Media does not alway show the best
picture
During these past few months we have had many unbelievable tragic deaths and issues come to light
by the various media networks . It is certainly heartbreaking to turn on the computer or tv and see
what is going on across the country. However it is just as discouraging that the media never shows
any of the positive stories/moments as fast as they show the inflammatory ones.
The story just last month of the young boy with a picture that advertised free hugs and the cop who
reached out and hugged him was a beautiful beacon in all this senseless violence. I believe it is so
easy to get instantly mad when we see the bad and we reach out to fight but we dont show as much
attention to the good deeds that go on. We need to try to make sure that the postive and good deeds
get shown as much as we can. Just one act of kindness a day can start a ripple effect that could be
felt everywhere.
The power of positive should not be derided or belittled.
I have included the link to one of the stories and pictures of the cop and the young boy in Missouri
originally published on the ABC news network 11/29/14
http://www.kvue.com/story/news/nation/2014/11/29/photo-of-cop-hugging-boy-at-ferguson-protest-tel
ls-poignant-story/19662537/
Photo of cop hugging boy at Ferguson
protest tells poignant story
ABC News 12:46 p.m. CST November 29, 2014
Police Sgt. Bret Barnum hugs 12-year-old Devonte Hart during a demonstration in Portland, Ore.
calling for police reform after the Ferguson grand jury decision on Nov. 25, 2014.(Photo: Johnnu
Nguyen)
CONNECT 3 TWEETLINKEDINCOMMENTEMAILMORE
Sometimes, all you really need is a good hug.
Amid the nationwide protests over the failure of a grand jury to indict a white police officer for
shooting an unarmed black teenager in Ferguson, Mo., freelance photographer Johnny Nguyen
snapped the picture above during a demonstration in Portland, Ore., on Nov. 25.
“I came upon this boy who had tears in his eyes and I knew this was the place to be, so I followed
him in the crowd,” Nguyen said. “Then he came upon the police officer. They talked and he gave him
a hug.”
Devonte Hart, 12, was at the demonstration holding a sign that said “free hugs” when Portland
Police Sgt. Bret Barnum noticed him, motioned the boy over and the two began talking.
Nguyen said that Barnum pointed to the sign and asked “Do I get one of those?” and they hugged.
Local christmas activities
DEC. 9
MUSIC
Music South’s Holiday Concert and Gala Dinner featuring the Atlanta Pops will be held Tuesday,
Dec. 9, at 7:30 p.m. at the Dothan Civic Center. Dinner will begin at 6 p.m. with music by The
Moonlighters. The dinner will be a gourmet buffet. Visit www.musicsouth.com for more information.
DEC. 13
THEATER
“Christmas on Broadway,” a special holiday musical production featuring a mix of Christmas and
Broadway songs, will be presented by the Wish Upon A Star Performing Arts Company on Saturday,
Dec. 13, at the Flowers Center for the Performing Arts in Ozark. There will be shows at 5 p.m. and
7:30 p.m. Tickets are $15 each, and all seats are reserved. Ticket sales are Tuesday and Thursday
from 4:30 to 6:30 p.m. through Dec. 11. The musical performance is dedicated to Carol Caffey, an
active and dedicated supporter of the local arts community and the Flowers Center for the
Performing Arts.
DEC. 14
ETC.
Landmark Park in Dothan will hold Victorian Christmas on Dec. 14 from 1 to 4 p.m. The annual open
house features arts and craft vendors, holiday music, ornament-making, holiday desserts, hot
chocolate and mulled cider, horse-drawn wagon rides, and a visit from Santa. Admission to Victorian
Christmas is free, but visitors are encouraged to bring a nonperishable food item for donation to the
Wiregrass United Way Food Bank. The park is located on U.S. 431.
THROUGH DEC. 19
ETC.
The Dothan Area Botanical Gardens will hold its second year of Sleigh(hay) Rides from 5 to 8 p.m. on
Fridays through Dec. 19. Visitors will be taken through a portion of the botanical gardens that have
been decorated with Christmas lights. Hot chocolate and homemade cookies served. Bring a
flashlight to search for some hidden surprises in an unlit portion of the paved trail. Rides are 30
minutes long and three wagons will be constantly circulating through the gardens, located on
Headland Avenue. Cost is $5 per person and free for children ages 5 and under.
Education is so Important
Education is so very important
As of the 2013 census only 82% of the people in the wiregrass had a high school education or higher.
We have a wonderful public school system in this area and there should truly be no reason that our
youth cannot graduate with a high school diploma or a GED. Graduating from high school is such a
huge milestone in a person’s life we dont need to take that away from them. We hear people
complain about trying to get ahead in life and yet they dont always take the next step so that they
can secure that better future for themselves and their families. A high school diploma is the
foundation for a much brighter and better future there are so many opportunities available to our
youth and even adults if we just take the time to reach out for it.
Please see this attached article from the Dothan Eagle about businesses trying to help make sure
that we get every opportunity that we can so that we can make our community better
http://www.dothaneagle.com/news/business/city-ensuring-it-can-provide-skilled-workers-to-sustain-n
ew/article_a3d63160-7d90-11e4-abfb-07839ab4a327.html
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=6035426&amp;amp;amp;amp;amp;cv=2.0&amp;amp;amp;amp;amp;cj=1&amp;amp;amp;amp;quot
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Posted: Saturday, December 6, 2014 3:41 pm | Updated: 3:44 pm, Sat Dec 6, 2014.
City ensuring it can provide skilled workers to sustain new industry Carly Omenhiser
Business Reporter dothaneagle.com
■
■
Posted on Dec 6, 2014by Carly Omenhiser
In order to maintain a successful industry, one of the key components is having a plentiful, highlyskilled workforce available. It’s one of the first things industries look for when planning a move or
expansion.
A collective effort from educational institutions, city, and county leaders has placed Dothan on a
path that if approached by a potential industry, the city would be ready to provide the workforce
needed to sustain it.
While Dothan city and business leaders work to draw in new industry and jobs into the Wiregrass,
state organizations, educational institutions and private companies have created programs to train a
highly-qualified workforce to help attract and supply those industries.
Nearby Wallace Community College, Lurleeen B. Wallace Community College, Enterprise-Ozark
Community College and Troy University all have programs to train individuals for specific jobs
available in the Wiregrass.
These training programs are happening out on the job site, giving students real world, hands-on
training.
Vincent Vincent, director of non-credit training at Wallace Community College , said the school
offers seven different courses ranging from 25 days to 40 weeks and the classes stay full.
“If Dothan was to land a major industry, we would all work together to make sure that they have the
training that they need. That’s not problamatic. That would happen. Not without some effort, but
that would definitely happen,” Vincent said.
Programs are developed as the need arises, and Vincent said a lot of thought goes into each
program’s development to ensure it remains sustainable.
Some programs are not affiliated with a college, yet people travel from throughout the country to
complete a heavy equipment operator training program located in Dothan.
Allied Career Training, which operates American Construction Training, is located off of Denton
Road and provides a course on heavy machinery operation.
Instruction director Al Cook said the need for heavy equipment operators has increased, especially
with the frequent road construction on Alabama’s roads and highways as a result of Gov. Robert
Bentley’s Alabama Transportation and Rehabilitation Improvement Program.
Attending a trade school, he said, is a short-term investment in a long-term career for an individual.
“I don’t care where you go across the county, you’re going to see road construction and you can’t
have road construction without the heavy equipment operators to do the work,” Cook said.
“Infrastructure is a steady, maintained business.”
Attending a trade school like Allied Career Training also allows a person to enter the workforce
more quickly.
“The way the economy is nowadays, people who are low on income, they don’t want to go to college
for two to four years and then go and try to find a job in that career,” Cook said, adding many times
a person spends years to attain a degree and then finds they can’t secure a job in their field of study.
“In a trade school you’re trained in one specific area and you spend less time, less money and you
can enter the workforce and start making money and be able to support your family a lot faster.”
Having a highly-qualified workforce in place helps industries make their decision on whether to
build or expand in the Dothan area.
The SoZo Group has made several trips to China, most recently with Dothan Mayor Mike Schmitz
and several other area business leaders, to meet with industry executives and potentially recruit new
industries for Dothan.
SoZo Group Executive Director Ken Tuck said he feels Dothan is prepared should one of these
Chinese industries decide to locate in the city.
“They look for incentives, everybody looks for incentives, but really the training is so key,” Tuck said.
“They could come over here and spend millions and have a pretty building, but if there is no
program to train the workforce, that industry is not going to be successful.”
He attributes the area’s preparedness to the proactive approach the city, county and educational
institutions have taken to ensure proper programs can be established to train workers.
“Everything that we’ve been looking at we’ve been able to put training ideas forward, because
everybody is working together,” Tuck said. “To be able to provide the opportunity for people to learn
skills is important and we have that here in Dothan.”
Tuck said the state also provides assistance thought the Alabama Industrial Development Training,
which works to develop a quality workforce through the establishment of training programs for new
and expanding industries.
One of those programs was established when Commercial Jet made its move to Dothan in 2013 and
announced they would employ hundreds of people from the area.
Commercial Jet, which expanded to Dothan from Miami, converts passenger jets into cargo planes,
which requires workers with experience in sheet metal.
AIDT assisted with the creation of the C-Jet Academy, an eight-week course which provides specific
training to potential employees, which students apply to directly through AIDT.
The state organization typically helps new industries for the first two years of their business before
the local college systems come in and take over the training needs.
John Schildroth, Commercial Jet’s vice president of business development, said AIDT was
instrumental in Commercial Jet being able to staff its facility when they opened in May 2014.
“AIDT has been available to us and has been helping us since we started business,” Schildroth said.
“About six months ago we saw a need to have specific training dedicated to the majority of work that
we do here.”
AIDT was able to come in and establish a training program to address the shortage of sheet metal
workers.
“What AIDT is doing is guaranteeing us a pipeline of people that we’re going to be able to draw from
over a period of time. The more classes we can run, the more that pipeline will stay full,” Schildroth
said.
Later this month, C-Jet Academy will graduate its first class of 25 students, who if their final test is
passed, will be offered jobs as aircraft structural mechanics at $14 per hour.
”Everybody is happy to have a job,” Schildroth said. “All of (the students) live within a 30-mile radius
of Dothan and they’re more than happy to get a job in this area so they don’t have to move out of the
area and move away from their families, wives and children. They’re all very grateful to have these
jobs.”
The next class has been planned for January, however a specific date has not been established.
Dothan Area Chamber of Commerce President Matt Parker said the chamber has a comprehensive
plan in place to enhance and ensure continued workforce development within the area.
Steve Turkoski, director of workforce and small business development, said currently the city’s top
two industries are in the medical services and aviation industries, but the city hopes to expand on its
workforce in the bio-medical field.
The first step in that process was the establishment of the Alabama College of Osteopathic Medicine,
which opened in Dothan in 2013, Parker said.
“That’s going to grow and evolve and I think we can really start capitalizing on that,” Parker said.
The city, he said, has put in place all the right ingredients to help sustain a workforce and ensure the
city will be able to supply a potential industry with the workers they’ll need.
“You can’t meet it all (the demand), but I think we’ve got that foundation that we can compliment a
lot of sectors and improve them and customize them through creative thought.”
Follow Carly Omenhiser on Twitter at @EagleBizCarly
Justice and Acountability Unity Walks near
YOU!!!
HANDS UP, DONT SHOOT, BECAUSE I WANT TO BREATHE. JUSTICE FOR ALL
Micheal Brown -Ferguson
Eric Garner – New York
Christopher Thomas – Dothan Ala.
Cameron Massey – Eufaula Ala.
Opatrick Humphrey – Headland Ala.
Jestaro Reynolds Dothan Ala and many many more!
I will show you my hands if I can breathe!
Join TOPS in a City near you for those who lost their lives in your City.
Eufaula Ala 3:00 pm Friday Dec. 12 Barbour County Courthouse
Dothan Ala 10:00 am Sat. Dec. 13 Houston County Courthouse
Montgomery Ala 1:00pm Greater Destiny Worship Center
Calling for all Preachers, Organizations, and Concerned Citizens to join me and the Families of those
who lost their lives!
Stealing at the Dollar Store
ON MY WAY TO WORK THIS MORNING ME AND A FELLOW CO WORKER WENT TO A LOCAL
DOLLAR GENERAL LOCATED NEAR THE BAPTIST BOTTOM AROUND ABOUT 9 AM AND WE
WENT IN PURCHASED SOME THINGS AND MY COWORKER AND I WAS WAITING TO PAY FOR
MY THINGS SO WE CAN LEAVE BUT NOT KNOWING SOMETHING BIGGER WAS GOING ON
WHILE WE WAITED THE CLERK EXSCUSED HERSELF AND WALKED TO THE BACK OF THE
STORE WE WAITED AND BY THIS TIME A LINE HAD FORMED WHEN SHE RETURNED SHE
INFORMED US THAT SHE HAD CALLED DOTHAN POLICE DEPARTMENT BECAUSE A FEMALE
THAT COULDN’T OF BEEN OVER 20 YEARS OLD STOOD IN FRONT OF HER AND WAS PACKED
TO CAPACITY WITH ITEMS FROM THE STORE SHE WAS ACCOMPANIED BY A BLACK MALE
ALSO IN HIS 20’S MY THING IS IF YOURE GONNA STEAL PEOPLE DON’T STEAL FROM THE
DOLLAR GENERAL ESPECIALLY WHEN YOU LIVE NEAR BY SO WE WILL KEEP YOU UPDATED
ON THIS STORY
The Smoke Alarm
This is another I’m just saying topic looks like a local couple was arrested at a local Howard Johnson
motel at the end of last month the couple was obliviously getting their “smoke on “ when the fire
alarm was set off when Dothan police and the fire and rescue arrived they was overwhelmed with
the smell of marijuana smoke and it landed to people in jail it was a black male and a black female
look people if you are going to fire up please do it in your own homes where there are no fire alarms
and if you are gonna do it please people dnt do it at the howard Johnson motel
Protest Erupt after Chokehold Death
Decision
Protests erupt after decision in chokehold death
NEW YORK (AP) — The cellphone video of the last moments of Eric Garner’s life was watched
millions of times on the Internet, clearly showing a white police officer holding the unarmed black
man in a chokehold, even as he repeatedly gasped, “I can’t breathe.”
But despite that visual evidence, and a medical examiner’s ruling that the chokehold contributed to
the death, a Staten Island grand jury decided Wednesday not to bring any charges against the
officer involved, prompting protests across the country and sending thousands onto New York’s
streets, where they marched, chanted and blocked traffic into the next morning.
While legal experts note it’s impossible to know how the grand jurors reached their conclusion, they
say the Garner case, like Michael Brown’s death in Ferguson, Missouri, once again raised concerns
about the influence local prosecutors have over the process of charging the police officers they work
with on a daily basis.
“The video speaks for itself,” said Jeffrey Fagan, a professor at Columbia Law School. “It appears to
show negligence. But if we learned anything from the Brown case, it’s the power of prosecutors to
construct and manage a narrative in a way that can shape the outcome.”
Ekow N. Yankah, a professor at Cardozo School of Law, agreed that, “It is hard to understand how a
jury doesn’t see any probable cause that a crime has been committed or is being committed when
looking at that video, especially.”
Another observer, James A. Cohen, who teaches at Fordham University Law School, went further,
saying, “Logic doesn’t play a role in this process.”
U.S. Attorney Eric Holder said federal prosecutors would conduct their own investigation of
Garner’s July 17 death as officers were attempting to arrest him for selling untaxed cigarettes on the
street. The New York Police Department also is doing an internal probe which could lead to
administrative charges against Officer Daniel Pantaleo, who remains on desk duty.
The grand jury’s decision prompted emotional protests around New York and in cities from Atlanta
to California.
In Manhattan, demonstrators laid down in Grand Central Terminal, walked through traffic on the
West Side Highway and blocked the Brooklyn Bridge. A City Council member cried. Hundreds
converged on the heavily secured area around the annual Rockefeller Center Christmas tree lighting
with a combination of professional-looking signs and hand-scrawled placards reading, “Black lives
matter” and “Fellow white people, wake up.” And in the Staten Island neighborhood where Garner
died, people reacted with angry disbelief and chanted, “I can’t breathe!” and “Hands up — don’t
choke!”
Police Commissioner William Bratton, in an interview Thursday on Fox-TV’s “Good Day New York,”
said 83 people were arrested. The department said most were for disorderly conduct.
The demonstrations were largely peaceful, in contrast to the widespread arson and looting that
accompanied the decision nine days earlier not to indict the officer in Brown’s death.
Staten Island District Attorney Daniel Donovan said the grand jury found “no reasonable cause” to
bring charges, but unlike the chief prosecutor in the Ferguson case, he gave no details on the grand
jury testimony. The district attorney said he will seek to have information on the investigation
released.
“Honestly, I think from the beginning I had no faith in Staten Island prosecutors … I didn’t have any
kind of encouragement, I felt no remorse, I felt no compassion, no anything from Staten Island
besides the people on Staten Island. But as far as the police and the DA, there was no sincerity from
day one,’ Garner’s widow, Esaw Garner, said in an interview on the “Today” show.
In order to find Pantaleo criminally negligent, the grand jury would have had to determine he knew
there was a “substantial risk” that Garner would have died. Pataleo’s lawyer and union officials
argued that the grand jury got it right, saying he used an authorized takedown move — not a banned
chokehold — and that Garner’s poor health was the main cause of his death.
The Rev. Al Sharpton, who has led protests over the custody death of Garner and the police shooting
of Brown in the St. Louis suburb of Ferguson, said the New York decision is yet another reason he
has lost confidence in state grand juries and local prosecutors to bring such cases.
“State grand juries tend to be too compromised with local politics because local prosecutors run for
office and they have to depend on the police for evidence,” he said. “Don’t we have the right to
question grand juries when we’re looking at a video and seeing things that don’t make sense?”
The video shot by an onlooker showed the 43-year-old Garner telling a group of police officers to
leave him alone as they tried to arrest him. Pantaleo responded by wrapping his arm around
Garner’s neck in what appeared to be a chokehold.
The heavyset father of six, who had asthma, was heard repeatedly gasping, “I can’t breathe!” He
later died at a hospital.
The medical examiner ruled Garner’s death a homicide and found that a chokehold contributed to it.
A forensic pathologist hired by Garner’s family agreed with those findings, saying there was
hemorrhaging on Garner’s neck indicative of neck compressions.
Columbia’s Fagan said another factor was that the Staten Island grand jury came from the most
conservative and least racially diverse of the city’s five boroughs, and home to many current and
retired police officers and their families.
“Staten Island is a very different borough,” he said. “In fact, it may be closer to suburban St. Louis,
and we can’t discount that.”
Micheal Brown's Stepfather Apologizes
Michael Brown’s Stepfather Apologizes for Comments During Protest
Michael Brown’s stepfather is apologizing for inflammatory comments he made during a protest last
week.
Louis Head said his emotions got the best of him, following the grand jury’s decision not to indict
Darren Wilson. Police are investigating if Head intended to incite rioting when he screamed to burn
buildings down.
Head said the last thing he wanted to see was the city go up in flames.
Wreck on Hartford Hwy
Dothan Police Department
210 North Saint Andrews Street
Dothan, Alabama 36303
Gregory J. Benton
Chief of Police
(334) 615-3000
E-mail [email protected]
Press Release
December 4, 2014
On December 04, 2014 at approximately 1:50am, the Dothan Police Department responded to the
2600 block of Hartford Highway after receiving information of a one vehicle wreck.
Investigators with the Dothan Police Department’s Traffic Division responded to the scene, and
through preliminary investigation have determined the vehicle, a 1999 Chevrolet S10, had left the
roadway and struck a tree.
Due to the damage of the Chevrolet S10, its occupant’s two adult males were extracted from the
vehicle. One of the occupant’s was transported to the Southeast Alabama Medical Center where he
was later airlifted to The University of Alabama at Birmingham Hospital where he has been listed in
critical condition.
The second occupant of the vehicle, Jeffery Jordan Speed succumbed to his injuries at the scene.
The Dothan Police Department would like to express our condolences to the family of Jeffery Speed
in their time of loss.
Our thoughts and prayers are with all parties involved in this tragedy.
Gregory J. Benton
Chief of Police
2
Filed lawsuit in Chris Thomas case
While we have had a group of ladies and children in front of our County Courthouse shouting ” No
More Silence, No More Violence ”
Advocating for Domestic Violence! A Federal Judge that has been asked to release his seat.
We have Katherine Thomas filing a complaint on Officer Moody who shot her son Christopher
Thomas 2 years ago.
The interesting part about her complaint is what it says about MOODY’S background history
regarding violence against women.
Mrs. Thomas says that the City of Dothan should have never hired Moody as a Dothan Police Officer.
Specifically Mrs. Thomas states the following in her Complaint:
(“The City of Dothan is liable to Mrs. Thomas because both non-police officer personnel and actual
police officer personnel for the City violated the City’s detailed policies/procedures and minimum
standards—some of which are described as minimum employment standards and procedures—in a
neglectful, unskillful and careless manner. The referred to minimum standards and other applicable
policies/procedures would have placed, and actually did place, both non-police and police personnel
on notice that Moody had violated detailed minimum employment standards and procedures by
committing, inter alia (1) acts which would constitute a serious misdemeanor whether criminally
prosecuted or not; (2) act or acts that would constitute domestic violence whether criminally Case
1:13-cv-00920-WHA-SRW Document 31 Filed 06/12/14 Page 21 of 26
22
prosecuted or not; and (3) acts which would give rise to substantial doubts about the applicant’s
respect for the law or for the rights of others—such as (1) Moody’s suspension from the Pensacola
Police Department, in 1996, for violating Florida’s battery statute when he punched his then
girlfriend in the eye while at a public establishment; (2) Moody’s resignation, in 2003, while being
investigated (and recommended for termination) for violating moral character standards
(characterized by his then Chief as scandalous and disgraceful conduct while on or off duty) related
to beating up a different girlfriend; (3) internal allegations of Moody violating policies regarding
control of evidence; (4) internal allegations of Moody violating reporting requirements; (5) Moody’s
proclivity to make “trivial” traffic stops and turn them into full blown search and seizures based on
unlawful grounds; (6) Moody’s “more than experimental use” of marijuana; (7) Chief’s demand that
Moody undergo evaluation and counseling for anger management and also a different
recommendation, by a different police official, that Moody take diversity training; and more.”
“Mrs. Thomas went on to say that if Moody couldnt work anymore as a police officer in Florida. Then
why was he allowed to work in Dotha Ala as a police officer.”:
“By failing to follow its own self-described detailed minimum employment standards and other
applicable policies/procedures regarding the hiring of Moody, the City of Dothan placed an officer
who never worked as a peace officer in Florida again after 2003 on to the streets of Dothan, Al—in
2008—with a license to use deadly force. Had the City followed its own “extensive” hiring practices,
the City would not (and should not) have hired Moody. If the City of Dothan had not hired Moody, we
know for sure that Moody would not have fatally shot the Decedent in the capacity of a Dothan
Police Officer. Consequently, the City of Dothan is liable to Mrs. Thomas for the Decedent’s death in
the form of all damages allowable under controlling law.”)
Entire Complaint Below:Now everybody reading this should ask themselves why did Moody get
hired before all the qualified candidates who did not have this background.
Every Dothan resident should ask the City why they hired a person with this background, and
importantly why is he still working as a Dothan Police Officer???
IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF ALABAMA
SOUTHERN DIVISION
KATHERINE THOMAS, )
individually, and as the administrator )
of the estate of CHRISTOPHER )
JEROME THOMAS; )
)
Plaintiff, ) CAFN: 1:13-cv-920-WHA-SRW
)
v. )
)
DARREN MOODY, )
in his individual capacity; )
)
And )
)
CITY OF DOTHAN, ALABAMA )
) JURY DEMANDED
Defendants. )
PLAINTIFF’S FIRST AMENDED COMPLAINT
Plaintiff KATHERINE THOMAS, as the administrator of the estate of
CHRISTOPHER JEROME THOMAS (“Decedent”), and through her
undersigned attorney, files this Complaint. Ms. Thomas will use 42 U.S.C. § 1983
as the vehicle to vindicate her rights under the Fourth and Fourteenth Amendments
to the United States Constitution, to redress the deprivation of the Decedent’s
Constitutional rights by Officer DARREN MOODY, a Defendant in this action.
Ms. Thomas will also seek to hold Defendant Moody liable under Alabama law for
the wrongful death of her son. Regarding the City of Dothan, Ms. Thomas will use
Case 1:13-cv-00920-WHA-SRW Document 31 Filed 06/12/14 Page 1 of 26
2
Alabama state law to vindicate her rights against the City. In support of her First Amended
Complaint, the Mrs. Thomas alleges the following:
INTRODUCTION
On June 28 2012, Defendant Moody shot and killed a person he claims he mistook for a criminal
suspect. On that date, Moody followed the Decedent while initially believing the Decedent was
another person, “Booty Bop,” suspected of a crime. Moody even called in “Booty Bop’s” real name on
his dispatch radio as he pulled behind the Decedent’s car. Moody, however, knew or had reason to
know that the vehicle he was following was not the same vehicle Moody’s suspect, Booty Bop, drove.
Further, the Decedent and “Booty Bop” look nothing alike–except the fact that both are AfricanAmerican. Nevertheless, Moody shot and killed the Decedent as the Decedent sat in a stopped
vehicle. At the time of the shooting, the Decedent posed no threat to Moody or to any other person,
nor was the Decedent’s car aimed at Moody or anyone else. Moody’s objectively unreasonable use of
deadly force violated the Decedent’s Constitutional right to be free from an unreasonable seizure.
Moody’s unreasonable use of deadly force also directly and proximately caused the Decedent’s
wrongful death. Therefore, the Plaintiff files this action on Decedent’s behalf.
Case 1:13-cv-00920-WHA-SRW Document 31 Filed 06/12/14 Page 2 of 26
3
PARTIES
2.
At all times relevant to this Complaint Katherine Thomas was a citizen of the United States and a
resident of Midland City, Alabama. Ms. Thomas is the natural mother of the Decedent and is the
administrator of the Decedent’s estate. At all times relevant to this Complaint the Decedent had
clearly established legal rights under state and federal law and the United States Constitution. Ms.
Thomas submits herself to the jurisdiction and venue of this Court and is entitled to bring this action
on the Decedent’s behalf under state and federal law for all general, special, compensatory, punitive,
and any other permissible damages.
3.
At all times relevant to this Complaint Darren Moody was a United States citizen, an Alabama
resident, and a sworn officer of the Dothan Police Department. At all relevant times to this
Complaint Defendant Moody was acting under the color of state law. At all relevant times, Defendant
Moody was subject to the laws of the State of Alabama and the Constitution of the United States. At
all relevant times, Moody was responsible for knowing and acting in accordance with all policies,
procedures, orders, special orders, general orders, guidelines and regulations of the Dothan City
Police Department, while upholding his responsibility to patrol the streets of Dothan, Alabama as a
Dothan City police
Case 1:13-cv-00920-WHA-SRW Document 31 Filed 06/12/14 Page 3 of 26
4
officer. When Moody first saw the Decedent, Moody called in the license plate of the vehicle the
Decedent was driving. Moody had reason to know, within seconds of pulling behind the Decedent’s
car, that the Decedent’s car was not the car of the suspect, Booty Bop, that Moody was looking for.
Moody pursued the Decedent nevertheless. The Decedent and Moody’s vehicle entered a spacious
and nearly empty parking lot. At that point, Moody misstated over his vehicle radio that the
Decedent was trying to ram cars. When the Decedent’s car stopped while in the parking lot, Moody
existed his car and circled around the back of his own patrol car. From the rear right side of his own
patrol car, Moody approach the left driver side window of the Decedent’s car, and at that time, the
Decedent’s car was completely stopped. Moody was several feet away from the subject driver side
window while the Decedent’s car was stopped and not facing or moving toward Moody in any
manner, and not facing or moving toward anyone in any manner. At that point, Moody saw that (1)
the Decedent was unarmed and that (2) the Decedent was not Booty Bop, the suspect who Moody
was looking for. Moody never gave the Decedent adequate time to obey any alleged command.
Instead, Moody shot the Decedent multiple times, including gunfire to the side of the Decedent’s
neck—all while the Decedent’s car was not moving and not facing (endangering) anyone, including
Moody. Ms. Thomas is using 42 U.S.C § 1983 as
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5
the vehicle to sue Moody in his individual capacity regarding federal claims. Moody has been served
in this case.
4. The City of Dothan, Alabama is a municipality organized and existing under the laws of the State
of Alabama, County of Houston, and has been so for a period preceding six months prior to the filing
of this case. Also, at the time of the subject event that has given rise to this lawsuit, the City of
Dothan was the public employer of Defendant Moody.
JURISDICTION AND VENUE
5.
This Court has original subject matter jurisdiction over the federal claim in this action in accordance
with 28 U.S.C. § 1331 because the claim raises a federal question under the laws and Constitution of
the United States.
6.
This Court has supplemental subject matter jurisdiction over the state claim in this action under 28
U.S.C. § 1367(a) because the state and federal claims form part of the same case or controversy
under Article III of the United States Constitution.
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7.
This Court has personal jurisdiction over the Defendant because he is domiciled in Alabama.
8.
Venue is proper in the Middle District of Alabama under 28 U.S.C. § 1391(b)(1) because the
Defendant resides in this district and under 28 U.S.C. § 1391(b)(2) because a substantial part of the
events giving rise to the claims occurred in this district.
STATEMENT OF FACTS
9.
When Defendant Moody pursued Christopher Thomas on June 28 2012, Moody was engaged in
official law enforcement duties on behalf of the City of Dothan.
10.
The firearm that Moody used to fatally shoot the Decedent was a government issued firearm.
11.
On June 28 2012, an official duty of Defendant Moody, in his capacity as a Peace Officer for the City
of Dothan, was to enforce traffic and criminal laws through his power of arrest. Case 1:13-cv-009-
0-WHA-SRW Document 31 Filed 06/12/14 Page 6 of 26
7
12.
When Defendant Moody aimed his firearm at the Decedent, Moody was engaged in law enforcement
duties, within the course and scope of his employment, as a peace officer for the City of Dothan.
13.
When Defendant Moody discharged his firearm on June 28 2012, he was engaged in law
enforcement duties, within the course and scope of his employment, as a peace officer for the City of
Dothan.
14.
When Defendant Moody shot Christopher Thomas on June 28 2012, Moody was engaged in official
law enforcement duties on behalf of the City of Dothan.
15.
On June 28 2012, when Defendant Moody was communicating with dispatch while following behind
the car being drove by the Christopher Thomas, Moody was engaged in law enforcement duties,
within the course and scope of his employment, as a peace officer for the City of Dothan.
16.
From the time Moody began pursuing the car Christopher Thomas was driving through the time
Moody shot Christopher Thomas, Moody was acting Case 1:13-cv-00920-WHA-SRW Document 31
Filed 06/12/14 Page 7 of 26
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within the course and scope of his employment as a peace officer for the City of Dothan.
17.
On June 28, 2012 Defendant Moody was an employee of the City of Dothan.
18.
On June 28, 2012, Defendant Moody had an encounter with an individual known as “Booty Bop” in
Dothan, Alabama.
19.
On June 28 2012, the Defendant Moody was patrolling the streets of Dothan when he passed the
Decedent’s white SUV going in the opposite direction. Moody mistakenly believed that the driver of
the white SUV was “Booty Bop.” In fact, the driver of the white SUV was the Decedent.
20.
At the point the Moody mistakenly believed the Decedent was “Booty Bop,” the Decedent had not
committed any crimes in the Defendant’s presence, and the Defendant had no reason to believe that
the Decedent had committed any crimes outside of his presence.
21.
In light of the facts above in paragraph 20, Moody nevertheless followed the Decedent into a
virtually empty parking lot. Case 1:13-cv-00920-WHA-SRW Document 31 Filed 06/12/14 Page 8 of 26
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22.
While in the parking lot, Moody misreported the event on his police radio, stating that the Decedent
had “tried to ram an unmarked car.”
23.
While still in the parking lot, the Decedent stopped his vehicle.
24.
Moody stopped his patrol car to the left of the Decedent’s vehicle. Moody then exited his patrol car
and moved around its back. From the back right rear of his Patrol car, Moody approached the left
side driver’s window of the Decedent’s car.
25.
Moody approached the Decedent’s driver’s side window with his gun drawn, standing at a distance
of several feet from the subject driver side window. At this point, Moody saw, and thus knew, that
the Decedent was unarmed.
26.
The Decedent’s vehicle had come to a complete stop, he was unarmed, and neither the Defendant
nor any other person was in a position to be struck or otherwise harmed by the Decedent.
Case 1:13-cv-00920-WHA-SRW Document 31 Filed 06/12/14 Page 9 of 26
10
27.
With his gun drawn, Moody saw the face of the Decedent while approaching the Decedent’s stopped
vehicle. At that moment, Moody knew and had every reason to know that the Decedent was not
Moody’s suspect, “Booty Bop.” Nevertheless, and before giving the Decedent any time to respond to
any alleged command, Moody immediately opened fire on the Decedent, while knowing the subject
vehicle was not aimed at (or moving towards) him in any manner, and while knowing the subject
vehicle was stopped and not aimed at (or moving toward) anyone.
28.
Moody’s gunfire struck the Decedent five times (twice in the side of the Decedent’s neck), killing
him.
29.
At no time prior to, during, or after Moody fatally shot the Decedent, did the Decedent aim his car at
Moody or any other police officer or pedestrian.
30.
The Decedent’s autopsy report demonstrates that all five shots entered the Decedent on a left-t-right trajectory (two in the neck from left to right). The trajectory and angle of Moody’s gunfire is
consistent with the allegation that Case 1:13-cv-00920-WHA-SRW Document 31 Filed 06/12/14 Page
10 of 26
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Moody fatally shot the Decedent while standing to the side of the Decedent’s vehicle out of harm’s
way.
Facts Regarding Negligent Hiring Claim
31.
The process regarding the hiring of Moody as a Dothan police officer required decision making by
both police personnel/officials and non-police personnel/officials for the City of Dothan. As early as
2005, the City of Dothan represented to this District Court in a previous case that its candidates for
the position of police officer underwent “extensive screening prior to hire….” Indeed, the Mayor
swore in 2005: “The City also maintains a strict hiring procedure for police officers….”
32.
The process regarding the hiring of Moody as a Dothan police officer required police personnel and
non-police personnel for the City of Dothan to follow strict minimum standards and procedures.
33.
Non-law enforcement personnel for the City of East Dublin had strict, minimum standards and other
detailed procedures that were required to be followed with respect to hiring Moody.
Case 1:13-cv-00920-WHA-SRW Document 31 Filed 06/12/14 Page 11 of 26
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34.
Law enforcement officers for the Dothan City police department were under strict, minimum
standards, as a matter of policy, with respect to hiring Moody.
35.
The minimum standards and other policies/procedures that governed the conduct of both law
enforcement personnel and non-law enforcement personnel with respect to hiring Moody are
designed to ensure that the best qualified person obtains employment as a police officer for the City
of Dothan.
36.
As early as 2005, the City of Dothan represented to this District Court in a previous case that its
candidates for the position of police officer underwent “extensive screening prior to hire….” Indeed,
the Mayor swore in 2005: “The City also maintains a strict hiring procedure for police officers….”
37.
The strict, minimum standards and procedures that applied to the hiring of Moody did—and should
have—provided both law enforcement personnel and non-law enforcement personnel with
information about Moody’s disreputable conduct as a police officer, such as (1) Moody’s suspension
from the Pensacola Police Department, in 1996, for violating Florida’s battery statute when he
punched his then girlfriend in the eye while at a public establishment; (2) Moody’s resignation,
Case 1:13-cv-00920-WHA-SRW Document 31 Filed 06/12/14 Page 12 of 26
13
in 2003, while being investigated (and recommended for termination) for violating moral character
standards (characterized by his then Chief as scandalous and disgraceful conduct while on or off
duty) related to beating up a different girlfriend; (3) internal allegations of Moody violating policies
regarding control of evidence; (4) internal allegations of Moody violating reporting requirements; (5)
Moody’s proclivity to make “trivial” traffic stops and turn them into full blown search and seizures
based on unlawful grounds; (6) Moody’s “more than experimental use” of marijuana; (7) Chief’s
demand that Moody undergo evaluation and counseling for anger management and also a different
recommendation, by a different police official, that Moody take diversity training; and more.
38.
Non-police personnel for the City of Dothan presented Moody as a top candidate for hire even
despite the fact that those same non-police personnel had information about Moody that disqualified
him for a top recommendation per strict procedures and minimum standards.
39.
Based on the strict procedures and minimum standards that governed the conduct of non-police
personnel for the City of Dothan with respect to hiring Moody, the subject non-police personnel who
hired Moody should have (1) never
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recommended him as a top candidate and also should have (2) disqualified him as a candidate,
period.
40.
Police personnel also presented and authorized Moody as a top candidate for hire, despite the fact
that strict policy and minimum standards provided these police personnel with information about
Moody that disqualified him as a candidate per strict guidelines and minimum standards that
governed the conduct of these police personnel with respect to the hiring of Moody.
a. Police personnel also presented and authorized Moody as a top candidate for hire, despite the fact
that had these same police personnel performed due diligence in accordance with strict
policies/procedures and minimum standards that governed their conduct with respect to hiring
Moody, these police personnel would have absolutely gained possession/knowledge of information
about Moody that would have disqualified him as a candidate.
b. Non-police personnel recommended Moody as a top candidate for hire, despite the fact that had
these same non-police personnel performed due diligence in accordance with strict
policies/procedures and minimum standards that governed their conduct with respect to hiring
Moody, these non-police personnel would have absolutely gained Case 1:13-cv-00920-WHA-SRW
Document 31 Filed 06/12/14 Page 14 of 26
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possession/knowledge of information about Moody that would have disqualified him as a candidate.
41.
Based on the strict policies/procedures and minimum standards that governed police personnel for
the City of Dothan with respect to hiring Moody, the subject police personnel who hired Moody
should have (1) never approved him as a top candidate and also should have (2) disqualified him as a
candidate, period.
COUNT ONE (FEDERAL CLAIM) 42 U.S.C. § 1983—FOURTH AMENDMENT VIOLATION
(Against Moody)
42.
The Plaintiff hereby reiterates and incorporates by reference the allegations contained in
paragraphs 1-30 as if set forth fully herein.
43.
At all times relevant to this Complaint the Decedent had a clearly established right under the Fourth
Amendment to the United States Constitution to be free from unreasonable seizure by government
agents such as the Defendant.
44.
Based on all facts that have been incorporated to support this Count, Moody violated the Decedent’s
clearly established right to be free from Case 1:13-cv-00920-WHA-SRW Document 31 Filed 06/12/14
Page 15 of 26
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unreasonable seizure by using deadly force on the Decedent when the Decedent posed no threat to
the Defendant or to any other person.
45.
Because of Moody’s objectively unreasonable conduct, the Plaintiff therefore seeks all damages
permitted by law, including punitive damages, against the Defendant, in an amount to be determined
by the enlightened conscience of a jury, together with interest and any costs this Court deems just.
COUNT TWO (STATE CLAIM) ALA. CODE § 6-5-410—WRONGFUL DEATH
(Against Moody)
46.
The Plaintiff hereby reiterates and incorporates by reference the allegations contained in
paragraphs 1-46 as if set forth fully herein.
47.
The Plaintiff is the natural mother of the Decedent and the administrator of the Decedent’s estate.
48.
Based on the incorporated facts and claim to support this Count, and while working within the scope
of his employment with the City of Dothan, Moody wrongfully killed the deceased by violating the
City of Dothan’s policy/regulation regarding the use of deadly force against Dothan residents such as
the Decedent. Case 1:13-cv-00920-WHA-SRW Document 31 Filed 06/12/14 Page 16 of 26
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49.
Moody’s wrongful conduct, as demonstrated above, directly and proximately caused the Decedent’s
death.
50.
Because the Defendant’s wrongful act caused the death of the Decedent, the Plaintiff is entitled to
bring this survival action pursuant to ALA. CODE § 6-5-410.
51.
The Plaintiff has complied with all Notice of Claim requirements.
52.
The Plaintiff therefore seeks all damages permitted by law, including punitive damages, against the
Defendant, in an amount to be determined by the enlightened conscience of a jury, together with
interest and any costs this Court deems just.
COUNT THREE (STATE CLAIM) ALA. CODE § 11-47-190—NEGLECTFULNESS, UNSKILLFULNESS
OR CARELESSNESS AGAINST THE CITY OF DOTHAN
The following case is relevant to this section: City of Birmingham v. Thompson, 404 So. 2d 589, 592
(Ala. 1981) (stating, “[t]his case was submitted to the jury on the theory that an agent of the City of
Birmingham had used “excessive force” upon the plaintiff, that is, a force which was excessive. That
is the equivalent of asserting an assault and battery not measured or patterned for the
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circumstances, or an unskilled response, whether the force used was, as the trial court charged,
exerted because of the plaintiff’s failure to respond to an order, or because the force was exerted in
meeting a counterforce of the plaintiff. In either case, the lack of a response measured by the
circumstances could have been due to his “unskillfulness” as an officer confronted by either of those
circumstances. As “unskillful” is used in s 11-47-190, it means “lacking in skill or proficiency.”
Webster’s Third New International Dictionary at 1510. Cf. Thomason v. Gray, supra. An assault and
battery committed under either circumstance, because “unskilled,” would be a negligent assault and
battery because it would fall below that response which a skilled or proficient officer would exercise
in similar circumstances.”)
53.
The Plaintiff hereby reiterates and incorporates by reference the allegations
contained in paragraphs 1-30, 42-52 as if set forth fully herein.
54.
The City of Dothan has policy and procedures that required Moody to call in accurate information
regarding his pursuit of the Decedent. Moody violated those procedures by failing to call in
information and accurate information, demonstrating unskilled, neglectful, and careless conduct that
fell below the standard of a well-trained officer. Case 1:13-cv-00920-WHA-SRW Document 31 Filed
06/12/14 Page 18 of 26
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55.
The policy and procedures that governed Moody’s pursuit of the Decedent required Moody to call
off—and actually not even begin—the pursuit based on knowledge Moody possessed from the very
start of the subject pursuit. Had Moody followed the strict policies and procedures that governed his
pursuit of the Decedent, and thereby called off the pursuit, we know for certain that Moody would
not have fatally shot the Decedent under the circumstances that took place. By violating the subject
policy and procedures, Moody’s conduct fell well below that of a well-trained officer and also led to
the assault and battery of the Decedent.
56.
Strict policy and procedures governed Moody’s use of force against the Decedent; these policies and
procedures forbade Moody from jumping out of his car and then simultaneously running over to the
Decedent while shooting the Decedent in the neck with no adequate warning, and without taking
cover behind his own car. The Decedent was sitting in a stopped vehicle while looking at Moody’s
gun pointed toward him, as Moody violated strict policy and procedures by exiting his car and
simultaneously running over and shooting the Decedent in the neck and body–that response fell well
below that of a well-trained officer, especially a well-trained officer of the Dothan Police Department
(notably, another officer on the scene was reaching for his taser while the Decedent’s car was Case
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20
stopped—a safer alternative according to the City’s use of force policy. But Moody ignored that
policy directive and decided to shoot to kill.
57.
At the time Moody fatally shot the Decedent, Moody knew that the use of force was no longer
justified according to his policy and procedures because, amongst other reasons, the Decedent’s car
was stopped and the Decedent was staring at Moody, yet Moody ran at the Decedent and began
shooting him in the neck with no adequate warning to obey any type of command.
58.
Based on the facts and factual statements incorporated into this Count, along with the facts and
factual statements expressly stated in this Count, the City of Dothan is liable for Moody’s conduct
because his conduct/response constituted neglectful, unskillful, and carless conduct that fell well
below that of a well-trained officer. Those same facts and factual statements demonstrate that
Moody’s conduct fell below that of a well-trained officer to the extent that Moody committed the act
of negligent assault and battery against the Decedent.
59.
For the above reasons in this Count, the City of Dothan is liable to Plaintiff for the neglectfulness,
unskillfulness, and carelessness of Defendant Moody.
Case 1:13-cv-00920-WHA-SRW Document 31 Filed 06/12/14 Page 20 of 26
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COUNT FOUR (STATE CLAIM)
ALA. CODE § 11-47-190—NEGLECTFULNESS, UNSKILLFULNESS OR CARELESSNESS AGAINST
THE CITY OF DOTHAN FOR NEGLIGENT HIRING
60.
The Plaintiff hereby reiterates and incorporates by reference the allegations
contained in paragraphs 1-52, with emphasis on facts 31-41.
61.
Based on the incorporated facts in this Count, the City of Dothan is liable for negligent hiring due to
the negligence of both its police personnel and non-police personnel who were responsible for hiring
Moody.
62.
The City of Dothan is liable to Mrs. Thomas because both non-police officer personnel and actual
police officer personnel for the City violated the City’s detailed policies/procedures and minimum
standards—some of which are described as minimum employment standards and procedures—in a
neglectful, unskillful and careless manner. The referred to minimum standards and other applicable
policies/procedures would have placed, and actually did place, both non-police and police personnel
on notice that Moody had violated detailed minimum employment standards and procedures by
committing, inter alia (1) acts which would constitute a serious misdemeanor whether criminally
prosecuted or not; (2) act or acts that would constitute domestic violence whether criminally Case
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22
prosecuted or not; and (3) acts which would give rise to substantial doubts about the applicant’s
respect for the law or for the rights of others—such as (1) Moody’s suspension from the Pensacola
Police Department, in 1996, for violating Florida’s battery statute when he punched his then
girlfriend in the eye while at a public establishment; (2) Moody’s resignation, in 2003, while being
investigated (and recommended for termination) for violating moral character standards
(characterized by his then Chief as scandalous and disgraceful conduct while on or off duty) related
to beating up a different girlfriend; (3) internal allegations of Moody violating policies regarding
control of evidence; (4) internal allegations of Moody violating reporting requirements; (5) Moody’s
proclivity to make “trivial” traffic stops and turn them into full blown search and seizures based on
unlawful grounds; (6) Moody’s “more than experimental use” of marijuana; (7) Chief’s demand that
Moody undergo evaluation and counseling for anger management and also a different
recommendation, by a different police official, that Moody take diversity training; and more.
63.
The non-police and police officials’ carelessness, unskillfulness, and neglectful (negligent) conduct
stems directly from failing to adhere to its own detailed minimum employment standards and other
applicable policies/procedures Case 1:13-cv-00920-WHA-SRW Document 31 Filed 06/12/14 Page 22
of 26
23
with respect to background investigations such as, for example, criminal records check and former
employment checks.
64.
By failing to follow its own self-described detailed minimum employment standards and other
applicable policies/procedures regarding the hiring of Moody, the City of Dothan placed an officer
who never worked as a peace officer in Florida again after 2003 on to the streets of Dothan, Al—in
2008—with a license to use deadly force. Had the City followed its own “extensive” hiring practices,
the City would not (and should not) have hired Moody. If the City of Dothan had not hired Moody, we
know for sure that Moody would not have fatally shot the Decedent in the capacity of a Dothan
Police Officer. Consequently, the City of Dothan is liable to Mrs. Thomas for the Decedent’s death in
the form of all damages allowable under controlling law.
ATTORNEY FEES
65.
Plaintiff is entitled to reasonable attorney fees under applicable federal and state law.
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PUNITIVE DAMAGES
66.
The wrongful conduct of Moody arose to a level that entitles Mr. Thomas to punitive damages under
applicable law regarding Plaintiff’s wrongful death claim.
PRAYER FOR RELIEF
WHEREFORE, the Plaintiff respectfully prays for the following relief:
1. That this Court exercise jurisdiction over this case and grant a jury trial;
2. That this Court decide, as a matter of law, all issues not required to be determined by a jury;
3. That this Court award all permissible damages recoverable from the Defendant, including general,
special, compensatory, punitive, and any other damages deemed appropriate, in an amount to be
determined at trial;
4. That this Court permit recovery of reasonable attorney’s fees and costs in an amount to be
determined by this honorable Court under applicable law; and
5. That this Court grant any additional relief that this Honorable Court deems appropriate under the
circumstances.
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Respectfully submitted this 12th day of June 2014,
s/MARIO WILLIAMS
Mario Williams GA Bar No.: 235254
Williams Oinonen, LLC
44 Broad Street, NW, Suite 200
Atlanta, Georgia 30303
(404) 654-0288 Telephone
(404) 592-6225 Facsimile
Counsel for Mrs. Thomas
s/ M. ADAM JONES______
M. Adam Jones (JON 126)
Al Bar No: ASB-7342-J63M
M. Adam Jones & Associates, LLC
206 N. Lena St.
Dothan, AL 36303
Phone: (334) 699-5599
fax: (334) 699-5588
Counsel for Mrs. Thomas
Case 1:13-cv-00920-WHA-SRW Document 31 Filed 06/12/14 Page 25 of 26
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CERTIFICATE OF SERVICE
I certify that on this day PLAINTIFF’S FIRST AMENDED COMPLAINT has been sent via CM/ECF
electronic mail to the following attorneys of record:
D. Kevan Kelly
P.O. Box 2128
Dothan, AL 36302
Counsel for Defendant
Respectfully submitted this 12th day of June 2014,
s/MARIO WILLIAMS
Mario Williams, Esq.
GA Bar No. 235254
WILLIAMS OINONEN LLC
The Grant Building, Suite 200
44 Broad Street N.W.
Atlanta, Georgia 30303
Phone: (404) 654.0288
Fax: (404) 592.6225
Counsel for Ms. Thomas
Case 1:13-cv-00920-WHA-SRW Document 31 Filed 06/12/14 Page 26 of 26