Case: 1:18-Cv-04242 Document #: 1 Filed: 06/19/18 Page 1 of 59 Pageid #:1
Case: 1:18-cv-04242 Document #: 1 Filed: 06/19/18 Page 1 of 59 PageID #:1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION CHICAGOANS FOR AN END TO THE ) GANG DATABASE: BLACK YOUTH ) PROJECT 100 CHICAGO, BLOCKS ) TOGETHER, BRIGHTON PARK ) NEIGHBORHOOD COUNCIL, LATINO ) Case No. UNION, MIJENTE, and ORGANIZED ) (Class Action) COMMUNITIES AGAINST DEPORTATION, ) as well as DONTA LUCAS, JONATHAN ) WARNER, LESTER COOPER, and LUIS ) PEDROTE-SALINAS, on behalf of themselves ) and a class of similarly situated persons, ) ) Plaintiffs, ) ) v. ) ) CITY OF CHICAGO, SUPERINTENDENT ) EDDIE JOHNSON, and CHICAGO POLICE ) OFFICERS MICHAEL TOMASO (#6404), ) MICHAEL GOLDEN (#15478), PETER ) TOLEDO (#2105), JOHN DOES 1-4, and ) JANE DOES 1-2, ) ) Defendants. ) CLASS ACTION COMPLAINT Organizational Plaintiffs CHICAGOANS FOR AN END TO THE GANG DATABASE: BLACK YOUTH PROJECT 100 CHICAGO, BLOCKS TOGETHER, BRIGHTON PARK NEIGHBORHOOD COUNCIL, LATINO UNION, MIJENTE, and ORGANIZED COMMUNITIES AGAINST DEPORTATION, as well as Plaintiffs DONTA LUCAS, JONATHAN WARNER, LESTER COOPER, and LUIS PEDROTE-SALINAS, individually and on behalf of a class of similarly situated individuals in the City of Chicago who have been or in the future will be listed as a gang member in the Gang Database by Chicago Police Case: 1:18-cv-04242 Document #: 1 Filed: 06/19/18 Page 2 of 59 PageID #:2 Department (the “CPD” or “Chicago Police” or “Department”) officers, file this Complaint for declaratory and injunctive relief against the CITY OF CHICAGO and CPD SUPERINTENDENT EDDIE JOHNSON in his official capacity, as well as CPD OFFICERS MICHAEL TOMASO, MICHAEL GOLDEN, PETER TOLEDO, JOHN DOES 1-4, and JANE DOES 1-2 in their individual capacities, and allege as follows: INTRODUCTION 1.
[Show full text]