in the court of common pleas summit county, ohio … · 2018. 5. 11. · 4 . akron police...

IN THE COURT OF COMMON PLEAS

SUMMIT COUNTY, OHIO

LISA CARSWELL, AS

ADMINISTRATRIX OF THE ESTATE

OF XAVIER MCMULLEN, AND

INDIVIDUALLY AS HIS MOTHER

Plaintiff,

v.

CITY OF AKRON, OHIO

146 South High Street, Suite 130

Akron, Ohio 44308;

and

AKRON POLICE DEPARTMENT

217 South High Street

Akron, Ohio 44308;

and


CAPTAIN BRIAN SIMCOX

(Individually and in his official capacity as

Captain of the Akron Police Department)


Akron, Ohio 44308;

and


SERGEANT JAMES P. DONOHUE

#1122


Sergeant of the Akron Police Department)


Akron, Ohio 44308;

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CASE NO.:

JUDGE:

COMPLAINT

(Complaint for Wrongful Death)

(Jury Demand Endorsed Hereon)

CV-2018-05-2026 CMCO05/10/2018 11:59:33 AMMCCARTY, ALISON E. of 21

Sandra Kurt, Summit County Clerk of Courts

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SERGEANT BRENT BAUKNECHT

#1285


Sergeant of the Akron Police Department)


Akron, Ohio 44308;

and


OFFICER ASHLEY CRANSTON #1373

(Individually and in her official capacity as

an Officer of the Akron Police Department)


Akron, Ohio 44308;

and


OFFICER BRIAN CURTIN #1311




Akron, Ohio 44308;

and


OFFICER UTOMHIN OKOH #1413




Akron, Ohio 44308;

and


OFFICER DEVIN RAY #1444




Akron, Ohio 44308;

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OFFICER JANUSZ JASKOLKA #1284




Akron, Ohio 44308;

and


OFFICER TIMOTHY SHMIGAL #1380




Akron, Ohio 44308;

and


OFFICER JACOB FANGMANN #1368




Akron, Ohio 44308;

and


OFFICER DEVLIN SAUNIER #1420




Akron, Ohio 44308;

and


OFFICER DERRICK JACKSON #1367




Akron, Ohio 44308

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OFFICER MICHAEL RADAK #1294




Akron, Ohio 44308

and


JOHN/JANE DOES 1-5


Akron, Ohio 44308

Defendants.

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Plaintiff Lisa Carswell as Administratrix of the Estate of Xavier McMullen and

individually as his mother (“Plaintiff Carswell”), for her Complaint against Defendants City of

Akron et al., by and through undersigned counsel, states as follows:

PARTIES

1. Plaintiff Carswell is the mother to Xavier McMullen (“Xavier”), deceased, and was

appointed Administratrix of the Estate of Xavier McMullen by the Probate Court of

Summit County, Ohio, Case No. 2018 ES 00125, on February 5, 2018.

2. Plaintiff Carswell is a citizen of the United States and is a resident of Ohio, and is, at all

times relevant to this Complaint, residing at 997 Florida Avenue, Akron, Ohio, 44314.

3. Defendant City of Akron (“Akron”) is now and was at all relevant times a municipal

corporation, organized and existing under and by virtue of the laws of the State of Ohio.

4. Now and at all relevant times, Akron operated, managed, maintained, supervised and

controlled the Akron Police Department (“APD”).



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5. Defendant APD is now and was at all relevant times an agency of Akron with its’

principal place of business at mailing address 217 South High Street, Akron, Ohio,

44308. (Akron and APD are collectively referred to as “APD”).

6. Defendant Captain Brian Simcox (hereinafter “Defendant Simcox”) was employed by

APD as a captain and was acting within the course and scope of his employment with

APD during all events described herein.

7. Defendant Sergeant James P. Donohue (hereinafter “Defendant Donohue”) was

employed by APD as a sergeant and was acting within the course and scope of his

employment with APD during all events described herein.

8. Defendant Sergeant Brent Bauknecht (hereinafter “Defendant Bauknecht”) was

employed by APD as a sergeant and was acting within the course and scope of his

employment with APD during all events described herein.

9. Defendant Officer Ashley Cranston (hereinafter “Defendant Cranston”) was employed

by APD as an officer and was acting within the course and scope of her employment

with APD during all events described herein.

10. Defendant Officer Brian Curtin (hereinafter “Defendant Curtin”) was employed by APD

as an officer and was acting within the course and scope of his employment with APD

during all events described herein.

11. Defendant Officer Utomhin Okoh (hereinafter “Defendant Okoh”) was employed by

APD as an officer and was acting within the course and scope of his employment with




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12. Defendant Officer Devin Ray (hereinafter “Defendant Ray”) was employed by APD as

an officer and was acting within the course and scope of his employment with APD

during all events described herein.

13. Defendant Officer Janusz Jaskolka (hereinafter “Defendant Jaskolka”) was employed by



14. Defendant Officer Timothy Shmigal (hereinafter “Defendant Shmigal”) was employed

by APD as an officer and was acting within the course and scope of his employment with


15. Defendant Officer Jacob Fangmann (hereinafter “Defendant Fangmann”) was employed

by APD as an officer and was acting within the course and scope of his employment with


16. Defendant Officer Devlin Saunier (hereinafter “Defendant Saunier”) was employed by



17. Defendant Officer Derrick Jackson (hereinafter “Defendant Jackson”) was employed by



18. Defendant Officer Michael Radak (hereinafter “Defendant Radak”) was employed by





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19. Defendants John/Jane Doe’s (hereinafter “Defendant John/Jane Doe”) was employed by

APD as officers and was acting within the course and scope of his/her employment with


VENUE AND JURISDICTION

20. Venue lies in Summit County, Ohio pursuant to Civil Rule 3(B)(2) and (3) as Defendants

City of Akron’s and Akron Police Department’s principal place of business is located,

and the activities that gave rise to these claims occurred, in Summit County, Ohio.

21. Jurisdiction is proper to this Court to R.C. 2305.01.

FACTS

22. Plaintiff Carswell brings this wrongful death action individually as his mother and as the

Administratrix of the Estate of Xavier McMullen for the exclusive benefit of the heirs of

Xavier McMullen.

23. At all relevant times, Defendant APD was acting by, and through, its’ employees, agents,

managers, and/or supervisors.

10th Street Incident

24. On August 25, 2017, Defendant APD received a 911 call from Justin Robert Pressley

(“Pressley”) at 21:55 reporting that he and his girlfriend, Lisa Ann Riley (“Riley”), had

been robbed at gunpoint at 2274 10th Street, Akron, Ohio, 44314 (“10th Street”).

25. APD dispatched Defendants to the scene for an aggravated robbery.

26. Defendants Cranston and Curtin, officers, were working in Car #17 on August 25, 2017

and responded to 10th Street, arriving on scene at 22:02.

27. Defendants Ray and Okoh, officers, were working in Car #7 on August 25, 2017 and

responded to 10th Street.



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28. Defendants Jaskolka and Shmigal, officers, were working in Car #6 on August 25, 2017

and responded to 10th Street.

29. Defendant Donahue, sergeant, was working in Car #47 on August 25, 2017 and

responded to 10th Street.

30. Defendants Cranston and Curtin spoke to Pressley and Riley, who stated that Riley was

robbed by two or three males.

31. Pressley and Riley informed Defendant Curtin that one of the suspects had something

white on his hand.

32. With the help of Joshua Earl Greathouse (“Greathouse”), Pressley and Riley identified

Matthew Wayne Allen (“Allen”), eighteen, as the primary male.

33. Defendant Curtin took photos of the crime scene and of the victim’s injuries and also

recovered a piece of evidence related to the alleged robbery.

34. Defendant Curtin knew Allen and his current address from prior encounters.

35. Defendant Curtin radioed to other officers in the area to head to 2230 7th Street SW,

Akron, Ohio, 44314 (“7th Street”), where Allen and the one or two other suspects were

believed to be residing.

36. No medical support was ever dispatched for Pressley or Riley’s alleged injuries.

37. Neither Pressley, Riley or Greathouse ever identified Xavier as one of the suspects.

38. No witness ever stated that they saw the alleged three suspects run to 2230 7th Street,

Akron, Ohio.



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7th Street Incident

39. Defendants Curtin, Cranston, Ray, Okoh, Jaskolka, Shmigal and Donohue all headed to

7th Street after receiving a single identification from a witness who has since gone

missing and his whereabouts are unknown.

40. Defendants Ray, Okoh, Jaskolka, Shmigal and Donohue arrived first at the 7th Street

residence first.

41. Defendant Ray and Okoh parked their police vehicle, Car #7, three houses down from

the residence on 7th Street.

42. Defendant Ray and Okoh approached the residence from the rear and knocked on the

back door at 22:18, looking for the alleged suspects.

43. Defendant Okoh identified Allen and two other teenage boys through the rear window

of the home and watched them run to the basement.

44. Allen’s mother permitted access to the residence to Defendant Ray and Okoh.

45. Defendants Jaskolka and Donohue entered the residence through the front door.

46. Many witnesses reported Defendant Cranston’s inappropriate behavior while at the

scene.

47. Defendant Shmigal looked into the residence’s basement windows upon arrival.

48. Defendant Shmigal saw one of the suspects grab something off a couch and then stash it

behind a wall before running upstairs.

49. Defendant Donohue instructed everyone to move to the back of the residence.

50. Defendants Ray and Okoh called the three boys to the kitchen.

51. Allen came upstairs and was immediately placed in handcuffs by Defendant Okoh,

searched and then escorted to Car #7.



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52. Defendant Cranston reported that when she arrived at the scene the three boys were all

sitting at the kitchen table handcuffed.

53. Defendants Jaskolka and Shmigal went into the basement of the residence where the

other two boys were located.

54. Defendant Jaskolka only found Anthony W. Criss (“Criss”), eighteen, sitting in front of

a TV in the basement.

55. Criss had a soft white cast on his hand and, because of that injury, Defendant Jaskolka

put two sets of handcuffs on Criss and searched him.

56. Defendant Jaskolka handed Criss over to another officer.

57. Defendant Ray reported that Defendant Jaskolka and Shmigal came upstairs with Xavier

and Criss.

58. Xavier was wearing a white t-shirt, two pairs of shorts (sweat shorts and basketball

shorts), ankle socks and shoes.

59. Defendant Shmigal followed Defendant Jaskolka into the basement.

60. Defendant Donohue noted in his report that both Allen and Xavier came upstairs from

the basement upon their arrival.

61. Defendant Donohue told Defendant Ray to place Xavier under arrest.

62. Xavier asked Defendant Ray if he could sit down on a chair following his arrest.

63. Xavier was never Mirandized or searched leading up to/or at the time of his arrest by any

of the named officers herein.

64. Xavier was never searched after his arrest by any of the named officers herein.

65. Defendant Donohue specifically instructed Defendants Ray and Okoh to treat Allen and

Xavier as prisoners and put them in separate vehicles.



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66. Defendant Shmigal did not perform any arrest or search any of the suspects, nor did he

witness any of the arrests or any search incident to an arrest.

67. All three boys were taken out around the same time, with Xavier being placed into Car

#6 by Defendant Ray, Allen being placed into Car #7 by Defendant Okoh, and Criss

being placed into Car #17 by Defendant Cranston.

68. Defendant Donohue instructed Defendants Okoh and Ray to transport the suspects to the

station for interviews and possible photo array.

69. Allen was left in the police cruiser unmonitored by any officer.

70. Defendant Ray pulled Car #6, with Xavier inside, up closer to the residence.

71. Defendant Ray, or any officer named herein, never searched Xavier prior to placing him

in Car #6 in handcuffs.

72. No one eye witnessed any officer named herein search Xavier at any point during the

arrest prior to his death.

73. Defendant Ray allegedly took cigarettes, a lighter, and a phone from Xavier and put them

on top of the dashboard of Car #6, prior to the incident.

74. There is no footage from Car #6 to show Defendant Ray’s, or any other officers’,

interaction with Xavier.

75. Defendant Cranston confirmed with Defendant Okoh that he was going to remain outside

with the suspects while she re-entered the home.

76. Unfortunately, none of the named officers were with the three boys while they sat in

police cruisers.

77. Defendant Shmigal admits that Xavier had questions for him which he couldn’t answer.



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78. Defendant Okoh was instructed by Defendant Donohue to transport Allen to the

detective bureau.

79. Defendant Donohue stated that he instructed Defendants Ray and Okoh to transport the

prisoners to the detective bureau.

80. Defendant Ray joined Defendant Okoh in the transportation of Allen, leaving Criss and

Xavier completely unsupervised.

81. Defendant Saunier and Jackson arrived in Car #16 at 22:26 to help search the house.

82. Defendant Jaskolka, Shmigal, Saunier, and Jackson searched the house.

83. Defendant Shmigal went outside when he heard a loud pop, but never checked on Xavier.

84. Defendant Cranston heard a “loud pop”, but never checked on Xavier.

85. Defendant Jackson located a black Marksman BB-gun and a knife under a brick under

the front porch.

86. Defendant Cranston placed the items located by Defendant Jackson into the back of Car

#17, where Criss was placed.

87. Nearly twenty minutes after the “loud pop”, Defendant Jaskolka and Shmigal walked

back to their cruiser.

88. Defendant Jaskolka saw Xavier leaning forward in the cruiser.

89. The back-passenger window of Defendants Jaskolka and Shmigal’s police cruiser #6 was

blown out.

90. Defendant Cranston observed Xavier with a gun on his lap.

91. The gunshot wound to Xavier’s head was reported to dispatch at 23:08.

92. Defendant Cranston reported that Defendant Shmigal removed the gun, a .45 Caliber

JHP pistol, from Xavier’s lap.



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93. Defendant Jaskolka reported Defendant Shmigal removed the gun from Xavier’s hand.

94. At least twenty minutes elapsed between the “loud pop” heard by APD Defendants and

the discovery of Xavier’s body.

95. Xavier was found with his hands handcuffed behind his back.

96. For nearly ten minutes after discovery, no officer removed Xavier from the car, or

administered any emergency medical services to Xavier.

97. Defendant Jaskolka did not know that Xavier was in the back of his vehicle.

98. Defendant Captain Simcox came to the scene.

99. Defendant Bauknecht was asked to pull the IVS videos from Cars #6, #16, #1, #17.

100. No footage of Xavier’s shooting apparently exists as of this date.

101. APD has stated that no officer entered the rear of Car #6 between the time that Xavier

was placed in the cruiser and the time the incident was discovered, contradicting

Defendant Ray’s statements in regards to the incident.

102. APD also contradicts Defendant Shmigal’s report.

103. None of the officers were wearing body-cameras.

104. Xavier was pronounced dead on August 25, 2017, at 23:36.

105. APD officers are expected to follow the polices and procedures of the APD.

106. APD has a policy specific to transportation and prisoner control procedure, P-2007-010.

107. APD policy 2007-010 was implemented to ensure the safe and effective transportation

of all prisoners and to properly attend to immediate medical needs of injured persons

under arrest.

108. APD polices and procedure state, “No prisoner shall be placed into a vehicle until he has

been searched.”



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109. APD transporting officers are responsible for the safety of all prisoners.

110. APD officers are to remove all items from the rear seat area before placing a prisoner

into the rear seat area.

111. Xavier was not searched prior to being placed as a prisoner in the rear seat of Car #6.

112. The rear seat area was not clear of a firearm while Xavier was in the cruiser.

113. APD officers failed to follow policies and procedures on or about August 25, 2017.

114. APD officers failed to keep Xavier safe from harm as required by the APD policy and

procedures on or about August 25, 2017.

115. If APD officers had followed the policy and procedures, Xavier would not have suffered

a fatal gunshot wound on or about August 25, 2017.

COUNT ONE

(Wrongful Death Against all Defendants)

116. Plaintiff incorporates the allegations in Paragraph 1 through 115 above as if fully

rewritten and re-alleged herein.

117. As a direct and proximate result of Defendants’ failure to follow policies and procedures

and the law, Xavier died from a fatal gunshot wound on August 25, 2017.

118. At the time of his death, Xavier McMullen, deceased, was not provided and/or afforded

the opportunity to live a full and productive life, nor the chance to bond with and/or love

his heirs at law and/or next of kin now and in the future, and that due to the wrongful

death of Xavier McMullen, the decedent’s heirs at law and/or next of kin have suffered

severe mental anguish and emotional distress, a loss of his society and companionship,

consortium and pecuniary losses.

119. At all times pertinent, Plaintiff Lisa Carswell, Administratrix for the Estate of Xavier

McMullen, deceased, states that because of Decedent’s wrongful death, the Decedent’s



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statutory beneficiaries have been damaged, deprived of his society and companionship,

suffered a loss of future earnings and services, love and affection, a loss of future

inheritance, severe mental anguish and emotional distress, and have sustained pecuniary

losses.

120. That the Estate of Xavier McMullen has incurred reasonable funeral and burial expenses

in the amount of $6,118.07.

COUNT TWO

(Loss of Consortium Against all Defendants)



122. Plaintiff states that she is the mother of her son Xavier McMullen, deceased, and as a

direct and proximate result of the Defendant’s negligence, as set forth above, she has

suffered a loss of her son’s care, comfort, services and consortium in the past and will

continue to suffer said losses in the future.

COUNT THREE

(Survival Action Against all Defendants)



124. Plaintiff, as the Administratrix of the Estate of Xavier McMullen, deceased, and pursuant

to R.C. §2125.01 brings this claim on behalf of Plaintiff’s decedent.

125. Plaintiff states Defendants caused the injuries by creating a dangerous situation in which

resulted in the death of Plaintiff’s decedent as stated above.

126. As a direct and proximate result of Defendants’ wrongful conduct, Plaintiff’s decedent

suffered massive and horrific injuries that ultimately led to his untimely death.



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127. As a direct and proximate result of Defendants’ wrongful conduct, Plaintiff’s decedent

suffered physical and mental pain until his tragic death.

COUNT FOUR

(Spoliation of Evidence Against all Defendants)



129. Defendants interfered with and destroyed critical evidence in this case when they did not

preserve all footage and recordings of Car #6 from August 25, 2017.

130. Defendant APD only provided footage from Car #6 following the fatal gunshot to

Xavier.

131. As a result, evidence relevant to Plaintiff’s claims against Defendants was not retained.

132. Defendants knew or should have known that claims involving Xavier McMullen were

likely given the gravity of the situation and, therefore, they should have preserved all

evidence and recordings from Car #6.

133. Defendants’ actions in interfering with and destroying the evidence was willful and

disrupted Plaintiff’s case.

134. As a direct and proximate result of this spoliation, Plaintiff’s case has been disrupted in

that Plaintiff has lost evidence relevant to her claims against Defendants in this action.

135. Defendants’ willful interference with and destruction of evidence caused Plaintiff to

suffer damages, including but not limited to, pain and suffering, severe emotional

distress, loss of past and future earnings, and punitive damages.



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COUNT FIVE

(Negligent Hiring, Training, and Retention against APD)



137. An employment relationship existed between Defendant APD and Defendants Simcox,

Donohue, Bauknecht, Cranston, Curtin, Okoh, Ray, Jaskolka, Shmigal, Fangmann,

Saunier, Jackson, and Radak.

138. Defendant APD failed to properly train its’ employees and agents to protect the

community and prisoners following an arrest, to properly conduct an investigation of an

aggravated robbery, to care for injured victims, to properly Mirandize suspects upon

arrest, to search suspects upon initial contact, to search suspects upon arrest, to search

suspects prior to placing them into police cruisers, to properly monitor suspects

following an arrest, to properly recover IVS footage from police cruisers, and to properly

notify family or next of kin upon the death of a suspect.

139. Defendant APD had actual and/or constructive knowledge of such incompetence and

improper training of its’ officers.

140. The actions and/or inactions of Defendant APD and its’ officers proximately caused

Xavier’s death.

141. As a result of the negligent hiring, training, and/or retention of Defendants Simcox,


Saunier, Jackson, and Radak, Plaintiff Lisa Carswell, individually and as Administratrix

of the Estate of Xavier McMullen, suffered, and continues to suffer, damages, including,

but not limited to, pain and suffering, severe emotional distress, loss of past and future

earnings, and other damages to be proven at trial.



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COUNT SIX

(Supervisory Liability/Respondent Superior Against APD)



143. Defendant APD played more than a passive role in implicitly authorizing, approving,

and knowingly acquiescing and/or in other ways directly participating in negligent

conduct on August 25, 2017, described herein through the actions of Defendants Simcox,



144. Defendant APD is subject to supervisory liability for the actions of Defendants Simcox,



145. Defendants Simcox, Donohue, Bauknecht, Cranston, Curtin, Okoh, Ray, Jaskolka,

Shmigal, Fangmann, Saunier, Jackson, and Radak’s actions against Xavier McMullen,

entitle Plaintiff Lisa Carswell, individually and as Administratrix of the Estate of Xavier

McMullen, to recover any and all damages, fees and expenses available.

COUNT SEVEN

(State Civil Rights Against all Defendants)



147. All Defendants are individuals who were acting under color of law in conducting an

investigation and proceedings pursuant to Ohio and Federal law, including as to

proceedings described in the Ohio Revised Code.



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148. To the extent not separately responsible, Defendants APD are vicariously responsible for

Defendants’ conduct.

149. As a result of the conduct of said Defendants, and each of them, as adopted and

incorporated by all paragraphs previously set forth herein, Defendants and each of them,

violated Xavier’s personal and civil rights, including the right from self-incrimination,

protection from unwarranted and unlawful seizure, bodily restraint or harm, from cruel

and unusual punishment, from personal and physical insult and violation, due process

and equal protection.

150. The acts of Defendants that are previously alleged in this Complaint and incorporated by

the references herein to the extent applicable, interfered, or attempted to interfere, with

the exercise of Xavier McMullen’s personal and civil rights under the laws and

Constitution of the State of Ohio.

151. As a direct and proximate result of the afore-mentioned conduct of Defendants, Plaintiff

Lisa Carswell, individually and as Administratrix of the Estate of Xavier McMullen, has

suffered and will continue to suffer damages, including, but not limited to, great

emotional and psychological distress, humiliation, and mental anguish, the nature and

amount of which will be shown according to proof at trial.

152. These violations of Xavier McMullen’s personal and civil rights by Defendants, are

protected and guaranteed by the Ohio Revised Code, entitling Plaintiff Lisa Carswell,

individually and as Administratrix of the Estate of Xavier McMullen, to damages and

relief, including other equitable relief, punitive damages, injunctive relief, statutory civil

penalty (including $25,000.00 as to each individual Defendant) and attorney’s fees, all

of which are requested herein.



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153. In doing the acts alleged in this Complaint, Defendants, and each of them, knew or

should have known, that their actions were likely to, or would injure and damage Xavier

McMullen. Plaintiff is informed and believes, and thereon alleges, that the individual

Defendants, and each of them, intended to cause injury and damage Xavier McMullen,

and/or acted with a willful and conscious disregard of Xavier’s life, rights, and safety,

thus entitling Plaintiff Lisa Carswell, individually and as Administratrix of the Estate of

Xavier McMullen, to punitive damages as against said individual Defendants.

COUNT EIGHT

(Liability for Punitive Damages Against all Defendants)



155. Defendants acted willful and reckless in their interaction with Xavier while in police

custody, demonstrating a complete disregard for Xavier’s life and safety.

WHEREFORE, Plaintiff demands judgment against Defendants in an amount in excess of

Twenty-Five Thousand Dollars ($25,000.00) for compensatory damages, together with interest,

punitive damages, the costs of this action, and any other damages deemed reasonable and proper

by this Court.



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Respectfully Submitted,

/s/Laura L. Mills

Laura L. Mills, Esq. (0063011)

Pierce C. Walker, Esq. (0097312)

Mills, Mills, Fiely & Lucas, LLC

101 Central Plaza South

200 Chase Tower

Canton, Ohio 44702

P: 330.456.0506

F: 855.764.3543

Email: [email protected]

[email protected]

JURY DEMAND ENDORSEMENT

Plaintiff demands a trial by jury.

/s/Laura L. Mills

Laura L. Mills, Esq. (0063011)



mailto:[email protected]

in the court of common pleas summit county, ohio … · 2018. 5. 11. · 4 . akron police...

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