Case 2:19-cv-01278-MSG Document 1 Filed 03/27/19 Page 1 of 24

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

DAVID NIEDRIST : JURY TRIAL DEMANDED

45 Indian Creek Entry :
Levittown, PA 19057, :
Plaintiff : CIVIL ACTION NO. 19-________
:
v. :
:
BRISTOL TOWNSHIP :
a/k/a THE TOWNSHIP :
OF BRISTOL :
2501 Bath Road :
Bristol, PA 19007 :
:
FALLS TOWNSHIP :
188 Lincoln Highway, Suite 100 :
Fairless Hills, PA 19030 :
:
JASON REILLY, # 136 :
2501 Bath Road :
Bristol, PA 19007 :
:
MICHAEL SARCEWICZ, # 140 :
2501 Bath Road :
Bristol, PA 19007 :
:
THOMAS GAFFNEY, # 02 :
2501 Bath Road :
Bristol, PA 19007 :
:
THEODORE THIEROFF, # 11 :
2501 Bath Road :
Bristol, PA 19007 :
:
SHAWN LYONS, # 158 :
2501 Bath Road :
Bristol, PA 19007 :
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:
C. HUFF, # 44105 :
2501 Bath Road :
Bristol, PA 19007 :
:
K. CARRAGHER, # 37059 :
2501 Bath Road :
Bristol, PA 19007 :
:
BRIAN HYAMS, # 44042 :
2501 Bath Road :
Bristol, PA 19007 :
:
M. SHEEHY, # 22331 :
2501 Bath Road :
Bristol, PA 19007 :
:
J. HORDIJENKO, # 22362 :
2501 Bath Road :
Bristol, PA 19007 :
:
D. CLIFTON, # 52037:
2501 Bath Road :
Bristol, PA 19007 :
:
L. HILGMAN, # 42029 :
2501 Bath Road :
Bristol, PA 19007 :
:
J. LANDIS, # 42050 :
2501 Bath Road :
Bristol, PA 19007 :
:
L. MATHEWS, # 46005 :
2501 Bath Road :
Bristol, PA 19007 :
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:
NICHOLAS PHILLIPPE, # 34113 :
188 Lincoln Highway, Suite 100 :
Fairless Hills, PA 19030 :
:
ANTON SPIRITOSANTO, # 34088:
188 Lincoln Highway, Suite 100 :
Fairless Hills, PA 19030 :
:
MICHAEL PARNES, # 34119 :
188 Lincoln Highway, Suite 100 :
Fairless Hills, PA 19030 :
:
EDWARD ELMORE, # 34084 :
188 Lincoln Highway, Suite 100 :
Fairless Hills, PA 19030 :
:
WILLIAM TANNER, # 34118 :
188 Lincoln Highway, Suite 100 :
Fairless Hills, PA 19030 :
:
MATTHEW KILLEEN, # 34107 :
188 Lincoln Highway, Suite 100 :
Fairless Hills, PA 19030 :
:
LEVITTOWN FAIRLESS HILLS :
RESCUE SQUAD, INC. :
7405 New Falls Road :
Levittown, PA 19055 :
:
GEORGE PETTIT :
7405 New Falls Road :
Levittown, PA 19055 :
:
ANTHONY LOGUE :
7405 New Falls Road :
Levittown, PA 19055 :
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:
CHRISTOPHER WOODS :
7405 New Falls Road :
Levittown, PA 19055 :
:
and :
:
MICHAEL STEBULIS :
7405 New Falls Road :
Levittown, PA 19055, :
:
Defendants :
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CIVIL COMPLAINT

JURISDICTION

1. This action is brought pursuant to the United States Constitution,

42 U.S.C. §§1983, 1988, 12132 and 29 U.S.C. §794. Jurisdiction is founded

upon 28 U.S.C. §§1331 and 1343 and the aforementioned provisions.

Plaintiff further invokes the supplemental jurisdiction of this Court under 28

U.S.C. §1367(a) to hear and adjudicate state law claims.

PARTIES

2. Plaintiff David Niedrist is a resident of the Commonwealth of

Pennsylvania, at the address set forth in the caption.

3. At the time of the events which form the basis of this action,

Plaintiff was a qualified individual with a disability as defined in the Americans

with Disabilities Act, 42 U.S.C. §12131(2) (“ADA”).

4. Defendant Township of Bristol a/k/a the Township

Of Bristol (“Bristol”) is a municipality of the Commonwealth of Pennsylvania

that owns, operates, manages, directs and controls the Bristol Police

Department and is the public employer of individual Bristol Police Defendants

as indicated below.

5. Defendant Bristol is a public entity as defined in the ADA, 42

U.S.C. §12131(1), and receives federal financial assistance under § 504 of

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the Rehabilitation Act, 29 U.S. §794 (“§ 504").

6. Defendant Falls Township (“Falls”) is a municipality of the

Commonwealth of Pennsylvania that owns, operates, manages, directs and

controls the Falls Township Police Department and is the public employer of

individual Falls Police Defendants as indicated below.

7. Defendant Falls is a public entity as defined in the ADA, 42 U.S.C.

§12131(1), and receives federal financial assistance under § 504 of the

Rehabilitation Act, 29 U.S. §794 (“§ 504").

8. Defendant Jason Reilly was at all relevant times a Bristol Police

Officer. He is being sued in his individual capacity.

9. Defendant Michael Sarcewicz was at all relevant times a Bristol

Police Officer. He is being sued in his individual capacity.

10. Defendant Thomas Gaffney was at all relevant times a Bristol

Police sergeant. He is being sued in his individual capacity.

11. Defendant Theodore Thieroff was at all relevant times a Bristol

Police Officer. He is being sued in his individual capacity.

12. Defendant Shawn Lyons was at all relevant times a Bristol Police

Officer. He is being sued in his individual capacity.

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13. Defendant C. Huff was at all relevant times a Bristol Police Officer

who is being sued in an individual capacity.

14. Defendant K. Carragher was at all relevant times a Bristol Police

Officer who is being sued in an individual capacity.

15. Defendant Brian Hyams was at all relevant times a Bristol Police

Officer who is being sued in an individual capacity.

16. Defendant M. Sheehy was at all relevant times a Bristol Police

Officer who is being sued in an individual capacity.

17. Defendant J. Hordijenko was at all relevant times a Bristol Police

Officer who is being sued in an individual capacity.

18. Defendant D. Clifton was at all relevant times a Bristol Police

Officer who is being sued in an individual capacity.

19. Defendant L. Hilgman was at all relevant times a Bristol Police

corporal who is being sued in an individual capacity.

20. Defendant J. Landis was at all relevant times a Bristol Police

Officer who is being sued in an individual capacity.

21. Defendant L. Mathews was at all relevant times a Bristol Police

Officer who is being sued in an individual capacity.

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22. Defendant Nicholas Phillippe was at all relevant times a Falls

Police Officer who is being sued in an individual capacity.

23. Defendant Anton Spiritosanto was at all relevant times a Falls

Police Officer who is being sued in an individual capacity.

24. Defendant Michael Parnes was at all relevant times a Falls Police

Officer who is being sued in an individual capacity.

25. Defendant Edward Elmore was at all relevant times a Falls Police

Officer who is being sued in an individual capacity.

26. Defendant William Tanner was at all relevant times a Falls Police

Officer who is being sued in an individual capacity.

27. Defendant Matthew Killeen was at all relevant times a Falls Police

Officer who is being sued in an individual capacity.

28. Defendant Levittown Fairless Hills Rescue Squad, Inc. (“Rescue

Squad”), is a Pennsylvania corporation operating as a private provider of

9-1-1 ambulance service to the communities in Lower Bucks County.

29. Defendant Levittown Fairless Hills Rescue Squad, Inc., was at all

relevant times the employer of Defendants Pettit, Logue, Woods, and

Stebulis, named below, and is liable for their actions and inaction.

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30. Defendant George Pettit was at all relevant times an Emergency

Medical Technician (“EMT”) employed by Defendant Levittown Fairless Hills

Rescue Squad, Inc., providing 9-1-1 ambulance service and medical care.

31. Defendant Anthony Logue was at all relevant times an EMT

employed by Defendant Levittown Fairless Hills Rescue Squad, Inc., providing

9-1-1 ambulance service and medical care.

32. Defendant Christopher Woods was at all relevant times an EMT

employed by Defendant Levittown Fairless Hills Rescue Squad, Inc., providing

9-1-1 ambulance service and medical care.

33. Defendant Michael Stebulis was at all relevant times an EMT

employed by Defendant Levittown Fairless Hills Rescue Squad, Inc., providing

9-1-1 ambulance service and medical care.

34. Defendants Petit, Logue, Woods, and Stebulis (collectively “EMT

Defendants”) were all medical professionals.

35. The Defendants’ names, addresses and (where applicable) badge

numbers are set forth in the caption of this Complaint.

36. At all relevant times, all Defendants were acting under color of

state law.

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37. At all relevant times, the actions taken by all Defendants deprived

Plaintiff of his constitutional and statutory rights.

38. At all relevant times, the individual Defendants were acting in

concert and conspiracy and their actions deprived Plaintiff of his constitutional

and statutory rights.

FACTUAL ALLEGATIONS

39. On April 2, 2017, Plaintiff was in the driver’s seat of his vehicle,

in the driveway of his home at 45 Indian Creek Entry, Bristol Township,

Pennsylvania.

40. At all relevant times the vehicle was parked and not running.

41. Plaintiff began to experience a tonic-clonic seizure.

42. Present were Plaintiff’s nephew and Plaintiff’s four minor children.

43. Plaintiff’s nephew called 911 and reported that his uncle was

experiencing a seizure.

44. The Police Defendants and EMT Defendants were dispatched to

Plaintiff's home.

45. The dispatcher informed Police and EMTs, including the individual

defendants that Plaintiff was suffering a seizure.

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46. Upon arrival at Plaintiff’s home, the individual defendants found

Plaintiff sitting in the driver's seat of his vehicle in a semi-conscious,

"post-ictal" state.

47. The individual defendants disregarded the evidence of Plaintiff’s

medical condition.

48. Because of his medical condition, Plaintiff was unable to

comprehend, respond or comply with the demands of the defendants.

49. The defendants treated Plaintiff’s medical condition as conscious

disobedience.

50. Although Plaintiff was not a threat to any officer, EMT, any other

person or himself, the individual defendants used physical force against him,

including, repeatedly punched, kicked, struck with a baton, and deployed a

Taser or electronic control device (ECD) against Plaintiff.

51. As a result of Defendants’ actions, Plaintiff was hospitalized for

four days with multiple injuries, including to his ribs, kidneys, back, face and

head.

52. When he awoke in the hospital Plaintiff was in handcuffs and

under police guard.

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53. Plaintiff was arrested and charged with felony aggravated assault,

multiple counts of simple assault, resisting arrest, disorderly conduct and two

counts of harassment.

54. Plaintiff was forced to retain an attorney to represent him in the

criminal prosecution initiated by the individual defendants, in the amount of

$40,000.

55. The aggravated assault charge was dismissed by a magisterial

district judge on July 18, 2017.

56. On January 30, 2018, a jury sitting in the Bucks County Court of

Common Pleas acquitted Plaintiff of all charges.

57. The Defendant officers, without cause or justification and in the

absence of probable cause, detained, handcuffed and arrested the Plaintiff,

and caused him to be charged with assault and related offenses.

58. The arrest and detention of Plaintiff by the Defendant officers,

acting in concert, were retaliatory, punitive and undertaken to cover-up the

misconduct of the defendant officers and thus constituted a violation of, and

conspiracy to, violate Plaintiff's constitutional and statutory rights.

59. At all times relevant hereto, Plaintiff suffered from a seizure

disorder/epilepsy.

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60. The individual Defendants were aware that Plaintiff was suffering

from a seizure and its aftereffects.

61. The individual Defendants did not account for the information they

had regarding Plaintiff’s physical condition and the circumstances they

observed.

62. The individual Defendants were deliberately indifferent to Plaintiff’s

serious medical need.

63. The individual Defendants exacerbated and escalated the

situation.

64. The individual Defendants created or increased the danger of

injury to Plaintiff.

65. The individual Defendants use of force against Plaintiff was

unreasonable and unnecessary.

66. The failure of the individual Defendants to act consistent with

reasonable and generally accepted procedures for dealing with persons

suffering from a seizure and its after effects, created or increased the danger

of injury to Plaintiff.

67. There were no exigencies interfering with the ability of the

individual Defendants to make plans for assisting Plaintiff consistent with

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reasonable and generally accepted procedures for dealing with persons

suffering a seizure and its aftereffects.

68. At no time did the Plaintiff pose a threat of harm to the individual

Defendants or any other person.

69. At no time did Plaintiff commit an offense against the laws of the

Commonwealth of Pennsylvania, the United States or local ordinance, which

justified the use of force against him.

70. At no time did Plaintiff commit illegal acts or engage in conduct

which justified the actions of Defendants.

71. It is the policy, practice and custom of Bristol and Falls that

officers do not use widely recognized and well-established crisis intervention

procedures and techniques with regard to individuals exhibiting seizures and

aftereffects, and to resort to unreasonable and excessive force.

72. The actions and conduct of the individual Defendants were the

direct result of the failure of Defendants Bristol and Falls to:

a) properly train, supervise, monitor and discipline police officers in

connection with well-established crisis intervention and procedures

related to individuals suffering seizures and aftereffects;

b) provide programs and services to qualified persons exhibiting

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seizures and aftereffects; and/or

c) ensure that police officers follow established crisis intervention

procedures under such circumstances as presented by this case.

73. The actions and inactions of Defendants were the proximate

cause of the injuries suffered by Plaintiff.

74. Defendants Gaffney and Hilgman bear supervisory liability for the

injuries suffered by Plaintiff.

75. The injuries to Plaintiff were a foreseeable consequence of the

actions and inactions of Defendants.

76. Defendants knew or should have known that their actions and

inaction could result in injuries to innocent persons, including Plaintiff.

77. Defendants knew or should have known that their actions and

inaction created a danger to Plaintiff.

78. Defendants failed to take reasonable care for the safety of

Plaintiff.

79. All the individual Defendants engaged in the aforesaid conduct for

the purpose of violating Plaintiff's constitutional rights by subjecting him to the

unreasonable use of force, unlawful arrest, prolonged detention and malicious

prosecution.

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80. The acts of the individual Defendants constituted willful

misconduct.

81. The actions and conduct of the individual Defendants were willful,

wanton, malicious, intentional, outrageous, deliberate and/or so egregious as

to shock the conscience.

82. As a direct and proximate result of the actions and inactions of

Defendants, Plaintiff was caused serious injuries and thereby caused to also

suffer loss of earnings and earnings capacity.

83. Plaintiff has suffered pecuniary loss, to his great detriment, and

has or will incur expenses for:

a. Past and future medical bills;

b. Past and future devices, accommodations and services

necessitated by his injuries; and

c. Attorney fees and costs to defend himself in the criminal

prosecution.

84. Since the incident, the individual Defendant officers continue to

harass and retaliate against Plaintiff by singling him out for police observation

and following him when he is driving, in the hope of spotting a traffic violation

or other conduct which they can use to justify retaliatory arrest, citations, or

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other punishment.

85. As a direct result of the actions and conduct of all Defendants,

Plaintiff suffered and will in the future suffer physical injuries, pain, emotional

distress, psychological harm, fear, horror and additional harms caused by the

violation of his rights under the United States Constitution, 42 U.S.C. §§1983,

42 U.S.C. § 12132 and 29 U.S.C. §794.

FIRST CAUSE OF ACTION

FEDERAL CIVIL RIGHTS VIOLATIONS UNDER 42 U.S.C. §1983

86. The allegations set forth in the preceding paragraphs, inclusive,

are incorporated herein as though fully set forth.

87. As a direct and proximate result of Defendants' conduct,

committed under color of state law, Defendants deprived and conspired to

deprive Plaintiff of his right to be free from the unreasonable use of force,

false arrest and malicious prosecution, to be secure in his person and

property, to due process and equal protection of the law, and to his right of

access to the courts. As a result, Plaintiff suffered harm, in violation of his

rights under the laws and Constitution of the United States, in particular the

First, Fourth and Fourteenth Amendments thereof, and 42 U.S.C. §1983.

88. Defendants Bristol and Falls have encouraged, tolerated, ratified

and been deliberately indifferent to a pattern, practice and custom of and to

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the need for more or different training, supervision, investigation or discipline

in the areas of:

a. The proper exercise of police powers, including the

unreasonable use of force, unlawful arrests and malicious

prosecution by its police officers;

b. Crisis intervention techniques for individuals who exhibit the

signs and symptoms of seizure and its aftereffects;

c. The procedures for the assisting and transporting persons

who exhibit the signs and symptoms of seizure and its

aftereffects;

d. Training and resources for crisis intervention teams of

police officers and others to respond to emergencies

involving persons who exhibit the signs and symptoms of

seizure and its aftereffects;

e. The failure of police officers to follow established policies,

procedures, directives and instructions regarding crisis

intervention techniques for individuals who exhibit the signs

and symptoms of seizure and its aftereffects;

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f. The failure of police officers to intervene when other officers

violate the rights of citizens in their presence; and

g. The failure of police officers to report or provide information

concerning the misconduct of other police officers, a

custom or practice known as the “Code of Silence.”

h. Falsely arresting and procuring cover charges to conceal

officer misconduct, as retaliation and to deny citizens like

Plaintiff access to the courts.

i. By these actions, Defendants Bristol and Falls deprived

Plaintiff of rights secured by the First, Fourth and

Fourteenth Amendments to the United States Constitution

in violation of 42 U.S.C. §1983.

89. Defendants Bristol and Falls failed to properly sanction or

discipline officers, who are aware of and conceal and/or aid and abet

violations of constitutional rights of individuals by other police officers, thereby

causing and encouraging police, including the defendant officers in this case,

to violate the rights of citizens such as the plaintiff.

90. Defendants Bristol and Falls are deliberately indifferent to the

need to train, supervise and discipline police officers.

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91. Defendants Bristol and Falls failed to supervise and audit the

conduct and training of the Rescue Squad, to whom they outsourced 9-1-1

ambulance and emergency medical services, and was deliberately indifferent

to the need to require training and supervision of Rescue Squad EMTs.

92. As a direct and proximate result of the actions and conduct of

Defendants, Plaintiff sustained damages as set forth above.

93. The actions of the individual Defendants were wanton, wilful,

reckless, malicious, oppressive, outrageous and unjustifiable and, therefore,

exemplary damages are necessary and appropriate.

94. Plaintiff is entitled to attorney’s fees and costs of prosecution of

this suit from Defendants, pursuant to 42 U.S.C. §1988.

SECOND CAUSE OF ACTION

FEDERAL CIVIL RIGHTS VIOLATIONS UNDER
THE AMERICANS WITH DISABILITIES ACT, 42 U.S.C. §12132, AND
§ 504 OF THE REHABILITATION ACT, 29 U.S.C. §794

95. The allegations set forth in the preceding paragraphs, inclusive,

are incorporated herein as though fully set forth.

96. As a direct and proximate result of all Defendants' conduct,

committed under color of state law, Defendants discriminated against Plaintiff

by reason of his health disability, denying him the benefits of the services,

programs and activities to which he was entitled as a person with a disability

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including but not limited to the right to be free of discriminatory or disparate

treatment by virtue of his disability, and to due process and equal protection

of the law. As a result, Plaintiff suffered harm in violation of his rights under

the laws and Constitution of the United States, the ADA and § 504.

97. Defendants Bristol, Falls and Rescue Squad have failed to comply

with the mandates of the ADA and § 504 in the following areas:

a. The failure to properly train, supervise and discipline police

officers and EMTs regarding crisis intervention technique

for individuals who exhibit the signs and symptoms of

seizure and its aftereffects;

b. The failure to provide adequate training and resources for

crisis intervention teams of police officers, EMTs and others

to respond to emergencies involving persons with health

disabilities including, but not limited to the treatment and

transportation of persons who exhibit the signs and

symptoms of seizure and its aftereffects; and

c. The failure of police officers and EMTs to follow established

policies, procedures, directives and instructions regarding

crisis intervention techniques for individuals who exhibit the

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signs and symptoms of seizure and its aftereffects.

98. By their actions, Defendants have deprived Plaintiff of rights

secured by the United States Constitution, the ADA and § 504.

99. Plaintiff is entitled to attorney’s fees and costs of prosecution of

this suit from Defendants.

THIRD CAUSE OF ACTION

SUPPLEMENTAL STATE CLAIMS

100. The allegations set forth in the preceding paragraphs, inclusive,

are incorporated herein as though fully set forth.

101. The acts and conduct of the individual defendants constituted the

torts of assault and battery, false arrest/false imprisonment, malicious

prosecution and outrageous conduct causing severe emotional distress,

under the laws of the Commonwealth of Pennsylvania.

102. The individual police Defendants were in the vicinity of Plaintiff

and had the authority to intervene to aid and protect Plaintiff, and the ability

to rectify the danger faced by Plaintiff.

103. The individual police Defendants intentionally failed to perform

their duty to Plaintiff, knowing or having reason to know that their acts and

omissions created an unreasonable and substantial risk of harm to Plaintiff.

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104. The conduct of the individual police Defendants constituted the

tort of reckless disregard of safety, § 500, 2 Restatement of Torts, 2d.

105. As a direct and proximate result of the negligence, carelessness

and/or tortious conduct of the EMT Defendants in failing to render medical

care and treatment to Plaintiff, in accordance with reasonably safe and

accepted standards of professional practice, Plaintiff suffered injuries and

damages as aforesaid.

106. The acts and conduct of the EMT defendants constituted

professional negligence.

107. Defendant Rescue Squad vicariously liable for the acts and

omissions of the EMT Defendants, each of whom was acting within the course

and scope of the employment relationship.

108. The actions of the individual defendants were wanton, wilful,

reckless, malicious, oppressive, outrageous and unjustifiable and, therefore,

exemplary damages are necessary and appropriate.

109. This Court has supplemental jurisdiction to hear and adjudicate

these claims.

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JURY DEMAND

110. Plaintiff demands a trial by jury as to each defendant and as to each

cause of action and claim.

WHEREFORE, Plaintiff demands judgment against each defendant,

jointly and severally, as to each count, along with costs, attorney’s fees,

interest, exemplary damages as to the individual defendants, and such other

and further relief as the Court may deem just and proper.

By: POPPER & YATVIN

Alan L. Yatvin,
and with him
Howard D. Popper,
230 South Broad Street, Suite 503
Philadelphia, PA 19102
(215)546-5700
Popper.yatvin@verizon.net

March 27, 2019 Attorneys for Plaintiff

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