Case 2:19-cv-04883-SMB Document 1 Filed 08/05/19 Page 1 of 4

1 J. Scott Halverson, SBN 10629

LAW OFFICES OF J. SCOTT HALVERSON, P.C.
2 1761 E. McNair Drive, Suite 103
Tempe, Arizona 85283
3 Telephone (480) 777-7776
Facsimile (602) 357-7444
4 Email: scott@halversonfirm.com
5 Taz F. Evans, SBN 010225
EVANS DOVE & NELSON PLC
6 2650 E. Southern Ave.
Mesa AZ 85204
7 Telephone: (480) 926-8600
Email: tazevans@hotmail.com
8
Attorneys for Plaintiff
9
IN THE UNITED STATES DISTRICT COURT
10
FOR THE DISTRICT OF ARIZONA
11
12 Samantha Glass, No.
13 Plaintiff,
COMPLAINT
14 vs.
15 Officer Christopher Robinson (Badge
No. 2849), and John Does I-X;
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Defendants.
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18 For the Complaint against the Defendants, Plaintiff alleges as follows:
19 JURISDICTIONAL ALLEGATIONS
20 1. At all relevant times, Plaintiff Samantha Glass resided in Mesa, Maricopa
21 County, Arizona.
22 2. At all relevant times, Defendant Officer Christopher Robinson was a
23 uniformed police officer employed by the Town of Gilbert Police Department.
24 3. The events giving rise to this Complaint occurred in Maricopa County,
25 Arizona.
26 4. Plaintiff asserts violations of his United States Constitutional rights, as
27 codified in 42 U.S.C. § 1983, et seq., so this Court has jurisdiction to preside over this
28 case, pursuant to 28 U.S.C. §§ 1331 and 1343(a)(3).
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1 5. Venue is proper in this Court, pursuant to 28 U.S.C. § 1391(b), as the

2 parties are residents of Arizona and the relevant events occurred in Arizona.
3 ALLEGATIONS OF FACT
4 6. On the evening of March 9, 2018, Plaintiff Samantha Glass arrived at the
5 apartment complex located at 230 E. Civic Center Drive in Gilbert, Arizona, to meet with
6 her ex-husband to discuss issues regarding their minor daughter.
7 7. The couple met out in the parking lot where a verbal argument ensued
8 between the two. Plaintiff’s ex-husband walked away, taking their minor daughter away
9 from Plaintiff.
10 8. Plaintiff attempted to enter her ex-husband’s vehicle in order to wait for
11 him, but was unable to enter the locked vehicle.
12 9. Plaintiff then walked to her ex-husband’s apartment and sat on the ground
13 outside his door, intending to speak with him when he returned.
14 10. Apparently, a resident of the apartment complex had mistakenly believed
15 that Plaintiff was trying to burglarize the vehicle and called 911.
16 11. Plaintiff had consumed an excessive amount of alcohol and was visibly
17 inebriated.
18 12. Officer Robinson was the first officer to arrive at the scene and confronted
19 Plaintiff while she was peacefully sitting on the ground in front of her ex-husband’s
20 upstairs apartment.
21 13. Officer Robinson questioned Plaintiff and tried to persuade her to admit that
22 she had attempted to break into a vehicle.
23 14. Plaintiff stood up and continued responding to the officer’s questions.
24 15. It was obvious from Plaintiff’s demeanor and manner of speech that she
25 was extremely impaired by alcohol consumption.
26 16. During Officer Robinson’s questioning, Plaintiff attempted to call her ex-
27 husband several times in an effort to clear up the misunderstanding and prove that she had
28 not attempted to commit a burglary.

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1 17. When her ex-husband did not answer, Plaintiff attempted to walk past
2 Officer Robinson toward the stairs to descend to the lower level.
3 18. The Officer told Plaintiff that she was not free to go and that he intended to
4 handcuff her.
5 19. Suddenly, the Officer grabbed Plaintiff’s right arm and twisted it behind her
6 back.
7 20. Plaintiff panicked and attempted to free her arm.
8 21. The Officer, while still holding Plaintiff’s right arm, put his left hand on her
9 back, pushed her down face-first, causing her face to violently slam onto concrete.
10 22. That degree of force that Officer Robinson used to throw Plaintiff to the
11 ground was unnecessary and unreasonable.
12 23. The Officer was acting under color of state law, as a police officer for the
13 Town of Gilbert throughout his involvement in the above-described incident.
14 24. The Defendant Officer was acting under color of state law during his
15 involvement in the above-described incident.
16 VIOLATION OF PLAINTIFF’S FEDERAL CIVIL RIGHTS
17 25. Plaintiff hereby incorporates all previous allegations in this Complaint.
18 26. Officer Robinson, acting under color of state law, deprived Plaintiff of her
19 rights, privileges and immunities secured by the Fourth and/or Fourteenth Amendments to
20 the United States Constitution and derivative rights under 42 U.S.C. § 1983 by
21 intentionally using unreasonable, unnecessary and excessive force against Plaintiff, while
22 detaining her.
23 27. The above-described civil rights violations, directly and proximately caused
24 Plaintiff general and special damages, including: physical injuries, pain, suffering,
25 physical impairment, psychological trauma, mental anguish, medical expenses, other
26 economic losses and permanent scarring.
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1 28. Additionally, Defendant Officer’s intentional and egregious use of unlawful

2 force against Plaintiff warrants the imposition of punitive damages against this
3 Defendant.
4 CONCLUSION
5 WHEREFORE, Plaintiff requests judgment against Defendants as follows:
6 A. For general damages and losses already incurred, and to be incurred in the
7 future, in an amount reasonable and proper in the premises;
8 B. For past and future medical expenses and other economic losses incurred by
9 Plaintiff in an amount to be proven at trial;
10 C. For punitive damages;
11 D. For attorney’s fees, pursuant to 42 U.S.C. § 1988;
12 E. For Plaintiff’s costs and expert fees, pursuant to 42 U.S.C. § 1988;
13 F. For such additional relief as the Court may deem just and proper in the
14 premises.
15
16 Dated this 1st day of August, 2019.
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18 LAW OFFICES OF J. SCOTT HALVERSON, P.C.
19
By /s/ J. Scott Halverson
20 J. Scott Halverson
Attorney for Plaintiff
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