IN THE UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF OHIO

EASTERN DIVISION

MEGAN BOLLINGER :

7059 Dutch Lane :

Johnstown, Ohio 43031 : CASE NO

:

and : JUDGE

:

WILLIAM C. BOLLINGER :

7059 Dutch Lane :

Johnstown, Ohio 43031 :

:

Plaintiffs, :

:

v. :

:

THE VILLAGE OF JOHNSTOWN, OHIO :

559 S. Main Street :

Johnstown, Ohio 43031 : JURY DEMAND

: ENDORSED HEREON

and :

:

JASON BOWMAN :

c/o Johnstown Police Department :

559 S. Main Street :

Johnstown, Ohio 43031 :

:

and :

:

BRADLEY MAY :

c/o Johnstown Police Department :

559 S. Main Street :

Johnstown, Ohio 43031 :

:

Defendants. :

JURISDICTION AND VENUE

1. This is a civil action for money damages brought pursuant to 42 U.S.C. § 1983 and 

1988, and the Fourth and Fourteenth Amendments to the United States. 

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2. This court has original jurisdiction over Plaintiffs’ claims presented in this 

Complaint based upon the laws of the United States pursuant to 28 U.S.C. § 1331, 1341 and 1343.

3. This Court has supplemental jurisdiction over Plaintiffs’ claims presented in this 

Complaint based upon the laws of the State of Ohio pursuant to 28 U.S.C. § 1367 because these 

claims are so related to the claims in this action that are within the original jurisdiction of this 

Court, as stated above, that they form part of the same case or controversy.

4. The amount in controversy exceeds Seventy-Five Thousand ($75,000.00) Dollars, 

excluding interest, costs and attorney fees.

5. The unlawful actions alleged in this Complaint took place within the jurisdiction of 

the United States District Court for the Southern District of Ohio (Eastern Division). Venue is 

proper under 28 U.S.C. §1391(b). 

PARTIES

6. Plaintiff, Megan Bollinger, is, and at all times relevant to this action was, a 

permanent resident of the State of Ohio.

7. Plaintiff, William C Bollinger, is, and at all times relevant to this action was, a 

permanent resident of the State of Ohio

8. Defendant, The Village of Johnstown, Ohio (“Johnstown”), is a local government 

entity organized and operating under the laws of the State of Ohio. At all relevant times hereto, 

Defendant Johnstown, acting through the Johnstown Police Department was responsible for the 

policy, practice, supervision, implementation and conduct of all Johnstown Police Department 

matters and was responsible for the appointment, training, supervision, discipline and retention 

and conduct of all Johnstown Police Department personnel. In addition, at all times relevant hereto, 

Defendant Johnstown was responsible for enforcing the rules of the Johnstown Police Department 

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and for ensuring that the Johnstown Police Department personnel obey the laws of the United 

States and the State of Ohio.

9. Defendant, Jason Bowman, at all times relevant to this action, was a law 

enforcement officer acting in the course and scope of his employment with Johnstown and under 

color of law. He is sued in his individual capacity.

10. Defendant, Bradley May, at all times relevant to this action, was a law enforcement 

officer acting in the course and scope of his employment with Johnstown and under color of law. 

He is sued in her individual capacity.

FACTUAL ALLEGATIONS

11. On or about July 16, 2016, around 3:03 a.m., Defendants Bowman and May were

working patrol. May received a call from Bowman to check out 64 S. Main Street, Johnstown, 

Ohio for a possible burglary.

12. As Defendant May arrived in the area of 64 S. Main Street, he observed a number 

of individuals outside of a bar and approached them including an individual by the name of 

Sunshine Williamson. 

13. According to Defendants May and Bowman, Ms. Williamson claimed Plaintiff 

William Bollinger barged into the home of Shawn Block and was threatening Ms. Williamson.

14. At this time and all relevant times hereto, Defendant May knew Ms. Williamson 

had been in a relationship with Plaintiff William Bollinger and Defendant Bowman.

15. Defendant Bowman was present to assist Defendant May with speaking to a 

number of individuals including, but not limited to, Ms. Williamson.

16. Although Defendant May knew about the relationship between Williamson and 

Bowman, he failed to request Defendant Bowman to recuse himself from the investigation, and he 

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failed to request a different police officer to assist with any investigation and disclose to anyone 

the relationship between Defendant Bowman and Ms. Williamson.

17. At all relevant times hereto, Defendants May and Bowman were wearing body 

cameras which depicted their alleged investigation.

18. The investigation conducted by Defendants May and Bowman is inconsistent with 

what is depicted on their body cameras as well as what is set forth in their written narrative report. 

Defendants May and Bowman were urging witnesses what to say in order to file criminal charges 

against Plaintiffs.

19. Defendants May and Bowman created and/or conjured up evidence to support 

criminal charges against Plaintiffs.

20. At all relevant times hereto, Defendant Bowman was upset and jealous of the 

relationship that Plaintiff William Bollinger had with Ms. Williamson. 

21. Defendant Johnstown had knowledge of the relationship that Defendant Bowman 

had with Ms. Williamson and his animosity towards Plaintiff William Bollinger; however, 

Defendant Johnstown continued to allow Defendant Bowman to harass, any and oppress Plaintiff 

William Bollinger.

22. Based upon the fictitious investigation conducted by Defendants May and 

Bowman, Defendant May interviewed Plaintiff Megan Bollinger who denied any of the claims 

being made by Defendants including ever entering the residence at 64 South Main Street, 

Johnstown, Ohio. In addition, Plaintiff Megan Bollinger indicated that at no time did Plaintiff 

William Bollinger ever enter the premises located at 64 South Main Street. 

23. Defendant May interviewed Plaintiff William Bollinger who denied ever entering 

the premises at 64 South Main Street, Johnstown, Ohio and denied the claims that were being made 

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by Defendants relating to any criminal conduct.

24. Defendant May also interviewed another individual who indicated that at no time 

did Plaintiffs enter the residence at 64 South Main Street, Johnstown, Ohio. 

25. On or about July 16, 2016, Defendant May, without probable cause, filed a criminal 

complaint along with an arrest warrant against Plaintiff William Bollinger alleging two counts of 

trespassing, a felony of the fourth degree, and one count of assault.

26. On or about July16, 2016, Defendants, without probable cause, filed a criminal 

complaint against Megan Bollinger alleging one count of trespassing, a felony of the fourth degree. 

27. During the pendency of the charges, Defendants never disclosed to the county 

prosecutor’s office and/or any county prosecutor and/or the Court or defense attorney that 

Defendant Bowman had been in a relationship with Ms. Williamson. 

28. Plaintiffs were required to hire counsel to represent them regarding the criminal 

charges filed against them as well as post bond. 

29. Plaintiffs were required to appear in court.

30. Due to the fact that there was no probable cause to bring the charges against 

Plaintiffs, all charges against Plaintiffs were dismissed. 

31. After Plaintiffs had been criminally charged, Defendant Bowman confided in Ms.

Williamson and admitted to her that he was “the puppet master” and colluded with Defendant May 

to create evidence, coerce witnesses, and use their power to charge Plaintiffs. 

32. Defendant Bowman admitted to Ms. Williamson that he was telling Defendant May 

what to charge Plaintiff William Bollinger with and controlling the criminal process against 

Plaintiffs. 

33. Defendant Bowman was motivated by his jealousy of the relationship between Ms.

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Williamson and Plaintiff William Bollinger. 

34. During the course of Defendant Bowman’s employment Defendant Johnstown 

became aware, or should have become aware, of information that Defendant Bowman was unfit 

to serve in the capacity of a police officer, that he posed a danger to the public and that he had 

repeatedly violated the civil rights of those he was sworn to serve and protect. 

35. Prior to July 16, 2016, Johnstown was on notice of Defendant Bowman’s 

misconduct including, but not limited to, his relationship with Ms. Williamson and his animosity 

and hatred towards Plaintiff William Bollinger. 

36. As a result of his lust for Ms. Williamson and his rage of jealousy against Plaintiff 

William Bollinger, Defendant Bowman was unfit to serve in the capacity of a police officer and 

he posed a danger to Plaintiffs.

37. With this knowledge, Defendant Johnstown did not fire, reprimand, discipline, 

counsel, reassign, or retrain Defendant Bowman prior to July 16, 2016. 

FIRST CAUSE OF ACTION – (42 U.S.C §1983)

38. Plaintiffs incorporate by reference and make a part hereof all preceding paragraphs 

of this Complaint is if completely rewritten herein. 

39. Defendants have deprived Plaintiff William Bollinger of his civil constitutional and 

statutory rights under color of law and have conspired to deprive him of such rights and are liable 

to Plaintiff William Bollinger under 42 U.S.C §1983.

40. Defendants conduct deprived Plaintiff William Bollinger of his right to be free of 

unreasonable searches and seizures pursuant to the Fourth and Fourteenth Amendments of the 

United States Constitution. Defendants conduct also deprived Plaintiff of his right to due process 

of law pursuant to the Fourteenth Amendment of the United States Constitution.

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41. Defendants falsely arrested Plaintiffs and failed to intervene in the obviously illegal 

actions.

42. As a direct and proximate result of the wrongful acts of Defendants, Plaintiff 

William Bollinger has suffered a violation of his rights under the United States Constitution, 

emotional trauma and suffering, loss of liberty, pain and suffering, economic damages and other 

damages to be determined at trial.

SECOND CAUSE OF ACTION – (42 U.S.C §1983)

43. Plaintiffs incorporate by reference and make a part hereof all preceding paragraphs 

of this Complaint is if completely rewritten herein.

44. Defendants have deprived Plaintiff Megan Bollinger of her civil constitutional and 

statutory rights under color of law and have conspired to deprive her of such rights and are liable 

to Plaintiff Megan Bollinger under 42 U.S.C §1983.

45. Defendants conduct deprived Plaintiff Megan Bollinger of her right to be free of 

unreasonable searches and seizures pursuant to the Fourth and Fourteenth Amendments of the 

United States Constitution. Defendants conduct also deprived of Plaintiff of her right to due 

process of law pursuant to the Fourteenth Amendment of the United States Constitution.

46. Defendants falsely arrested Plaintiffs and failed to intervene in the obviously illegal 

actions.

47. As a direct and proximate result of the wrongful acts of Defendants, Plaintiff Megan 

Bollinger has suffered a violation of her rights under the United States Constitution, emotional 

trauma and suffering, loss of liberty, pain and suffering, economic damages and other damages to 

be determined at trial.

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THIRD CAUSE OF ACTION - (42 U.S.C §1983)

48. Plaintiffs incorporate by reference and make a part hereof all preceding paragraphs 

of this Complaint is if completely rewritten herein.

49. Defendants have deprived Plaintiff William Bollinger of his civil constitutional and 

statutory rights under color of law and have conspired to deprive him of such rights and are liable 

to Plaintiff William Bollinger under 42 U.S.C §1983.

50. Defendants conduct deprived Plaintiff William Bollinger of his right to be free of 

unreasonable searches and seizures pursuant to the Fourth and Fourteenth Amendments of the 

United States Constitution. Defendants conduct also deprived Plaintiff of his right to due process 

of law pursuant to the Fourteenth Amendment of the United States Constitution.

51. The criminal proceedings clearly were brought with malice towards Plaintiff 

William Bollinger

52. As a direct and proximate result of the wrongful acts of Defendants, Plaintiff 

William Bollinger has suffered a violation of his rights under the United States Constitution, 

emotional trauma and suffering, loss of liberty, pain and suffering, economic damages and other 

damages to be determined at trial.

FOURTH CAUSE OF ACTION - (42 U.S.C §1983)

53. Plaintiffs incorporate by reference and make a part hereof all preceding paragraphs 

of this Complaint is if completely rewritten herein.

54. Defendants have deprived Plaintiff Megan Bollinger of her civil constitutional and 

statutory rights under color of law and have conspired to deprive her of such rights and are liable 

to Plaintiff Megan Bollinger under 42 U.S.C §1983.

55. Defendants conduct deprived Plaintiff Megan Bollinger of her right to be free of 

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unreasonable searches and seizures pursuant to the Fourth and Fourteenth Amendments of the 

United States Constitution. Defendants conduct also deprived of Plaintiff of her right to due 

process of law pursuant to the Fourteenth Amendment of the United States Constitution.

56. The criminal proceedings clearly were brought with malice towards Plaintiff 

Megan Bollinger

57. As a direct and proximate result of the wrongful acts of Defendants, Plaintiff Megan

Bollinger has suffered a violation of her rights under the United States Constitution, emotional 

trauma and suffering, loss of liberty, pain and suffering, economic damages and other damages to 

be determined at trial.

FIFTH CAUSE OF ACTION – Municipal and Supervisory Liability

55. Plaintiffs incorporate by reference and make a part hereof all preceding paragraphs 

of this Complaint is if completely rewritten herein. 

56. Defendant Johnstown is liable for the damage suffered by Plaintiffs as a result of 

the conduct of their employees, agents, and servants in that after learning of their employees’

violation of Plaintiffs’ constitutional rights, they failed to remedy the wrong, they created a policy 

or custom under which unconstitutional practices occurred and allowed such policies or customs 

to continue, and they have been grossly negligent in managing subordinates who caused the 

unlawful condition or event. 

57. Defendant Johnstown has been alerted to the conduct of Defendants but 

nevertheless exhibited deliberate indifference to their conduct and that deliberate indifference is 

cause for violation of Plaintiffs’ constitutional rights in this case. 

58. Defendant Johnstown was aware of the conduct of Defendant Bowman and his 

relationship with Ms. Williamson and Defendant Bowman’s animosity toward Plaintiff William 

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Bollinger yet it failed to take any corrective action to ensure that Plaintiffs’ constitutional rights 

would not be violated. This failure and these policies caused the officers in the present case to 

violate Plaintiffs’ civil rights without fear of reprisal.

59. Plaintiffs have been damaged as a result of the deliberate indifference of Defendant 

Johnstown.

60. Defendant Johnstown is liable for the damages suffered by Plaintiffs as a result of 

the conduct of their employees, agents, and servants. Defendant Johnstown has been alerted to the 

use of false arrests and malicious prosecution by its police officers but has, nevertheless, exhibited 

deliberate indifference and that deliberate indifference has caused a violation of Plaintiffs’ 

constitutional rights.

SIXTH CAUSE OF ACTION – Negligent Hiring and Retention

61. Plaintiffs incorporate by reference and make a part hereof all preceding paragraphs 

of this Complaint is if completely rewritten herein. 

62. Defendant Johnstown, through the police department, owed a duty of care to 

Plaintiffs to present the loss of liberty and mental abuse sustained by Plaintiffs. Defendant 

Johnstown, through the police department, owed a duty of care to Plaintiffs because under the 

same or similar circumstances a reasonable, prudent, and careful person should have anticipated 

an injury to Plaintiffs or those in a position similar to Plaintiffs as a result of this conduct. 

63. Upon information and belief, Defendants Bowman and May were incompetent and 

unfit for their positions.

64. Upon information and belief, Defendant Johnstown knew or should have known 

through exercise of reasonable diligence that the Defendants were potentially dangerous and had 

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previously harassed Plaintiffs as a result of the relationship between Defendant Bowman and Ms.

Williamson.

65. Defendant Johnstown’s negligence in hiring and retaining Defendants May and 

Bowman proximately caused Plaintiffs’ injuries.

66. Because of Defendant Johnstown’s negligent hiring and retention of Defendants 

May and Bowman, Plaintiffs incurred damages.

WHEREFORE, Plaintiffs demands judgment against defendants, jointly and severally as 

follows:

(A) Reasonable and appropriate compensatory damages;

(B) Plaintiffs’ costs, expenses, and reasonable attorney’s fees pursuant to 42 U.S.C 

§1988;

(C) Punitive damages against Defendants May and Bowman and

(D) Such other relief as the Court deems necessary and proper.

Respectfully submitted,

/s/ David A. Goldstein

DAVID A. GOLDSTEIN (0064461)

DAVID A. GOLDSTEIN CO., L.P.A.

511 S. High Street, Suite 200

Columbus, Ohio 43215

(614) 222-1889

(614) 222-1899(Fax)

dgoldstein@dgoldsteinlaw.com

Attorney for Plaintiffs

JURY DEMAND

A trial by jury composed of the maximum number of jurors permitted under the law is 

hereby demanded.

/s/ David A. Goldstein

DAVID A. GOLDSTEIN (0064461)

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