 17th Kevin planned to travel
approximately twenty (20) miles to Booneville, Mississippi, to cook dinner for his children and
his former wife. It was a Wednesday evening and Kevin planned to help with homework and
church activities. This was a normal course of action for Kevin and his former wife, Laura
Curtis. Kevin loaded some food into his car and also gathered his small dog, Moo Cow, for the
short drive.
6.
Upon leaving his driveway Kevin approached his mailbox to check his mail. At that
exact moment his life changed forever. In the blink of an eye he was literally swarmed by
countless men in SWAT gear with automatic weapons drawn. The swarm yelled at him, barked
orders and cursed him as they cuffed and shackled him. Kevin was in a state of shock, as was
Moo Cow, who ran away in the melee. Kevin asked multiple times for someone to help with his
dog but his requests were unheeded.
7.
The army of GI Joe looking men began interrogating Kevin on the spot. Kevin answered
every question truthfully and without hesitation, despite his obvious shock and fear. He was put
in the back of a black unmarked SUV and driven to Oxford, Mississippi. (Kevin learned later
where he was taken. He had no idea at the time where he was going and the officers/agents did
not offer any information.) There were demands to search his home and Kevin begged the army
of men to search his home as he had nothing to hide. These government agents then searched
Kevins automobile and home, completely wrecking his home and damaging his vehicle.
8.
Once the convoy stopped, Kevin was taken inside a building and handcuffed to a chair.
Numerous individuals interrogated him, demanding that he admit his guilt in a Presidential
assassination plot. Kevin answered their questions, but not to their satisfaction. Kevin was
confused and could not comprehend the purpose of their actions. He was literally jerked out of
his car and hauled away in an unmarked car by people whose identity were unknown to him. His
dog ran away and he was not allowed to make a call or to communicate with anyone in the
outside world. At some point Kevin made the now infamous statement I dont even eat rice in
response to their accusations and allegations about Ricin. Kevin offered to take a polygraph
examination and that offer was ignored. Kevin suggested perhaps he should talk to a lawyer and
that suggestion was discouraged.
9.
As the evening wore on, more and more people interrogated Kevin. Each successive one
was more forceful than the one before. At some point a federal agent told Kevin there was a
young woman in the hospital clinging to life and that she would die if Kevin did not tell him
what was in the poison. This, of course, was just an outright lie. There is no other way to
characterize that line of questioning other than to say that the United States Government, in an
effort to obtain a confession that they believed was necessary to their case, lied and lied and lied
some more.
10.
Kevin was in the unenviable position of being accused of a horrific crime he did not
commit. He was told countless times he would spend the rest of his life in prison. He was
berated and chastised, harassed and lied to. The agents used everything short of water boarding
to force a confession from Kevin Curtis. . . .all based on something he posted on Facebook. To
believe Kevin Curtis was guilty, one would have to believe that he didnt care if he got caught
and that he wanted to get caught.
11.
Despite this gargantuan leap of logic and reality and based on a substandard investigation,
the government persisted. Having set their jackboot clad feet on a course of action, they were
unwilling to turn around. On Thursday morning, April 18, 2013, Kevin appeared before United
States Magistrate Judge S. Allan Alexander, charged as a terrorist trying to kill the President and
other government officials. The government asked that he be detained without bond. The Judge
signed a temporary detention order and set the next hearing for Friday, April 19, 2013, at 3:00
p.m. The Judge initially mentioned setting the case for the following Monday to give the defense
adequate time to prepare. However, counsel undersigned asked the Court to set it sooner rather
than later and the Court obliged.
Defense Counsel Meets With The Government and Solves the Case
12.
Following the meeting counsel for Kevin Curtis met with Assistant United States
Attorney Chad Lamar concerning the charges against Kevin. AUSA Lamar was very confident
that Kevin was guilty. He informed counsel undersigned that they would be introducing proof
that Kevin had made threats against a church and that he had no doubt that Kevin was guilty as
charged. Counsel undersigned Neilson wrote a name on a piece of paper and passed it to AUSA
Lamar with the strong suggestion that the government investigate the person listed. The name, of
course, was James Everett Dutcshke, the true perpetrator of the crime. AUSA Lamar laughed
and said the government was well aware of Dutschke but they had their guy.
13.
Friday April 19th was a lovely Spring day in Oxford, Mississippi, home to the countrys
Most Beautiful College Campus, the University of Mississippi. Among blooming flowers and
exercising co-eds, the media began to assemble. Associated Press picked up the release from the
FBI that FBI Special Agents arrested Paul Kevin Curtis, the individual believed to be
responsible for the mailings of the three letters sent through the U.S. Postal Inspection Service
which contained a granular substance that preliminarily tested positive for ricin. Counsel
undersigned was preparing for the afternoon hearing when they were summoned to the federal
Counsel appeared as directed and met with Judge Mills and AUSA Chad Lamar. AUSA
Lamar brought a motion and a proposed order in the Curtis case that would subject Kevin Curtis
to a psychological evaluation in the custody of the Bureau of Prisons. Counsel undersigned
objected to the motion. The government argued that Kevin was unbalanced and not mentally
stable. AUSA Lamar stated repeatedly that the government merely wanted to protect the rights
of Mr. Curtis. Judge Mills noted that Kevin Curtis had counsel who was able to determine if he
was competent to understand the proceedings, and further, that it was the duty of his counsel to
insure his rights were protected.
15.
The government was unpersuaded that counsel undersigned was able to protect Kevins
interests and insisted on a hearing to determine whether or not Kevin should be subjected to a
psychological evaluation courtesy of the Bureau of Prisons and the United States Government.
Judge Mills advised the government that he would be happy to hear their petition on a day the
following week. The government insisted that the probable cause hearing be continued until
such time as a hearing could be held to determine whether Kevin Curtis was competent to
understand the proceedings against him. Counsel undersigned assured the government and the
Court that they had conferred with Kevin at length as well as his friends and family members and
that they were confident of his competence and ability to understand the proceedings against him.
16.
The government continued to insist that the probable cause hearing be continued
indefinitely until the Court could hold a hearing to determine competence. Judge Mills declined
to accept the governments position and was clear that he would not intervene and stop the
hearing scheduled by Magistrate Alexander. Judge Mills made the statement that even if the
government was correct and Kevin was incompetent that even incompetent defendants are
entitled to due process.
The Motion to Continue
17.
The Judge dismissed the meeting and counsel undersigned continued preparing for the
afternoon probable cause hearing. Shortly thereafter counsel received a Motion to Continue the
probable cause hearing. The motion was received via the electronic docketing program of the
United States District Court and was a complete surprise to the defense. Counsel undersigned
spoke with AUSA Lamar several times on Thursday, April 18, 2013, including a conference at
the U.S. Attorneys office referenced, supra, when AUSA Lamar was advised that James Everett
Dutschke was the likely perpetrator of the crime. Counsel spent well over an hour with AUSA
Lamar in judges chambers as AUSA Lamar argued vehemently that the probable cause hearing
must be continued on the basis that Kevin Curtis was incompetent to understand the proceeding.
The government never indicated a lack of readiness for the probable cause hearing. To the
contrary, Mr. Lamar was very clear in his certainty that Kevin Curtis was the terrorist who
committed these heinous acts and that the government could and would prove it.
18.
The governments motion urged the Court to delay the proceedings so that the hearing
could be as complete and thorough as possible. The motion referenced subpoenas that needed
to be answered and searches that needed to be conducted or were not complete. Defense counsel
adamantly opposed the motion in a written response as well as at the time of the hearing.
The Judge Denies the Governments Motion
19.
When the hearing commenced the government again urged the Court to delay the
proceedings against Kevin Curtis. The government stated more time was needed to prepare their
case. The Court disagreed and made note of the fact that the governments burden of proof was
extremely low and that all the parties were there and available for the hearing; therefore the
hearing would proceed as scheduled.
20.
The governments witness was FBI Special Agent Brandon Grant. Agent Grant is a
very capable agent with impeccable credentials and extensive experience in the field of
terrorism. Agent Grant was adamant that Kevin Curtis was the perpetrator of the crimes and in
fact, he stated that he was 100% confident of Kevins guilt.
The Hearing Cannot be Concluded
21.
The hearing was well underway but by no means complete as the clock edged toward the
6:00 p.m. hour. The Court noted that it was highly unlikely the hearing could be completed that
evening. The Court expressed dismay that Kevin Curtis would remain in jail over the weekend
without a resolution to the complaint, but it was clear to everyone that there was simply no other
alternative. Furthermore, the government advised the Court that searches were ongoing at
Kevins home and that the result of those searches would be available on Monday.
22.
Kevin was frightened by the prospect of spending the weekend in jail. He had been taken
from his quiet life and thrust into the spotlight as the man who tried to kill the President, a United
States Senator and a local judge. He was concerned for his safety in jail, as well as the safety of
his family. Counsel undersigned shared his concerns but were secure in the fact that the ongoing
searches would reveal what they already knew: Kevin Curtis was an innocent man.
The Weekend
23.
Over the weekend counsel undersigned made several efforts to speak with representatives
of the government. Defense counsel sought information about the searches that were being
conducted at Kevin Curtiss home. The government represented to the Court that the searches
were ongoing and would be probative in determining probable cause against Kevin Curtis. The
government did not respond to counsel undersigneds requests for information concerning the
searches. Counsel undersigned sent an investigator to the Curtis home on Saturday to check the
status of the searches. The house and the surrounding area were deserted. Despite no official
word of the futility of the search, logic dictated that had ricin or any hazardous materials been
found the property would be cordoned off and covered with decontamination teams as well as
evidence collection teams.
24.
Counsel undersigned reached out to the government numerous times over the weekend to
discuss the circumstances and how the matter could be concluded. Counsel was confident that
the government would recognize the serious lack of evidence against Kevin Curtis and release
him immediately. Counsel had advised Kevin that his release would not stop the investigation
against him. To the contrary, the investigation could (and would) continue with the full forces
and resources of the United States government. The difference would be that his liberty would
not be compromised or denied during the investigation.
25.
On April 21, 2013, at approximately 10:30 p.m., counsel undersigned spoke with AUSA
Lamar by telephone. AUSA Lamar acknowledged that the searches of Kevins home and
computers had yielded no evidence of ricin preparation or manufacturing. Counsel undersigned
truly believed that the government would recognize its mistake and release Kevin Curtis. She
relayed to AUSA Lamar and later to United States Attorney Felicia Adams that Kevin Curtis was
willing to accept that mistakes were made in the interest of national security and let bygones be
bygones. At that point Kevin and his defense team were willing to give the government the
benefit of the doubt and accept that the arrest had been in good faith. The government refused to
consider the possibility of a mistake and AUSA Lamar advised counsel undersigned that they
were proceeding with their theory that Kevin Curtis mailed ricin to the President of the United
States, Senator Roger Wicker and Justice Court Judge Sadie Holland.
26.
Counsel undersigned had one question: what was the proof? AUSA Lamar advised that
the government had strong evidence that Kevin Curtis had committed the crimes. Specifically
AUSA Lamar explained that tests had been conducted on the envelopes containing the suspected
ricin. According to AUSA Lamar, the envelopes contained an imprint of Kevin Curtiss address
in the upper left hand corner. AUSA Lamar explained that experts would testify that the
particular envelopes had been in a stack of envelopes and that Kevin Curtiss address had been
written in the upper left hand corner of envelopes at the top of the stack. According to AUSA
Lamar, this evidence solidly linked Kevin Curtis to the envelopes used in the attack.
The Hearing Resumes
27.
Court resumed on Monday with FBI Special Agent Brandon Grant returning to the
witness stand for cross examination. Throughout the morning he maintained he was 100
percent positive that Kevin Curtis was the perpetrator of the crime. Despite this confidence, he
readily admitted there was not a shred of evidence that linked Kevin Curtis to the crime. Agent
Grant and the government focused on Kevins mental state - alleging that Kevin was possibly bipolar and mentally unstable. Additionally, the envelope evidence never materialized yet the
government refused to back away from their position and would not consider a dismissal of the
charges.
The Government Seeks Yet Another Delay
28.
After the noon recess Kevin Curtis was returned to the courtroom where he was able to
conference with counsel undersigned. AUSA Lamar and his colleagues were not in the
courtroom. Defense counsel was called to judges chambers where several government attorneys
were gathered, including AUSA Lamar and (then) Criminal Division Chief John Marshall
Alexander and First Assistant United States Attorney Bill Martin. AUSA Lamar stated that the
government needed to stop the hearing due to some evidence uncovered that could be potentially
beneficial to Kevin Curtis. However, the government wanted to keep Kevin Curtis in custody
while they investigated the fact that he was innocent. The government did not want to share their
information and the defense team was extremely skeptical. However, based solely on the
statement of AUSA Lamar, counsel undersigned agreed to the continuance as long as the matter
would be resolved the next morning.
The Morning of April 23, 2013 and the Demands of the Criminal Chief
29.
On April 23, 2013, counsel again gathered in Magistrate Alexanders chambers. The
government, led by John Marshall Alexander, informed the Court that they were unwilling to
share the new evidence and they again wanted to delay the proceedings. Counsel undersigned
objected and stated that unless they were prepared to release Kevin Curtis immediately that the
hearing would resume. It was abundantly clear to the most casual observer that the governments
case had failed to materialize and that there was no credible evidence to implicate Kevin Curtis.
Yet AUSA Alexander demanded that Kevin remain incarcerated.
30.
Counsel undersigned had learned through various resources that the government knew as
early as Friday that there was no trace of ricin found in Kevin Curtiss home, his car, or his
possessions. The government was well aware of the fact that not a single reference to ricin
appeared on any computer owned or possessed by Kevin Curtis. The government was unable to
find any yellow paper (similar to the yellow paper sent to the officials) in Kevin Curtiss
possessions, nor were they able to locate any place where Kevin Curtis could have made copies
of the letters. They certainly knew that Kevin Curtis did not have a printer or a copier in his
home. They interviewed/interrogated/harassed area library employees as well as employees of
local print shops and office supply businesses and the government came up completely empty.
Despite the glaring lack of evidence, the Chief of the Criminal Division of the United States
Attorneys office showed up on Tuesday, April 23, 2013, and demanded that Kevin Curtis be
held without bail unless he agreed to the following conditions:
1.
2.
3.
Kevins defense counsel declined and insisted that the hearing resume or the charges be
dismissed and Kevin released immediately. Criminal Chief Alexander stated That is our offer.
If he wants out, he will take it. Counsel then excused themselves to go and visit with their
client in preparation for the hearing.
31.
While visiting with Kevin in the U.S. Marshals holding facility counsel was summoned
into the hallway by AUSA Chad Lamar. AUSA Lamar stated We will release Kevin. Will you
give me until 5:00 to file the official motion to dismiss? Kevin and his defense team was
exasperated by the actions of the government. It had been clear since Friday that the government
had major concerns about their case. It was obvious no later than Saturday that Kevin Curtis was
completely innocent of the charges against him. Yet the government had persisted in their quest
to convict this man, or at the very least, to subject him to an inpatient mental health evaluation
while in custody of the United States Bureau of Prisons.
32.
Counsel undersigned had quite literally begged United States Attorney Felicia Adams to
simply release Kevin Curtis while the investigation was ongoing as he was not a threat to the
community at large or any one person individually. Counsel repeated her request in two separate
written communications between April 19th and April 22nd, advising that Kevin Curtis was
presuming the government was acting in good faith and that mistakes were made. As of the
filing of this complaint and some two years later, Ms. Adams has not shown the professional
courtesy to respond or even acknowledge the letters, let alone say anything about the travesty her
office brought upon the life of Kevin Curtis.
The Release of Kevin Curtis
33.
Kevin Curtiss only objective on April 23, 2013, was to be let out of the cage the
government had shoved him as if he were a dangerous animal. He simply wanted to go home,
find his dog, and return to his life. Only due to the trust of AUSA Lamar was counsel
undersigned willing to allow the government the concession of a 5:00 motion to dismiss.
Counsel undersigned was (and continues to be) perplexed by the fact that the chief of the
criminal division of the United States Attorneys office was unwilling to simply release an
innocent man, and insisted on the continued incarceration knowing that person was innocent and
misled counsel undersigned as well as the Court. Be that as it may, counsel undersigned agreed
to the offer of AUSA Lamar. Kevin was immediately released from the custody of the United
States Marshals and AUSA Lamar followed through with his word and filed the motion to
dismiss before the 5:00 p.m. hour. The order of dismissal was entered without prejudice,
presumably to allow the investigation against Kevin Curtis to continue.
The Arrest of Dutschke
34.
The true perpetrator was arrested a few days after Kevins release. To no ones surprise,
the identity of the criminal was the name given to AUSA Lamar by defense counsel Hal Neilson
on April 18, 2013 - James Everett Dutschke. To the surprise of Kevin Curtis, it appeared that the
government actively investigated Dutschke without arresting him, quite unlike the treatment
bestowed upon Kevin. Furthermore, it was clear the government had been in possession of
evidence implicating Dutschke since at least April 19, 2013. Yet four days later, on April 23,
2013, the division chief of the criminal division of the United States Attorneys office demanded
that Kevin Curtis remain in the custody of the United States.
The Aftermath
35.
Kevin Curtis was released to a different world from the one he was taken from a week
before. He was suddenly cast into the national and global media as a terrorist. His home was
destroyed, his possessions were ransacked and taken. He was placed on the no fly list and was
subjected to humiliating delays and searches at the airport.
36.
Kevin was unable to have peace and quiet in his own home as he was bombarded with
strangers gawking and asking questions. His music career came to a screeching halt and he was
unable to book events. The government has refused over and over to remove the language
without prejudice from the order of dismissal. Kevin continues to suffer from extreme
emotional distress caused by his false arrest and wrongful incarceration.
CAUSES OF ACTION:
37.
Plaintiff adopts all preceding facts, statement and allegations as if fully incorporated
therein. The United States of America, by and through its agents, officers and representatives,
all or some, in whole or in part, conspired with one another, while under color of law, to deny
Paul Kevin Curtis the rights guaranteed by the United States Constitution, particularly
Amendments One, Four and Six.
The United States of America, by and through its agents, officers and representatives,
acting under color of law, caused injury to Paul Kevin Curtis in that he was denied his right to be
free from unlawful search and seizure, he was subjected to wrongful and false prosecution, false
Plaintiff suffered physical, mental, emotional and financial damages through the actions
of the Defendant, specifically, through the denial of his constitutionally protected rights to be
safe and secure in his life/home without unwarranted government intrusion.
40.
At all times material hereto, the Defendant was vested by with the authority and the non-
delegable responsibility of adhering to, complying with, and enforcing the laws of the United
States of America. Consequently, while acting under color of law, the Defendant commenced to
engage in a course of conduct and to implement a policy, custom, use, plan, or practice wherein
the rights, privileges, or immunities of Paul Kevin Curtis were violated.
41.
As a direct and proximate result of the aforementioned customs, policies and/or practices
of the said Defendant, Paul Kevin Curtis suffered injuries and damages as alleged herein.
B.
C.
Pre-judgment interest;
D.
E.
Plaintiff demands trial by jury, and respectfully prays this Honorable Court for such other
and further relief as may be just.
Respectfully submitted,
/s/Christi R. McCoy
Christi R. McCoy, MSB#9986
/s/Philip H. Neilson
Philip H. Neilson, MSB#3798
Christi R. McCoy
MCCOY LAW FIRM
1739 University Avenue, No. 252
Oxford, Mississippi 38655
Telephone:
662-513-6366
E-Mail: [email protected]
Attorneys for Paul Kevin Curtis
Philip H. Neilson
NEILSON LAW FIRM
706A Jackson Avenue
Oxford, Mississippi 38655
Telephone:
662-832-8070
E-Mail: [email protected]
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