Brown vs. Amerson suit

Page 1

Case 1:11-cv-01182-RBP Document 1

FILED

Filed 04/05/11 Page 1 of 13

2011 Apr-05 PM 01:29 U.S. DISTRICT COURT N.D. OF ALABAMA

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA EASTERN DIVISION J.B., a minor, who sues by and through his mother and next friend, STACY BROWN, Plaintiff, v. SHERIFF LARRY AMERSON, in his official and individual capacities, and DEPUTY WARD, in his official and individual capacities, Defendants.

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Civil Case No. JURY TRIAL DEMANDED

COMPLAINT

COMES NOW Plaintiff, by and through his attorneys of record, and would show unto the Court as follows: JURISDICTION AND VENUE 1.

Plaintiff files this Complaint and invokes the jurisdiction of this Court under and by virtue of the Fourth, Fifth, and Fourteenth Amendments to the Constitution of the United States, 42 U.S.C. § 1983, 42 U.S.C. § 1985, 42 U.S.C. § 1986, 42 U.S.C. § 1988, 28 U.S.C. § 1331, 28 U.S.C. § 1343, 28 U.S.C. § 2201, 28 U.S.C. § 2202, and the doctrine of supplemental jurisdiction to obtain declaratory relief and compensatory and punitive damages. Defendants violated Plaintiff’s rights as guaranteed by the Constitution of the United States and by Federal law.

2.

The violations of Plaintiff’s rights as alleged herein occurred in Calhoun County, Alabama, and were committed within the Eastern Division of the Northern District of the Page 1 of 13


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