1

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

TIFFANY A. RENT, )

T.B. A MINOR DOB 1/31/2003, AND ) 

T.B. A MINOR DOB 5/30/2009, )

)

Plaintiffs, ) 

 )

-vs- ) Case No.: 12-cv-4653

)

CITY OF CHICAGO, AN ILLINOIS )

MUNICIPAL CORPORATION, POLICE ) JURY TRIAL DEMANDED

OFFICER REGINALD PIPPEN BADGE )

#15512, Individually and as an Agent ) 

and/or Employee of the City of Chicago. ) 

POLICE OFFICER RONALD FORGUE )

BADGE #1600, Individually and as an ) 

Agent and/or an Employee of the City of ) 

Chicago, POLICER OFFICER DENNIS ) 

SMITH BADGE #1449, Individually and as ) 

an Agent and/or an of the City of Chicago, )

AND UNKNOWN CITY OF CHICAGO ) 

POLICE OFFICERS, )

)

Defendants. )Aa

 

COMPLAINT AT LAW 

NOW COMES Plaintiffs TIFFANY A. RENT, T.B. A MINOR CHILD DOB 

1/31/2003 and T.B. A MINOR CHILD DOB 5/30/2009, by and through their 

attorneys Keenan J. Saulter and Curtis J. Tarver II of Saulter Tarver LLP and for 

their Complaint against Defendants CITY OF CHICAGO an Illinois Municipal 

Corporation, POLICE OFFICER REGINALD PIPPEN, Badge #15512, Individually 

and as an Employee of the City of Chicago, POLICE OFFICER RONALD FORGUE 

Badge #1600, Individually and as an Employee of the City of Chicago, POLICE 

Case: 1:12-cv-04653 Document #: 1 Filed: 06/14/12 Page 1 of 8 PageID #:1
2

OFFICER DENNIS SMITH, Badge #1449, Individually and as an Employee of the 

City of Chicago, and UNKNOWN CITY OF CHICAGO POLICE OFFICERS, state 

as follows:

Overview 

1. This action arises out of an illegal, unwarranted and brutal Taser 

attack, beating, and false imprisonment of Plaintiff TIFFANY A. RENT while her 

minor children T.B. A MINOR CHILD DOB 1/31/2003 and T.B. A MINOR CHILD 

DOB 5/30/2009 were sitting a mere few feet away by Defendants on June 5, 2012. 

2. As a result of this attack by the Defendants, members of the City of 

Chicago Police Department, Plaintiffs were deprived their rights, privileges and/or 

immunities secured by the United States Constitution and Federal laws, including 

their Due Process Rights, pursuant to 42 U.S.C. § 1983.1

Plaintiffs 

3. Plaintiffs TIFFANY A. RENT, T.B. A MINOR CHILD DOB 1/31/2003 

and T.B. A MINOR CHILD DOB 5/30/2009, were each residents of Northern 

District of Illinois, Eastern Division at the time of the incident (and remain 

permanent residents here as of the filing of this action). 

 

 

1 42 U.S.C. §1983. Every person who under color of any statute, ordinance, regulation, custom, or 

usage, of any State or Territory or the District of Columbia, subjects, or causes to be subjected, any 

citizen of the United States or other person within the jurisdiction thereof to the deprivation of any 

rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party 

injured in an action at law, Suit in equity, or other proper proceeding for redress, except that in any 

action brought against a judicial officer for an act or omission taken in such officer's judicial capacity, 

injunctive relief shall not be granted unless a declaratory decree was violated or declaratory relief 

was unavailable. For the purposes of this section, any Act of Congress applicable exclusively to the 

District of Columbia shall be considered to be a statute of the District of Columbia.

Case: 1:12-cv-04653 Document #: 1 Filed: 06/14/12 Page 2 of 8 PageID #:2
3

Defendants 

4. Defendant CITY OF CHICAGO, an Illinois Municipal Corporation, 

(the “CITY”) is located in the Northern District of Illinois, Eastern Division.

5. Upon information and belief POLICE OFFICER REGINALD PIPPEN, 

Badge #15512, Individually and as an Employee of the City of Chicago, is a resident 

of the Northern District of Illinois, Eastern Division and is employed in this 

District. 

6. POLICE OFFICER RONALD FORGUE Badge #1600, Individually and 

as an Employee of the City of Chicago, is a resident of the Northern District of 

Illinois, Eastern Division and is employed in this District. 

7. POLICE OFFICER DENNIS SMITH, Badge #1449, Individually and 

as an Employee of the City of Chicago, is a resident of the Northern District of 

Illinois, Eastern Division and is employed in this District. 

8. Upon information and belief the UNKNOWN CITY OF CHICAGO 

POLICE OFFICERS are residents of the Northern District of Illinois, Eastern 

Division and are employed in this district. 

Jurisdiction and Venue 

9. This Court has jurisdiction over Plaintiffs’ claims pursuant to 28 

U.S.C. § 1331. Plaintiffs’ claims arise under 42 U.S.C. §1983 and their state law 

claims arise out of the same subject matter. Moreover the amount in controversy 

exceeds this Court’s jurisdictional minimum. 

Case: 1:12-cv-04653 Document #: 1 Filed: 06/14/12 Page 3 of 8 PageID #:3
4

10. This Court has Supplemental Jurisdiction over the state law claims

pursuant to 28 U.S.C. §1367. 

11. Venue is proper as Plaintiffs and Defendants are residents of this 

judicial district and all of the events that give rise to the case occurred in this 

judicial district. 

Facts Common to All Counts 

12. At all times relevant hereto, all Defendants, named and unnamed, 

were and are duly appointed officers, agents, and/or employees of the CITY.

13. At all times relevant hereto, each and every Defendant was the agent 

of each and every other Defendant and had the legal duty to oversee and supervise 

the hiring, conduct, training, employment and discipline of each and every 

Defendant named and unnamed in this Complaint.

14. At all times relevant hereto, it was the responsibility of the CITY to 

screen, hire, train, and employ police officers, investigators and detectives for the 

purposes of providing law enforcement to the residents, inhabitants and any 

individuals present in the CITY OF CHICAGO at all times.

15. At all times relevant hereto, the CITY employed Defendants PIPPEN, 

FORGUE, SMITH and the UNKNOWN CITY OF CHICAGO POLICE OFFICERS.

16. At all times relevant hereto, the CITY had a duty to properly hire, 

supervise train and discipline Defendants PIPPEN, FORGUE, SMITH and the 

UNKNOWN CITY OF CHICAGO POLICE OFFICERS.

17. At all times relevant hereto, the CITY was a municipality organized 

pursuant to the laws of the State of Illinois.

Case: 1:12-cv-04653 Document #: 1 Filed: 06/14/12 Page 4 of 8 PageID #:4
5

18. On or about June 5, 2012, and at all times relevant before and after 

said date, the CITY screened, hired, trained and employed Defendants PIPPEN, 

FORGUE, SMITH and the UNKNOWN CITY OF CHICAGO POLICE OFFICERS.

19. On or about June 5, 2012 Defendants PIPPEN, FORGUE, SMITH and 

the UNKNOWN CITY OF CHICAGO POLICE OFFICERS were acting under the 

color of authority and in their official capacity as peace officers dully employed by 

Defendant CITY.

20. On June 5, 2012 while at a Walgreens Drug Store located at 10300 

South Michigan Avenue, Chicago, Illinois 60628 Plaintiff TIFFANY A. RENT had 

an encounter with Defendants PIPPEN, FORGUE, SMITH and the UNKNOWN 

CITY OF CHICAGO POLICE OFFICERS relating to a parking ticket.

21. Following the issuance of the parking ticket, Plaintiff TIFFANY A. 

RENT was brutally attacked, shocked with a Taser Gun all while she was visibly 

eight months pregnant. Plaintiff RENT was also enduring a medically high risk 

pregnancy at the time. 

22. Following the brutal Taser Gun attack, Plaintiff RENT was forcefully

taken to the ground and left there while Defendants PIPPEN, FORGUE, SMITH

and the UNKNOWN CITY OF CHICAGO POLICE OFFICERS mocked and laughed

at Plaintiff RENT writhing on the ground in pain.

23. Plaintiff RENT’s children who were with her at the time, T.B. A 

MINOR CHILD DOB 1/31/2003 and T.B. A MINOR CHILD DOB 5/30/2009, were 

also unreasonably detained and falsely imprisoned by Defendants.

Case: 1:12-cv-04653 Document #: 1 Filed: 06/14/12 Page 5 of 8 PageID #:5
6

24. Defendants also charged Plaintiff TIFFANY A. RENT with criminal 

offenses in an attempt to cover-up the illegal and brutal attacks and false 

imprisonment that they perpetrated against the Plaintiffs. 

25. Following these attacks PLAINTIFF RENT and her unborn child 

required medical attention in two separate medical facilities.

42 U.S.C. §1983 Claim—Violation of Constitutionally Guaranteed Rights 

26. Plaintiffs repeat, reallege and incorporate by reference the allegations 

contained in Paragraphs 1 through 25 above with the same force and effect as if 

herein set forth. 

27. At all times relevant herein, the conduct of all Defendants was subject 

to and governed by 42 U.S.C. §1983. 

28. At all times relevant herein, the all Plaintiffs were entitled to the 

rights established by the Fourth Amendment of the United States Constitution.

29. Acting under the color of law, Defendants intentionally and unlawfully 

made physical contact with their persons and used excessive force to constrain the 

Plaintiffs which was harmful and offensive without valid cause.

30. Acting under the color of law, Defendants arrested and detained 

Plaintiffs without probable cause as required by the United States Constitution and 

by federal law.

31. The Defendants’ conduct of attacking, and falsely imprisoning 

Plaintiffs who committed no criminal conduct was unarmed, was extreme and 

outrageous.

Case: 1:12-cv-04653 Document #: 1 Filed: 06/14/12 Page 6 of 8 PageID #:6
7

State Law Claim Intentional Infliction of Emotional Distress 

32. Plaintiffs repeat, reallege and incorporate by reference the allegations 

contained in Paragraphs 1 through 31 above with the same force and effect as if 

herein set forth. 

33. The Defendants’ attacking, tasering and falsely imprisoning Plaintiff

RENT a mere few feet away from Plaintiff’s minor children T.B. A MINOR CHILD 

DOB 1/31/2003 and T.B. A MINOR CHILD DOB 5/30/2009 was extreme and 

outrageous.

34. The Defendants either intended to cause, recklessly caused or 

consciously disregarded the probability of causing extreme emotional distress to the

minor Plaintiffs T.B. A MINOR CHILD DOB 1/31/2003 and T.B. A MINOR CHILD 

DOB 5/30/2009.

WHEREFORE for the foregoing reasons Plaintiff TIFFANY A. RENT, T.B. A 

MINOR CHILD DOB 1/31/2003 and T.B. A MINOR CHILD DOB 5/30/2009, 

respectfully request that this Court enter judgment in her favor and against 

defendants in an amount in excess of $75,000.00, as assessed by a jury, costs, 

attorneys’ fees, any other legal and equitable remedies available under the law and 

any other such relief as this Court may deem just and proper.

 

 

 

Case: 1:12-cv-04653 Document #: 1 Filed: 06/14/12 Page 7 of 8 PageID #:7
8

A Jury Trial is Demanded on Behalf of All Plaintiffs and for All Counts

s/ Keenan J. Saulter

 Keenan J. Saulter

Attorney for Plaintiff 

Keenan J. Saulter

Curtis J. Tarver II

SAULTER TARVER LLP 

330 South Wells, Suite 1110

Chicago, Illinois 60606

(312) 986-8330 Telephone

(312) 577-1710 Facsimile 

Case: 1:12-cv-04653 Document #: 1 Filed: 06/14/12 Page 8 of 8 PageID #:8