Wherefore, Plaintiffs Immanuel Campbell, Rubin Carter, Markees Sharkey, Deonte Beckwith, Chante Linwood, and Rachel Jackson, on behalf of themselves and the putative class they seek to represent, request that this Court grant the following relief:
a. Issue an Order certifying this case as a class action pursuant to Federal Rules of Civil Procedure 23(a) and 23(b)(2); and
b. Issue a class-wide judgment declaring that the policies, practices, and conduct of the City of Chicago, through the CPD and as described in this Complaint, constitute violations of the rights of Plaintiffs and the class they represent under the U.S. Constitution and Illinois state law.
In addition, the individual named Plaintiffs, on behalf of the class, as well as Organizational Plaintiffs Black Lives Matter Chicago, Blocks Together, Brighton Park Neighborhood Council, Chicago Urban League, Justice For Families, NAACP, Network Case: 1:17-cv-04467 Document #: 83 Filed: 09/05/17 Page 133 of 137 PageID #:1135 134 49, Women’s All Points Bulletin, and 411 Movement for Pierre Loury, request that this Court:
c. Issue an order granting the following injunctive relief:
i) Enjoining the CPD from its policy, practice and/or custom of excessive use of force;
ii) Enjoining the CPD from its policy and practice of using force in a racially discriminatory manner;
iii) Appointing an independent monitoring team that reflects the diversity of Chicago’s communities, and which will report to the federal court on the status of the CPD’s compliance with the order. The Monitoring Team will have unfettered access to all CPD data, records, videos and any other materials needed to assess compliance with the order and will file monitoring reports on a quarterly basis. The Monitoring Team will be required to incorporate community perspectives in each monitoring report. The monitoring reports shall be publicly available via a website, at public libraries, community centers, and other locations that will ensure communities’ wide-spread access to the reports;
iv) The Plaintiffs seek an order from this Court designed to fundamentally transform the CPD operations related to use of force policies and practices, accountability supervision, discriminatory policing, training, data collection, and transparency, and ensure the CPD provides officers with the comprehensive training and supportive resources that they need to eliminate excessive and discriminatory uses of force. The specific provisions the Plaintiffs seek will include, but are not limited to the following:
a) USE OF FORCE: The development and implementation of use of force policy, practices, and training, including force reporting and oversight, that: (i) minimize the use of force to circumstances only when force is necessary, after other available means have been exhausted and, (ii) seek to limit the amount of Case: 1:17-cv-04467 Document #: 83 Filed: 09/05/17 Page 134 of 137 PageID #:1136 135 force used to the least amount necessary under the circumstances, emphasizing principles of de-escalation, and tactics such as time and distance;
b) ACCOUNTABILITY AND SUPERVISION: The development and implementation of policies and practices ensuring that: the entire system of police accountability is community-based, impartial, transparent, effective, adequately resourced, and timely. The development and implementation of policies, practices, and training that address head-on the CPD’s code of silence. Reformation of the CPD’s supervisory practices and incentives to ensure constitutional and accountable policing. Revision to policies, procedures, supervision, and training concerning the use of police cameras and video;
c) DISCRIMINATORY POLICING: The development and implementation of policies, procedures, and a comprehensive training module ensuring that CPD officer actions and the CPD’s programs and initiatives are free from discrimination on the basis of race, color, ethnicity, national origin, religion, gender, disability, sexual orientation or gender identity and that all officers are responsible for intervening to stop instances of discriminatory policing and for reporting such instances to their direct supervisor(s);
d) REDUCING UNNECESSARY POLICE RESPONSE: The development and implementation of policies and procedures that reduce unnecessary police response, significantly reduce overall use of force incidents and eliminate racial disparities in the use of force, including but not limited to the following: a data-driven pre-arrest diversion program that reduces excessive uses of force and racial disparities in the use of force by empowering officers with the discretion to divert people from the formal justice system; a requirement that officers obtain supervisory approval prior to making an arrest for certain minor offenses and offenses often falsely charged in an effort to conceal incidents of excessive force; the measurement, evaluation, and issuance of commendations at the individual, Case: 1:17-cv-04467 Document #: 83 Filed: 09/05/17 Page 135 of 137 PageID #:1137 136 supervisory and agency level for positive, non-arrest-based community-engagement, crime prevention and conflict resolution;
e) DATA AND TRANSPARENCY: The development and implementation of a system of public dissemination of all data and information pertaining to officer misconduct, including but not limited to: (i) judicial findings that an officer is not credible, (ii) civil lawsuits pertaining to all uses of force and the attendant investigations, whether conducted by BIA or COPA, including complainant allegations and, (iii) the release of video and other information in police misconduct and shooting investigations within 48 hours of the incident/receipt of the video. All public data used in the preparation of any reports should be made available as machine-readable data through a publicly accessible portal;
f) SUPPORTIVE SERVICES FOR SURVIVORS OF POLICE VIOLENCE: The provision of comprehensive, community-based, trauma-informed support services for individuals who are victims of excessive force and other forms of police misconduct.
d. Issue an order and judgment granting reasonable attorneys’ fees and costs, pursuant to 42 U.S.C. § 1988;
e. Grant such other relief as this Court deems just and proper.
The individual named Plaintiffs also seek compensatory damages against all Defendants for the violations alleged in this Complaint. They similarly seek punitive damages against the individual Defendant Officers for these violations.