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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

ANTRON ADAMS, )

)

Plaintiff, )

)

v. ) No. 

)

CITY OF CHICAGO and CHICAGO POLICE )

OFFICERS EDWARD ZEMAN, Star #19750, )

DIANA KLAUS, Star #15865, and JEFFREY )

DOHNAL, Star #13529, )

)

Defendants. )

COMPLAINT

NOW COMES the Plaintiff, ANTRON ADAMS, by and through counsel, BRANDON 

BROWN, THE BROWN LAW LTD., and complaining of the defendants, CITY OF CHICAGO and 

CHICAGO POLICE OFFICERS EDWARD ZEMAN, Star #19750, DIANA KLAUS, Star 

#15865, and JEFFREY DOHNAL, Star #13529, states as follows:

INTRODUCTION

This is a civil action seeking damages against defendants for committing acts under color 

of law, and depriving Plaintiff of his rights secured by the Constitution and laws of the United 

States of America. 

JURISDICTION

1. This action is brought pursuant to the Civil Rights Act, 42 U.S.C. § 1983, and the Fourth 

and Fourteenth Amendments to the United States Constitution. 

2. The jurisdiction of this Court is invoked pursuant to the judicial code 28 U.S.C. § 1331 

and 1343 (a); the Constitution of the United States; and pendent jurisdiction as provided 

under U.S.C. § 1367(a).

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PARTIES

3. PLAINTIFF ANTRON ADAMS is a citizen of the United States of America, who, at all 

times relevant, resided in Cook County, Illinois.

4. DEFENDANTS ZEMAN, Star #19750, KLAUS, Star #15865, and DOHNAL, Star 

#13529, (“Defendant Officers”), were, at the time of this occurrence, duly licensed 

Chicago Police Officers. They engaged in the conduct complained of in the course and 

scope of their employment and under color of law. They are sued in their individual 

capacities. 

5. DEFENDANT CITY OF CHICAGO (“City”) is a municipal corporation duly 

incorporated under the laws of the State of Illinois, and is the employer and principal of 

Defendant Officers. 

FACTS

6. On March 20, 2020, at or around 2:40 pm, Plaintiff ANTRON ADAMS was standing

near a Bus Stop located at or around 420 S. Damen Avenue, Chicago, Illinois.

7. Defendant Officers, without reasonable and articulable suspicion or any other lawful 

basis, initiated a Terry stop on Plaintiff ANTRON ADAMS.

8. At the initiation of the Terry stop or anytime thereafter, Plaintiff ANTRON ADAMS was 

not engaged in any criminal or suspicious activity. 

9. Defendant Officers upon initiating contact with ANTRON ADAMS, while using

excessive force against Plaintiff ANTRON ADAMS, tackled and severely attacked 

ANTRON ADAMS. The force used against Plaintiff was objectively unreasonable and 

required immediate medical care and the hospitalization of ANTRON ADAMS. 

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10. Plaintiff ANTRON ADAMS was then arrested by Defendant Officers. Plaintiff’s arrest 

was made without a warrant. Immediately before he was arrested by the Defendant 

Officers, Plaintiff was not violating any laws, rules or ordinances. As the Plaintiff was 

being arrested, he was not violating any laws, rules, or ordinances. There was no probable 

cause or justification for the arrest of Plaintiff ANTRON ADAMS on March 20, 2020.

11. At the time that Plaintiff was arrested, Defendant Officers knew that there was no 

probable cause or legal justification to arrest the Plaintiff.

12. The acts of the Defendant Officers were intentional, willful and wanton and pursuant to 

the policy or custom of the Chicago Police Department wherein they apply the use of 

excessive force and hastily arrest innocent citizens as an investigatory technique. 

13. The excessive force used against Plaintiff was captured on video. Plaintiff ANTRON 

ADAMS requested the footage pursuant to a Freedom of Information Act Request, to 

which the Chicago Police Department has not fully complied.

14. As a direct and proximate result of the unlawful actions of the defendants, Plaintiff was

injured, including physical injuries, pain and suffering, humiliation, embarrassment, fear, 

emotional trauma, mental anguish, the deprivation of their constitutional rights and 

dignity, interference with a normal life, lost time, and attorneys’ fees.

COUNT I: 42 U.S.C. § 1983 – Excessive Force

15. Plaintiff re-alleges the above paragraphs as though fully set forth herein.

16. The actions of the Defendant Officers Zeman, Klaus and Dohnal constituted 

unreasonable, unjustifiable, and excessive force against Plaintiff, thus violating his rights 

under the Fourth Amendment to the Constitution of the United States and 42 U.S.C. 

§1983.

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17. As a direct and proximate result of the above-detailed actions of the defendants, Plaintiff 

was injured, including severe pain, physical injury, mental suffering, anguish and 

humiliation, emotional distress, and fear. 

WHEREFORE the Plaintiff, ANTRON ADAMS, purusant to 42 U.S.C. §1983, demands

judgment against the Defendant Officers, ZEMAN, Star #19750, KLAUS, Star #15865, and 

DOHNAL, Star #13529, for compensatory damages, punitive damages, the costs of this action

and attorneys’ fees, and any such other and further relief as this Court deems equitable and just.

COUNT II: 42 U.S.C. § 1983 – Failure to Intervene (Excessive Force)

Against Defendant Klaus

18. Plaintiff re-alleges the above paragraphs as though fully set forth herein.

19. The actions of the Defendant Officers constituted unreasonable, unjustifiable, and 

excessive force against Plaintiff, thus violating his rights under the Fourth Amendment to 

the Constitution of the United States and 42 U.S.C. §1983.

20. Defendant Klaus failed to intervene when Defendant Zeman and Defendant Dohnal used 

unreasonable and excessive force against Plaintiff, as alleged above, even though there 

was no legal basis for it.

21. The aforementioned actions of Defendant Klaus was the direct and proximate cause of 

the Constitutional violations set forth above. 

22. As a proximate result of the above-detailed actions, Plaintiff was injured, including the 

deprivation of his liberty and the taking of his person. In addition, the violations 

proximately caused Plaintiff mental anguish, embarrassment, and humiliation, exposed 

him to public scandal and disgrace, and caused him to incur various expenses, including 

but not limited to attorneys’ fees, all to Plaintiff’s damage. 

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WHEREFORE the Plaintiff, ANTRON ADAMS, purusant to 42 U.S.C. §1983, demands

judgment against the Defendant Officers, ZEMAN, Star #19750, KLAUS, Star #15865, and 

DOHNAL, Star #13529, for compensatory damages, punitive damages, the costs of this action 

and attorneys’ fees, and any such other and further relief as this Court deems equitable and just.

COUNT III: 42 U.S.C. § 1983 – Failure to Intervene (Excessive Force)

Against Defendant Dohnal

23. Plaintiff re-alleges the above paragraphs as though fully set forth herein.

24. The actions of the Defendant Officers constituted unreasonable, unjustifiable, and 

excessive force against Plaintiff, thus violating his rights under the Fourth Amendment to 

the Constitution of the United States and 42 U.S.C. §1983.

25. Defendant Dohnal failed to intervene when Defendant Zeman and Defendant Klaus used 

unreasonable and excessive force against Plaintiff, as alleged above, even though there 

was no legal basis for it.

26. The aforementioned actions of Defendant Dohnal was the direct and proximate cause of 

the Constitutional violations set forth above. 

27. As a proximate result of the above-detailed actions, Plaintiff was injured, including the 

deprivation of his liberty and the taking of his person. In addition, the violations 

proximately caused Plaintiff mental anguish, embarrassment, and humiliation, exposed 

him to public scandal and disgrace, and caused him to incur various expenses, including 

but not limited to attorneys’ fees, all to Plaintiff’s damage. 

WHEREFORE the Plaintiff, ANTRON ADAMS, purusant to 42 U.S.C. §1983, demands

judgment against the Defendant Officers, ZEMAN, Star #19750, KLAUS, Star #15865, and 

DOHNAL, Star #13529, for compensatory damages, punitive damages, the costs of this action 

and attorneys’ fees, and any such other and further relief as this Court deems equitable and just.

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COUNT IV: 42 U.S.C. § 1983 – Failure to Intervene (Excessive Force)

Against Defendant Zeman

28. Plaintiff re-alleges the above paragraphs as though fully set forth herein.

29. The actions of the Defendant Officers constituted unreasonable, unjustifiable, and 

excessive force against Plaintiff, thus violating his rights under the Fourth Amendment to 

the Constitution of the United States and 42 U.S.C. §1983.

30. Defendant Zeman failed to intervene when Defendant Dohnal and Defendant Klaus used 

unreasonable and excessive force against Plaintiff, as alleged above, even though there 

was no legal basis for it.

31. The aforementioned actions of Defendant Zeman was the direct and proximate cause of 

the Constitutional violations set forth above. 

32. As a proximate result of the above-detailed actions, Plaintiff was injured, including the 

deprivation of his liberty and the taking of his person. In addition, the violations 

proximately caused Plaintiff mental anguish, embarrassment, and humiliation, exposed 

him to public scandal and disgrace, and caused him to incur various expenses, including 

but not limited to attorneys’ fees, all to Plaintiff’s damage. 

WHEREFORE the Plaintiff, ANTRON ADAMS, purusant to 42 U.S.C. §1983, demands

judgment against the Defendant Officers, ZEMAN, Star #19750, KLAUS, Star #15865, and 

DOHNAL, Star #13529, for compensatory damages, punitive damages, the costs of this action 

and attorneys’ fees, and any such other and further relief as this Court deems equitable and just.

COUNT V: 42 U.S.C. § 1983 – Illegal Search and Seizure

33. Plaintiff realleges each of the foregoing paragraphs as if fully set forth here.

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34. The actions of Defendant Officers, described above, knowingly caused Plaintiff to be 

unreasonably searched and seized in violation of Plaintiff’s right under U.S. Constitution 

in violation of the Fourth and Fourteenth Amendment.

35. As a proximate result of the above-detailed actions, Plaintiff was injured, including the 

deprivation of his liberty and the taking of her person. In addition, the violations 

proximately caused Plaintiff mental anguish, embarrassment, and humiliation, exposed 

him to public scandal and disgrace, and caused him to incur various expenses, including 

but not limited to attorneys’ fees, all to Plaintiff’s damage.

WHEREFORE the Plaintiff, ANTRON ADAMS, purusant to 42 U.S.C. §1983, demands

judgment against the Defendant Officers, ZEMAN, Star #19750, KLAUS, Star #15865, and 

DOHNAL, Star #13529, for compensatory damages, punitive damages, the costs of this action 

and attorneys’ fees, and any such other and further relief as this Court deems equitable and just.

COUNT VI: 42 U.S.C. § 1983 – False Arrest 

36. Plaintiff realleges each of the foregoing paragraphs as if fully set forth here.

37. The actions of the Defendant Officers, described above, knowingly caused Plaintiff to be 

arrested and imprisoned without probable cause or any other justification, constituted a 

deliberate indifference to Plaintiff’s right under U.S. Constitution in violation of the 

Fourth and Fourteenth Amendment.

38. As a proximate result of the above-detailed actions, Plaintiff was injured, including the 

deprivation of his liberty and the taking of his person. In addition, the violations 

proximately caused Plaintiff mental anguish, embarrassment, and humiliation, exposed 

him to public scandal and disgrace, and caused him to incur various expenses, including 

but not limited to attorneys’ fees, all to Plaintiff’s damage.

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WHEREFORE the Plaintiff, ANTRON ADAMS, purusant to 42 U.S.C. §1983, demands

judgment against the Defendant Officers, ZEMAN, Star #19750, KLAUS, Star #15865, and 

DOHNAL, Star #13529, for compensatory damages, punitive damages, the costs of this action 

and attorneys’ fees, and any such other and further relief as this Court deems equitable and just.

COUNT VII: 42 U.S.C. 1983 – Conspiracy to Deprive Constitutional Rights

Against Defendant Officers

39. Plaintiff realleges each of the foregoing paragraphs as if fully set forth here.

40. As described more fully above, Defendant Officers reached an agreement amongst 

themselves to punish Plaintiff for a crime he did not commit, and to thereby deprive 

Plaintiff of his Constitutional rights, all as described more fully throughout this 

Complaint. 

41. In this manner, Defendant Officers, acting in concert with each other, have conspired by 

concerted action to accomplish an unlawful purpose by an unlawful means. 

42. In furtherance of the conspiracy, each of the co-conspirators committed overt acts and 

was an otherwise willful participant in joint activity. 

43. As a direct and proximate result of the illicit prior agreement referenced above, Plaintiff’s 

rights were violated, and he suffered damages, severe emotional distress and anguish, and 

a deprivation of his liberty, as is more fully alleged above. 

44. The misconduct described in this Count was undertaken with malice, willfulness, and 

reckless indifference to the rights of Plaintiff and others. 

45. As a proximate result of the above-detailed actions of Defendant Officers, Plaintiff was 

injured, including the deprivation of his liberty. In addition, the violations proximately 

caused Plaintiff mental anguish, embarrassment, and humiliation, exposed her to public 

scandal and disgrace, and caused her to incur various expenses, all to Plaintiff’s damage. 

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WHEREFORE the Plaintiff, ANTRON ADAMS, purusant to 42 U.S.C. §1983, demands

judgment against the Defendant Officers, ZEMAN, Star #19750, KLAUS, Star #15865, and 

DOHNAL, Star #13529, for compensatory damages, punitive damages, the costs of this action 

and attorneys’ fees, and any such other and further relief as this Court deems equitable and just.

COUNT VIII: 745 ILCS 10/9-102 – Indemnification

46. Plaintiff realleges each of the foregoing paragraphs as if fully set forth here.

47. Defendant City of Chicago is the employer of the Defendant Officers.

48. Defendant Officers committed the acts alleged above under color of law and in the scope 

of their employment as employees of the City of Chicago.

WHEREFORE the Plaintiff, ANTRON ADAMS, demands that, should any Defendant 

Officers be found liable on one or more of the claims set forth above, pursuant to 745 ILCS 10/9-

102, the Defendant, CITY OF CHICAGO, be found liable for any judgment Plaintiffs obtain, as 

well as attorney’s fees and costs awarded.

PLAINTIFF DEMANDS TRIAL BY JURY.

Respectfully Submitted,

ANTRON ADAMS

By: /s/ Brandon Brown

 One of Plaintiff’s Attorneys

THE BROWN LAW LTD.

4659 S. Cottage Grove Ave, 

Suite 202

Chicago, IL 60653

T: 773-624-8366

F: 773-624-8365

E: bbrown@thebrownlaw.com 

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 By: /s/ Sean Brown

 One of Plaintiff’s Attorneys

Sean Brown

The Law Office of Sean Brown

111 West Jackson Blvd.

Chicago, IL. 60604

T: 312-675-6116

F: 312-675-6001

E: attorneyseanbrown@gmail.com

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