UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF INDIANA

HAMMOND DIVISION

LASHAWNDA WALKER, individually and as next

friend of her children, D. W., a minor, M. H., a minor,

Z. H., a minor and M. W., a minor;

Plaintiffs,

v.

CITY OF EAST CHICAGO, ANTHONY

COPELAND (individually and in his official capacity

as Mayor of the City of East Chicago), BP

PRODUCTS NORTH AMERICA INC. (“BP”), E I

DU PONT DE NEMOURS and COMPANY

(“DuPont”), and ATLANTIC RICHFIELD

COMPANY ("ARCO"),

Defendants.

 Case No. 

 TRIAL BY JURY DEMANDED

COMPLAINT

Plaintiffs, LASHAWNDA WALKER, individually and as next of friend of her minor

children, D.W., M.H., Z.H., and M.W., by and through counsel, state as follows: 

Jurisdiction and Venue

1. This Court has jurisdiction over Plaintiffs’ 42 U.S.C. § 1983 claims pursuant to 28

U.S.C. §§ 1331, as those claims arise under the Constitution and laws of the United States. This

court has jurisdiction over Plaintiffs’ remaining claims pursuant to 28 U.S.C. § 1367 because

they are part of the same case or controversy under Article III of the United States and are related

to the claims within the Court’s original jurisdiction. 

2. This action does not present novel or complex issues of State law that predominate

over claims for which this Court has original jurisdiction. 

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3. There are no compelling reasons for declining supplemental jurisdiction over

those claims that do not arise under 42 U.S.C. § 1983.

4. Venue is proper in this court because:

a. the unlawful housing practices, the personal injuries, the constitutional and civil

rights violations, and the other wrongful acts of the Defendants alleged in this complaint have

been, and are now being committed within the Northern District of the State of Indiana;

b. the Defendants are entities with the capacity to sue and be sued in their common

names under applicable Indiana laws and subject to the court's personal jurisdiction with respect

to this civil action and venue is proper pursuant to 28 U.S.C. § 1391; and

c. the Plaintiffs reside in this district.

Parties

5. Plaintiffs, LASHAWNDA WALKER, and her minor children D.W., M.H., Z.H.

and M.W. have been residents of the West Calumet Housing Complex, which is intended for

those who are of low income, located in East Chicago, Indiana for approximately ten (10) years.

LASHAWNDA WALKER and her four (4) minor children have been exposed to extremely high

levels of lead and arsenic due to the actions of the Defendants.

6. LASHAWNDA WALKER is a member of the general public and believes there

are others similarly situated to her in that there are other members of the general public that have

been subjected to the same harms by these same Defendants.

7. As a result of Defendants’ actions, Plaintiffs have suffered past, present and future

personal injuries, including (but not necessarily limited to): various health problems, weight loss,

shortened life expectancy, miscarriage, physical pain and suffering, mental anguish, medical

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expenses, medical monitoring expenses, wage loss, brain and developmental injuries, cognitive

deficits, lost earning capacity, aggravation and exacerbation of pre-existing conditions and

contract damages. 

8. Defendant, CITY OF EAST CHICAGO (“The City”) is an Indiana municipal

corporation located in Lake County, Indiana. 

9. Defendant, CITY OF EAST CHICAGO employed ANTHONY COPELAND

who is the current mayor of the City of East Chicago. 

10. Mr. Copeland's wrongful acts were done intentionally, individually and in his

official capacity as Mayor of the City of East Chicago. As such, he was empowered to make

decisions on all matters affecting the abridged rights of the Plaintiffs.

11. Defendant CITY OF EAST CHICAGO by and through the EAST CHICAGO

HOUSING AUTHORITY (“ECHA”) provides affordable housing and low income housing

programs. ECHA is an arm of the CITY OF EAST CHICAGO and carried out the policies and

procedures of the City.

12. Defendant BP PRODUCTS NORTH AMERICA INC. (“BP”) has its headquarters

in London, England but regularly transacts business in the United States and in the State of

Indiana. 

13. Defendant E I DU PONT DE NEMOURS and COMPANY ("DuPont") has its

headquarters in Wilmington, Delaware but regularly transacts business in the State of Indiana;

Defendant ATLANTIC RICHFIELD COMPANY (“ARCO”) has its headquarters in La Palma,

California but regularly transacts business in the state of Indiana.

14. BP, ARCO and DuPont (herein referred to as the "Corporate Defendants") are and

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at all material times have been companies authorized or organized and existing under laws of the

State of Indiana, with one or more of the Corporate Defendants having offices located in Lake

County, Indiana.

15. Defendants are subject to the provisions of the United States Constitution.

Conditions Precedent

16. LASHAWNDA WALKER has begun to file her tort claims with the State of

Indiana, the City of East Chicago, and the United States agencies, as applicable.

Facts Common to all Counts

17. In 2014, DuPont and Atlantic Richfield Company entered into an agreement with

the EPA and IDEM for a $26 million cleanup of lead and arsenic contamination in East Chicago;

IDEM and the EPA failed to provide notice to the Plaintiffs or the general public regarding the

agreement and the terms of the agreement or the underlying circumstances which detrimentally

affected the property, health and lives of the Plaintiffs.

18. The combined actions of the Defendants in this matter have caused harm to the

Plaintiffs, namely by exposing them to extremely high levels of lead, arsenic and other

potentially harmful contaminants.

19. The wrongful acts of Copeland were a manifestation of the City of East Chicago's

own wrongful acts and are fairly those of the City because of his position as Mayor.

20. The City of East Chicago policies and customs supported the deliberate

concealment of dangers affecting the Plaintiffs, inter alia, and these policies and customs were

the moving force behind the conduct of its Mayor, housing authority, its legislative body, and

other employees that caused the harm to the Plaintiffs.

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21. The Indiana Department of Environmental Management (“IDEM”) is an agency of

the State of Indiana who is responsible for protecting the environment and human health. 

22. DOE 2 is believed to be a current or former director of IDEM.

23. The United States Environmental Protection Agency (“EPA”) is an agency of the

U.S. federal government who is responsible for protecting the environment and human health. 

24. DOE 3 is believed to be a current or former director of the EPA but cannot yet be

named as a Defendant pursuant to the Federal Tort Claims Act (“FTCA”). If Plaintiffs’

anticipated FTCA claims are rejected, they reserve the right to amend this complaint.

25. Should it be proven at trial that the concealment by EPA and IDEM of information

material to the rights of the Plaintiffs and the general public these entities should be prevented

from any such future act and the Plaintiffs should be afforded injunctive relief against any such

future conduct.

26. According to the World Health Organization, lead is a cumulative toxicant that

affects multiple body systems and is particularly harmful to young children. Even relatively low

levels of exposure can cause serious and irreversible neurological damage. 

27. Arsenic is highly toxic and is a carcinogen which has been associated with the

development of cancer. Arsenic poisoning typically occurs as a result of industrial exposure or in

cases of malicious intent. 

28. Defendants failed to protect the Plaintiffs and concealed the fact that lead and

arsenic were present on the premises of the West Calumet Housing Complex as Plaintiffs

continued to suffer (See Exhibit A: Letter from Mayor Anthony Copeland to Residents of the

West Calumet Housing Complex). The Defendants wrongful acts constitute fraud,

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misrepresentation, conspiracy, gross negligence and constitutional violations, for which the

IDEM, the Director of IDEM, the EPA, the Director of the EPA, the ECHA, the Director of

ECHA, the City of East Chicago and Anthony Copeland are not afforded immunity. 

29. The Corporate Defendants deposited the above-mentioned lead, arsenic and other

potential contaminants, on the site that is now the West Calumet Housing Complex.

30. As a direct and proximate result of Defendants’ actions and failures to act,

Plaintiffs’ constitutional rights have been violated and Plaintiffs have suffered serious physical,

mental and emotional injuries, as described in this complaint. 

COUNT I: 42 U.S.C. § 1983 – Substantive Due Process – State Created Danger

(Against Defendant the City of East Chicago)

31. Plaintiffs hereby incorporate allegations in paragraphs 1 through 30 of this

complaint as though fully restated herein. 

32. Plaintiffs, in this action, are citizens of the United States and all of the Defendants

are persons for purposes of 42 U.S.C. § 1983. 

33. All Defendants, at all times relevant hereto, were acting under the color of law in

their individual and official capacity as State and City officials, and their acts and/or omissions

were conducted within the scope of their official duties and employment. 

34. Policies and procedures of the EPA, IDEM, ECHA and the City of East Chicago

condoned and effectuated the wrongdoing of the individual government officials.

35. Plaintiffs herein, at all times relevant hereto, have a clearly established

Constitutional right under, inter alia, the Fourteenth Amendment, such that a city or state cannot

deprive a person of their life, liberty or property without due process of law. 

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36. Defendants each acted to expose the Plaintiffs to arsenic and lead and other

potentially harmful contaminants.

37. Defendants actions and omissions were malicious and involved reckless, callous

and deliberate indifference to Plaintiffs’ federally protected rights. These actions shock the

conscience of any reasonable person and violate the constitutional rights of the Plaintiffs.

38. The City of East Chicago, ECHA, EPA and IDEM or its predecessor agency knew

for more than thirty (30) years that the West Calumet Housing Complex had issues with lead and

arsenic poisoning. 

39. Mayor Anthony Copeland also had personal knowledge of the contaminants

(namely lead and arsenic) present at the West Calumet Housing Complex. 

40. In July of 2012, the EPA proposed a cleanup for the residential area that includes

the West Calumet Housing Complex. 

41. Plaintiffs and other residents of the West Calumet Housing Complex were never

told about the extremely high levels of lead and arsenic until July of 2016.

42. Consequently, the above-mentioned Defendants intentionally withheld this

information from the Plaintiffs. 

43. Defendants concealed and hid said information that demonstrated the danger the

Plaintiffs faced. 

44. Defendants acted with deliberate indifference to a known and obvious danger. 

45. Defendants created and increased the danger facing the Plaintiffs.

46. As a result of Defendants’ actions, Plaintiffs have suffered past, present and future

personal injuries, including (but not necessarily limited to): various health problems, weight loss,

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shortened life expectancy, miscarriage, physical pain and suffering, mental anguish, medical

expenses, medical monitoring expenses, wage loss, brain and developmental injuries, cognitive

deficits, lost earning capacity, aggravation and exacerbation of pre-existing conditions and

contract damages. 

COUNT III: 42 U.S.C. § 1983 – Fourteenth Amendment – Equal Protection & Privileges or

Immunities Clause (Against Defendant City of East Chicago)

47. Plaintiffs hereby incorporate allegations in paragraphs 1 through 46 of this

complaint as though fully restated herein. 

48. Defendants acted in concert and joint action to violate the Equal Protection Clause

and the Privileges and Immunities Clause of the Fourteenth Amendment. 

49. Plaintiffs are members of a protected class and were unlawfully discriminated

against because of the color of their skin and their race, which is African American. 

50. Plaintiffs are residents of the West Calumet Housing Complex, which

predominantly consists of African Americans and other minorities. 

51. The City had no compelling interest for discriminating against and treating the

Plaintiffs differently because of their race.

52. Plaintiffs were deprived of their constitutional rights, specifically the Equal

Protection Clause of the Fourteenth Amendment but also the Privileges and Immunities Clause

of the United States Constitution.

53. Defendants’ actions were intentional, malicious, willful, wanton and in gross and

reckless disregard of Plaintiffs’ constitutional rights. 

54. As a direct and proximate result of the Defendants’ unlawful actions and/or

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failures to act, Plaintiffs have suffered past, present and future personal injuries, including (but

not necessarily limited to): various health problems, weight loss, shortened life expectancy,

miscarriage, physical pain and suffering, mental anguish, medical expenses, medical monitoring

expenses, wage loss, brain and developmental injuries, cognitive deficits, lost earning capacity,

aggravation and exacerbation of pre-existing conditions, compensatory and special damages.

COUNT IV: 42 U.S.C. § 1983 – Substantive Due Process – Bodily Integrity

(Against Defendant City of East Chicago)

55. Plaintiffs hereby incorporate allegations in paragraphs 1 through 54 of this

complaint as though fully restated herein. 

56. Plaintiffs, in this action, are citizens of the United States and all of the Defendants

are persons for purposes of 42 U.S.C. § 1983. 

57. All Defendants, at all times relevant hereto, were acting under the color of law in

their individual and official capacity as State and City officials, and their acts and/or omissions

were conducted within the scope of their official duties and employment. 

58. Plaintiffs have a clearly established right to bodily integrity under the Fourteenth

Amendment.

59. At all times relevant hereto, that right is and has been well established.

60. In exposing Plaintiffs to arsenic, lead and other possible contaminants, Defendants

violated Plaintiffs’ right to bodily integrity.

61. Defendants failed to protect the Plaintiffs from a foreseeable risk of harm from

exposure to lead, arsenic and other possible contaminants.

62. As a result of Defendants’ actions and/or omissions, Plaintiffs suffered bodily

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harm and their rights to bodily integrity were violated. 

63. Defendants actions and omissions were malicious, reckless, and/or were made

with deliberate indifference to Plaintiffs’ constitutional rights. Defendants engaged in these acts

willfully, maliciously, in bad faith, and/or in reckless disregard for Plaintiffs’ constitutional

rights.

64. These actions shock the conscience of the Plaintiffs and of any reasonable person.

65. As a result of the Defendants’ unlawful conduct, Plaintiffs have suffered injuries

and seek relief.

66. Defendants’ actions and/or omissions were the proximate cause of the Plaintiffs’

injuries.

67. As a direct and proximate result of all of the Defendants’ actions and/or failures to

act, Plaintiffs have suffered past, present and future personal injuries, including (but not

necessarily limited to): various health problems, weight loss, shortened life expectancy,

miscarriage, physical pain and suffering, mental anguish, medical expenses, medical monitoring

expenses, wage loss, brain and developmental injuries, cognitive deficits, lost earning capacity,

aggravation and exacerbation of pre-existing conditions, contract and punitive damages.

COUNT V: 42 U.S.C. § 1983 – Procedural Due Process – Deprivation of a Contractually

Created Property Right (Against Defendant City of East Chicago)

68. Plaintiffs hereby incorporate allegations in paragraphs 1 through 67 of this

complaint as though fully restated herein. 

69. Lashawnda Walker entered into a lease agreement (See Exhibit B) with the East

Chicago Housing Authority, which is authorized to carry out rental abilities by the City of East

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Chicago, as its agent. 

70. Defendants deprived Plaintiffs of their contractually based property right, pursuant

to the lease agreement, without proper notice or hearing. 

71. Defendants have not provided Plaintiffs with just compensation for their taking of

Plaintiffs’ property interests. 

72. Defendants’ actions and/or omissions were the proximate cause of the Plaintiffs’

injuries.

73. As a direct and proximate result of all of the Defendants’ actions and/or failures to

act, Plaintiffs have suffered past, present and future personal injuries, including (but not

necessarily limited to): various health problems, weight loss, shortened life expectancy,

miscarriage, physical pain and suffering, mental anguish, medical expenses, medical monitoring

expenses, wage loss, brain and developmental injuries, cognitive deficits, lost earning capacity,

aggravation and exacerbation of pre-existing conditions, contract, and punitive damages.

COUNT VI: Conspiracy (Against All Defendants)

74. Plaintiffs hereby incorporate allegations in paragraphs 1 through 73 of this

complaint as though fully restated herein. 

75. The Defendants had an agreement together to unlawfully and deliberately deprive

Plaintiffs of their rights, to misrepresent the West Calumet Housing complex as safe and to

expose the Plaintiffs to lead, arsenic and other potentially harmful contaminants. 

76. Defendants’ actions and/or omissions were the proximate cause of the Plaintiffs’

injuries.

77. As a direct and proximate result of all of the Defendants’ actions and/or failures to

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act, Plaintiffs have suffered past, present and future personal injuries, including (but not

necessarily limited to): various health problems, weight loss, shortened life expectancy,

miscarriage, physical pain and suffering, mental anguish, medical expenses, medical monitoring

expenses, wage loss, brain and developmental injuries, cognitive deficits, lost earning capacity,

aggravation and exacerbation of pre-existing conditions, contract, and punitive damages.

COUNT VII: Personal Injury (Against Corporate Defendants)

78. Plaintiffs hereby incorporate allegations in paragraphs 1 through 77 of this

complaint as though fully restated herein. 

79. DuPont and Atlantic Richfield have entered into an agreement with the EPA and

IDEM for a $26 million cleanup of lead and arsenic contamination in East Chicago.

80. DuPont and Atlantic Richfield contributed to more than a century of lead and

arsenic contamination, in East Chicago, including what is now the West Calumet Housing

Complex.

81. As such, DuPont and Atlantic Richfield contributed to Plaintiffs’ exposure to lead

and arsenic. 

82. Atlantic Richfield was acquired by BP and is part of the BP Group.

83. The Corporate Defendants had a duty to prevent their operations from

contaminating the environment where the Plaintiffs reside, to clean up the environment where the

Plaintiffs reside, to inform the Plaintiffs of the dangerous environment where they resided, and to

generally protect the wellbeing of the Plaintiffs and the general public from the harmful

contaminants for which these Defendants had information but failed to act.

84. The wrongful acts of the Corporate Defendants constituted gross negligence

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because they were so reckless and demonstrated a substantial lack of concern for whether an

injury would result. 

85. As a result of the actions of these Defendants, Plaintiffs suffered injuries including

but not limited to personal injuries, illnesses and exposure to toxic substances. 

86. These Defendants’ actions and/or omissions were the proximate cause of the

Plaintiffs’ injuries. 

87. As a result of these Defendants’ actions and/or failures to act, Plaintiffs have

suffered past, present and future personal injuries including (but not necessarily limited to):

various health problems, weight loss, shortened life expectancy, miscarriage, physical pain and

suffering, mental anguish, medical expenses, medical monitoring expenses, wage loss, brain and

developmental injuries, cognitive deficits, lost earning capacity, aggravation and exacerbation of

pre-existing conditions, contract damages and punitive damages. 

COUNT VIII: Breach of Contract and Implied Warranty 

(Against Defendant City of East Chicago)

88. Plaintiffs hereby incorporate allegations in paragraphs 1 through 87 of this

complaint as though fully restated herein. 

89. In order to live at the West Calumet Housing Complex, Lashawnda Walker

entered into a lease agreement (See Exhibit B) with the East Chicago Housing Authority, which

is authorized to carry out rental abilities by the City of East Chicago as its agent. 

90. By signing the lease agreement, Lashawnda Walker agreed to pay rent for residing

at the West Calumet Housing Complex.

91. The ECHA, as Management, was obligated to maintain the premises in a decent,

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safe and sanitary condition. 

92. The ECHA, City of East Chicago and its Mayor promised and impliedly promised

that the West Calumet Housing Complex was fit for human habitation. 

93. The ECHA, City of East Chicago and its Mayor have admitted that the West

Calumet Housing Complex is highly contaminated with lead and arsenic (See Exhibit A) and

therefore, clearly not fit for human habitation.

94. The City of East Chicago and its Mayor materially and irreparably breached this

contract and the implied warranty of habitability by failing to provide a safe environment for

Lashawnda Walker and her four (4) minor children and instead exposing Plaintiffs to a harmful

and contaminated environment that is and was unfit for human habitation. 

95. As a result of these Defendants’ breach, Plaintiffs suffered damages for all

amounts billed, charged and/or collected, whether paid or unpaid. 

96. Defendants’ actions and/or omissions were the proximate cause of the Plaintiffs’

injuries. 

97. As a direct and proximate result of the Defendants’ actions and/or failures to act,

Plaintiffs have suffered past, present and future personal injuries, including (but not necessarily

limited to): various health problems, weight loss, shortened life expectancy, miscarriage, physical

pain and suffering, mental anguish, medical expenses, medical monitoring expenses, wage loss,

brain and developmental injuries, cognitive deficits, lost earning capacity, aggravation and

exacerbation of pre-existing conditions, contract damages and exemplary damages.

COUNT IX: Fraud and Misrepresentation (City of East Chicago)

98. Plaintiffs hereby incorporate allegations in paragraphs 1 through 97 of this

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complaint as though fully restated herein. 

99. The City of East Chicago and its Mayor fraudulently misrepresented to the

Plaintiffs that the West Calumet Housing Complex was safe and fit for human habitation. 

100. This representation was clearly false since the City of East Chicago and its Mayor

have admitted that the West Calumet Housing Complex is highly contaminated with lead and

arsenic (See Exhibit A) and therefore, clearly unsafe and unfit for human habitation.

101. Based on these fraudulent misrepresentations, Lashawnda Walker was induced to

enter into the lease agreement with the East Chicago Housing Authority. 

102. The City and its Mayor failed to disclose material facts, that would be relevant

before signing of the lease.

103. The City and its Mayor wrongfully and deliberately deceived the Plaintiffs with

the intent of financial and personal gain and also, to deprive the Plaintiffs of their legal rights. 

104. As a result of these Defendants’ fraudulent misrepresentations, Plaintiffs suffered

damages.

105. Defendants’ actions and/or omissions were the proximate cause of the Plaintiffs’

injuries. 

106. As a direct and proximate result of the Defendants’ actions and/or failures to act,

Plaintiffs have suffered past, present and future personal injuries, including (but not necessarily

limited to): various health problems, weight loss, shortened life expectancy, miscarriage, physical

pain and suffering, mental anguish, medical expenses, medical monitoring expenses, wage loss,

brain and developmental injuries, cognitive deficits, lost earning capacity, aggravation and

exacerbation of pre-existing conditions, contract damages and exemplary damages. 

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COUNT X: Trespass (Against all Defendants)

107. Plaintiffs hereby incorporate allegations in paragraphs 1 through 106 of this

complaint as though fully restated herein. 

108. Defendants’ negligent, grossly negligent, willful, and/or wanton conduct and/or

failures to act caused contaminants (namely lead and arsenic) to enter upon the West Calumet

Housing Complex and subsequently onto the Plaintiffs’ person.

109. Upon information and belief, Defendants had exclusive control over the premises

of the West Calumet Housing Complex at all relevant times.

110. Defendants, knowingly or in circumstances under which they should have known,

engaged in deliberate actions that released contaminants, which were substantially certain to

invade the West Calumet Housing Complex, where Plaintiffs resided. 

111. Defendants actions were done with actual malice or wanton, reckless or willful

disregard for Plaintiffs’ rights and/or safety. 

112. Defendants’ actions and/or omissions were the proximate cause of the Plaintiffs’

injuries. 

113. As a direct and proximate result of the Defendants’ actions and/or failures to act,

Plaintiffs have suffered past, present and future personal injuries, including (but not necessarily

limited to): various health problems, weight loss, shortened life expectancy, miscarriage, physical

pain and suffering, mental anguish, medical expenses, medical monitoring expenses, wage loss,

brain and developmental injuries, cognitive deficits, lost earning capacity, aggravation and

exacerbation of pre-existing conditions, contract damages and exemplary damages.

Jury Demand

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COMES NOW the Plaintiffs, by counsel, and demands trial by jury for all counts.

WHEREFORE, premises considered, the Plaintiffs, by counsel, request that this Court

demand judgment against the Defendants, jointly and severally, and issue: 

1) an order declaring the conduct of the Defendants unconstitutional;

2) an order of equitable relief to establish a medical monitoring fund;

3) an order for an award of general damages, compensatory damages and punitive damages;

4) an order for an award of attorney fees and litigation expenses; 

5) any and all appropriate injunctive relief; and 

6) an order for all other relief that is just and proper, in the premises. 

Respectfully submitted,

 /s/ Maryam Hassani 

Maryam Hassani #31728-49

Zamudio Law Professionals, PC

233 South Colfax

Griffith, Indiana 46319

Phone (219) 924-2300

Fax (219) 924-2401

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