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UNITED STATES DISTRICT COURT

IN THE WESTERN DISTRICT OF TEXAS 

SAN ANTONIO DIVISION

CHRISTOPHER GRISHAM; JAMES 

EVERARD, 

Plaintiffs,

v.

RENE VALENCIANO; J. LOPEZ; 

HECTOR RUIZ; A. VIERA; CITY 

OF OLMOS PARK,

Defendants.

Case No. 5:20-cv-00387

Hon.

Solomon M. Radner 

Michigan Bar No. P73653

Attorney for Plaintiffs

26700 Lahser Road, Suite 401

Southfield, Michigan 48033

(866) 939-2656

sradner@excololaw.com

COMPLAINT AND JURY DEMAND 

NOW COME Plaintiffs, CHRISTOPHER GRISHAM and JAMES EVERARD, by 

and through their attorneys, EXCOLO LAW, PLLC, complaining of Defendants, 

respectfully allege as follows:

JURISDICTION AND VENUE

1. This is a civil rights action in which Plaintiffs seek relief for the violation of 

their rights secured by 42 U.S.C. § 1983, the First, Second, Fourth, and Fourteenth 

Amendments of the United States Constitution. 

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2. Jurisdiction of this Court is found upon 28 U.S.C. § 1331 since this action 

arises under the Constitution and the laws of the United States. 

3. Venue is proper in the United States District Court for the Western District 

of Texas because the majority of events complained of occurred in this district. 

4. Pursuant to 42 U.S.C. § 1983, and other applicable laws, the Court may

award nominal, compensatory, and punitive damages, as well as equitable relief against all 

of the Defendants in their individual capacity, for the violations of Plaintiffs Constitutional 

rights and harm caused by their actions/inactions.

PARTIES

5. Plaintiff, CHRISTOPHER GRISHAM, (“Plaintiff” or “Mr. Grisham”), is a 

law-abiding citizen of the State of Texas.

6. Plaintiff, JAMES EVERARD, (“Plaintiff” or “Mr. Everard”), is a lawabiding citizen of the State of Texas.

7. Upon information and belief, all defendants are Texas residents and are being 

sued in their individual, supervisory, and/or Official capacities as permitted by law. 

8. Defendant, RENE VALENCIANO, (herein after Defendant Valenciano or 

Defendant police chief Valenciano) was a Texas resident at all times relevant to this 

complaint and acted as a direct supervisor to City of Olmos Police Department employees 

as the Chief of police. He is being sued in his individual, supervisory, and official capacity. 

9. Defendant, OFFICER J. LOPEZ, was a Texas resident at all times relevant 

to this complaint and acted as an Olmos Police Officer. He is being sued in his individual 

capacity. 

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10. Defendant, HECTOR RUIZ, was a Texas resident at all times relevant to this 

complaint and acted as an Olmos Police Officer. He is being sued in his individual capacity. 

11. Defendant. A. VIERA was a Texas resident at all times relevant to this 

complaint and acted as an Olmos Police Officer. He is being sued in his individual capacity. 

12. Defendant, CITY OF OLMOS PARK, is a municipality in the State of Texas.

FACTUAL ALLEGATIONS

13. On March 26, 2018, Plaintiff Grisham called Olmos Park Police and asked 

whether he would be approached by police if he or others were open carrying their firearms. 

He was assured by Chief of Police Defendant Valenciano that Plaintiffs and others who 

were open carrying pursuant to Texas state law would not be approached by police officers. 

14. On March 27, 2018, Plaintiffs were walking on public sidewalk while open 

carrying. Plaintiff Grisham had a handgun strapped to his waist, and Plaintiff Everard had 

an unloaded rifle slung across his chest. Plaintiffs were both holding video cameras and 

recording the public view.

15. Upon information and belief, a witness called 911 and explained that 

someone was carrying a gun. The witness further explained that the men carrying the guns

did not seem dangerous; rather, they looked like they just wanted the attention. The 911 

dispatcher said something to the effect of “those are the second amendment people.” 

16. Prior to arriving on the scene, the Olmos Park officers were made aware the 

call was regarding “the second amendment people.” Officers arrived, and Plaintiffs began 

recording the interaction with the officers. 

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17. Defendant Officer Lopez began yelling at Plaintiff Everard stating, “lay on 

the ground and disarm yourself or we will fucking disarm you.” At this point, Plaintiff 

Grisham moved to the corner where Plaintiff Everard was standing, and he continued to 

film the interaction with the officers from that angle. Several other citizens were recording 

this interaction as well. Several cars drove past the scene. At one point, a lady stopped to 

chat with Plaintiff Grisham, and a bicyclist casually strolled past the scene. An image of 

the scene can be found below.

18. Plaintiff Everard continued to ask the officers what crime he had committed. 

When asked to lay on the ground, he said he would comply if he was told why he was being 

detained. 

19. Then, Defendant Valenciano and Defendant Officer Viera approach 

Plaintiffs. At this point, Defendant Officer Viera begins reaching for Grisham. Here, 

Grisham placed his hands in the air and took several steps back. Defendant Valenciano, 

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without prior warning, shot Plaintiff Grisham with his taser while Defendant Viera shoved 

Plaintiff in his chest. An image of the scene can be found below.

20. The tasing caused Plaintiff Grisham to fall backward onto the pavement and 

smack his head on the pavement. Soon thereafter, it becomes apparent Plaintiff is bleeding 

and seriously injured. Plaintiff Grisham suffered a concussion and a serious abrasion to the 

back of his head. An image of the scene can be found below.

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21. While Plaintiff Grisham is being assaulted by Defendant Valenciano and 

Defendant Viera, Plaintiff Everard is placed under arrest by Defendant Officer Ruiz. Once 

Defendant Ruiz had Plaintiff Everard cuffed, he took Plaintiff Everard’s camera and threw 

it into the street. Then, Defendant Officer Ruiz pushed Plaintiff Everard onto his knees. 

Once Plaintiff Everard was on his knees, Defendant Valenciano and Defendant Ruiz

shoved Plaintiff Everard face first into the pavement for no lawful reason. Images from 

the scene can be found below.

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22. Defendant Officers Lopez and Viera attempted to lift Plaintiff Grisham to his 

feet. Clearly disoriented and bleeding from the head, Plaintiff Grisham was unable to gain 

solid footing. In response, Defendant Officer Lopez and Defendant Officer Viera dragged 

Plaintiff by his arms and legs to the police car. Soon after EMS arrived and Defendant 

Valenciano waived them away, denying medical treatment for Plaintiff’s serious injuries. 

An image of the scene can be found below.

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23. Valenciano had witnessed Plaintiff Grisham struggle to gain his footing, and 

saw that Plaintiff had to be dragged to the police vehicle. Nevertheless, he waived away 

EMS, who could have provided Plaintiff Grisham with the needed medical Care. Defendant 

Valenciano then directed Defendant Officers to take a longer route back to the police 

station in order to further delay Plaintiff Grisham’s necessary medical treatment. 

24. Plaintiff Grisham suffered a serious abrasion to his head, a concussion, 

aggravated PTSD symptoms, and chronic migraines due to his injuries. 

25. Due to being thrown to the ground and face shoved into pavement, Plaintiff 

Everard suffered a fractured wrist and a serious shoulder injury. Thereafter, Plaintiff 

Everard underwent shoulder surgery to repair the damage caused by the unlawful arrest.

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26. When Defendant Valenciano removed Plaintiff Everard from the squad car, 

he used excessive force causing injury, ligament damage to Plaintiff’s wrist and his hand. 

Valenciana used force on Everard once again when he asked about Plaintiff Grisham’s 

injuries.

27. After Defendants arrested Plaintiffs, Defendant Valenciano called over the 

radio that he has “squashed the rebels.” 

28. Once Defendant Officers had Plaintiff’s detained at the police station, they

proceeded to destroy Plaintiffs’ property. Specifically, the SD cards from the videocamera 

and GoPro and cellphones of both Plaintiffs were deleted. 

29. Moreover, officers made false statements that Everard’s gun was loaded, that 

Mr. Everard’s gun was equipped with armor piercing ammunition, a felony in Texas, and 

that Mr. Everard refused to display his identification. None of these statements are true.

Mr. Everard had done nothing unlawful. 

30. While at the station, Plaintiff Everard was held at taser point and forced into 

leg shackles while being called derogatory names such as “retard” by Defendant Officers. 

31. Plaintiffs were both held in a small room for 8 hours in handcuffs and 

shackles. One officer tried to remove the shackles once they arrived at the station, per 

standard practice, but Defendant Chief Valenciano required the shackles remain on 

Plaintiffs. At no point were Plaintiffs combative or a flight risk to Defendants. The shackles 

were not used for legitimate safety reasons, instead Chief did so for maximum pain and 

discomfort as well as humiliation. The shackles were tight and caused pain to Plaintiffs. 

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32. Plaintiffs were refused food, phone calls, and answers to their questions. 

Several officers intentionally ate food in front of Plaintiffs. 

33. Plaintiff Grisham requested and was denied a phone call to his attorney.

34. When they were finally transferred to San Antonio, they were held as taser 

point and in full physical restraints, to sign their property paperwork. 

35. Upon information and belief, Defendant Officers were acting or otherwise 

responding to the scene pursuant ordinance 24-84. This order is unconstitutional and is 

superseded by state law. 

36. There is a lengthy history of Olmos Officers harassing Second Amendment 

demonstrators. In fact, several other videos online depict similar instances of police 

misconduct being perpetrated by some of the same officers who were present and involved 

in the March 27, 2018 incident. 

37. Plaintiff Grisham was charged with Interference with Duties of a Public 

Servant, Obstruction of a Passageway/Roadway, Resisting Arrest, and Assault. 

38. Plaintiff Everard was charged with Interference with Duties of a Public 

Servant, Obstruction of a Passageway/Roadway, and Disorderly Conduct. 

39. Two days later, on March 29, 2018, Olmos City Council repealed ordinance 

24-84, explaining that it violated state law. 

40. Later, all charges against Plaintiffs were dropped. 

41. Upon information and belief, the Olmos Park police department, its Officers, 

and Defendant Police Chief Valenciano have communicated with other surrounding police 

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departments in an effort to stop Second Amendment activists from exercising their first 

Amendment rights. 

42. Upon information and belief, Defendant Chief Valenciano and Defendant 

officers have constructed and carried out plans to get Second Amendment activists off of 

the public sidewalk.

43. Olmos Park Officers are trained to forcefully pressure second amendment 

protestors to stop protesting even when protestors are compliant with state and federal law. 

44. On multiple occasions, Defendants have cited Second Amendment activists 

with bogus charges. Such charges are typically dropped prior to trial as they are meritless. 

COUNT I

VIOLATION OF CIVIL RIGHTS UNDER 42 U.S.C. § 1983

(Fourth Amendment – Excessive Force) 

45. Plaintiffs restate and incorporate by reference each and every allegation set 

forth in all prior allegations. 

46. At all times relevant herein, Defendants were acting under color of State law. 

47. Defendants use of force was objectively unreasonable. 

48. Defendants never gave Plaintiffs a lawful order. Defendants did not have 

reasonable suspicion to detain Plaintiffs. Defendants did not have probable cause to arrest 

plaintiffs. 

49. At no point did Plaintiff Everard resist officers. Nevertheless, officers 

unreasonably cuffed and shoved Plaintiff Everard. Plaintiff Everard never exhibited any 

signs of violence, nor did officers suspect Plaintiff Everard of being a violent criminal. 

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50. Defendants acted unreasonable when they tased and shoved Plaintiff 

Grisham for backing away from an officer who was unlawfully attempting to detain or 

otherwise seize Plaintiff Grisham. Plaintiff Grisham exhibited no signs of violence, and he 

was not suspected of being a violent criminal. Defendants used unreasonable force when 

holding Plaintiff’s at taser point once in full body restraints. 

51. Defendants were not in a high-pressure situation that would require split 

second decisions. 

52. Defendants used so much force on Plaintiffs so as to cause Plaintiff Grisham 

to sustain a concussion and a serious abrasion to his head.

53. Defendants used so much force on Plaintiff Everard that they broke his wrist 

and caused him a significant shoulder injury for which he may be required to receive 

surgery for. 

54. At all times relevant, Defendants were required to obey the laws of the United 

States. 

55. At all times relevant, Plaintiffs had a clearly established right to be free from 

excessive force of this nature. 

56. At all times relevant, Defendants intentionally, knowingly, maliciously, 

recklessly, unreasonably, and/or grossly negligently used excessive force on Plaintiffs. 

57. As a direct and proximate result of Defendants’ unlawful actions, Plaintiffs 

suffered damages for their physical, mental, and emotional injury, and for pain, mental 

anguish, humiliation and embarrassment. 

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COUNT II

VIOLATION OF CIVIL RIGHTS UNDER 42 U.S.C. § 1983

(Fourth Amendment – Unlawful Arrest) 

58. Plaintiffs restate and incorporate by reference each and every allegation set 

forth in all prior paragraphs. 

59. At all times relevant herein, Defendants were acting under color of state law. 

60. Defendants acted unreasonably and unlawfully when they arrest Plaintiffs 

absent probable cause. 

61. A reasonably officer in the Defendants’ situation would have understood that 

probable cause did not exist for an arrest. 

62. At all times relevant, Defendants were required to obey the laws of the United 

States. 

63. At all times relevant, Plaintiffs had a clearly established right to be free from 

arrest absent probable cause. 

64. At all times relevant, Defendants intentionally, knowingly, maliciously, 

recklessly, unreasonably, and/or grossly negligently furthered malicious prosecution 

against Plaintiffs. 

65. As a direct and proximate result of Defendant’s unlawful actions, Plaintiffs 

suffered damages for their mental, emotional, and physical injury, and for pain, mental 

anguish, humiliation, and embarrassment. 

COUNT III

VIOLATION OF CIVIL RIGHTS UNDER 42 U.S.C. § 1983

(First Amendment – Unlawfully Preventing Protected Conduct)

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66. Plaintiffs restate and incorporate by reference each and every allegation set 

forth in all prior paragraphs. 

67. At all times relevant herein, Defendants were acting under color of state law. 

68. Plaintiffs have a First Amendment right to be present on public sidewalks.

69. Plaintiffs have a statutory right to be present on public sidewalks in Texas 

while open carrying a firearm.

70. Plaintiffs were engaged in constitutionally protected conduct when they were 

recording while open carrying on a public sidewalk. 

71. Defendants tased, shoved, and arrested Plaintiffs while they were exercising 

their First Amendment right to record officers on a public sidewalk. 

72. Defendants intentionally, knowingly, maliciously, recklessly, and/or 

unreasonably prevented Plaintiffs from recording police officers conducting their duties.

73. Plaintiffs had a clearly established constitutional right to record the police.

74. The Defendants’ acts deprived Plaintiffs of the rights, privileges, and 

immunities guaranteed to citizens of the United States by the First and Fourteenth 

Amendments to the Constitution of the United States, and in violation of 42 U.S.C. § 1983. 

75. As a proximate cause of the illegal and unconstitutional acts of the 

Defendants, Plaintiffs were harmed and suffered damages as a result.

COUNT IV

VIOLATION OF CIVIL RIGHTS UNDER 42 U.S.C. § 1983

(First Amendment – Retaliation for Protected Conduct)

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76. Plaintiffs restate and incorporate by reference each and every allegation set 

forth in all prior paragraphs. 

77. At all times relevant herein, Defendants were acting under color of state law. 

78. Plaintiffs have a First Amendment right to be present on public sidewalks.

79. Plaintiffs have a statutory right to be present on public sidewalks in Texas 

while open carrying a firearm.

80. Plaintiffs were engaged in constitutionally protected conduct when they were 

recording while open carrying on a public sidewalk. 

81. Defendants have frequently targeted Plaintiffs and others engaged in similar 

displays as Plaintiffs. 

82. In retaliation for engaging in protected conduct, Defendants arrested 

Plaintiffs for carrying firearms and recording the public view on a public sidewalk. 

83. Officers had no knowledge or information that would lead a reasonable 

officer in their situation to believe that there was probable cause to arrest Plaintiffs. 

84. At all times relevant, Defendants were required to obey the laws of the United 

States. 

85. At all times relevant, Defendants intentionally, knowingly, maliciously, 

recklessly, unreasonably, and grossly negligently retaliated against Plaintiffs for engaging 

in protected conduct. 

86. As a direct and proximate result of Defendant’s unlawful actions, Plaintiffs 

suffered damages for their physical, mental, and emotional injury, and for pain, mental 

anguish, humiliation, and embarrassment. 

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COUNT V

VIOLATION OF CIVIL RIGHTS UNDER 42 U.S.C. § 1983

(Fourth Amendment – Unlawful Search and Seizure)

87. Plaintiffs restate and incorporate by reference each and every allegation set 

forth in all prior paragraphs. 

88. At all times relevant here in, Defendants were acting under color of state law. 

89. Defendants did not have reasonable suspicion to stop Plaintiffs. 

90. Defendants never gave Plaintiffs a lawful order. 

91. Defendants did not have probable cause to arrest and search Plaintiffs items. 

92. At all times relevant Defendants were required to obey the laws of the United 

States.

93. At all times relevant, Plaintiffs had a clearly established right to be free from 

unlawful search and seizures of this nature. 

94. At all times relevant, Defendants intentionally, knowingly, maliciously, 

recklessly, unreasonably, and/or grossly negligently unlawfully searched and seized 

Plaintiffs.

95. As a direct and proximate result of Defendants’ unlawful actions, Plaintiffs 

suffered damages for their physical, mental, and emotional injury, and for pain, mental 

anguish, humiliation, and embarrassment. 

COUNT VI

VIOLATION OF CIVIL RIGHTS UNDER 42 U.S.C. § 1983

(Failure to Intervene) 

96. Plaintiffs restate and incorporate by reference each and every allegation set 

forth in all prior allegations. 

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97. At all times relevant herein, Defendants were acting under color of State law. 

98. Defendants observed excessive force and other constitutional violations 

being committed by their counterparts. 

99. Defendants had the opportunity and the means to prevent harm from 

occurring.

100. Defendants stood by and let the harm unfold. 

101. The events did not unfold over a matter of moments, giving defendants ample 

opportunity and time to intervene. 

102. At all times relevant, Plaintiffs had a clearly established right to be free from 

state actors’ failure to intervene. 

103. At all times relevant, Defendants intentionally, knowingly, maliciously, 

recklessly, unreasonably, and/or grossly negligently allowed their fellow officers to use 

excessive force against Plaintiffs and otherwise violate Plaintiffs’ constitutional and 

statutory rights. 

104. As a direct and proximate result of Defendants’ unlawful actions, Plaintiffs 

suffered damages for their physical, mental, and emotional injury, and for pain, mental 

anguish, humiliation, and embarrassment. 

COUNT VII

VIOLATION OF CIVIL RIGHTS UNDER 42 U.S.C. § 1983

(Fourteenth Amendment – Deprivation of Property)

105. Plaintiffs restate and incorporate by reference each and every allegation set 

forth in all prior allegations. 

106. At all times relevant herein, Defendants were acting under color of State law. 

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107. Defendants deprived Plaintiffs of their property without due process of law 

when they threw and destroyed Defendant Everard’s camera, when they wiped the memory 

cards of Plaintiffs’ go pro, and cellphones. 

108. Defendants seized and destroyed Plaintiffs’ property without a court order, 

or without a hearing where Plaintiffs’ could be meaningfully heard. 

109. At all times relevant, Plaintiffs had a clearly established right not to have 

their property seized and destroyed absent a warrant or court order. 

110. At all times relevant, Defendants intentionally, knowingly, maliciously, 

recklessly, unreasonably, and/or grossly negligently deprived Plaintiffs’ of their property 

without due process of law. 

111. As a direct and proximate result of Defendants’ unlawful actions, Plaintiffs 

suffered damages for the loss of their property as well as their physical, mental, and 

emotional injury, and for pain, mental anguish, humiliation, and embarrassment. 

COUNT VIII

VIOLATION OF CIVIL RIGHTS UNDER 42 U.S.C. § 1983

(Fourteenth Amendment - Failure to Provide Medical Care) 

112. Plaintiffs restate and incorporate by reference each and every allegation set 

forth in all prior allegations. 

113. At all times relevant herein, Defendants were acting under color of State law. 

114. The Fourteenth Amendment to the United States Constitution requires state 

officials to provide medical care to individuals injured in their custody. 

115. As discussed herein, both Plaintiffs were severely injured by the force used 

by Defendants. 

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116. Instead of promptly providing medical attention, Defendant Chief 

Valenciano waved away the EMS vehicle and first responders who had arrived at the scene 

to take Plaintiffs to the hospital. They were told to keep it moving instead of providing 

treatment. After denying proper medical attention, Defendant Valenciano later instructs his

officers to take a longer than necessary route, for no reason other than to prolong Plaintiffs 

suffering. 

117. At the police station, Defendant Valenciano ordered WMS to stay back and 

not provide care to Plaintiff Grisham who was nearly passing out. He could not stand up 

on his own nor did he know the date. 

118. Defendant Valenciano intentionally delayed, denied, and interfered with 

medical treatment when Plaintiffs were obviously severely injured. 

119. Defendants’ acts and omissions demonstrate deliberate indifference to 

Plaintiffs serous medical needs in violation of the Fourth and Fourteenth Amendment to 

the Constitution and 42 U.S.C. § 1983.

120. As a proximate result of the illegal and unconstitutional acts of Defendants, 

Plaintiff was harmed and suffered damages for her physical, mental, emotional injury and 

pain, fright and shock, mental anguish, humiliation, and embarrassment. 

121. As a proximate result of the illegal and unconstitutional acts of Defendants, 

Plaintiff was harmed and suffered damages for her physical, mental, emotional injury and 

pain, fright and shock, mental anguish, humiliation, and embarrassment.

COUNT IX

VIOLATION OF CIVIL RIGHTS UNDER 42 U.S.C. § 1983

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(Malicious Prosecution) 

122. Plaintiffs restate and incorporate by reference each and every allegation set 

forth in all prior paragraphs. 

123. At all times relevant herein, Defendants were acting under color of state law. 

124. Defendants played an integral part in the prosecution of Plaintiffs when the 

cited Plaintiffs with tickets that were wholly unsupported by any legal basis or probable 

cause. 

125. Defendants prosecuted Plaintiffs with malice when they cited Plaintiffs 

despite any legal basis to do so in order to stop Plaintiffs from exercising their First 

Amendment and statutorily protected rights. 

126. Defendants prosecuted Plaintiffs with malice when they made false 

statements regarding the conduct of Plaintiffs and the ammunition possessed by Plaintiffs. 

127. Defendants demonstrated malice in prosecuting Plaintiffs through various 

other dishonest actions previously stated. 

128. Defendants did not have probable cause for citing Plaintiffs because 

Defendants never had reasonable suspicion to stop Plaintiffs, Defendants never gave 

Plaintiffs a lawful order, and Plaintiffs never engaged in any conduct which a reasonable 

officer would believe gave him or her probable cause to cite Plaintiffs. 

129. Plaintiffs’ proceedings terminated in their favor. 

130. At all times relevant, Defendants were required to obey the laws of the United 

States. 

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131. At all times relevant, Plaintiffs had a clearly established right to be free from 

malicious prosecution. 

132. At all times relevant, Defendants intentionally, knowingly, maliciously, 

recklessly, unreasonably, and/or grossly negligently furthered malicious prosecution 

against Plaintiffs. 

133. As a direct and proximate result of Defendants’ unlawful actions, Plaintiffs 

suffered damages for their physical, mental and emotional injury, and for pain, mental 

anguish, humiliation, and embarrassment.

MUNICIPAL LIABILITY 42 U.S.C. § 1983

134. Defendants Officers actions, and the actions of the Olmos Park Police 

Department in previous open carry instances demonstrate a policy practice or custom to 

deprive Plaintiffs and other open carry activists of their first amendment rights. On multiple 

occasions, individual Defendants and the Olmos Park police department have detained, 

arrested, or otherwise charged Second Amendment activists for open carrying per Texas 

State Law. 

135. Time and time again, Defendants have cited second amendment activists 

with meritless charges, only to have these charges dropped prior to trial. 

136. Despite the fact that these charges are frequently dropped, Defendants 

continue to cite Second Amendment activists in hopes to curtail the activists from 

exercising their First Amendment Rights. 

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137. Defendants’ actions and inactions constitute an impermissible policy practice 

or custom that deprive Plaintiffs of their right to be free from retaliation for protected 

conduct. 

138. At all times relevant, Plaintiffs had a clearly established right to be free from 

unlawful policies, practices, and customs. 

139. Ordinance 24-84 was unlawful as it conflicted with Texas law permitting the 

open carry of fire arms. Thus, it was an unlawful policy or custom which was the moving 

force behind Plaintiffs’ injuries. 

140. The City Council is a final policy maker for Defendant City. 

141. Even if Ordinance 24-84 was not unlawful, it was an officially adopted policy 

that had plainly obviously consequences resulting in a constitutional violation. 

142. Further, the City had notice of such recurring constitutional violations 

stemming from Ordinance 24-84. 

143. As a direct and proximate result of Defendant City’s unlawful actions, 

Plaintiffs suffered damage for their physical, mental, and emotional injury, and for pain, 

mental anguish, humiliation and embarrassment.

PRAYER FOR RELIEF 

WHEREFORE, Plaintiffs, Christopher Grisham and James Everard, demands 

judgment and prays for the following relief, jointly and severally, against all Defendants.

a. Full and fair compensatory damages in an amount to be determined by a 

jury;

b. Punitive damages in an amount to be determined by a Jury;

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c. Reasonable attorney’s fees and costs of this action; and

d. Any such other relief as appears just and proper. 

JURY DEMAND

Plaintiff hereby demands a trial by jury of all issues so triable, pursuant to Fed. R. 

Civ. P. 38(b). 

Respectfully submitted, 

EXCOLO LAW, PLLC

By: /s/ Solomon M. Radner

Solomon M. Radner 

Michigan Bar No. P73653

Attorney for Plaintiffs 

26700 Lahser Rd, Suite 401

Southfield, MI 48033

(866) 939-2656

Dated: March 26, 2020 sradner@excololaw.com

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