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IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF MISSISSIPPI
EASTERN DIVISION

JHAQULIA STEVENS PLAINTIFF

VERSUS Civil Action No. 2:24-cv-00070-TBM-RPM

OFFICER PATRICK DICKERSON

in his individual and official capacity,
OFFICER TAMMY MYERS
in her individual and official capacity,
OFFICER DEVIN CRAVEN
in his individual and official capacity,
OFFICER AMANDA GOULD
in her individual and official capacity,
THE CITY OF LAUREL, MISSISSIPPI,
a municipal corporation,
CHIEF TOMMY COX
in his individual and official capacity,
& DOE OFFICERS 1-10 DEFENDANTS

COMPLAINT
[JURY TRIAL DEMANDED]

INTRODUCTION

This civil rights action seeks monetary damages against Defendants for past violations of

the Plaintiffs' rights guaranteed by the United States Constitution and Mississippi law. The

Defendants' wrongful conduct began on February 2, 2023 in Laurel, MS. Before her interaction

with the Defendants, Jhaqulia had never been convicted of any criminal act. At no time relevant

herein was Jhaqulia engaged in any illegal activity. At all times relevant herein, the individual

Defendants were acting under color of law.

The constitutional violations resulted from the policies and customs as established and

observed by the final policymaker for the Laurel Police Department, Tommy Cox. The systemic

abuses by the Laurel Police Department result from a custom and culture that encourages,

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sanctions, minimizes, and protects violations of the constitutional rights of regular citizens and an

ongoing pattern and practice of failing to train, supervise, and discipline properly.

Therefore, each Defendant is liable for the constitutional violations explained herein and

all resulting damages and harms.

A. THE PARTIES

1. Plaintiff Jhaqulia Stevens (“Jhaqulia”) is an adult citizen of Jones County, MS.

2. Defendant Officer Patrick Dickerson (“Officer Dickerson”) is and/or was at the

time of the incident complained of herein an officer with the Laurel Police Department.

3. Defendant Officer Tammy Myers (“Tammy Myers”) is and/or was at the time of

the incident complained of herein an officer with the Laurel Police Department.

4. Defendant Officer Devin Craven (“Officer Craven”) is and/or was at the time of the

incident complained of herein an officer with the Laurel Police Department.

5. Defendant Officer Amanda Gould (“Officer Gould”) is and/or was at the time of

the incident complained of herein an officer with the Laurel Police Department.

6. Defendant Tommy Cox (“the Chief” or “Chief”) is and/or was at the time of the

incident complained of herein the chief of the Laurel Police Department.

7. Defendants named above may be served at their headquarters at 317 Magnolia

Street, Laurel, MS 39440.

8. Defendant City of Laurel, Mississippi (“the City” or “City”) is a municipal

corporation incorporated under the laws of the State of Mississippi and is the entity that governs

and is liable for any malfeasance of the Laurel Police Department. The City of Laurel may be

served through its mayor or city clerk at 401 N. 5th Avenue, Laurel, MS 39440.

B. JURISDICTION & VENUE

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1. This action arises under the United States Constitution and federal law under

provisions of the Fourth and Fourteenth Amendments of the United States Constitution and 42

U.S.C. § 1983.

2. This action seeks redress for violations of the civil rights laws of the United States,

and jurisdiction is therefore invoked under 28 U.S.C. §§ 1331 and 1343, inter alia.

3. The claims made in this Complaint occurred and arose in the State of Mississippi

in the city of Laurel and therefore in this District and the Hattiesburg Division. Venue, therefore,

lies in this Court under 28 U.S.C. § 1391.

4. Under 28 U.S.C. § 1367, this Court also has pendent jurisdiction to hear state law

claims.

C. FACTS UNDERLYING THE CLAIMS

1. On February 2, 2023, JHAQULIA was driving on 2nd Avenue in Laurel, MS near

the intersection of Teresa Street and 6th Street.

2. As she was driving, JHAQULIA noticed that a car that she thought was her

brother’s car had been pulled over by the police.

3. JHAQULIA stopped momentarily in the roadway to see if that was her brother’s

car.

4. Officer Dickerson instructed JHAQULIA to “get on down the road”, and she

immediately drove away.

5. Nothing JHAQULIA did was illegal, and she did nothing that would make any

reasonable person upset or feel that she had disrespected or questioned them.

6. Officer Dickerson became angry, jumped in his squad car, and peeled out to chase

the vehicle of JHAQULIA. Officer Dickerson did this even though he had just told her to go down

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the road, and she complied with that request immediately without saying anything even remotely

disrespectful or inflammatory to Officer Dickerson.

7. Upon noticing Officer Dickerson pursue her, JHAQULIA immediately pulled into

a parking lot that was no more than 500 feet away from the spot where her brother had been pulled

over.

8. Officer Dickerson sped into the parking lot where JHAQULIA was parked, got out

of his squad car, and aggressively approached JHAQULIA’s vehicle.

9. As he approached JHAQULIA’s vehicle, she had already opened her door and had

her wallet in her hand ready to retrieve her license to give to Officer Dickerson.

10. Officer Dickerson did not immediately ask for JHAQULIA’s license and instead

began asking her rhetorical and antagonistic questions.

11. Officer Dickerson accused JHAQULIA of interfering with a traffic stop, and she

denied such accusations.

12. Officer Dickerson then asked JHAQULIA to give him her driver’s license, and she

immediately gave it to him.

13. Officer Dickerson continued to threaten and antagonize JHAQULIA, and because

she questioned him, he ordered JHAQULIA to get out of her car. She immediately got out of the

car.

14. Officer Dickerson again accused JHAQULIA of interfering with a traffic stop, and

she denied such accusations again.

15. Officer Dickerson became progressively frustrated with JHAQULIA simply for

questioning him and retaliated against JHAQULIA for denying that she had interfered with a

traffic stop by placing her under arrest.

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16. Officer Dickerson has a history of getting angry at citizens for talking or expressing

their First Amendment Rights when they assert that he is wrong about something. Officer

Dickerson is frequently wrong about things.

17. At the time of her arrest, JHAQULIA had committed no crime. No reasonable

person, much less officer, would have believed or suspected that JHAQULIA had committed a

crime.

18. JHAQULIA was arrested, booked into the local jail, and charged by Officer

Dickerson and Officer Gould with resisting or obstructing arrest under Miss. Code § 97-9-73 and

failure to comply with an officer under Miss. Code § 97-35-7.

19. JHAQULIA spent about 4 hours in jail. While she was in jail, she missed out on a

business opportunity.

20. JHAQULIA never resisted arrest nor did she disobey any orders even though the

orders she was given by Officer Dickerson were not lawful.

21. Officer Dickerson provided statements to a supervising officer, who he called

‘Stringer’, on the phone shortly after arresting JHAQULIA seemingly in an attempt to justify his

arrest of JHAQULIA after he had already made the arrest.

22. The practice of manufacturing post hoc justifications and corroborations for

unconstitutional actions is common in the Laurel Police Department. The practice is encouraged

by supervisors to create the false appearance of credibility in frivolous arrests.

23. Officer Dickerson and Officer Craven were in direct contact with JHAQULIA at

the time of and directly after her arrest. In other words, Officer Craven assisted in the unreasonable

seizure and arrest of JHAQULIA. Other Officers may have assisted as well.

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24. Officer Myers was on the scene during and after the time of JHAQULIA’s arrest.

Officer Myers did not intervene to stop Officer Dickerson from violating JHAQULIA’s rights. It

is unknown the extent to which Officer Myers participated in the arrest and prosecution of

JHAQULIA at this time.

25. Other Laurel Police Officers who were on the scene during the incident described

above did not intervene to stop Officer Dickerson despite witnessing him manufacture a cause of

action against JHAQULIA in violation of her rights on several counts.

26. Officer Amanda Gould executed a false arrest affidavit accusing JHAQULIA of

resisting arrest although it is unknown whether she was on the scene during the violations of

Jahqualia’s rights described above. It is unknown if Officer Gould had observed any of the that

led to the arrest of JHAQULIA. In other words, it is unclear if Officer Gould knew that the affidavit

she swore to was actually false at the time that she signed it. Officer Gould never repudiated her

false affidavit regardless of what she became aware of after executing it.

27. On May 15, 2023, Officer Dickerson testified falsely against JHAQULIA in Laurel

Municipal Court before Judge Kyle Robertson to various facts about the incident. The testimony

included, but was not limited to, the following false claims:

a. JHAQULIA jerked her arm away from Officer Dickerson.

b. JHAQULIA refused to drive away from the area where the officers had

pulled over her brother.

c. JHAQULIA yelled curse words at the officers.

d. JHAQULIA locked her door to prevent Officer Dickerson from gaining

access to her.

e. JHAQULIA refused to provide her identification.

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f. JHAQULIA’s car door was closed when the officer approached her vehicle.

g. JHAQULIA refused repeatedly to get out of her vehicle when commanded

to do so.

28. Indisputable body cam footage proves that Officer Dickerson’s testimony against

JHAQULIA was false.

29. Indisputable body cam footage proves that Officer Dickerson and Officer Gould’s

affidavits of arrest against JHAQULIA were false.

30. Indisputable body cam footage proves that Officer Dickerson had no probable cause

to arrest JHAQULIA.

31. Indisputable body cam footage proves that Officer Dickerson was unnecessarily

aggressive and created a public danger without justification by driving his squad car in a reckless

fashion.

32. Indisputable body cam footage proves that JHAQULIA never yelled at nor cursed

at the officers during the incident described above.

33. Indisputable body cam footage proves that Officer Dickerson’s actions were

unreasonable.

34. The body cam footage of the incident described herein speaks for itself and contains

more information than could be fully stated in a complaint.

35. After JHAQULIA motioned in the underlying municipal court case against her to

have the cause against her dismissed based on the clear evidence and false testimony of Officer

Dickerson, JHAQULIA was instead found not guilty sua sponte on both counts by Judge Kyle

Robertson in Laurel Municipal Court.

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36. Officer Craven personally participated in the arrest and unlawful treatment of

JHAQULIA. Officer Craven was also present to testify against JHAQULIA, but after JHAQULIA

was found not guilty, his testimony was not taken.

37. During the course of the arrest of JHAQULIA, Officer Craven tried to calm down

officer Dickerson, who was visibly angry, but Officer Craven did nothing to stop Officer

Dickerson. Instead, he participated in the wrongful conduct on the scene and in the prosecution of

JHAQULIA.

38. JHAQULIA, through her undersigned attorney, submitted evidence of the false

testimony and the incident described above to Chief Tommy Cox after being found not guilty on

both counts against her.

39. Over a year later, no disciplinary action has been taken against Officer Dickerson

nor any of the other officers involved by the Laurel Police Department for their illegal,

unconstitutional and/or fraudulent actions described above. The Chief is the person responsible for

correcting the misconduct of his officers and is the chief decision and policy maker for the Laurel

Police Department.

D. DEPRIVATION OF FEDERAL RIGHTS UNDER 42 U.S.C. § 1983

1. All of the relevant acts of Defendants, their agents, servants and employees, were

carried out under the color of state law and in their official capacity as agents of the Department.

2. These acts deprived Plaintiff of the rights, privileges and immunities guaranteed to

citizens of the United States by the Fourth and Fifth Amendments as incorporated against the States

by the Fourteenth Amendment to the Constitution and in violation of 42 U.S.C. § 1983.

FIRST COUNT – Unlawful Seizure by Officer Dickerson

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3. Officer Dickerson initially violated JHAQULIA’s rights by getting into his squad

car and chasing JHAQULIA down without reasonable suspicion or probable cause to believe that

she had committed a crime.

4. The illegal seizure of JHAQULIA’s vehicle and person by Officer Dickerson was

done in such a manner that no reasonable person would have thought that they were free to leave.

5. The illegal seizure of JHAQULIA’s vehicle and person was a deprivation of her

civil rights to be free from unlawful seizures under the Fourth Amendment.

6. The purpose of Officer Dickerson pursuing and seizing JHAQULIA was not for

any lawful purpose, rather it was to teach her a lesson about what Officer Dickerson perceived to

be a slight against him, which in fact did not occur.

SECOND COUNT – False Arrest by Officer Dickerson and Officer Craven

7. Officer Dickerson violated the Plaintiff’s rights by placing her under arrest without

probable cause to believe that she had committed a crime. Officer Craven assisted with the arrest.

8. The purpose of Officer Dickerson placing JHAQULIA under arrest was not for any

lawful purpose, rather it was to teach her a lesson about what Officer Dickerson perceived to be a

slight against him, which in fact did not occur.

9. The false arrest of JHAQULIA was a deprivation of her civil rights to be free from

arrest without necessary probable cause under the Fourth Amendment.

THIRD COUNT – False Imprisonment

10. Officer Dickerson, Officer Craven, Officer Gould, and/or Doe Officers violated the

Plaintiff’s rights by having her booked into the Laurel Municipal Jail without reasonable suspicion

or probable cause to believe that she had committed a crime.

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11. The false imprisonment was a deprivation of her liberty without the requisite due

process of law as defined under the Fourteenth Amendment.

FOURTH COUNT – Malicious Prosecution

12. Officers Dickerson and Officer Gould violated the Plaintiff’s rights by filing false

charging documents against JHAQULIA and/or by executing a false affidavit to support her

prosecution and to justify her arrest.

13. Officer Dickerson initiated the prosecution against JHAQULIA for the purpose of

retaliating against her for questioning his false seizure of her.

14. Officer Dickerson testified falsely against JHAQULIA.

15. Officer Craven was prepared to testify falsely against JHAQULIA.

16. JHAQULIA was found to be not guilty of any criminal act for the incident

described above. No reasonable person with knowledge of the facts would believe that she had

committed a crime at the time of her arrest and subsequent prosecution.

SIXTH COUNT – Failure to Intercede and Prevent the Violation of Rights

17. Officers Craven, Gould, and Myers failed to intercede on behalf of JHAQULIA

even though they knew or should have known that the actions being taken by Officer Dickerson

were an egregious violation of JHAQULIA’s rights.

18. Officers Craven, Gould, and Myers knew and/or should have known that

JHAQULIA was unjustifiably seized, arrested, jailed and/or prosecuted. The Officers knew and/or

had a duty to know that JHAQULIA’s constitutional rights were violated.

19. Officers Craven, Gould, and Myers all had realistic opportunities to intervene to

prevent the constitutional violations from occurring.

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20. Defendants are liable for Officers Craven, Gould, and Myers failing to intercede on

JHAQULIA’s behalf to stop the violations under .

SEVENTH COUNT – Monell Claim

21. On information and belief, the Laurel Police Department has a custom and culture

of violating the constitutional rights of others. Though not a written policy, this custom was so

widespread as to have the force of law.

22. The Laurel Police Department has a history of wrongfully tolerating, condoning,

and encouraging constitutional violations. As a result, the custom and culture at the Laurel Police

Department is to protect its officers when they violate the constitutional rights of others. The Laurel

Police Department only disciplines deputies, if at all, when their actions are exposed by third-party

video, making the misconduct impossible to deny or explain away.

23. Tommy Cox and the Laurel Police Department have a well-established history of

failing to properly train, supervise, investigate, and discipline its deputies when they violate the

constitutional rights of the citizens in Laurel, Mississippi.

24. The Laurel Police Department has a history of fabricating facts and falsely

testifying against arrestees and victims of excessive force to cover up these constitutional

violations.

25. The Laurel Police Department has acted with deliberate indifference to a pattern of

past occurrences of constitutional violations of citizens such that its deputies feel empowered to

violate the constitutional rights of its targets with impunity.

26. These customs and practices are the moving force behind the violations of the

Plaintiff’s rights enumerated herein.

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27. Plaintiffs are aware of many other situations where the Laurel Police Department

violated the constitutional rights of others.

28. Chief Tommy Cox has never taken corrective action to fix the culture within his

department. If fact, Chief Tommy Cox encourages it.

29. Chief Tommy Cox and the Laurel Police Department have a demonstrable pattern

and practice of improperly training, supervising, and disciplining deputies.

E. DAMAGES

1. The Defendants are liable to the Plaintiff, jointly and severally, for all wrongful acts

which harmed and caused damage to the Plaintiff.

2. The Defendants are liable for damages for all violations of the civil rights of the

Plaintiff under the Constitution of the United States as defined by 42 U.S.C. 1983.

3. Based on the facts and circumstances described in this Complaint, and as a direct

result of said acts and omissions of the Defendants, the Plaintiff has suffered damage to reputation;

past pain and suffering; past, present, and future emotional distress; and other financial losses.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff requests a JURY TRIAL, and that after a jury trial a judgment be

entered against Defendants, jointly and severally, as follows:

1. Compensatory damages of at least $250,000 or such other amount supported by the

evidence at trial;

2. Punitive damages in an amount to sufficiently deter the bad behavior described in

this Complaint;

3. Attorney fees and costs of suit under 42 U.S.C. § 1988;

4. Ordinary taxable costs of suit;

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5. Prejudgment and post-judgment interest at the legal rate; and

6. Any and all other further relief as the Court deems appropriate.

Respectfully submitted, May 7, 2024.

JHAQULIA STEVENS

By:
Matthew W. Lawrence

Matt Lawrence Law Firm

525 N. Main Street
Hattiesburg, MS 39401
(408) 605-8473
[email protected]
MSB # 105958

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