6 .. lo o 1 '6 - courthouse news servicethis is a civil rights action brought by the plaintiff,...

23
IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF ARKANSAS HOT SPRINGS DIVISION CANDACE PAIGE LYDON vs. cAsE No. \ lo O 1 MIKE MCCORMICK, individually and in his official capacity as Sheriff for Garland County, Arkansas; MARK CHAMBERLAIN, individually and in his official capacity as Chief Deputy Sheriff for Garland County, Arkansas; JASON LAWRENCE, individually and in his official capacity as Supervisory Officer for Garland County, Arkansas; STEVEN ELROD, individually and in his official capacity as Chief Deputy of Corrections; DEPUTY JARRETHM, individually and official capacity as an Officer for the Garland County Sheriff's Depament; JARRET CANTRELL, Badge No. 149, individually and in his US DiSI COT :J WESTE DIST S ED AUG 2 9 2018 UG F. YOG, Q By PL�- official capacity as an Officer for the Hot Springs Police Depament; KAY DUKES, LPN, individually and in her official capacity as Nurse for the Garland County Detention Center; GARLAND COUNTY, ARKANSAS; and JOHN DOE I, JOHN DOE II, JOHN DOE Ill, JOHN DOE IV, JOHN DOE V, JOHN DOE VI, JOHN DOE VII, JOHN DOE VIII, in their individual and official capacity DEFENDANTS COMPLAINT COMES NOW, the Plaintiff, CANDACE PAIGE LYOON, by and through her attorneys, Hurst Law Group, through Justin B. Hurst, and for her Complaint against the Defendants herein, she states and alleges: I. INTRODUCTION 1. This is a civil rights action brought by the Plaintiff, Candace Paige Lydon, to seek relief for the Defendants' violations of her rights secured by the Civil Rights Act of 1964, 42 U.S.C. § 1983; 42 U.S.C. § 1988 and the rights secured by the Fifth, Fourth, Eighth and Fourteenth Amendments to the Page 1 of 23 Case 6:18-cv-06078-SOH-BAB Document 1 Filed 08/29/18 Page 1 of 23 PageID #: 27

Upload: others

Post on 24-May-2020

0 views

Category:

Documents


0 download

TRANSCRIPT

Page 1: 6 .. lo O 1 '6 - Courthouse News ServiceThis is a civil rights action brought by the Plaintiff, Candace Paige Lydon, to seek relief for the Defendants' violations of her rights secured

IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF ARKANSAS

HOT SPRINGS DIVISION

CANDACE PAIGE LYDON

vs. cAsE No. \'6 .. lo O 1 '6 MIKE MCCORMICK, individually and in his official capacity as Sheriff for Garland County, Arkansas; MARK CHAMBERLAIN, individually and in his official capacity as Chief Deputy Sheriff for Garland County, Arkansas; JASON LAWRENCE, individually and in his official capacity as Supervisory Officer for Garland County, Arkansas; STEVEN ELROD, individually and in his official capacity as Chief Deputy of Corrections; DEPUTY JARRETHM, individually and official capacity as an Officer for the Garland County Sheriff's Department; JARRET CANTRELL, Badge No. 149, individually and in his

US DiSTRICT COURT :J WESTERN DIST ARKANSAS

FILED

AUG 2 9 2018 DOUGLAS F. YOUNG, Qedc --rBy

PL�-

official capacity as an Officer for the Hot Springs Police Department; KAY DUKES, LPN, individually and in her official capacity as Nurse for the Garland County Detention Center; GARLAND COUNTY, ARKANSAS; and JOHN DOE I, JOHN DOE II, JOHN DOE Ill, JOHN DOE IV, JOHN DOE V, JOHN DOE VI, JOHN DOE VII, JOHN DOE VIII, in their individual and official capacity DEFENDANTS

COMPLAINT

COMES NOW, the Plaintiff, CANDACE PAIGE L YOON, by and through her

attorneys, Hurst Law Group, through Justin B. Hurst, and for her Complaint against the

Defendants herein, she states and alleges:

I.

INTRODUCTION

1. This is a civil rights action brought by the Plaintiff, Candace Paige Lydon, to

seek relief for the Defendants' violations of her rights secured by the Civil

Rights Act of 1964, 42 U.S.C. § 1983; 42 U.S.C. § 1988 and the rights

secured by the Fifth, Fourth, Eighth and Fourteenth Amendments to the

Page 1 of 23

Case 6:18-cv-06078-SOH-BAB Document 1 Filed 08/29/18 Page 1 of 23 PageID #: 27

Page 2: 6 .. lo O 1 '6 - Courthouse News ServiceThis is a civil rights action brought by the Plaintiff, Candace Paige Lydon, to seek relief for the Defendants' violations of her rights secured

Case 6:18-cv-06078-SOH-BAB Document 1 Filed 08/29/18 Page 2 of 23 PageID #: 28

Page 3: 6 .. lo O 1 '6 - Courthouse News ServiceThis is a civil rights action brought by the Plaintiff, Candace Paige Lydon, to seek relief for the Defendants' violations of her rights secured

Case 6:18-cv-06078-SOH-BAB Document 1 Filed 08/29/18 Page 3 of 23 PageID #: 29

Page 4: 6 .. lo O 1 '6 - Courthouse News ServiceThis is a civil rights action brought by the Plaintiff, Candace Paige Lydon, to seek relief for the Defendants' violations of her rights secured

Case 6:18-cv-06078-SOH-BAB Document 1 Filed 08/29/18 Page 4 of 23 PageID #: 30

Page 5: 6 .. lo O 1 '6 - Courthouse News ServiceThis is a civil rights action brought by the Plaintiff, Candace Paige Lydon, to seek relief for the Defendants' violations of her rights secured

Case 6:18-cv-06078-SOH-BAB Document 1 Filed 08/29/18 Page 5 of 23 PageID #: 31

Page 6: 6 .. lo O 1 '6 - Courthouse News ServiceThis is a civil rights action brought by the Plaintiff, Candace Paige Lydon, to seek relief for the Defendants' violations of her rights secured

Case 6:18-cv-06078-SOH-BAB Document 1 Filed 08/29/18 Page 6 of 23 PageID #: 32

Page 7: 6 .. lo O 1 '6 - Courthouse News ServiceThis is a civil rights action brought by the Plaintiff, Candace Paige Lydon, to seek relief for the Defendants' violations of her rights secured

Case 6:18-cv-06078-SOH-BAB Document 1 Filed 08/29/18 Page 7 of 23 PageID #: 33

Page 8: 6 .. lo O 1 '6 - Courthouse News ServiceThis is a civil rights action brought by the Plaintiff, Candace Paige Lydon, to seek relief for the Defendants' violations of her rights secured

Case 6:18-cv-06078-SOH-BAB Document 1 Filed 08/29/18 Page 8 of 23 PageID #: 34

Page 9: 6 .. lo O 1 '6 - Courthouse News ServiceThis is a civil rights action brought by the Plaintiff, Candace Paige Lydon, to seek relief for the Defendants' violations of her rights secured

Case 6:18-cv-06078-SOH-BAB Document 1 Filed 08/29/18 Page 9 of 23 PageID #: 35

Page 10: 6 .. lo O 1 '6 - Courthouse News ServiceThis is a civil rights action brought by the Plaintiff, Candace Paige Lydon, to seek relief for the Defendants' violations of her rights secured

Case 6:18-cv-06078-SOH-BAB Document 1 Filed 08/29/18 Page 10 of 23 PageID #: 36

Page 11: 6 .. lo O 1 '6 - Courthouse News ServiceThis is a civil rights action brought by the Plaintiff, Candace Paige Lydon, to seek relief for the Defendants' violations of her rights secured

Case 6:18-cv-06078-SOH-BAB Document 1 Filed 08/29/18 Page 11 of 23 PageID #: 37

Page 12: 6 .. lo O 1 '6 - Courthouse News ServiceThis is a civil rights action brought by the Plaintiff, Candace Paige Lydon, to seek relief for the Defendants' violations of her rights secured

Case 6:18-cv-06078-SOH-BAB Document 1 Filed 08/29/18 Page 12 of 23 PageID #: 38

Page 13: 6 .. lo O 1 '6 - Courthouse News ServiceThis is a civil rights action brought by the Plaintiff, Candace Paige Lydon, to seek relief for the Defendants' violations of her rights secured

Case 6:18-cv-06078-SOH-BAB Document 1 Filed 08/29/18 Page 13 of 23 PageID #: 39

Page 14: 6 .. lo O 1 '6 - Courthouse News ServiceThis is a civil rights action brought by the Plaintiff, Candace Paige Lydon, to seek relief for the Defendants' violations of her rights secured

Case 6:18-cv-06078-SOH-BAB Document 1 Filed 08/29/18 Page 14 of 23 PageID #: 40

Page 15: 6 .. lo O 1 '6 - Courthouse News ServiceThis is a civil rights action brought by the Plaintiff, Candace Paige Lydon, to seek relief for the Defendants' violations of her rights secured

Case 6:18-cv-06078-SOH-BAB Document 1 Filed 08/29/18 Page 15 of 23 PageID #: 41

Page 16: 6 .. lo O 1 '6 - Courthouse News ServiceThis is a civil rights action brought by the Plaintiff, Candace Paige Lydon, to seek relief for the Defendants' violations of her rights secured

Case 6:18-cv-06078-SOH-BAB Document 1 Filed 08/29/18 Page 16 of 23 PageID #: 42

Page 17: 6 .. lo O 1 '6 - Courthouse News ServiceThis is a civil rights action brought by the Plaintiff, Candace Paige Lydon, to seek relief for the Defendants' violations of her rights secured

Case 6:18-cv-06078-SOH-BAB Document 1 Filed 08/29/18 Page 17 of 23 PageID #: 43

Page 18: 6 .. lo O 1 '6 - Courthouse News ServiceThis is a civil rights action brought by the Plaintiff, Candace Paige Lydon, to seek relief for the Defendants' violations of her rights secured

Case 6:18-cv-06078-SOH-BAB Document 1 Filed 08/29/18 Page 18 of 23 PageID #: 44

Page 19: 6 .. lo O 1 '6 - Courthouse News ServiceThis is a civil rights action brought by the Plaintiff, Candace Paige Lydon, to seek relief for the Defendants' violations of her rights secured

Case 6:18-cv-06078-SOH-BAB Document 1 Filed 08/29/18 Page 19 of 23 PageID #: 45

Page 20: 6 .. lo O 1 '6 - Courthouse News ServiceThis is a civil rights action brought by the Plaintiff, Candace Paige Lydon, to seek relief for the Defendants' violations of her rights secured

Case 6:18-cv-06078-SOH-BAB Document 1 Filed 08/29/18 Page 20 of 23 PageID #: 46

Page 21: 6 .. lo O 1 '6 - Courthouse News ServiceThis is a civil rights action brought by the Plaintiff, Candace Paige Lydon, to seek relief for the Defendants' violations of her rights secured

Case 6:18-cv-06078-SOH-BAB Document 1 Filed 08/29/18 Page 21 of 23 PageID #: 47

Page 22: 6 .. lo O 1 '6 - Courthouse News ServiceThis is a civil rights action brought by the Plaintiff, Candace Paige Lydon, to seek relief for the Defendants' violations of her rights secured

Case 6:18-cv-06078-SOH-BAB Document 1 Filed 08/29/18 Page 22 of 23 PageID #: 48

Page 23: 6 .. lo O 1 '6 - Courthouse News ServiceThis is a civil rights action brought by the Plaintiff, Candace Paige Lydon, to seek relief for the Defendants' violations of her rights secured

Case 6:18-cv-06078-SOH-BAB Document 1 Filed 08/29/18 Page 23 of 23 PageID #: 49