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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

JOE ALCIDES RODRIGUEZ,

CASE NO.: NO.: 0:20-CV-61229-RAR

Plaintiff,

vs.

JURY TRIAL DEMANDED

SONIA QUIÑONES, in her official 

Capacity as Chief of the Hallandale Beach 

Police Department, and Officer MATTHEW 

CASEY

Individually.

Defendants.

___________________________________/

SECOND AMENDED COMPLAINT

Plaintiff Joel Alcides Rodriguez (“Rodriguez”), sues Defendants Sonia Quiñones in her 

official capacity as Chief of the Hallandale Beach Police Department (“Quiñones” or “Chief of 

Police” or “Hallandale Police”), and Officer Matthew Casey (“Casey”), individually and, in 

support thereof, alleges the following:

INTRODUCTION

1. This action is brought to redress violations of federally protected constitutional 

rights pursuant to 42 U.S.C. §1983, the Fourth Amendment of the United States Constitution, and 

the laws of the State of Florida. 

PARTIES

2. Plaintiff Rodriguez is an individual who resides in Hollywood, Florida and is 

subject to the jurisdiction of this Court. 

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3. Defendant Quiñones is the Chief of the Hallandale Police Department. In this 

cause, Defendant Quiñones acted through her capacity as Chief of the Hallandale Police 

Department by and through her agents and employees, including but not limited to Casey. 

4. At all times material, Defendant Casey was acting under color of law as an 

employee or agent of Defendant Chief of Police. 

JURISDICTION AND VENUE

5. This Court has jurisdiction pursuant to 28 U.S.C. §1331 and 28 U.S.C. §1343. 

6. This Court has supplemental jurisdiction pursuant to 28 U.S.C. §1367(a) over the 

state law claims asserted herein which are so related to the federal claims that they form part of 

the same case of controversy. 

7. Venue is proper in this District under 28 U.S.C. § 1391(b), because a substantial 

part of the events or omissions giving rise to the claim occurred in this District.

FACTUAL ALLEGATIONS APPLICABLE TO ALL COUNTS

8. In the afternoon of June 23, 2016, Rodriguez had a disagreement with his 

girlfriend. After the dispute, she left the apartment and did not return that day. The apartment is 

located on the second floor of their apartment building. The apartment building is located in 321 

NE 1st Court, Apartment Number 212 Hallandale, FL, 33039.

9. A few moments after his girlfriend left, Rodriguez heard people knocking on his 

door. Rodriguez opened the door and greeted the defendant, Officer Casey. Rodriguez asked Casey

what he needed, and Casey asked Rodriguez to step outside of his apartment. 

10. Speaking with Casey while the door was open, Rodriguez asked Casey why 

Casey was asking him to step outside of his apartment. Casey told Rodriguez that he needed to 

talk to him. 

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11. Rodriguez told Casey that he had no problem talking with Casey, but that he could 

talk to Casey from the door while he was standing inside of his apartment.

12. Casey continued to ask Rodriguez to step outside of his apartment. Rodriguez 

replied that he felt more comfortable speaking to Casey from where he was standing. There were 

no obstacles or barriers impeding the two from communicating because the door was ajar. 

13. Five to eight minutes later, after Casey persistently asked Rodriguez to leave his 

apartment, Casey said that “he had had enough” and, without consent, came inside Rodriguez’s 

home. Then, Casey told Rodriguez to put his hands behind his back and Rodriguez complied. 

Without warning, Casey violently punched Rodriguez’s head and body while inside of Rodriguez’s 

apartment. Casey then forcibly took Rodriguez out of his apartment, and forcefully twisted his arm 

hard, high up towards the back of his head, pulled him and took him to a secluded area of the 

apartment complex. Once Casey was in a private area, Casey slammed Rodriguez against a 

concrete wall and dragged him down a flight of stairs.

14. After Rodriguez was dragged to the first floor, other officers arrived at the scene. 

Alarmed, Rodriguez’s neighbors came out of their apartments. Casey dragged Rodriguez to his 

truck. Rodriguez was shirtless because he was forcibly removed from his home. As Rodriguez got 

close to Casey’s police truck, Casey slammed Rodriguez onto the hood of his truck. The hood of 

Casey’s truck was so hot that Rodriguez’s body bounced right back. Casey slammed him again, 

so hard that Rodriguez’s face broke the side window and went through it. Then, Casey grabbed

Rodriguez again and slammed him onto the hot pavement. 

15. Desperate, Rodriguez yelled and said, among other things: “I am a former United 

States Marine, call the sergeant and get off me.” 

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16. Rodriguez remained on the floor for a while until the sergeant finally came. The 

sergeant told Casey to get away from Rodriguez. The sergeant then turned to Rodriguez and told 

him he would help him up, but given the circumstances, Rodriguez refused. Due to Casey’s violent 

attack, Rodriguez was bleeding profusely from his chin and forehead. Casey scratched Rodriguez’s 

skin, causing him to bleed from numerous places on his body. Further, Rodriguez’s skin was burnt 

because of the heat of Casey’s hood and the hot pavement. 

17. Moments later, an ambulance came in, and a female officer helped Rodriguez get 

into the ambulance. The ambulance took Rodriguez to Memorial Regional Hospital. After

approximately three hours, receiving several stitches in his face, and other treatment, Rodriguez

was taken to the Hallandale Beach Police Department. The Police Department did not charge 

Rodriguez with any domestic violence counts. Rather he was charged with “resisting arrest,” 

“criminal mischief,” and “damaging property.”

18. Rodriguez’s incident does not appear to be an isolated one. On information and 

belief, this is the customary practice of the Hallandale Police overseen by Quiñonez (and others 

before her). In fact, the Hallandale Police has a long history of controversial shootings, beatings, 

and huge payouts to victims of police brutality. 

19. Moreover, there were around five other officers who either contributed to or did 

absolutely nothing other than casually observe the beating, or to prevent Casey from violently 

abusing Rodriguez. This further corroborates the normalcy of the abuse endured by Rodriguez. To 

officers in the Hallandale Police Department. beating a citizen absent probable cause is typical 

practice.

COUNT I—EXCESSIVE AND UNREASONABLE FORCE

42 U.S.C. §1983

20. Plaintiff incorporates paragraphs 1 through 19 fully in this Count.

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21. This is a cause of action for depravation of constitutional rights within the 

meaning of 42 U.S.C. §1983. 

22. While Defendant Casey was acting under authority of the State of Florida and 

under color of law as a police officer in the employ of Defendant Chief of Police, Casey deprived 

Rodriguez of his constitutional right to be free from the excessive use of force under the Fourth 

Amendment, within the meaning of 42 U.S.C. §1983.

23. Specifically, Defendant Casey used unreasonable and excessive force when he: 

(1) pulled Rodriguez’s arm excessively towards the back of his head, (2) slammed Rodriguez

against a wall, (3) dragged Rodriguez through the stairs, (4) slammed Rodriguez’s body on a hot 

SUV hood, (5) slammed Rodriguez’s body and face through an SUV’s glass and thereby broke it

and (6) slammed Rodriguez’s shirtless body on the hot pavement. 

24. Casey’s excessive and unreasonable force inflicted numerous physical and mental

injuries on Rodriguez including but not limited to bruises, contusions, and lacerations. 

25. As a direct and proximate result of the above-mentioned unconstitutional acts of 

Casey, Rodriguez suffered, and continues to suffer, mental anguish, loss of capacity of enjoyment 

of life, physical injury, personal humiliation, and loss of his freedom and civil rights. Moreover, 

he was brought into public scandal with great humiliation, suffered loss of income, endured mental 

suffering, and damage to his reputation. 

WHEREFORE, based on the allegations on this Count I Rodriguez requests: 

(a) Judgment for compensatory damages in excess of $15,000;

(b) Judgment for exemplary damages; 

(c) Cost of suit; 

(d) Reasonable attorney’s fees, pursuant to 42 U.S.C. §1988; 

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(e) Trial by jury as to all issues so triable; and 

(f) Such other relief as this Honorable Court may deem just and appropriate. 

COUNT II – FOURTH AMENDMENT FALSE ARREST/UNLAWFUL SEIZURE

42 U.S.C. §1983

26. Plaintiff incorporates the allegations in paragraphs 1 through 19 fully in this 

Count.

27. This is an action for depravation of Rodriguez’s constitutional rights within the 

meaning of 42. U.S.C §1983.

28. While Casey was acting under authority of the State of Florida and under color 

of law as a police officer in the employ of Chief of Police, Casey violated Rodriguez of his 

constitutional right not to be deprived of liberty and to be free from unlawful or unreasonable

search and/or seizure under the Fourth Amendment, within the meaning of 42 U.S.C. §1983.

29. Specifically, Defendant Casey unlawfully and unreasonably searched and/or 

seized Rodriguez by entering in his house without authorization, seizing his body, detaining him, 

and continuing to detain him absent reasonable suspicion or probable cause that any crime was 

being committed, thereby inflicting numerous physical and mental injuries and damages upon 

Rodriguez, including but not limited to bruises, contusions, and lacerations. 

30. At no point, did Casey have a warrant to enter Rodriguez’ home. 

31. At no point did Rodriguez authorize Casey to enter his home. 

32. Casey did not have and could not have had reasonable suspicion that a crime was 

being committed since Rodriguez’s girlfriend was not in the house at the time Casey arrived. Casey

knew this. In fact, Rodriguez was never charged with a domestic violence related offence. Rather, 

Rodriguez was charged with offenses that were caused by Casey. 

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33. As a direct and proximate result of the above-mentioned unconstitutional acts of 

Casey, Rodriguez suffered, and continues to suffer, mental anguish, loss of capacity of enjoyment 

of life, physical injury, personal humiliation, and loss of his freedom and civil rights. Moreover, 

he was brought into public scandal with great humiliation, suffered loss of income, endured mental 

suffering and damage to his reputation. 

WHEREFORE, based on the allegations on this Count I Rodriguez requests: 

(g) Judgment for compensatory damages in excess of $15,000;

(h) Judgment for exemplary damages; 

(i) Cost of suit; 

(j) Reasonable attorney’s fees, pursuant to 42 U.S.C. §1988; 

(k) Trial by jury as to all issues so triable; and 

(l) Such other relief as this Honorable Court may deem just and appropriate. 

COUNT III – TRESPASS

34. Plaintiff incorporates the allegations in paragraphs 1 through 19 fully in this 

Count.

35. This is an action for trespassing. 

36. Rodriguez was in possession of the subject property. 

37. Casey without authorization from Rodriguez entered Rodriguez’s property. 

38. As a direct and proximate result of Casey’s trespass, Rodriguez suffered, and 

continues to suffer, mental anguish, loss of capacity of enjoyment of life, physical injury, 

humiliation personally, and loss of his freedom and civil rights. Moreover, he was brought into 

public scandal with great humiliation, suffered loss of income, endured mental suffering and 

damage to his reputation. 

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WHEREFORE, based on the allegations on this Count I Rodriguez requests: 

(m) Judgment for compensatory damages in excess of $15,000;

(n) Cost of suit; 

(o) Trial by jury as to all issues so triable; and 

(p) Such other relief as this Honorable Court may deem just and appropriate. 

DEMAND FOR JURY TRIAL

Plaintiff demands a trial by jury on all claims so triable.

Dated: August 24, 2020

Respectfully submitted,

Eduardo A. Maura, Esq.

Luis F. Quesada, Esq.

Attorneys for Plaintiff

Ayala Law, P.A.

1390 Brickell Ave, Ste 335

Miami, FL 33131

Telephone: 305-570-2208

Email: eayala@ayalalawpa.com

By: /s/ Eduardo A. Maura

Eduardo A. Maura

Florida Bar No. 91303

Jorge Garcia-Menocal, Esq.

Attorney for Plaintiff

Garcia Menocal, Pastori & Irias LLP

368 Minorca Ave

Coral Gables, Florida 33134

Telephone: 305-400-9652

Email: jgm@gmilaw.com

By: /s/ Jorge G. Menocal

Jorge G. Menocal

Florida Bar No. 17990

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CERTIFICATE OF SERVICE

I certify that a copy of this document was filed using the CM/ECF filing system on August 24, 

2020, which will electronically serve the same upon counsel for Defendant Quinonez.

By: /s/ Eduardo A. Maura

Eduardo A. Maura

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