UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION 

DARREN SHANNON, 

 Plaintiff, Case No. 

 Hon. 

v. 

MICHIGAN DEPARTMENT OF CORRECTIONS, 

RAYMOND BOOKER, KENNETH ROMANOWSKI, 

WENDY LANE, KEVIN MAYFIELD, DARRYL 

BROOKS, AND OTHER UNKNOWN EMPLOYEES OF 

MICHIGAN DEPARTMENT OF CORRECTIONS 

in their individual and official capacities, 

 Defendants. 

_____________________________________________________________________________/ 

CHRISTOPHER TRAINOR & ASSOCIATES 

CHRISTOPHER J. TRAINOR (P42449) 

Attorneys for Plaintiff 

9750 Highland Road 

White Lake, Michigan 48386 

248-886-8650 

_____________________________________________________________________________/ 

THERE IS NO OTHER PENDING OR RESOLVED CIVIL ACTION ARISING OUT OF THE TRANSACTION OR 

OCCURRENCE ALLEGED IN THE COMPLAINT 

COMPLAINT AND JURY DEMAND

NOW COMES Plaintiff, DARREN SHANNON, by and through his attorney, 

CHRISTOPHER TRAINOR & ASSOCIATES, and for his Complaint against the above named 

Defendants, states as follows: 

1. Plaintiff is a resident of City of Detroit, County of Wayne, State of Michigan. 

2. At all relevant times herein, Plaintiff was a prisoner housed at Mound Correctional 

Facility (“MCF”) located in the County of Wayne, State of Michigan. 

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3. Defendant Michigan Department of Corrections (“MDOC”) is a governmental 

subdivision organized and existing under the laws of the State of Michigan. 

4. Defendant RAYMOND BOOKER is and/or was MDOC Warden of MCF, and at all 

relevant times herein, he was acting in his individual and official capacities, under 

color of law, and within the course and scope of his employment. 

5. Defendant KENNETH ROMANOWSKI is and/or was MDOC Warden of MCF, and 

at all relevant times herein, he was acting in his individual and official capacities, 

under color of law, and within the course and scope of his employment. 

6. Defendant WENDY LANE is and/or was the Assistant Resident Unit Supervisor of 

MCF, and at all relevant times herein, she was acting in her individual and official 

capacities, under color of law, and within the course and scope of her employment. 

7. Defendant KEVIN MAYFIELD is and/or was a Resident Unit Officer of MCF, and at 

all relevant times herein, he was acting in his individual and official capacities, under 

color of law, and within the course and scope of his employment. 

8. Defendant DARRYL BROOKS is and/or was a Resident Unit Officer of MCF, and at 

all relevant times herein, he was acting in his individual and official capacities, under 

color of law, and within the course and scope of his employment. 

9. All relevant events giving rise to this lawsuit occurred in the County of Wayne, State 

of Michigan. 

10. Jurisdiction is vested in this Court pursuant to 28 U.S.C. § 1331 [federal question], 28 

U.S.C. § 1343 [civil rights]. 

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11. That this lawsuit arises out of Defendants’ violations of Plaintiff’s federal 

constitutional rights as secured by the Eighth and Fourteenth Amendments of the 

United States Constitution and consequently, Plaintiff has a viable claim for damages 

under 42 U.S.C. § 1983. Plaintiff also brings claims under state law. 

12. That the amount in controversy exceeds Seventy-Five Thousand Dollars ($75,000.00) 

not including interest, costs, and attorney fees. 

FACTS

13. Plaintiff realleges and incorporates by reference each and every paragraph of this 

Complaint as though fully set forth herein. 

14. On February 8, 2007, Plaintiff was incarcerated within the Michigan Department of 

Corrections at MCF and housed in housing unit 200 and was scheduled to be released 

from MCF on February 13, 2007. 

15. During his stay at MCF, Plaintiff was in the Michigan Prisoner Re-Entry Initiative 

(“MPRI”) which is a low level security program that transitions prisoners from prison 

life to the community. 

16. Upon information and belief, it is a policy of Defendant MDOC that all prisoners are 

to be secured in their cells during a formal prisoner count. 

17. While a formal prisoner count was being conducted on February 8, 2007, Defendant 

MAYFIELD ordered Plaintiff, who was secured in his cell, to Defendant LANE’S 

office. 

18. Plaintiff complied with the order and went to Defendant LANE’s office even though 

it was during formal prisoner count. 

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19. When Plaintiff arrived at Defendant LANE’s office, she had paperwork for him to 

complete regarding the MPRI program. 

20. While Plaintiff was speaking with Defendant LANE, prisoner Carlos Lott (“Lott”) 

entered the room where he demanded to speak to Defendant LANE immediately. 

21. There was no reason for Lott to be out of his cell and in Defendant Lane’s office 

because it was during formal prisoner count. 

22. Lott left Defendant LANE’s office and then re-entered in which a heated argument 

erupted between Lott and Defendant LANE while Plaintiff was present. 

23. During such argument, Plaintiff requested to Defendant LANE that she dismiss him 

from her office and allow him to return to his cell. 

24. Defendant LANE denied Plaintiff’s request and demanded that he sit down and wait 

until she was finished arguing with Lott. 

25. Lott then turned to Plaintiff and shouted “what do you have to do with this” in which 

Plaintiff did not reply but requested again to Defendant LANE that he be dismissed to 

this cell because he feared for his safety. 

26. Defendant LANE again denied Plaintiff’s request and ordered him to remain seated in 

her office. 

27. At such time, Lott screamed at Plaintiff “you are not going anywhere” and left the 

office. 

28. While Plaintiff was seated, Lott returned to Defendant LANE’s office and 

immediately jumped on Plaintiff and began to stab him continuously with an eight 

inch shank. 

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29. Plaintiff instantly jumped up and Lott pushed him to the floor and began to stab him 

causing Plaintiff to scream for help. 

30. Upon information and belief, Defendant BROOKS and/or another unknown officer 

were supposed to be outside Defendant LANE’s office and could have prevented Lott 

from stabbing Plaintiff. 

31. After stabbing Plaintiff six (6) times, Lott left the office. 

32. Plaintiff was then transported to Detroit Receiving Hospital for medical treatment of 

his injuries. 

33. Plaintiff remained at Detroit Receiving Hospital over night, whereupon he was 

returned to MCF and placed into solitary confinement for no reason whatsoever. 

34. Plaintiff was forced to stay in solitary confinement for four (4) days. 

35. Plaintiff was subsequently released from MCF on parole on February 13, 2007. 

COUNT I

42 U.S.C. § 1983

EIGHTH AMENDMENT 

CRUEL AND UNUSUAL PUNISHMENT

36. Plaintiff realleges and incorporates by reference each and every paragraph of this 

Complaint as though fully set forth herein. 

37. The Eighth Amendment to the United States Constitution prohibits cruel and unusual 

punishment. 

38. The Eighth Amendment imposes the following duties on Defendants: 

 a. to provide humane conditions of confinement; 

b. to take reasonable measures to guarantee inmates’ safety; and 

 c. to protect inmates from harm. 

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39. Defendants displayed a conscious disregard of the dangers that were apparent to 

Plaintiff and displayed a deliberate indifference to Plaintiff’s safety and health when 

they knowingly and deliberately exposed him to a dangerous prisoner. 

40. Defendants’ actions in denying Plaintiff those rights is a violation of his rights as set 

forth and enforced by 42 U.S.C. §1983 and the constitutional rights afford to him by 

the Eighth Amendment of the United States Constitution. 

41. At all pertinent times, the individual Defendants were acting in both their individual 

and official capacities and under color of law and therefore owed Plaintiff the duty to 

avoid a violation of his constitutionally guaranteed civil rights. 

42. That as a direct and proximate result of Defendants’ unlawful actions against Plaintiff 

as described above, Plaintiff has suffered injuries and damages. 

43. As a result of Defendants’ violation/deprivation of Plaintiff’s constitutional rights, 

Plaintiff has a viable claim for compensatory and punitive damages pursuant to 42 

U.S.C. § 1983 together with costs, interest and attorney fees pursuant to 42 U.S.C. § 

1988. 

WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an award 

in his favor and against Defendants in an amount in excess of Seventy-Five Thousand Dollars 

($75,000.00) exclusive of interest, costs, and attorney fees. 

COUNT II

42 U.S.C. § 1983

14TH AMENDMENT DUE PROCESS

44. Plaintiff realleges and incorporates by reference each and every paragraph of this 

Complaint as though fully set forth herein. 

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45. Plaintiff has a right to be free from inmate violence and such right is secured by the 

Due Process Clause of the Fourteenth Amendment of the United States Constitution. 

46. Notwithstanding the liberty interest at issue, Defendants made a conscious decision to 

expose Plaintiff to a known and substantial risk of severe injury by ordering that 

Plaintiff remain outside his cell and in the close proximity of a known dangerous 

prisoner. 

47. The affirmative action of ordering Plaintiff to remain in a known dangerous 

environment is conscious shocking as it was intended to directly cause harm to 

Plaintiff. 

48. At all pertinent times, the individual Defendants were acting in both their individual 

and official capacities and under color of law and therefore owed Plaintiff the duty to 

avoid a violation of his constitutionally guaranteed civil rights. 

49. That as a direct and proximate result of Defendants’ unlawful actions against Plaintiff 

as described above, Plaintiff has suffered injuries and damages. 

50. As a result of Defendants’ violation/deprivation of Plaintiff’s constitutional rights, 

Plaintiff has a viable claim for compensatory and punitive damages pursuant to 42 

U.S.C. § 1983 together with costs, interest and attorney fees pursuant to 42 U.S.C. § 

1988. 

WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an award 

in his favor and against Defendants in an amount in excess of Seventy-Five Thousand Dollars 

($75,000.00) exclusive of interest, costs, and attorney fees. 

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COUNT III

CONSTITUTIONAL VIOLATIONS OF 

MICHIGAN DEPARTMENT OF CORRECTIONS

51. Plaintiff realleges and incorporates by reference each and every paragraph of this 

Complaint as though fully set forth herein. 

52. At all pertinent times, the individual Defendants were acting in both their individual 

and official capacities and under color of law and therefore owed Plaintiff the duty to 

avoid a violation of his constitutionally guaranteed civil rights. 

53. Acting intentionally, recklessly and/or with deliberate indifference, Defendant 

Michigan Department of Corrections practiced and/or permitted customs and/or 

policies which resulted in the violations of Plaintiff’s constitutional rights complained 

of herein. 

54. These customs, policies, and/or practices included, but were not limited to the 

following: 

a. Failure to supervise its corrections officers to insure that they are acting in 

the best interest of those in its custody so at to prevent unnecessary 

injuries as a result of improper attention; 

b. Failure to train its corrections officers in the proper policies and 

procedures for formal prisoner counts; 

c. Failure to supervise, review, and/or discipline its corrections officers 

whom it knew or should have known were acting contrary to policies and 

procedures involving safeguarding the health, safety, and well-being of 

citizens in custody. 

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55. Defendants’ actions in denying Plaintiff those rights is a violation of Plaintiff’s rights 

as set forth and enforced by 42 U.S.C. § 1983 and the constitutional rights afforded to 

Plaintiff by the Due Process Clause of the Fourteenth Amendment of the U.S. 

Constitution. 

56. That as a direct and proximate result of Defendants’ unlawful actions against Plaintiff 

as described above, Plaintiff has suffered injuries and damages. 

57. As a result of Defendants’ violation/deprivation of Plaintiff’s constitutional rights, 

Plaintiff has a viable claim for compensatory and punitive damages pursuant to 42 

U.S.C. § 1983 together with costs, interest and attorney fees pursuant to 42 U.S.C. § 

1988. 

WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an award 

in his favor and against Defendants in an amount in excess of Seventy-Five Thousand Dollars 

($75,000.00) exclusive of interest, costs, and attorney fees. 

COUNT IV

GROSS NEGLIGENCE

58. Plaintiff realleges and incorporates by reference each and every paragraph of this 

Complaint as though fully set forth herein. 

59. At all pertinent times, the individual Defendants were acting in both their individual 

and official capacities and under color of law and therefore owed Plaintiff the duty to 

avoid a violation of his constitutionally guaranteed civil rights. 

60. The individually-named Defendants had a duty to perform their employment 

activities so as not to endanger or cause harm to individuals. 

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61. Nevertheless, in performing their duties, the individually-named Defendants breached 

this duty by acting indifferently or by acting in a grossly negligent manner without 

regard to Plaintiff’s welfare. 

62. The individual Defendants either knew or should have known that breach of these 

duties would cause harm to Plaintiff. 

63. Defendants’ indifferent/grossly negligent acts and/or omissions caused Plaintiff to 

suffer damages. 

64. As a direct and proximate result of Defendants’ intentional and/or reckless conduct, 

Plaintiff suffered severe emotional distress and the damages described herein. 

 65. As a direct and proximate result of Defendants’ actions against Plaintiff as described, 

Plaintiff has suffered injuries and damages, including, but not limited to, loss of 

earnings and earning capacity; loss of career opportunities; loss of reputation and 

esteem in the community; mental and emotional distress; and loss of the ordinary 

pleasures of life. 

66. Defendants’ actions were so outrageous that Plaintiff’s damages were heightened and 

made more severe, thus Plaintiff is entitled to exemplary damages. 

WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an award 

in his favor and against Defendants in an amount in excess of Seventy-Five Thousand Dollars 

($75,000.00) exclusive of interest, costs, and attorney fees. 

Respectfully submitted, 

 CHRISTOPHER TRAINOR & ASSOCIATES 

BY:s/Christopher J. Trainor

 CHRISTOPHER TRAINOR (P42449) 

 Attorneys for Plaintiff 

 9750 Highland Road 

Dated: February 3, 2009 White Lake, MI 48386 

CJT/ajd (248) 886-8650 

Robin.woodhull@cjtrainor.com 

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UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION 

DARREN SHANNON, 

Plaintiff, Case No. 

 Hon. 

v. 

MICHIGAN DEPARTMENT OF CORRECTIONS, 

RAYMOND BOOKER, KENNETH ROMANOWSKI, 

WENDY LANE, KEVIN MAYFIELD, DARRYL BROOKS, 

AND OTHER UNKNOWN EMPLOYEES OF 

MICHIGAN DEPARTMENT OF CORRECTIONS 

in their individual and official capacities, 

 Defendants. 

_____________________________________________________________________________/ 

CHRISTOPHER TRAINOR & ASSOCIATES 

CHRISTOPHER J. TRAINOR (P42449) 

Attorneys for Plaintiff 

9750 Highland Road 

White Lake, Michigan 48386 

248-886-8650 

_____________________________________________________________________________/ 

DEMAND FOR JURY TRIAL

NOW COMES Plaintiff, DARREN SHANNON, by and through his attorney, 

CHRISTOPHER TRAINOR & ASSOCIATES, and hereby makes a Demand for Trial by Jury in 

the above-entitled cause. 

Respectfully submitted, 

 CHRISTOPHER TRAINOR & ASSOCIATES 

BY:s/Christopher J. Trainor

 CHRISTOPHER TRAINOR (P42449) 

 Attorneys for Plaintiff 

 9750 Highland Road 

Dated: February 3, 2009 White Lake, MI 48386 

CJT/ajd (248) 886-8650 

 Robin.woodhull@cjtrainor.com

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