R. Doc. 86 - First Amended Complaint

Case 5:15-cv-00544-SMH-KLH Document 86 Filed 09/08/15 Page 1 of 47 PageID #: 487
IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF LOUISIANA
GLENN FORD, )
)
Plaintiff, )
) Case No. 5:15-cv-544
v. )
) Hon. S. Maurice Hicks,
The CITY OF SHREVEPORT, DON ) District Judge
ASHLEY, GARY ALDERMAN, )
GARY PITTMAN, EVERETT T. ) Hon. Judge Hayes,
RUSHING, the ESTATE OF BILLY ) Magistrate Judge
LOCKWOOD, FRANK DATCHER, )
GLYNN MITCHELL, R. PRICE, )
POLICE DOES 1-10, ESTATE OF )
GEORGE MCCORMICK, CADDO )
PARISH, PAUL CARMOUCHE, in )
his official capacity as District )
Attorney of Caddo Parish, DALE )
COX, in his official capacity as )
District Attorney of Caddo Parish, )
CADDO PARISH DISTRICT )
ATTORNEY’S OFFICE, and ABC ) JURY TRIAL DEMANDED
INSURANCE COMPANIES, )
)
Defendants. )
FIRST AMENDED COMPLAINT
Plaintiff GLENN FORD, by and through his attorneys, complains of
Defendants the CITY OF SHREVEPORT, DON ASHLEY, GARY ALDERMAN,
GARY PITTMAN, EVERETT T. RUSHING, the ESTATE OF BILLY LOCKWOOD,
FRANK DATCHER, GLYNN MITCHELL, R. PRICE, POLICE DOES 1-10,
ESTATE OF GEORGE MCCORMICK, CADDO PARISH, PAUL CARMOUCHE, in
his official capacity as District Attorney of Caddo Parish, DALE COX, in his official
capacity as District Attorney of Caddo Parish, CADDO PARISH DISTRICT
ATTORNEY’S OFFICE,1 and ABC INSURANCE COMPANIES, as follows:
INTRODUCTION
1. In 1984, Glenn Ford was convicted of a murder he did not commit.
Today, evidence currently being kept secret by law enforcement officials in
Louisiana demonstrates without question that Glenn Ford should never have been
arrested, let alone prosecuted for the murder.
2. Probable cause never existed to arrest and prosecute Glenn Ford for
this crime.
3. On March 10, 2014, Plaintiff was finally exonerated more than thirty
years after he was arrested—when he was released, Glenn Ford was the longest-
serving death row inmate in the United States, spending 29 years, 3 months, and 5
days in solitary confinement. Mr. Ford has Stage Four lung cancer and may not
have long to live—Defendants have therefore taken most of Plaintiff’s adult life
away from him for a crime he did not commit.
4. Mr. Ford’s arrest, detention, prosecution, conviction, and
imprisonment were the product of unconstitutional and unlawful efforts by the
Shreveport Police officers named in this complaint, acting individually and in
concert with one another and others unknown, under municipal and parish policies
and practices, to use any means necessary to gain a conviction.
1 Pending before this Court is a Motion to Dismiss the Caddo Parish District Attorney’s Office
based on case law that provides that the District Attorney in his or her official capacity is the proper
party. Plaintiff includes the Caddo Parish District Attorney’s Office as a party in this First Amended
Complaint to preserve his claims in the event that this Court or an appellate court determines that
the Office itself is the proper party.
2
5. Defendant Ashley, a lead detective in the case, admitted under oath
that, “the chief goal [of a Shreveport Police investigation] is to identify any suspects,
defendants, and then develop evidence that would support an arrest of those
identified suspects.”
6. The Shreveport Police officers did exactly as Defendant Ashley
admitted they do—they identified Glenn Ford as the perpetrator and manufactured
evidence against him, in violation of the United States Constitution and Louisiana
law. In addition, the Shreveport Police officers named in this complaint destroyed
and suppressed exculpatory evidence that would have shown Mr. Ford to be
innocent. These police officers did all of this pursuant to the policies and practices of
the Shreveport Police Department and the City of Shreveport.
7. Pleading in the alternative, employees and representatives of the
Caddo Parish District Attorney’s Office knew of some or all of the exculpatory
evidence described in this complaint. Instead of turning that evidence over to Mr.
Ford and his defense attorneys prior to Mr. Ford’s criminal proceedings, those
employees and representatives of the Caddo Parish District Attorney’s Office
suppressed the evidence, acting pursuant to the policies and practices of the Caddo
Parish District Attorney’s Office, which deprived Mr. Ford of his rights under the
United States Constitution and Louisiana law.
8. As a direct result of Defendants’ intentional, bad faith, willful, wanton,
reckless, and deliberately indifferent acts and omissions, Mr. Ford sustained
injuries and damages including the loss of his freedom for almost thirty years,
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personal injuries, pain and suffering, severe mental anguish, emotional distress,
loss of income, inadequate medical care, humiliation, indignities and
embarrassment, degradation, permanent loss of natural psychological development;
and restrictions on all forms of personal freedom including but not limited to diet,
sleep, personal contact, educational opportunity, vocational opportunity, athletic
opportunity, personal fulfillment, sexual activity, family relations, reading,
television, movies, travel, enjoyment, and freedom of speech and expression.
9. This civil action seeks money damages and other relief for these
extraordinary injuries and losses suffered by Glenn Ford at the hands of
Defendants.
PARTIES
10. Plaintiff Glenn Ford is an African-American man who spent nearly 30
years of his life in solitary confinement for a crime he did not commit.
11. Defendants Don Ashley, Gary Alderman, Everett Rushing, Gary
Pittman, the Estate of Billy Lockwood, Frank Datcher, Glynn Mitchell, R. Price,
and Police Does 1-10 (collectively “Law Enforcement Defendants”) are present or
former Shreveport Police officers, who are sued in their individual capacities.
12. Defendant City of Shreveport is a Louisiana municipality that is or
was the employer of the Law Enforcement Defendants. In addition, each of the Law
Enforcement Defendants acted as an agent of the City of Shreveport. The City of
Shreveport is liable for all torts committed by the Law Enforcement Defendants
while employed by the City of Shreveport under the doctrine of respondeat superior.
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Defendant City of Shreveport is additionally responsible for the policies and
practices of the Shreveport Police Department.
13. Defendant Paul Carmouche was, at times pertinent to this Complaint,
the District Attorney for Caddo Parish. Defendant Carmouche is being sued in his
official capacity because at times relevant to this Complaint, he was the official
responsible for the prosecution of Glenn Ford and he was a final policymaker
responsible for his own actions and the actions of his subordinate employees of the
Caddo Parish District Attorney’s Office. As such, he is additionally responsible for
the policies and practices of the Caddo Parish District Attorney’s Office, and the
Caddo Parish District Attorney’s Office is responsible for actions taken by its final
policymakers.
14. Defendant Dale Cox is the current District Attorney for Caddo Parish.
He is being sued in his official capacity as the successor in office and liability to
District Attorney Carmouche.
15. Defendant Caddo Parish District Attorney’s Office was, at times
pertinent to this Complaint, the office responsible for the prosecution of Glenn Ford.
16. Defendants Carmouche, Cox, and Caddo Parish District Attorney’s
Office are referred to collectively in this Complaint as the “District Attorney.”
17. Defendant George McCormick was, at relevant times herein, a person
who represented himself as an expert in forensic pathology and was then the
recently elected Coroner of Caddo Parish. He was involved in the unlawful
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investigation and conviction of Plaintiff. He engaged in the conduct complained of in
the course and scope of his employment and is sued in his individual capacity.
18. Defendant Caddo Parish is a Louisiana municipality that is or was the
employer of Defendant McCormick. In addition, Defendant McCormick acted as an
agent of Caddo Parish, which is liable for all torts committed by McCormick while
employed by Caddo Parish under the doctrine of respondeat superior. Defendant
Caddo Parish is additionally responsible for the policies and practices of the Caddo
Parish Coroner’s Office.
19. Defendants ABC Insurance Companies 1-10 are as yet unknown
insurance companies, who, upon information and belief, have issued and currently
have in effect one or more policies of insurance covering one or more of the
Defendants named herein.
20. At all relevant times herein, each Defendant was and is a “person” for
purposes of 42 U.S.C. § 1983 and acted under color of law and within the scope of
his employment to deprive plaintiff of his constitutional rights.
21. Defendants’ constitutional violations and other acts were the
proximate cause of the injuries and damages suffered by Glenn Ford.
JURISDICTION AND VENUE
22. This action is brought under 42 U.S.C. § 1983 and Louisiana law to
redress the Defendants’ tortious conduct and their deprivation of Plaintiff’s rights
secured by the United States Constitution.
23. This Court has jurisdiction of Plaintiff’s federal claims under 28 U.S.C.
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§ 1331 and supplemental jurisdiction of his state-law claims under 28 U.S.C. §
1367.23.
24. Venue in this Court is proper under 28 U.S.C. § 1391(b)—the majority
of the Defendants reside in this judicial district, and the events and omissions
giving rise to Plaintiff’s claims occurred within this judicial district.
FACTUAL ALLEGATIONS
I. The Investigation of Isadore Rozeman’s Murder
25. On the afternoon of November 5, 1983, Isadore Rozeman was found
dead in his jewelry and watch repair shop in Shreveport, Louisiana. He was shot
once in the back of the head with a .38 caliber bullet.
26. To this day, the crime remains unsolved. By focusing exclusively on the
wrong man, Defendants have let the real killer remain at large for three decades.
27. Mr. Ford’s name was allegedly first raised to the Law Enforcement
Defendants by Mr. Rozeman’s neighbors, children who told Shreveport police that
Mr. Ford did yard work for Mr. Rozeman and that they recalled seeing him the day
of the murder.
28. In the middle of the night after the crime, Mr. Ford was told by his
father that the police wanted to talk to him. Mr. Ford voluntarily went to the police
station at approximately 2:00 a.m. on November 6, 1983.
29. Mr. Ford cooperated completely with police—after an initial interview,
Mr. Ford agreed to be fingerprinted, photographed and tested for gunshot residue.
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He also consented to a search of his room. A detective described Ford as being “very
cooperative.”
30. Mr. Ford provided police information despite the fact that he was
afraid to identify anyone because the people responsible would kill him.
31. On November 8, 1983, after Law Enforcement Defendants purportedly
discovered pawn shop receipts that they suggested implicated Mr. Ford, the Law
Enforcement Defendants arrested Mr. Ford for receiving (or possessing) stolen
things.
II. Law Enforcement Defendants Manufacture and Suppress

Evidence In an Effort to Frame Mr. Ford
A. Multiple Reports that Corroborate Mr. Ford and Implicate Other Suspects are
Buried
32. Within a week of the Rozeman murder, Sergeant Glynn Mitchell of the
Shreveport Police Department received a tip from a confidential informant that
implicated Jake and Henry Robinson as the murderers.
33. The informant told Mitchell that Jake Robinson still had the murder
weapon and had also shot a man named Ralph Frazier.
34. Defendant Mitchell passed this information to Defendants Ashley and
Alderman, who were conducting the murder investigation.
35. Defendants Ashley and Alderman also learned that multiple
crimestoppers’ reports confirmed the same information as the confidential
informant.
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36. Defendants Ashley and Alderman contacted Ralph Frazier, who did
confirm that he had been shot, corroborating the informant’s and crimestoppers’
reports.
37. Defendants Ashley and Alderman, and other Law Enforcement
Defendants, suppressed this information—they suppressed the police reports that
said that Jake Robinson still had the murder weapon less than a week after the
murder and that Jake Robinson had also used the weapon to shoot Ralph Frazier
shortly before Rozeman was murdered. They also suppressed the reports that
verified that Frazier had indeed been shot.
B. Police Suppress a Second Report That One of the Robinson Brothers Had the
Murder Weapon at a Relative’s House
38. After receiving multiple reports about the Robinson brothers, and that
they likely still had the murder weapon, Defendants Ashley and Alderman set out
to find them.
39. Defendants Ashley and Alderman went to the home of Jake and Henry
Robinson’s aunt, uncle, and cousin. Jake and Henry’s cousin, Jeffrey Robinson, told
Defendants Ashley and Alderman that days after the murder he saw Henry remove
the likely murder weapon from under a mattress and put it in his suitcase.
40. Defendants Ashley and Alderman recorded this information in a police
report, but they and other Law Enforcement Defendants failed to disclose that
report to Mr. Ford and his attorneys.
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C. Police Hide More Evidence about the Robinson Brothers
41. Law Enforcement Defendants also did not disclose that Mr. Ford had
reason to fear the Robinsons and Larry Thompson, who police suspected was
working with the Robinsons. Thompson’s criminal expertise was bank and jewelry
store robberies and Rozeman’s home was also a jewelry shop. Thompson was a
known murderer.
42. Moreover, Detective Ashley recorded, though never disclosed, that the
Robinsons had a reputation for being mean and brutal, and that they were feared
by people who lived near them.
43. Law Enforcement Defendants never disclosed that when Henry
Robinson was arrested in San Diego he was found to have bullet proof vests and
handcuffs in his suitcase. This evidence provides additional support to Jeffrey
Robinson’s statement (also withheld) that he saw Henry Robinson take something
he thought might be a handgun from under the mattress and put it in his suitcase.
44. Law Enforcement Defendants also did not disclose that San Diego
Police reported that a handgun was likely taken from Henry Robinson in San Diego.
D. Police Manufacture Witness Evidence against Mr. Ford
45. From the murder on November 5, 1983 through February 1984, Law
Enforcement Defendants were unable to find physical evidence to tie anyone to the
murder. Instead, they began to manufacture witness evidence against Mr. Ford, the
man they identified as the suspect.
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46. On February 9, 1984, Law Enforcement Defendants interviewed Jake
Robinson’s girlfriend, Marvella Brown.
47. According to Defendants, Ms. Brown said that Mr. Ford had arrived at
her apartment around noon the day of the Rozeman murder and left with the
Robinsons, only to return with a sack containing jewelry. Ms. Brown also allegedly
stated that Mr. Ford carried a .22 pistol and that Jake Robinson had a .38 revolver.
48. This statement was fed to Ms. Brown by Law Enforcement Defendants
to frame Mr. Ford for the crime since he was a convenient target. Marvella Brown
later testified that Law Enforcement Defendants had fabricated some of her
responses. Law Enforcement Defendants suppressed this fabrication.
49. Three months later, in May 1984, Marvella Brown recanted her
statement, but Law Enforcement Defendants failed to disclose that recantation to
anyone, including Mr. Ford’s attorneys.
50. Coincidentally, also in February 1984, Law Enforcement Defendants in
general and Defendants Alderman and Ashley specifically located an informant,
Donnie L. Thomas, who they claimed implicated Mr. Ford in Rozeman’s murder.
51. This statement, too, was fed to Mr. Thomas by Law Enforcement
Defendants to frame Mr. Ford for the crime since he was a convenient target to
“solve” the crime. Law Enforcement Defendants suppressed this fabrication.
52. Law Enforcement Defendants never disclosed to anyone that they
manufactured these witness statements.
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. 53. If Plaintiff had been given access to information that Law Enforcement
Defendants were fabricating evidence against him from witnesses, it would have
been powerful evidence of his innocence and critical evidence by which he could
have impeached the individuals who testified falsely against him and also the Law
Enforcement Defendants who testified that the evidence they had gathered in their
investigation pointed toward Plaintiff.
E. Further Steps to Frame Glenn Ford
54. Because Mr. Ford was innocent, Law Enforcement Defendants were
forced to contort the facts further to make them fit their suspect.
55. Initial police reports identified that Rozeman was alive at 2:30 p.m.
based on a telephone call between him and Dr. Ebrahim. Mr. Ford had an alibi
defense for a murder happening after that time. At trial, the State’s theory
changed—prosecutors argued that the murder happened between 12:00 p.m. and
1:00 p.m. Law Enforcement Defendants suppressed evidence that both Detective
Roy Don Watts and Officer Trant confirmed the report that Dr. Ebrahim spoke with
Rozeman at 2:30 p.m. and not between 12:00 and 1:00. This suppressed evidence
supported Mr. Ford’s theory of the case.
56. Separately, the only physical evidence that purported to tie Mr. Ford to
the crime scene was a whorl pattern fingerprint allegedly taken from a paper bag at
the scene. Whorl patterns are found on approximately 35% of people. Law
Enforcement Defendants failed to disclose to Mr. Ford or his attorneys that three
other suspects had whorl pattern fingerprints. This suppression was especially
12
detrimental to Mr. Ford because the State argued at trial that no other suspect had
whorl-patterned fingerprints.
57. Law Enforcement Defendants also destroyed important fingerprint
evidence. Because the paper bag found at the scene had a porous surface, the only
way to develop a fingerprint from the bag was by using chemicals. And the only way
to preserve such a print is to photograph the print. Billy Lockwood destroyed the
fingerprint evidence by not taking a photograph of it and then compounding this
destruction by not preserving the paper bag as evidence. Moreover, Law
Enforcement Defendants suppressed evidence about whether the victim could have
been the source of the print. Lockwood also failed to disclose where the print was
allegedly found on the paper bag. This destruction of evidence denied Mr. Ford the
opportunity to demonstrate that his fingerprints did not appear on the paper bag
and thus negate the only physical evidence that the State used against him.
58. In addition, Glenn Ford was initially identified as being near
Rozeman’s house around 1:00 p.m. on the day of the murder by neighborhood
children. Law Enforcement Defendants suppressed the exculpatory evidence
gathered during interviews with those children, which would have supported Mr.
Ford’s defense and could have been used to impeach State’s witnesses.
59. Law Enforcement Defendants suppressed that they interviewed the
children together, which likely led to the children inventing and reinforcing their
claims.
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60. Law Enforcement Defendants suppressed that J.W. Nash said that he
saw Mr. Ford on the street at 1:00 p.m., which supported Mr. Ford’s defense;
61. Police fabricated and suppressed evidence by Chandra Nash, who
testified that she saw Ford alone in the alley on the day of the crime, and that she
saw no one else. But a police report from right after the murder documents that she
initially told Detective Mitchell that she had seen two individuals in the area the
day of the crime, but did not see Mr. Ford.
62. In addition, a witness saw Rozeman, the murder victim, argue with a
man he described as being “Mexican” and “Black” and the witness did not identify
that man as Mr. Ford. The Law Enforcement Defendants suppressed this evidence.
63. The Law Enforcement Defendants also had the names of other people
suspected of the murder, including one known as “sissy boy,” but they suppressed
the name of those alternative suspects.
III. Policies and Practices of the City of Shreveport, Shreveport Police

Department, Caddo Parish, and Caddo Parish Coroner’s Office
64. Despite actual and constructive notice that the Shreveport Police
Department’s custom, pattern and practice of promoting, facilitating, or condoning
improper, illegal, and unconstitutional investigative techniques, and failing to
adequately supervise, discipline and train its officers, was reasonably likely to lead
to constitutional violations similar to those perpetuated against Plaintiff, the
Department leadership continued to maintain those customs, patterns and practices
of deliberate indifference to the rights of the suspects.
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65. Prior to and at the time of the unlawful investigation, prosecution, and
incarceration of Ford, Shreveport Police Department, through its final
policymakers, maintained a policy, custom, or pattern and practice of condoning
corruption, that included widespread investigative misconduct, including by failing
to supervise, discipline, and train its investigative officers.
66. Upon information and belief, the Shreveport Police Department’s
supervisors and policymakers also had actual and constructive notice of their
Department’s policy, custom, or pattern and practice of investigative misconduct
and failures to supervise and train through numerous cases and investigations that
took place prior to the investigation in this case. The misconduct committed in those
cases by Shreveport Police Department officers, including investigators involved in
the investigation of the murder of Isadore Rozeman, was actually or constructively
known to Shreveport Police Department’s supervisors and policymakers prior to the
Rozeman investigation—including by means of their direct participation in the
investigations—and, upon information and belief, Shreveport Police Department
supervisors and policymakers failed to train, supervise, discipline, or otherwise
remediate Shreveport Police Department investigators in response to such notice.
67. Further, upon information and belief, persons with final policymaking
authority for the Shreveport Police Department participated personally in the
misconduct described in this Complaint.
68. The Shreveport Police Department’s policy, custom, or pattern and
practice of investigative misconduct and failing to train and supervise officers in
15
lawful investigative techniques was reflected in the multiple acts of misconduct and
illegality committed by multiple officers and supervisors in relation to the Rozeman
investigation, as described above and below.
69. The final policymakers, policies, and practices of the Shreveport Police
Department are one and the same as the final policymakers, policies, and practices
of the City of Shreveport.
70. Despite actual and constructive notice that the Caddo Parish Coroner’s
Office’s custom, pattern and practice of promoting, facilitating, or condoning
improper, illegal, and unconstitutional investigative techniques, and failing to
adequately supervise, discipline and train its officers, was reasonably likely to lead
to constitutional violations similar to those perpetuated against Plaintiff, the its
leadership continued to maintain those customs, patterns and practices of
deliberate indifference to the rights of the suspects.
71. Prior to and at the time of the unlawful investigation, prosecution, and
incarceration of Ford, Shreveport, Caddo Parish Coroner, through its final
policymakers, maintained a policy, custom, or pattern and practice of condoning
corruption, that included widespread investigative misconduct, including by failing
to supervise, discipline, and train its staff.
72. Upon information and belief, the Caddo Parish Coroner’s supervisors
and policymakers also had actual and constructive notice of its policy, custom, or
pattern and practice of investigative misconduct and failures to supervise and train
through numerous cases and investigations that took place prior to the
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investigation in this case. The misconduct committed in those cases by Caddo
Parish Coroner staff, including those involved in the investigation of the murder of
Isadore Rozeman, was actually or constructively known to Caddo Parish Coroner’s
supervisors and policymakers prior to the Rozeman investigation—including by
means of their direct participation in the investigations—and, upon information and
belief, Caddo Parish Coroner’s supervisors and policymakers failed to train,
supervise, discipline, or otherwise remediate staff in response to such notice.
authority for the Caddo Parish Coroner’s Office participated personally in the
misconduct described in this Complaint.
74. The Caddo Parish Coroner’s policy, custom, or pattern and practice of
investigative misconduct and failing to train and supervise staff in lawful
investigative techniques was reflected in the multiple acts of misconduct and
illegality committed by staff and supervisors in relation to the Rozeman
investigation, as described above and below.
75. The final policymakers, policies, and practices of the Caddo Parrish
Coroner’s office are one and the same as the final policymakers, policies, and
practices of the Caddo Parish.
IV. In the alternative, Prosecutors Working for the District

Attorney Manufacture Evidence and Suppress
Evidence in an Effort to Frame Mr. Ford
76. Plaintiff pleads in the alternative, as discussed in paragraphs 76-83
and 178-197, below, some or all of the exculpatory and impeachment evidence,
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including fabricated evidence, discussed above and below, was known to employees
of the District Attorney at the time of Glenn Ford’s criminal trial and was not
turned over by prosecutors to Mr. Ford and his criminal defense attorneys.
77. This evidence was suppressed by final policymakers for the District
Attorney and also by other prosecutors pursuant to the policies and practices of the
District Attorney.
78. Despite actual and constructive notice, the District Attorney had a
custom, pattern and practice of promoting, facilitating, or condoning improper,
illegal, and suppression of exculpatory and impeachment evidence, and failed to
adequately supervise, discipline and train its prosecutors. Despite being aware that
this was reasonably likely to lead to constitutional violations similar to those
perpetuated against Plaintiff, the District Attorney continued to maintain those
customs, patterns and practices of deliberate indifference to the rights of
defendants.
79. Prior to and at the time of the unlawful prosecution, the District
Attorney, through its final policymakers, maintained a policy, custom, or pattern
and practice of condoning corruption, that included widespread prosecutorial
misconduct, including by failing to supervise, discipline, and train its prosecutors.
80. Examples of the repeated constitutional violations caused by the
District Attorney’s policies and practices include but are by no means limited to the
following:
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a. In the prosecution at issue in State v. Palmer, 344 So. 2d 964, 968 (La.
1977), prosecutors for the District Attorney withheld latent
fingerprints from murder scene.
b. In the prosecution at issue in State v. Cass, 356 So. 2d 936, 944 (La.
1977), prosecutors for the District Attorney withheld evidence that
eyewitness identified someone other than defendant as the
perpetrator.
c. In the prosecution at issue in State v. Langendorfer, 389 So. 2d 1271,
1277 (La. 1980), prosecutors for the District Attorney suppressed a
rape victim’s statement made to police after she was attacked, in which
the victim described a long conversation she had with defendant prior
to the alleged rape.
d. In the prosecution at issue in State v. Davenport, 399 So. 2d 201 (La.
1981), prosecutors for the District Attorney withheld impeachment
evidence from the defense.
e. In the prosecution at issue in State v. McLeland, 456 So. 2d 633, 637
(La. Ct. App. 1984), prosecutors for the District Attorney withheld that
witness who identified defendant as robber at trial had only been
shown photograph of one person—the defendant—during the police
investigation, and had never been shown a line-up.
f. In the prosecution at issue in State v. Robertson, 511 So. 2d 1237, 1242
(La. Ct. App. 1987), prosecutors for the District Attorney suppressed
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victim’s description of her attacker that directly contradicted the
physical characteristics of the defendant on trial.
g. In the prosecution at issue in State v. Barker, 628 So. 2d 168, 176 (La.
Ct. App. 1993), prosecutors for the District Attorney withheld
exculpatory evidence that a rape victim and her sister colluded to give
the police false statements.
h. In the prosecution at issue in State v. Henderson, 31,986 (La. App. 2
Cir. 8/18/99), 740 So. 2d 240, prosecutors for the District Attorney
suppressed two witnesses’ grand jury testimony after defense filed a
motion before trial for the transcripts.
i. In the prosecution at issue in State v. Hampton, 98-0331 (La. 4/23/99),
750 So. 2d 867, 883, prosecutors for the District Attorney failed to
hand over transcript of grand jury testimony from eye-witness to
robbery/murder, which said that someone other than the defendant
was the murderer.
81. Upon information and belief, the District Attorney’s supervisors and
policymakers also had actual and constructive notice of their Department’s policy,
custom, or pattern and practice of prosecutorial misconduct and failures to
supervise and train through numerous cases and prosecutions that took place prior
to this case. The misconduct committed in those cases by the District Attorney’s
prosecutors, including prosecutors involved in the case of the murder of Isadore
Rozeman, was actually or constructively known to the District Attorney’s
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supervisors and policymakers before the Rozeman prosecution—including by means
of their direct participation in the prosecutions—and, upon information and belief,
the District Attorney supervisors and policymakers failed to train, supervise,
discipline, or otherwise remediate prosecutors in response to such notice.
authority for the District Attorney participated personally in the prosecution of
Plaintiff.
83. The District Attorney’s policy, custom, or pattern and practice of
prosecutorial misconduct and failing to train and supervise prosecutors in lawful
techniques was reflected in the multiple acts of misconduct and illegality committed
by multiple prosecutors and supervisors in relation to the Rozeman investigation, as
described above and below.
V. Prosecution of Glenn Ford
84. The case against Glenn Ford at trial was strictly circumstantial.
Exculpatory and impeachment evidence were the weapons that Mr. Ford’s defense
team needed to defeat the State’s circumstantial case.
85. Dr. George McCormick, a self-described “public witness” and parish
coroner, who never examined the body of the victim in this case, delivered opinions
on two crucial issues: the gunman’s dominant hand and the victim’s time of death.
86. Defendant McCormick fabricated evidence that the victim was killed
by a left-handed gunman. Ford is left-handed, whereas both of the Robinson
brothers are right-handed.
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87. Defendant McCormick also fabricated evidence that Mr. Rozeman had
been dead longer than an hour and probably two or more hours when paramedics
found the body at 3:30 p.m., and therefore the time of death was “consistent with
the time the defendant was at the scene of the crime.”
88. In addition, Pat Wojtkiewicz, a purported ballistics expert, also
testified for the State. Wojtkiewicz stated that using a Scanning Electron
Microscopy (“SEM”) he found, from Ford’s left hand, one particle unique to gunshot
residue and four particles characteristic of gunshot residue; and, from Ford’s right
hand, three particles characteristic of gunshot residue. This evidence was useless
under accepted principles of gunshot residue analysis.
89. The State also relied on the findings of Sergeant Billy Lockwood, a
fingerprint analyst who had never been qualified as an expert prior to Ford’s capital
murder trial. Lockwood testified that he was able to lift a single latent print from
the end of a paper bag left at the scene of the crime, ostensibly used to grasp the
gun that killed the victim. He testified that the latent print contained a “whorl”
type pattern and that Ford had such a pattern, whereas the Robinson brothers did
not. As stated above, this was false, but the defense had not been tendered the
evidence by Law Enforcement Defendants to contradict this testimony.
90. As a result of Law Enforcement Defendants’ misconduct, the all-white
jury convicted Glenn Ford of Rozeman’s murder. Without Defendants’ fabrication of
evidence and withholding of exculpatory evidence, Mr. Ford would never have been
convicted.
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91. During the penalty phase of the trial, Dr. McCormick (who had not
examined the victim’s body) testified that “it was his expert opinion…that [a] duffel
bag was placed over Mr. Rozeman’s head to muffle the gunshot and to shield the
murderer from blood spatter.” Dr. McCormick proceeded to tell the jury what the
victim was thinking about “when the bag was placed over his head.”
92. At the conclusion of the penalty phase, the jury deliberated for two and
one-half hours before returning its recommendation for a death sentence. On
February 26, 1985, Glenn Ford was sentenced to die as punishment for a crime he
had not committed.
93. For reasons still unknown to Mr. Ford, the State dropped related
charges against Henry Robinson, Jake Robinson, and Lorenzo Starks after Ford
was convicted.
94. The Robinson brothers remained free. They are suspected of killing at
least four additional people after the murder of Mr. Rozeman.
VI. Post-Conviction Proceedings
95. Ford’s conviction was affirmed on appeal by the Louisiana Supreme
Court, though the court clearly was troubled by the adequacy of the State’s
evidence. Ford, 489 So.2d at 1254-57. The Court’s affirmance was not unanimous,
as one justice was “not convinced that a rational trier of fact could have found the
essential elements of the crime of first degree murder beyond a reasonable doubt.”
Ford, 489 So.2d at 1268 (Calogero, J., dissenting).
23
96. The United States Supreme Court granted Ford’s Petition for Writ of
Certiorari, and remanded for a hearing under Batson v. Kentucky, 476 U.S. 79
(1986). After a hearing in 1989, the state trial court found the use of peremptory
strikes to be legitimate; the Louisiana Supreme Court denied a petition for a writ of
review, State v. Ford, 563 So.2d 873 (La. 1990); and the United States Supreme
Court denied a petition for a writ of certiorari, Ford v. Louisiana, 498 U.S. 992
(1990).
97. From 1992 to 2005, Ford sought post-conviction relief, on grounds of
ineffective assistance of counsel, that the state suppressed material exculpatory
evidence, and that he was actually innocent.
98. During this process, Dr. Leroy Riddick, a Board Certified Forensic
Pathologist and Mobile County (Alabama) Medical Examiner demonstrated the
fabrication of Dr. McCormick’s assertion related to handedness of the murderer,
time of death, and the alleged placing of the duffel bag over the victim’s head.
99. Dr. Riddick also challenged Dr. McCormick’s opinion that the duffel
bag was placed over Mr. Rozeman’s head when he was shot. Dr. Riddick stated that
“there is evidence that that didn’t happen.” As Dr. Riddick pointed out, the crime
scene photos depicted the bag laying next to the victim’s head, exactly where it was
where the first responders found it. As Dr. Riddick put it, “I don't think the
assailant, after shooting him, would pull the bag off of his head and set it aside.”
Further, there was only a spot of blood on the bag, a point inconsistent with the
victim wearing the bag when he was shot since he would he would have bled inside
24
the bag. Finally, the victim’s glasses were on the floor instead of being inside the
bag.
100. During the post-conviction hearings, experts also concluded that the
gunshot residue evidence was of no relevance to the question of whether Ford shot
or handled a firearm because of the fact that the sample was collected some 12 to 14
hours after the commission of the crime, and that “with a living subject, the
probability that any residues that are found on the hand [are] related to a shooting
incident, has diminished to the point where it is no longer of any scientific value” –
especially when a sample is taken in a police station, a location full of ambient
gunshot residue.
101. Experts similarly undermined the fingerprint evidence provided by the
prosecution, showing that because Lockwood was unable to view the center of the
whorl print, it could have been left by Jake or Henry Robinson. The reliability of
Lockwood’s testimony was also compromised by his failure to follow standard
protocol for analysis and preservation of latent prints from a porous surface.
102. On October 19, 2009, the state district court denied Ford post-
conviction relief. On February 4, 2011, the Louisiana Supreme Court affirmed the
denial in a two-word order.
VII. Glenn Ford is Exonerated and Released
103. On March 10, 2014, the State filed a Motion to Vacate the Conviction
and the Sentence of Glen Ford, explaining that “credible evidence” had become
known to First Assistant District Attorney Dale G. Cox and Assistant District
25
Attorney Catherine Estopinal in late 2013 which “support[ed] a finding that Ford
was neither present at, nor a participant in, the robbery and murder of Isadore
Rozeman.” In the motion, the State claimed that “if the information had been within
the knowledge of the State, Ford might not even have been arrested or indicted for
this offense.”
104. The Motion to Vacate did not explain what the “credible evidence” is,
nor did it provide any substantiation of the date of its discovery.
105. Judge Ramona Emanuel signed an order granting the State’s Motion
to Vacate the Conviction and the Sentence of Glen Ford.
106. On March 11, 2014, Glenn Ford walked out of prison. Upon his release,
Ford was given $20 by the prison authorities. To this date, that $20 is the only
money he has received from the state for his 30 years in prison for a crime he did
not commit.
107. On June 10, 2014, the State dropped all charges against Ford.
CLAIMS
COUNT I – Against the Law Enforcement Defendants, the City of

Shreveport, McCormick, and Caddo Parish
42 U.S.C. § 1983 – Due Process
108. Plaintiff incorporates each paragraph of this Complaint as if fully
restated here.
109. As described in detail above, the Law Enforcement Defendants and
McCormick, while acting individually, jointly, and in conspiracy with one another,
as well as under color of law and within the scope of their employment, deprived
26
Plaintiff of his constitutional right to a fair trial, in violation of Plaintiff’s right to
due process.
110. In the manner described more fully above, the Law Enforcement
Defendants and McCormick destroyed and deliberately withheld exculpatory
evidence from Plaintiff and his criminal defense attorneys and from the District
Attorney, among others, thereby misleading and misdirecting the criminal
prosecution of Plaintiff.
111. In addition, the Law Enforcement Defendants and McCormick
fabricated and solicited false evidence, including testimony that they knew to be
false and perjured and fabricated police reports, implicating Plaintiff in the crime,
obtained Plaintiff’s conviction using that false evidence, and failed to correct
fabricated evidence that they knew to be false when it was used against Plaintiff at
his criminal trial.
112. In addition, the Law Enforcement Defendants and McCormick
destroyed, concealed, and fabricated additional evidence that is not yet known to
Plaintiff.
113. The Law Enforcement Defendants’ and McCormick’s misconduct
directly resulted in the unjust criminal conviction of Plaintiff, thereby denying his
constitutional right to a fair trial and due process guaranteed by the Fifth and
Fourteenth Amendments. Absent this misconduct, the prosecution of Plaintiff could
not have and would not have been pursued.
27
114. The misconduct described in this Count was objectively unreasonable
and was undertaken intentionally, with malice, with reckless indifference to the
rights of others, and in total disregard of the truth and Plaintiff’s clear innocence.
115. As a result of the misconduct described in this Count, Plaintiff suffered
loss of liberty, great mental anguish, humiliation, degradation, physical and
emotional pain and suffering, and other grievous and continuing injuries and
damages as set forth herein.
116. The misconduct described in this Count and Plaintiff’s injuries
described in this Count were caused by the policies, practices, and customs of
Defendants City of Shreveport and/or Caddo Parish, in that their employees and
agents regularly failed to disclose exculpatory evidence to criminal defendants,
fabricated false evidence implicating criminal defendants in criminal conduct,
elicited false and coerced witness testimony, pursued wrongful convictions through
profoundly flawed investigations, and otherwise violated due process in a similar
manner to that alleged herein.
117. The above-described widespread practices, which were so well-settled
as to constitute the de facto policy of the City of Shreveport and/or Caddo Parish
were allowed to exist because municipal policymakers with authority over the same
exhibited deliberate indifference to the problem, thereby effectively ratifying it.
Furthermore, the widespread practices described in the preceding paragraphs were
allowed to flourish because the City of Shreveport and/or Caddo Parish declined to
implement sufficient training or any legitimate mechanism for oversight or
28
punishment of officers and agents who withheld material evidence, fabricated false
evidence and witness testimony, and pursued wrongful convictions.
118. The misconduct described in this Count was undertaken under the
policies and practices of the City of Shreveport and/or Caddo Parish in that the
constitutional violations committed against Plaintiff were committed by or with the
knowledge or approval of persons with final policymaking authority for the City of
Shreveport and/or Caddo Parish or were committed by persons with such final
policymaking authority.
119. The policies, practices, and customs set forth above were the moving
force behind the numerous constitutional violations in this case and directly and
proximately caused Plaintiff to suffer the grievous and permanent injuries and
damages set forth above.
COUNT II – Against the Law Enforcement Defendants, the City of

42 U.S.C. § 1983 –Federal Malicious Prosecution2
restated here.
121. In the manner described above, the Law Enforcement Defendants and
McCormick, individually, jointly, and in conspiracy with one another, as well as
under color of law and within the scope of their employment, accused Plaintiff of
criminal activity and exerted influence to initiate, continue, and perpetuate judicial
2 Plaintiff recognizes that this Circuit currently holds that malicious prosecution is not
actionable under 42 U.S.C. § 1983. Other Court of Appeals have taken the opposite position. Plaintiff
pleads the claim here under the Fourth and Fourteenth Amendments to preserve the issue for
reconsideration in the U.S. Court of Appeals for the Fifth Circuit or review in the Supreme Court of
the United States.
29
proceedings against Plaintiff without any probable cause for doing so and in spite of
the fact that they knew Plaintiff was innocent, in violation of his rights secured by
the Fourth and Fourteenth Amendments. In their drive to secure Ford’s wrongful
arrest, conviction, and incarceration, these Defendants deliberately engaged in
arbitrary and conscience-shocking conduct that contravened fundamental canons of
decency and fairness and violated Ford’s substantive due process rights under the
Fourteenth Amendment.
122. In so doing, these Defendants caused Plaintiff to be subjected
improperly to judicial proceedings for which there was no probable cause. These
judicial proceedings were instituted and continued maliciously, resulting in injury.
123. Based on the March 10, 2014, exoneration of Plaintiff and the
subsequent dropping of all charges against him, the criminal action has terminated
in Plaintiff’s favor.
126. The misconduct describe in this Count and Plaintiff’s injuries
30
agents regularly subjected suspects to prosecutions for which there was no probable
case in a similar manner to that alleged herein.
punishment of officers and agents who subjected suspects to prosecution even in the
absence of probable cause to do so.
damages set forth herein.
31
130. Louisiana state tort law does not provide Plaintiff with a
constitutionally adequate post-deprivation remedy for the injuries that he has
suffered, in violation of Plaintiff’s rights under the Fourteenth Amendment. As a
result, Plaintiff is entitled to pursue a claim of malicious prosecution under federal
law.
COUNT III – Against the Law Enforcement Defendants, the City of

Shreveport, McCormick and Caddo Parish
42 U.S.C. § 1983 – Failure to Intervene
restated here.
132. In the manner described above, during the constitutional violations
described herein, one or more of the individual Law Enforcement Defendants or
McCormick stood by without intervening to prevent the violation of Plaintiff’s
constitutional rights, even though they had the opportunity to do so.
133. As a result of the Law Enforcement Defendants’ or McCormick’s
failure to intervene to prevent the violation of Plaintiff’s constitutional rights,
Plaintiff suffered pain and injury, as well as emotional distress. The Law
Enforcement Defendants or McCormick had ample, reasonable opportunities to
prevent this harm but failed to do so.
and was undertaken intentionally, with malice, reckless indifference to the rights of
others, and in total disregard of the truth and Plaintiff’s clear innocence.
32
135. As a result of the Law Enforcement Defendants’ or McCormick’s
misconduct described in this Count, Plaintiff suffered loss of liberty, great mental
anguish, humiliation, degradation, physical and emotional pain and suffering, and
other grievous and continuing injuries and damages as set forth herein.
elicited false and coerced witness testimony, pursued wrongful convictions without
probable cause, through profoundly flawed investigations, and otherwise violated
due process in a similar manner to that alleged herein.
evidence and witness testimony, and pursued wrongful convictions.
33
policies and practices of the City of Shreveport and/or Caddo Parisn in that the
damages set forth herein.
COUNT IV – Against the Law Enforcement Defendants, the City of

42 U.S.C. § 1983 – Conspiracy to Deprive Constitutional Rights
restated here.
141. After Rozeman’s murder, the Law Enforcement Defendants and
McCormick, acting in concert with other co-conspirators, known and unknown,
reached an agreement among themselves to frame Plaintiff for a crime he did not
commit and thereby to deprive him of his constitutional rights, all as described in
the various paragraphs of this Complaint.
142. In so doing, the Law Enforcement Defendants, McCormick, and these
co-conspirators conspired to accomplish an unlawful purpose by an unlawful means.
34
In addition, these co-conspirators agreed among themselves to protect one another
from liability for depriving Plaintiff of these rights.
143. In furtherance of their conspiracy, each of these co-conspirators
committed overt acts and were otherwise willful participants in joint activity.
145. As a result of the misconduct committed by the Law Enforcement
Defendants, McCormick, and these co-conspirators described in this Count, Plaintiff
suffered loss of liberty, great mental anguish, humiliation, degradation, physical
and emotional pain and suffering, and other grievous and continuing injuries and
elicited false and coerced witness testimony, pursued wrongful convictions without
probable cause through profoundly flawed investigations, and otherwise violated
due process in a similar manner to that alleged herein.
35
evidence and witness testimony, and pursued wrongful convictions without probable
cause.
COUNT V – Against the Law Enforcement Defendants and McCormick

State Law Claim – Malicious Prosecution
restated here.
151. The State of Louisiana commenced a criminal action against Plaintiff.
36
152. The criminal case against Plaintiff was caused and continued by the
Law Enforcement Defendants and McCormick.
in Plaintiff’s favor.
154. At the time of the initiation of the criminal action against Plaintiff,
there was no probable cause to charge him in the criminal action.
156. As a result of Defendants’ misconduct described in this Count, Plaintiff
suffered loss of liberty, great mental anguish, humiliation, degradation, physical
and emotional pain and suffering, and other grievous and continuing injuries and
COUNT VI – Against the Law Enforcement Defendants and McCormick

State Law Claim – Intentional Infliction of Emotional Distress
restated here.
158. The actions, omissions, and conduct of the Law Enforcement
Defendants and McCormick and as set forth above were extreme and outrageous.
These actions were rooted in an abuse of power and authority and were undertaken
with the intent to cause, or were in reckless disregard of the probability that their
37
conduct would cause, severe emotional distress to Plaintiff, as is more fully alleged
herein.
159. As a direct and proximate result of the Law Enforcement Defendants
and McCormick actions, Plaintiff suffered and continues to suffer emotional distress
and other grievous and continuing injuries and damages as set forth herein.
Count VII – Against the Law Enforcement Defendants and

McCormick
State Law Claim – Article 2315 Negligence
160. Plaintiff realleges all of the above as though fully set forth herein.
161. The Law Enforcement Defendants’ and McCormick’s actions described
above caused Ford’s harms as described above and below.
162. Due to their professional roles, the Law Enforcement Defendants and
McCormick owed duties to avoid these harms to Ford.
163. These duties were breached by the Law Enforcement Defendants’ and
McCormick’s acts and omissions, including their negligent or grossly negligent acts
in investigating the murder of Isadore Rozeman, fabricating and reporting false
evidence against Ford, withholding exculpatory evidence, providing testimony at
trial that was speculative and unsupported by science, negligently hiring and
supervising those under their supervision, and failing to prosecute the actual
murderers.
164. The risks and harms that the Law Enforcement Defendants and
McCormick caused were within the scope of protection afforded by the duties they
owed to Ford.
38
165. As a result of the Law Enforcement Defendants’ and McCormick’s
actions and omissions, Ford sustained actual damages.
166. It was foreseeable, that as a result of the Law Enforcement
Defendants’ and McCormick’s negligence, Mr. Ford would suffer the physical,
emotional and pecuniary damages as described above and below.
Count VIII – Against the Law Enforcement Defendants and McCormick

State Law Claim – Violations of the Louisiana Constitution
167. Plaintiff realleges all of the above as though fully set forth herein.
168. The Louisiana State Constitution guarantees a person’s right to be
secure in his person and effect from unreasonable seizure, to equal protection of the
law, to due process of law, to be free from discrimination, to be free from cruel,
excessive or unusual punishment and to additional unenumerated rights. See La.
Cost. Art. I, §§ 2, 3, 5, 12, 13, 15, 16, 20, 22, and 24.
169. By reason of the same intentional, malicious, reckless and deliberate
conduct that violated Ford’s rights under the United States Constitution, the Law
Enforcement Defendants’ and McCormick’s conduct violated the rights guaranteed
plaintiffs under Article I, §§ 2, 3, 5, 12, 13, 15, 16, 20, 22, and 24 of the Louisiana
State Constitution.
170. These violations by the Law Enforcement Defendants and McCormick
of the Louisiana State Constitution proximately and directly caused Ford to be
wrongfully detained and incarcerated for decades at Angola for a crime he did not
commit, and suffer the additional physical, emotional and pecuniary damages as
described above and below.
39
COUNT IX – Against the City of Shreveport and Parish of Caddo

State Law Claim – Respondeat Superior
restated here.
172. While committing the misconduct alleged in the preceding paragraphs,
the Law Enforcement Defendants and McCormick were employees, members, and
agents of the City of Shreveport or the Parish of Caddo acting at all relevant times
within the scope of their employment.
173. Defendants City of Shreveport and Parish of Caddo, are liable as
principal for all torts committed by its agents.
COUNT X – Against the City of Shreveport and the Parish of Caddo

State Law Claim – Indemnification
restated here.
175. Louisiana law provides that public entities are directed to pay any tort
judgment for compensatory damages for which employees are liable for actions
taken in the discharge of their duties that are within the scope of their employment
activities.
176. The Law Enforcement Defendants and McCormick were employees,
members, and agents of the City of Shreveport or the Parish of Caddo, acting at all
relevant times within the scope of their employment and discharging their duties in
committing the misconduct described above.
40
177. Defendant City of Shreveport and the Parish of Caddo is obligated by
Louisiana statute to pay any judgment entered against its employees.
Count XI – Pleaded in the Alternative Against the District Attorney

42 U.S.C. § 1983 Monell Claim
178. Plaintiff pleads this entire Count in the alternative, incorporating
paragraphs 76-83 of this Complaint.
179. Prosecutors working for the District Attorney, while acting
individually, jointly, and in conspiracy with one another, as well as under color of
law and within the scope of their employment, deprived Plaintiff of his
constitutional right to a fair trial, in violation of Plaintiff’s right to due process.
180. In the manner described more fully above, these prosecutors destroyed
and deliberately withheld exculpatory evidence from Plaintiff and his criminal
defense attorneys, thereby misleading and misdirecting the criminal prosecution of
Plaintiff.
181. In addition, these prosecutors fabricated and solicited false evidence,
including testimony that they knew to be false and perjured, implicating Plaintiff in
the crime, obtained Plaintiff’s conviction using that false evidence, and failed to
correct fabricated evidence that they knew to be false when it was used against
Plaintiff at his criminal trial.
182. In addition, these prosecutors also destroyed, concealed, and fabricated
additional evidence that is not yet known to Plaintiff.
183. These prosecutors’ misconduct directly resulted in the unjust criminal
conviction of Plaintiff, thereby denying his constitutional right to a fair trial and
41
due process guaranteed by the Fifth and Fourteenth Amendments. Absent this
misconduct, the prosecution of Plaintiff could not have and would not have been
pursued.
184. In addition, in the manner described above, these prosecutors
individually, jointly, and in conspiracy with one another, as well as under color of
law and within the scope of their employment, accused Plaintiff of criminal activity
and exerted influence to initiate, continue, and perpetuate judicial proceedings
against Plaintiff without any probable cause for doing so and in spite of the fact that
they knew Plaintiff was innocent, in violation of his rights secured by the Fourth
and Fourteenth Amendments. In their drive to secure Ford’s wrongful arrest,
conviction, and incarceration, these prosecutors deliberately engaged in arbitrary
and conscience-shocking conduct that contravened fundamental canons of decency
and fairness and violated Ford’s substantive due process rights under the
Fourteenth Amendment.
185. In so doing, these prosecutors caused Plaintiff to be subjected
improperly to judicial proceedings for which there was no probable cause. These
judicial proceedings were instituted and continued maliciously, resulting in injury.
in Plaintiff’s favor..
187. In addition, in the manner described above, during the constitutional
violations described herein, one or more prosecutors stood by without intervening to
42
prevent the violation of Plaintiff’s constitutional rights, even though they had the
opportunity to do so.
188. As a result of these prosecutors’ failure to intervene to prevent the
violation of Plaintiff’s constitutional rights, Plaintiff suffered pain and injury, as
well as emotional distress. These prosecutors had ample, reasonable opportunities
to prevent this harm but failed to do so.
189. In addition, in the manner described above, these prosecutors, acting
in concert with other prosecutors, known and unknown, reached an agreement
among themselves to frame Plaintiff for a crime he did not commit and thereby to
deprive him of his constitutional rights, all as described in this Count.
190. In so doing, these prosecutors conspired to accomplish an unlawful
purpose by an unlawful means. In addition, these prosecutors agreed among
themselves to protect one another from liability for depriving Plaintiff of these
rights.
191. In furtherance of their conspiracy, each of these prosecutors committed
overt acts and were otherwise willful participants in joint activity.
and was undertaken intentionally, with malice, reckless indifference to the rights of
others, and in total disregard of the truth and Plaintiff’s clear innocence.
43
194. The misconduct described in this County and Plaintiff’s injuries were
caused by the policies, practices, and customs of the District Attorney, in that the
District Attorney’s employees and agents regularly failed to disclose exculpatory
evidence to criminal defendants, fabricated false evidence implicating criminal
defendants in criminal conduct, elicited false and coerced witness testimony,
pursued wrongful convictions through profoundly flawed investigations, and
otherwise violated due process in a similar manner to that alleged herein.
as to constitute the de facto policy of the District Attorney were allowed to exist
because the District Attorney’s policymakers with authority over the same exhibited
deliberate indifference to the problem, thereby effectively ratifying it. Furthermore,
the widespread practices described in the preceding paragraphs were allowed to
flourish because the District Attorney declined to implement sufficient training or
any legitimate mechanism for oversight or punishment of prosecutors who withheld
material evidence, fabricated false evidence and witness testimony, and pursued
wrongful convictions without probable cause.
policies and practices of the District Attorney in that the constitutional violations
committed against Plaintiff were committed by or with the knowledge or approval of
44
persons with final policymaking authority for the District Attorney or were
committed by persons with such final policymaking authority.
198. Louisiana state tort law does not provide Plaintiff with a
constitutionally adequate post-deprivation remedy for the injuries that he has
suffered, in violation of Plaintiff’s rights under the Fourteenth Amendment. As a
result, Plaintiff is entitled to pursue a claim of malicious prosecution under federal
law.
Count XII – Against Defendant ABC Insurance Companies 1-10

State Law Claim – Direction Action
restated here.
200. Defendant ABC Insurance Companies 1-10, upon information and
belief, have issued and/or currently have in effect one or more policies of insurance
covering one or more of the Defendants named herein. For valuable consideration
received, these policies obligated Defendant ABC Insurance Companies 1-10, jointly
and/or severally, to pay on behalf of their insured Defendant(s) any sums the
insured Defendant(s) may become obligated to pay to Plaintiff or to indemnify their
insured Defendant(s) for any sums the insured Defendant(s) may become obligated
to pay Plaintiff.
45
201. By reason of their illegal and unconstitutional acts, Defendants are
liable to Plaintiff for all damages and injuries Plaintiff has suffered as a result.
Upon information and belief, Defendant ABC Insurance Companies 1-10 are
contractually obligated to pay these sums on behalf of the insured Defendant(s).
202. Upon information and belief, Defendant ABC Insurance Companies 1-
10 are liable to Plaintiff for any and all damages incurred by reason of the insured
Defendant(s)’ acts, up to their policy limits, notwithstanding the fact that the
insured Defendant(s) may themselves be able to assert claims of privilege or
immunity from liability.
203. Under Louisiana Revised Statute § 22:655(B), Plaintiff brings a direct
action against Defendant ABC Insurance Companies 1-10 to recover any and all
sums they are obligated to pay Plaintiff on behalf of their insureds or to indemnify
their insureds.
WHEREFORE, Plaintiff GLENN FORD respectfully requests that this Court

enter a judgment in his favor and against Defendants the CITY OF SHREVEPORT,
DON ASHLEY, GARY ALDERMAN, GARY PITTMAN, EVERETT T. RUSHING,
the ESTATE OF BILLY LOCKWOOD, FRANK DATCHER, GLYNN MITCHELL,
R. PRICE, POLICE DOES 1-10, ESTATE OF GEORGE MCCORMICK, CADDO
PARISH, PAUL CARMOUCHE, in his official capacity as District Attorney of
Caddo Parish, DALE COX, in his official capacity as District Attorney of Caddo
Parish, CADDO PARISH DISTRICT ATTORNEY’s OFFICE, and ABC
INSURANCE COMPANIES awarding compensatory damages, attorneys’ fees and
46
costs against each Defendant, punitive damages against each of the individual
Defendants, and any other relief this Court deems just and appropriate.
JURY DEMAND
Plaintiff, GLENN FORD, hereby demands a trial by jury pursuant to Federal
Rule of Civil Procedure 38(b) on all issues so triable.
Respectfully submitted,
DATED: June 25, 2015
/s/ Mummi Ibrahim
Mummi Ibrahim, Louisiana Bar No. 34200
Ibrahim & Associates, LLC
4164 Canal Street
New Orleans, LA 70119
(504) 327-5289
mibrahim@iandalaw.com
/s/ Mark Loevy-Reyes
Mark Loevy-Reyes, Illinois Bar No. 6209841

Admitted to this Court pro hac vice
Jon Loevy (pro hac vice motion pending)
Arthur Loevy (pro hac vice motion pending)
Steven Art (pro hac vice motion pending)
Loevy & Loevy
312 N. May Street
Chicago, IL 60607
(312) 243-5900
mark@loevy.com
Attorneys for Plaintiff Glenn Ford
47

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Case 5:15-cv-00544-SMH-KLH Document 86 Filed 09/08/15 Page 1 of 47 PageID #: 487

IN THE UNITED STATES DISTRICT COURT

FIRST AMENDED COMPLAINT

Plaintiff GLENN FORD, by and through his attorneys, complains of

Defendants the CITY OF SHREVEPORT, DON ASHLEY, GARY ALDERMAN,

GARY PITTMAN, EVERETT T. RUSHING, the ESTATE OF BILLY LOCKWOOD,

FRANK DATCHER, GLYNN MITCHELL, R. PRICE, POLICE DOES 1-10,

ESTATE OF GEORGE MCCORMICK, CADDO PARISH, PAUL CARMOUCHE, in

capacity as District Attorney of Caddo Parish, CADDO PARISH DISTRICT

ATTORNEY’S OFFICE,1 and ABC INSURANCE COMPANIES, as follows:

1. In 1984, Glenn Ford was convicted of a murder he did not commit.

Today, evidence currently being kept secret by law enforcement officials in

arrested, let alone prosecuted for the murder.

away from him for a crime he did not commit.

4. Mr. Ford’s arrest, detention, prosecution, conviction, and

imprisonment were the product of unconstitutional and unlawful efforts by the

Shreveport Police officers named in this complaint, acting individually and in

and practices, to use any means necessary to gain a conviction.

5. Defendant Ashley, a lead detective in the case, admitted under oath

6. The Shreveport Police officers did exactly as Defendant Ashley

the Shreveport Police Department and the City of Shreveport.

7. Pleading in the alternative, employees and representatives of the

employees and representatives of the Caddo Parish District Attorney’s Office

United States Constitution and Louisiana law.

8. As a direct result of Defendants’ intentional, bad faith, willful, wanton,

loss of income, inadequate medical care, humiliation, indignities and

embarrassment, degradation, permanent loss of natural psychological development;

sleep, personal contact, educational opportunity, vocational opportunity, athletic

opportunity, personal fulfillment, sexual activity, family relations, reading,

television, movies, travel, enjoyment, and freedom of speech and expression.

extraordinary injuries and losses suffered by Glenn Ford at the hands of

10. Plaintiff Glenn Ford is an African-American man who spent nearly 30

11. Defendants Don Ashley, Gary Alderman, Everett Rushing, Gary

12. Defendant City of Shreveport is a Louisiana municipality that is or

Enforcement Defendants acted as an agent of the City of Shreveport. The City of

Defendant City of Shreveport is additionally responsible for the policies and

practices of the Shreveport Police Department.

13. Defendant Paul Carmouche was, at times pertinent to this Complaint,

Caddo Parish District Attorney’s Office. As such, he is additionally responsible for

District Attorney Carmouche.

15. Defendant Caddo Parish District Attorney’s Office was, at times

16. Defendants Carmouche, Cox, and Caddo Parish District Attorney’s

Office are referred to collectively in this Complaint as the “District Attorney.”

17. Defendant George McCormick was, at relevant times herein, a person

recently elected Coroner of Caddo Parish. He was involved in the unlawful

investigation and conviction of Plaintiff. He engaged in the conduct complained of in

18. Defendant Caddo Parish is a Louisiana municipality that is or was the

employer of Defendant McCormick. In addition, Defendant McCormick acted as an

employed by Caddo Parish under the doctrine of respondeat superior. Defendant

Parish Coroner’s Office.

19. Defendants ABC Insurance Companies 1-10 are as yet unknown

Defendants named herein.

his employment to deprive plaintiff of his constitutional rights.

21. Defendants’ constitutional violations and other acts were the

proximate cause of the injuries and damages suffered by Glenn Ford.

JURISDICTION AND VENUE

secured by the United States Constitution.

§ 1331 and supplemental jurisdiction of his state-law claims under 28 U.S.C. §

24. Venue in this Court is proper under 28 U.S.C. § 1391(b)—the majority

giving rise to Plaintiff’s claims occurred within this judicial district.

I. The Investigation of Isadore Rozeman’s Murder

25. On the afternoon of November 5, 1983, Isadore Rozeman was found

once in the back of the head with a .38 caliber bullet.

station at approximately 2:00 a.m. on November 6, 1983.