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Jerome Roman v. City of New York, The NYPD, and Detective David Terrell
Jerome Roman v. City of New York, The NYPD, and Detective David Terrell
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JEROME ROMAN, :UNITED STATES DISTRICT COURT
:SOUTHERN DISTRICT OF NEW YORK
Plaintiff(s), :
: CASE No.:_______________
against :
: CIVIL ACTION
:
THE CITY OF NEW YORK, DETECTIVE : COMPLAINT
DAVID TERRELL, and JOHN DOES :
1-5, :
: PLAINTIFF DEMANDS
: TRIAL BY JURY
Defendant(s). :
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JURISDICTION
2. The jurisdiction of this Court is invoked under 28 U.S.C.
1343(3), this being an action authorized by law to redress
the deprivation of rights secured under color of state and
city law, statute, ordinance, regulation, custom and usage
of a right, privilege and immunity secured to the plaintiff
by the Fourth, Fifth and Fourteenth Amendments to the
Constitution of the United States. Jurisdiction of this
court exists pursuant to 42 USC 1983 and under the Fourth,
Fifth, and Fourteenth Amendments to the United States
Constitution.
3. As the deprivation of rights complained of herein occurred
within the Southern District of New York, venue is proper
in this district pursuant to 28 U.S.C. 1391 (b) and (c).
PARTIES
4. Plaintiff, Jerome Roman, is currently 22 years of age, and
resides in the Bronx, within the City and State of New
York.
5. The actions which form the underlying basis for this case
all took place in the County of Bronx, within the
jurisdiction of the Southern District of New York.
6. Defendants Detective David Terrell and Police Officers John
Does 1 to 5, are police officers for the City of New York
acting under color of state law. At all material times, the
defendant Police Officers were employed at the 42nd precinct
of the New York City Police Department, which covers the
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unconstitutional practices:
a. Wrongfully arresting individuals on the pretext that
they are engaged in illegal or criminal conduct;
b. manufacturing evidence against individuals allegedly
involved in illegal or criminal conduct;
c. unlawfully searching detainees and/or their property in
the absence of any reasonable suspicion that said
individuals were concealing weapons or contraband;
d. arresting innocent persons in order to meet
"productivity" goals (i.e. arrest quotas); and
e. wrongfully and unreasonably brutalizing innocent members
of the public, despite the lack of probable cause to do so.
187. The aforesaid event was not an isolated incident. The City
and its police commissioner has been aware for some time,
from lawsuits, notices of claim, complaints filed with the
Civilian Complaint Review Board, and judicial rulings
suppressing evidence and finding officers incredible as a
matter of law, that a disturbing number of their police
officers unlawfully search and seize citizens, bring
charges against citizens with no legal basis, perjure
themselves in charging instruments and testimony, and fail
to intervene in and report the obviously illegal actions of
their fellow officers. Nevertheless, the City and its
police commissioner have allowed policies and practices
that allow the aforementioned to persist.
188. For example, the well documented failures of the Civilian
Complaint Review Board (the CCRB), a City agency, to
substantiate obviously meritorious citizen complaints have
gone uncorrected. The CCRB regularly finds complainants
lack credibility based on the fact that such complainants
have also brought lawsuits to remedy the wrongs they have
experienced, a practice that often results in not
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/s/
Chukwuemeka Nwokoro, Esq.
Nwokoro & Scola, Esquires
Attorney for Plaintiff
44 Wall Street, Suite 1218
New York, New York 10005
Tel. (212) 785-1060
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