Craig - Scso

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TENNESSEE

GREENEVILLE DIVISION
BRADLEY CRAIG, GARY CRAIG, and JERRY CRAIG, }

}
Plaintiffs, }
}
v. } CASE NO.:
}
SULLIVAN COUNTY, TENNESSEE ex rel. } JURY TRIAL DEMANDED
SULLIVAN COUNTY SHERIFF’S DEPARTMENT, }
CITY OF BRISTOL, TENNESSEE ex rel. }
BRISTOL TENNESSEE POLICE DEPARTMENT, }
WASHINGTON COUNTY, VIRGINIA ex rel. }
WAHINGTON COUNTY SHERIFF’S DEPARTMENT, }
T.M. WIDENER, in his official capacity, }
J.S. BLEVINS, in his official capacity, }
WILLIAM FORD, in his official capacity, }
JONATHAN LEICHLITER, in his official capacity, }
ERIC SARGENT, in his official capacity, }
RAY HAYES, in his official capacity, }
BURK MURRAY, in his official capacity, }
MATTHEW PRICE, in his official capacity, and }
JOHN AND JANE DOES 1 THROUGH 50, }
in their official capacities, all whose true names }
are unknown, }
}
Defendants. }
COMPLAINT
COME NOW, the Plaintiffs, Bradley Craig (“B. Craig”), Gary Craig (“G. Craig”), and Jerry Craig (“J.
Craig”) (collectively, “Plaintiffs” or “Craigs”), by and through undersigned counsel, Law Office of James W.
Friauf, PLLC, and for their Complaint against Sullivan County, Tennessee ex rel. Sullivan County Sheriff’s
Department (“SCSD”), City of Bristol, Tennessee ex rel. Bristol Tennessee Police Department (“BPD”),
Washington County, Virginia ex rel. Washington County Sheriff’s Department (“WCSD”), William Ford
(“Ford”), Jonathan Leichliter (“Leichliter”), Eric Sargent (“Sargent”), T.M. Widener (“Widener”), J.S. Blevins
Case 2:18-cv-00051-PLR-MCLC Document 1 Filed 04/03/18 Page 1 of 49 PageID #: 1

(“Blevins”), Ray Hayes (“Hayes”), Burk Murray (“Murray”), Matthew Price (“Price”), and John and Jane Does
1 through 50 (“Doe(s)”) (collectively, “Defendants”) aver as follows:
I. PARTIES
1. Plaintiff Bradley Craig is a resident citizen of the State of Tennessee, County of Sullivan. At
all times material hereto, B. Craig resided at 218 and 255 Morrell Creek Road, Bluff City, Tennessee 37618.
2. Plaintiff Jerry Craig is a resident citizen of the State of Tennessee, County of Sullivan. At all
times material hereto, J. Craig resided at 265 Morrell Creek Road, Bluff City, Tennessee 37618.
3. Plaintiff Gary Craig is a resident citizen of the State of Tennessee, County of Sullivan. At all
times material hereto, G. Craig resided at 249 Morrell Creek Road, Bluff City, Tennessee 37618.
4. Defendant SCSD is a governmental entity that, by and through its Sheriff’s Department, is
responsible for the hiring, training, supervision, and discipline of Sullivan County Sheriff’s Deputies. This
defendant may be served with process via Mayor Richard S. Venable, 3411 Highway 126, Suite 206,
Blountville, Tennessee 37617.
5. Defendant BPD is a governmental entity that, by and through its Police Department, is
responsible for the hiring, training, supervision, and discipline of City of Bristol, Tennessee police officers.
This defendant may be served with process via Mayor Jack Young, 801 Anderson Street, Bristol, Tennessee
37620.
6. Defendant WCSD is a governmental entity that, by and through its Sheriff’s Department, is
responsible for the hiring, training, supervision, and discipline of Washington County, Virginia Sheriff’s
Deputies. This defendant may be served with process via county attorney Lucy E. Phillips, Government
Center Building, 1 Government Center Place, Suite A, Abingdon, Virginia 24210.
7. Upon information and belief, Defendant T.M. Widener is a resident citizen of the
Commonwealth of Virginia, County of Washington. At all times material hereto, Defendant WCSD employed
Widener as a detective for the Washington County Sheriff’s Department, and Widener acted under the color

of state law. Plaintiffs are suing Widener in his official capacity. This defendant may be served with process:
(i) at the Washington County Office of Sheriff, 20281 Rustic Lane, Abingdon, Virginia, 24210; and (ii) via
county attorney Lucy E. Phillips, Government Center Building, 1 Government Center Place, Suite A,
Abingdon, Virginia 24210
8. Upon information and belief, Defendant J.S. Blevins is a resident citizen of the
Commonwealth of Virginia, County of Washington. At all times material hereto, Defendant WCSD employed
Blevins as a lieutenant for the Washington County Sherriff’s Department, and Blevins acted under the color
of state law. Plaintiffs are suing Blevins in his official capacity. This defendant may be served with process:
(i) at the Washington County Office of Sheriff, 20281 Rustic Lane, Abingdon, Virginia, 24210; and (ii) via
county attorney Lucy E. Phillips, Government Center Building, 1 Government Center Place, Suite A,
Abingdon, Virginia 24210
9. Upon information and belief, Defendant William Ford is a resident citizen of the State of
Tennessee, County of Sullivan. At all times material hereto, Defendant SCSD employed Ford as a detective
for the Sullivan County Sheriff’s Department, and Ford acted under the color of state law. Plaintiffs are suing
Ford in his official capacity. This defendant may be served with process via Mayor Richard S. Venable, 3411
Highway 126, Suite 206, Blountville, Tennessee 37617.
10. Upon information and belief, Defendant Jonathan Leichliter is a resident citizen of the State
of Tennessee, County of Sullivan. At all times material hereto, Defendant SCSD employed Leichliter as a
detective for the Sullivan County Sheriff’s Department, and Leichliter acted under the color of state law.
Plaintiffs are suing Ford in his official capacity. This defendant may be served with process via Mayor Richard
S. Venable, 3411 Highway 126, Suite 206, Blountville, Tennessee 37617.
11. Upon information and belief, Defendant Ray Hayes is a resident citizen of the State of
Tennessee, County of Sullivan. At all times material hereto, Defendant SCSD employed Hayes as a detective
for the Sullivan County Sheriff’s Department, and Hayes acted under the color of state law. Plaintiffs are

suing Hayes in his official capacity. This defendant may be served with process via Mayor Richard S.
Venable, 3411 Highway 126, Suite 206, Blountville, Tennessee 37617.
12. Upon information and belief, Defendant Burk Murray is a resident citizen of the State of
Tennessee, County of Sullivan. At all times material hereto, Defendant SCSD employed Murray as a
detective for the Sullivan County Sheriff’s Department, and Murray acted under the color of state law.
Plaintiffs are suing Murray in his official capacity. This defendant may be served with process via Mayor
Richard S. Venable, 3411 Highway 126, Suite 206, Blountville, Tennessee 37617.
13. Upon information and belief, Defendant Matthew Price is a resident citizen of the State of
Tennessee, County of Sullivan. At all times material hereto, Defendant SCSD employed Price as a detective
for the Sullivan County Sheriff’s Department, and Price acted under the color of state law. Plaintiffs are suing
Price in his official capacity. This defendant may be served with process via Mayor Richard S. Venable, 3411
Highway 126, Suite 206, Blountville, Tennessee 37617.
14. Upon information and belief, Defendant Eric Sargent is a resident citizen of the State of
Tennessee, County of Sullivan. At all times material hereto, Defendant BPD employed Sargent as an
investigator for the City of Bristol, Tennessee Police Department, and Sargent acted under the color of state
law. Plaintiffs are suing Sargent in his official capacity. This defendant may be served with process via Mayor
Jack Young, 801 Anderson Street, Bristol, Tennessee 37620.
15. Upon information and belief, Defendants John and Jane Does 1 through 50 are resident
citizens of the : (i) State of Tennessee, County of Sullivan; or (ii) Commonwealth of Virginia, County of
Washington. At all times material hereto, Defendants WCSD, BPD, and SCSD, respectively, employed Does
as a police officers, sheriff’s deputies, investigators, or detectives during the three (3) searches of Plaintiffs’
property. At all times material hereto, Does acted under the color of each of their respective state laws.
Plaintiffs are suing Does in their official capacities. Each Doe may be served through its employer, i.e., Mayor
Richard S. Venable (SCSD), Mayor Jack Young (BPD), and county attorney Lucy E. Phillips (WCSD).

II. JURISDICTION AND VENUE
16. Plaintiffs re-allege and incorporate by reference each and every averment set forth in
paragraphs 1-15 herein, inclusive.
17. This action arises from Defendants’ violation(s) of 42 U.S.C. § 1983 and the United States
Constitution. The Court has jurisdiction over this matter. 28 U.S.C. § 1331.
18. The remaining causes of action are so related to the claims within the original jurisdiction of
this Court so as to form part of the same case or controversy. Accordingly, the Court has supplemental
jurisdiction over Plaintiffs’ claims against Defendants for their violation(s) of the Tennessee Constitution and
Tennessee common law. 28 U.S.C. § 1367.
19. A substantial part of the events or omissions giving rise to this matter occurred in Sullivan
County, Tennessee. Venue is proper. 28 U.S.C. § 1391(b)(2).
III. GENERAL ALLEGATIONS
21. At all times material hereto, Plaintiff B. Craig owned and operated a legitimate family
business specializing in automobile “bodywork” and repair.
22. At all times material hereto, Defendants were aware of Plaintiffs’ legitimate, family business.
In fact, Plaintiffs have previously performed “bodywork” and repair for sheriff’s deputies and police officers
employed by Defendants WCSD, SCSD, and BPD.
A. April 22, 2017: Unidentified assailant(s) steal six (6) John Deere lawnmowers from
Meade Tractor.
23. Meade Tractor is a John Deere equipment dealership located at 19226 Lee Highway,
Abingdon, Virginia 24210 (Washington County).

24. On April 22, 2017, at approximately 6:20 PM, unidentified assailant(s) broke into Meade
Tractor and stole six (6) John Deere lawnmowers by placing them into a large, white box trailer. [See Exhibit
“1,” attached hereto and incorporated herein by reference].
25. The unidentified assailant(s) broke into Meade Tractor by cutting the fence surrounding
Meade Tractor in two (2) places. [See id.].
26. Pursuant to Meade Tractor surveillance footage, the unidentified assailant(s) drove a black
Chevrolet Tahoe and a “truck” towing the box trailer. [See id.].
27. The box trailer: (i) was completely rectangular; and (ii) did not contain a side door. [See id.].
28. According to the language of Ford, “[t]he trailer would have been of sufficient size to transport
the six (6) stolen mowers from the business.” [See id.].
29. Specifically, based on the dimensions of the stolen lawnmowers, the trailer had to have been
at least forty-two (42) feet in length in order to have transported all six (6) lawnmowers simultaneously. [See
id.].
30. On April 24, 2017, Meade Tractor Vice President Chad Beasley (“Mr. Beasley”) reported the
lawnmowers stolen.1
B. April 23, 2017: J. Craig purchases six (6) John Deere lawnmowers from Daniel Helton.
31. In or around early April 2017, J. Craig traveled to Abingdon, Virginia, to visit a flea market.
32. While at the flea market, J. Craig met (and purchased goods from) a vendor named Daniel
Helton (“Mr. Helton”).
33. Upon information and belief, Mr. Helton was a resident citizen of the Commonwealth of
Virginia, County of Washington.
1
The April 28, 2017, Affidavit of Complaint indicates Mr. Beasley reported the lawnmowers stolen on April
23, 2017. This is incorrect. According to a dispatch recording, Mr. Beasley made the report on April 24, 2017.

34. J. Craig and Mr. Helton discussed the possibility of future sales.
35. Approximately two weeks later, on or about April 23, 2017, Mr. Helton showed up at J.
Craig’s doorstep with six (6) John Deere lawnmowers for sale.
36. J. Craig purchased all six (6) lawnmowers for Six Thousand Dollars and 00/100 ($6,000.00).
37. Mr. Helton passed away shortly thereafter.
C. Defendant WCSD contacts Defendant BPD to assist with the investigation.
38. After reviewing the surveillance footage(s) from Meade Tractor and Roadrunner Market
(“Roadrunner”), 18224 Lee Highway, Abingdon, Virginia 24210, Widener contacted BPD “to ask for
assistance in identifying” the black Chevrolet Tahoe, “truck,” and large, white box trailer. [See id.].
39. Sargent responded to Widener and “indicated that he as [sic] familiar with one of those
vehicles, and the persons known to him to be the owners,” i.e., the Craigs. [See id.].
40. Sargent advised Widener that the Craigs owned a vehicle “matching the black Chevrolet
Tahoe.” [See id.].
41. This is a lie. Neither J. Craig nor B. Craig have ever owned a black Chevrolet Tahoe or any
vehicle similar thereto.
42. Sargent also advised Widener that he (personally) had “worked numerous thefts and
burglaries that Jerry and Bradley Craig were the prime suspects [sic].” [See id.].
43. This is also a lie. Prior to the instant matter, neither BPD nor Sargent had ever investigated
J. Craig or B. Craig as the “prime suspects” of any “thefts and burglaries,” much less “numerous” ones.
44. Unfortunately, this is not the first time Sargent has lied about the Craigs.
45. In 2015, unidentified assailant(s) stole five (5) vehicles from Proffitt Tri-City Auto Parts, 116
Old Thomas Bridge Road, Bluff City, Tennessee 37618.
46. In response, owner Darrell Proffitt (“Mr. Proffitt”) contacted BPD.

47. Almost immediately after arriving at Proffitt Tri-City Auto Parts, Sargent began insinuating
that the Craigs were guilty of stealing the five (5) vehicles.
48. At the time, Sargent had absolutely no proof of the Craigs’ involvement.
49. In fact, SCSD ultimately recovered all five (5) vehicles. Unsurprisingly, the Craigs were not
involved.
50. Upon information and belief, by presenting Mr. Proffitt with this unsolicited (and inaccurate)
information, Sargent was attempting to gather information he could utilize to persecute the Craigs for crimes
they did not commit.
51. Sargent did not stop there. After Mr. Proffitt repeatedly reassured Sargent that the Craigs
were not involved with the car theft(s), Sargent (inaccurately) informed Mr. Proffitt that the Craigs had
previously stolen a Chevrolet truck from Bristol Motor Speedway in 2008.
52. This is yet another lie. Notwithstanding the fact that no law enforcement agency has ever
investigated the Craigs for stealing any type of automobile (prior to the instant matter), no individual has ever
even contacted the Craigs regarding a Chevrolet truck stolen from Bristol Motor Speedway in 2008.
53. As evidenced above, Sargent has personally led a witch hunt against the Craigs since 2015.
D. April 27, 2017: Defendants perform a warrantless, aerial surveillance of the Craigs’
properties.
54. On April 27, 2017, Widener and Blevins performed an aerial surveillance of the Craigs’
properties with the assistance of the Virginia State Police Aviation Unit. [See id.].
55. Upon information and belief, WCSD did not obtain a warrant for this aerial surveillance.
56. According to the April 28, 2017, Affidavit of Complaint, “[t]he flight pattern used by the
helicopter was in the normal flight zone.” [See id.].
57. However, contrary to the information contained in the Affidavit of Complaint, at times, the
pilot was eye-level with the tree line.

58. The Craigs’ tree line is approximately fifty-eight (58) feet above ground.
59. During this aerial surveillance, Widener and Blevins claimed to have identified: (i) a “red or
maroon colored [sic] truck consistent in appearance with the one seen pulling the white box trailer”; (ii) a
“black colored [sic] SUV consistent with the black Chevrolet Tahoe”; and (iii) “a white colored [sic] box trailer
matching the description of the one seen in the surveillance videos.” [See id.].
60. The “red or maroon colored [sic] truck” is a 2002 Chevrolet Trailblazer. This Trailblazer does
not have the towing capabilities necessary to haul a 42’ x 36’ trailer.
61. The “black colored [sic] SUV consistent with the black Chevrolet Tahoe” is a 2002 Toyota
Sequoia. This Sequoia is inoperable and missing its front end. Plaintiffs removed the front end approximately
one (1) year prior to April 27, 2017.
62. Moreover, the 2002 Toyota Sequoia was sitting in plain view, unobscured, in the middle of
B. Craig’s property. All persons involved in the warrantless aerial surveillance would have immediately
identified the Toyota Sequoia as missing its front end.
63. However, Widener and Blevins conveniently captured no photos evidencing this pertinent,
mitigating factor.
64. As indicated by Blevins’s and Widener’s own surveillance photos, unlike the large box trailer
depicted in the Meade Tractor and Roadrunner video surveillance footage(s), the Craigs’ box trailer: (i) is not
completely rectangular; and (ii) contains a side door.
65. Most importantly, the Craigs’ box trailer is twenty-four (24) feet in length.
66. As indicated in Paragraph 29, the trailer used to steal the lawnmowers had to be at least
forty-two (42) feet in length.
67. Accordingly, the Craigs’ trailer is approximately one-half the size of the trailer contained in
the surveillance footage(s).

68. Contrary to Blevins’s and Widener’s assertions, neither the inoperable 2002 Chevrolet
Sequoia, 2002 Chevrolet Trailblazer, nor the twenty-four (24) foot box trailer matches the description(s) of
those vehicles used during the April 22, 2017, lawnmower heist.
E. April 28, 2017: Defendants search the Craigs’ properties.
69. Upon information and belief, Does employed by BPD and SCSD entered (and inspected)
Plaintiffs’ property prior to April 28, 2017. Such Does did so absent either Plaintiffs’ consent or a valid search
warrant.
70. On April 28, 2017, Ford applied for (and obtained) a warrant to search Plaintiffs’ property.
71. The Affidavit of Complaint contains numerous inaccuracies and blatant misrepresentations:
a. “On April 23, 2017….Beasley reported a theft of six (6) John Deere lawn mowers [sic]
from the night before.” [Id.].
i. No one from Meade Tractor reported a theft on April 23, 2017. On April 24,
2017, Mr. Beasley reported vandalism, not theft.
b. “Detective Eric Sargent…provided that…[Plaintiffs] had a vehicle matching the black

Chevrolet Tahoe.” [Id.].
i. Plaintiffs have never owned a black Chevrolet Tahoe or any type of vehicle
similar thereto. Moreover, Blevins and Widener would have noticed the fact that
Plaintiffs’ black Toyota Sequoia is missing its front end.
c. “Detective Eric Sargent…told…[Detective William Ford] and the Washington County

detectives that he and his department have worked numerous thefts and burglaries that
Jerry and Bradley Craig were prime suspects [sic].” [Id.].
i. Neither Sargent nor BPD have ever questioned or investigated Plaintiffs with
respect to any theft or burglary.
d. “Your Affiant [Detective William Ford] also knows…that these individuals are suspected
of committing similar offenses in Sullivan County, TN.” [Id.].
i. SCSD has never questioned or investigated Plaintiffs with respect to any theft
or burglary.
e. During the aerial surveillance, “Lieutenant Blevins and Detective Widener…observed

part of a white colored [sic] box trailer…that matched that seen on the surveillance
videos.” [Id.].

i. Plaintiffs’ box trailer is approximately one-half the size of the trailer used by the
unidentified assailants. In further dissimilarity, Plaintiffs’ box trailer: (i) is not
completely square; and (ii) contains a side-door. The color white is the only
similarity.
f. During the aerial surveillance, “[a] red or maroon colored [sic] truck consistent in
appearance with the one seen pulling the white box trailer was located.” [Id.].
i. Defendants identified a 2002 Chevrolet Trailblazer dissimilar in appearance to

the truck contained in the surveillance videos. The color red is the only similarity.
g. During the aerial surveillance, “[a] black colored [sic] SUV consistent with the black
Chevrolet Tahoe seen in the surveillance video was located.” [Id.].
i. Defendants identified a 2002 Toyota Sequoia. The Toyota Sequoia is

inoperable and missing its front end.
h. “Your Affiant [Detective William Ford] has learned...[Plaintiffs] have criminal histories
that include convictions for burglary and theft.” [Id.].
i. This is a blatant lie. Neither B. Craig nor J. Craig have convictions for burglary.
ii. In 2008, B. Craig and J. Craig pled guilty to Theft under One Thousand Dollars
($1,000.00) in United States District Court for the Eastern District of Tennessee.
Plaintiffs appealed this conviction and are currently awaiting a ruling by the Sixth
Circuit Court of Appeals.
72. The explicit language of the search warrant limited Defendants’ search to: (i) the six (6)
missing John Deere lawnmowers; (ii) keys to the lawnmowers; (iii) “universal keys used in the thefts”; and
(iv) “[b]urglary tools including bolt cutters and grinders to cut the locks and fencing.” [See id.].
73. However, contrary to the explicit language of the April 28, 2017, search warrant, Defendants
did not limit their search whatsoever.
74. In addition to those items contained in the search warrant, Defendants also seized the
following property:
a. 2012 Ranger z520 (Boat);
b. A boat trailer;

c. All of Plaintiffs’ fishing gear, including rods, reels, lures, tackle, etc.2;
d. A nearly new Wildwood Camper (and its Bill of Sale);
e. Four (4) box trailers stocked with various mechanic’s tools;
f. Three (3) portable Honda generators;
g. Table saw;
h. Various hand tools;
i. Multiple motorcycles;
j. Five (5) golf carts (and their Bill(s) of Sale);
k. Four (4) brand new wheels (with tires) for a Toyota Tundra (still containing stickers);
l. Four (4) brand new trailer wheels (with tires) (still containing stickers);
m. Four (4) brand new, 10-ply tires (still containing stickers);
n. An automobile toolbox;
o. A Toyota 4Runner;
p. Multiple box trailers, including Plaintiffs’ twenty-four (24) foot box trailer identified during
the aerial surveillance;
q. 2016 Polaris XP1000 Highlifter;
r. 2015 Polaris RZR 5900;
s. 2015 Polaris RZR 570 (belonging to B. Craig’s grandson);
t. 2015 Polaris Sportsman 90 (belonging to B. Craig’s grandson);
u. Wild Game Innovations Trail Camera (ripped from a tree at the end of J. Craig’s driveway
by Ford);
v. Multiple other trail cameras and other electronics;
2
Upon information and belief, Defendants’ deputies and police officers are avid fisherman and confiscated
Plaintiffs’ fishing supplies (and boat) for personal use.

w. Various jet skis;
x. Multiple vehicles registered in family members’ names (including the title(s) and/or Bill(s)
of Sale);
y. Multiple vehicles registered in Plaintiffs’ names (including the title(s) and/or Bill(s) of
Sale); and
z. Multiple vehicles registered in Plaintiffs’ friends’ names (including the title(s) and/or
Bill(s) of Sale).
75. Defendants SCSD and Doe(s) prepared an Inventory List containing some of the items
confiscated from Plaintiffs’ property. [See Exhibit “2,” attached hereto and incorporated herein by
reference].
76. However, unfortunately, this Inventory List is grossly inaccurate and does not begin to
itemize the extent of personal property unlawfully confiscated from Plaintiffs’ residences.
77. Due to the sheer volume of personal property unlawfully removed from Plaintiffs’ residences,
Plaintiffs are unable to prepare an accurate itemization of missing goods.
78. Defendants did not intend to abide by the unambiguous parameters of the search warrant.
79. For example, Plaintiffs (and their respective family members) personally witnessed
Defendants: (i) use their radios to run automobile VIN numbers through some type of database; (ii) receive
indication that the VIN numbers were “clear” – or words to that effect; and (iii) confiscate the “clear” vehicles
anyways.
80. In further example of this reckless disregard for the parameters of the search warrant,
Plaintiffs witnessed Hayes and Leichliter: (i) pick-up bolt cutters; (ii) use the bolt cutters to cut a lock on one
of Plaintiffs’ trailers; (iii) throw the bolt cutters onto the ground; and (iv) leave them there.
81. The search warrant specifically itemizes “bolt cutters.” Clearly, Defendants were not
interested in adhering to the strict parameters of the search warrant.
82. At one point, Ford advised G. Craig, “we’re going to take all this stuff and sort it out later.”

83. Defendants have failed to “sort it out later.” They are currently in unlawful possession of
Plaintiffs’ personal property and refuse to return it in accordance with the U.S. Constitution and Tennessee
administrative law.
F. April 28, 2017: Defendants unlawfully search G. Craig’s garage.
84. As evidenced by Exhibit 1, the search warrant does contain G. Craig’s name.
85. As further evidenced by Exhibit 1, the Affidavit of Complaint does not contain G. Craig’s
name.
86. Clearly, the search warrant did not contemplate a search of G. Craig’s property.
87. Notwithstanding the foregoing, Defendants unlawfully searched a garage located on G.
Craig’s property.
88. During the search of the garage, G. Craig’s wife and children arrived at their residence.
89. Does employed by Defendants met G. Craig’s wife and children by brandishing their firearms
and aggressively demanding G. Craig’s wife and children leave their residence.
90. G. Craig’s wife and children advised the Does that they resided at the location being
searched.
91. Despite that information, the Does continued brandishing their firearms, yelling at the family,
and aggressively demanding they leave their residence.
92. Fearing for their safety, G. Craig’s wife and children left their residence and notified G. Craig
of the ongoing search.
93. G. Craig left work immediately. When G. Craig arrived at his residence and informed Ford
that he was the lawful owner of the garage (and property) Defendants were searching, Ford hung his head.
94. Despite Ford’s knowledge of the illegality of the search, Defendants continued their
rampage, unabated.

95. Despite Ford’s knowledge of the illegality of the search, Defendants recklessly disregarded
G. Craig’s constitutional rights and seized his property without due process of law.
96. Later that evening, (presumptively, after realizing his error), Ford advised G. Craig that
SCSD would compensate G. Craig for the damage to his garage and the locks cut by Does employed by
SCSD.
97. However, to date, SCSD: (i) has not returned the property unlawfully seized from G. Craig’s
garage; and (ii) has not compensated G. Craig for the damage to his garage or the locks cut by Does
employed by SCSD.
G. May 3, 2017: Defendants search B. Craig’s business.
98. On April 28, 2017, Price and other Does employed by all Defendants demanded B. Craig:
(i) meet Price and such Does at his body shop; and (ii) provide consent to search the body shop.
99. B. Craig attempted to invoke his Fourth Amendment rights and express his disinclination to
provide such consent,
100. In response, Price threatened, “you can do this the easy way or the hard way. Given the
circumstances, we can do whatever we want” – or words to that effect.
101. Feeling he had no choice, B. Craig provided his consent to search the body shop.
102. Based partly on the information obtained during the April 28, 2017, search, Leichliter applied
for (and obtained) a warrant to search Plaintiff B. Craig’s business on May 3, 2017. [See Exhibit “3,”
attached hereto and incorporated herein by reference].
103. In his application for the search warrant, Leichliter relies heavily on: (i) items confiscated
during the April 28, 2017, search; and (ii) personal observations arising from the April 28, 2017, search(es).
a. “Your Affiant, Jonathan Leichliter…have [sic] been involved in investigations in

which…[Plaintiffs] were the suspects in theft related [sic] cases.” [Id.].

i. Neither SCSD nor Leichliter have ever questioned or investigated Plaintiffs with
respect to any theft.
b. “Your Affiant, Jonathan Leichliter…has firsthand knowledge of the location of…evidence

establishing that…[Plaintiffs] were operating a chop shop.” [Id.].
i. Neither SCSD nor Leichliter have any “firsthand knowledge” of evidence

establishing Plaintiffs “were operating a chop shop.”
c. During the April 28, 2017, search “your Affiant and other officers immediately
noticed...tools capable of being used to remove vehicle identification numbers.” [Id.].
i. Plaintiffs were not (and never have been) in possession of “tools capable of
being used to remove vehicle identification numbers.” Therefore, Leichliter
could not have “noticed” such tools.
d. During the April 28, 2017, search “[y]our Affiant also observed...slim jims which are
flexible pieces of metal.” [Id.].
i. Plaintiffs are not (and never have been) in possession of “slim jims.” Therefore,
Leichliter could not have “observed” such tools.
e. “Also observed by detectives...were pieces of metal and number punches that can be
used to produce counterfeit VIN plates.” [Id.].
i. Plaintiffs were not (and never have been) in possession of “number punches
that can be used to produce counterfeit VIN plates.” Leichliter observed
extremely thin, flimsy number punches intended for leather customization.
These “number punches” cannot be used on metal.
f. “…stolen golf carts found on…[Plaintiffs’] property on April 28-29, 2017.” [Id.].
i. To begin with, Defendants were not on Plaintiffs’ property on April 29, 2017.
ii. Furthermore, Defendants confiscated Plaintiffs’ golf carts with their respective
Bill(s) of Sale. Accordingly, at the time Leichliter authored this Affidavit of
Complaint, he was aware the golf carts were not “stolen.”
g. “Your Affiant also saw…tools that were capable of being used to punch the legitimate
VIN numbers or markings on stolen cars.” [Id.].
i. Again, Plaintiffs were not (and never have been) in possession of “number
punches that can be used to produce counterfeit VIN plates.” Leichliter
observed extremely thin, flimsy number punches intended for leather
customization. These “number punches” cannot be used on metal.

h. During the April 28, 2017, search “[y]our affiant [discovered]…frame rales [sic] removed
from motor vehicles which contained VIN markings, said property being illegal to
possess.” [Id.].
i. To begin with, Plaintiffs are not (and never have been) in possession of frame
rails containing VIN markings.
ii. Moreover, it is not “illegal” to possess leftover car parts.
105. In his Affidavit of Complaint, Liechliter states “Agent [Rocky] Johnson…has determined
that…[Plaintiffs’] vehicles were stolen despite the NCIC giving a report that the records were clear.” [Id.].
106. However, Leichliter fails to: (i) attach an Affidavit (or Statement) of Rocky Johnson; (ii) attach
any type of report indicating Plaintiffs’ vehicles were stolen; (iii) mention the fact Defendants confiscated
Plaintiffs’ title(s) and Bill(s) of Sale; (iv) explain the discrepancy with the NCIC system; or (v) otherwise explain
how Rocky Johnson “determined” Plaintiffs’ vehicles were stolen despite NCIC indicating the vehicles were
not stolen.
107. Upon information and belief, Leichliter falsified this information in order to obtain a warrant
to search B. Craig’s business.
108. The explicit language of the search warrant limited Defendants’ search to: (i) stolen motor
vehicles and motorcycles; (ii) motor vehicle parts; (iii) previously removed VIN plates and markings; (iv) tools
and instruments used to remove motor vehicle parts and VIN plates/markings; (v) golf cart parts; (vi) number
punches used to fabricate VIN plates/markings; (vii) tools that could be used to illegally enter motor vehicles
(“slim jims”); and (viii) frame rails with VIN numbers. [See id.].
109. However, contrary to the explicit language of the May 3, 2017, search warrant, Defendants
did not limit their search whatsoever.
110. In addition to those items contained in the search warrant, Defendants also seized the
following property:
a. A 1971 Chevrolet El Camino (and its title);

b. A brand new .38 caliber Dillinger firearm registered to B. Craig;
c. Two (2) trucks belonging to B. Craig’s customers;
d. Multiple plasma cutters (for use on non-metal);
e. Multiple welders and other welding materials (for use on non-metal);
f. Automobile paint and painting materials;
g. Two (2) DeVilbiss paint-spraying guns;
h. One (1) Sharp paint-spraying gun;
i. A 1970 Oldsmobile Cutlass Plaintiff had owned for thirty (30) years; and
j. Various hand tools.
111. SCSD and Doe(s) failed to prepare an Inventory List delineating the items confiscated from
B. Craig’s business.
112. Accordingly, Plaintiffs are unable to prepare an accurate itemization of missing goods.
113. Defendants did not intend to abide by the unambiguous parameters of the search warrant.
114. For example, Plaintiff B. Craig personally witnessed SCSD’s Doe(s): (i) use their radios to
run automobile VIN numbers through some type of database; (ii) receive indication that the VIN numbers
were “clear” – or words to that effect; and (iii) confiscate the “clear” vehicles anyways.
115. In further example of this reckless disregard for the parameters of the search warrant,
Defendants failed to confiscate hundreds of “motor vehicle parts,” despite their specific itemization in the
same.
116. Again, Defendants clearly were not interested in adhering to the strict parameters of the
search warrant.
117. Moreover, during the search, a customer arrived at B. Craig’s business to retrieve his vehicle
(with title in hand). Doe(s) refused to release the vehicle to the customer. Instead, Doe(s) confiscated the
vehicle.

118. Defendants are currently in unlawful possession of Plaintiff B. Craig’s personal property and
refuse to return it in accordance with the U.S. Constitution and Tennessee administrative law.
H. May 3, 2017: Defendants search J. Craig’s residence.
119. On May 3, 2017, Ford applied for (and obtained) a warrant to search Plaintiff J. Craig’s
residence. [See Exhibit “4,” attached hereto and incorporated herein by reference].
120. In his application for the search warrant, Ford relies heavily on: (i) items confiscated during
the April 28, 2017, search; and (ii) personal observations arising from the April 28, 2017, search.
a. “Mr. Craig advised detective Hayes that he knew that items on his property were stolen.”
[Id.].
i. Neither B. Craig nor J. Craig ever made such a statement.
b. “Mr. Craig…knows that the property that he is purchasing is stolen.” [Id.].
c. “Mr. Craig told Detective Hayes that he knew that he was doing wrong.” [Id.].
d. “Many of the vehicles that have been inventoried thus far contained fraudulent
documentation to include titles and insurance cards that contained the altered VIN
numbers and identification.” [Id.].
i. Neither B. Craig nor J. Craig were in possession of “fraudulent documentation

to include titles and insurance cards.” Defendants confiscated Plaintiffs’ actual
insurance cards and titles. Ford has singularly concluded this documentation is
“fraudulent” absent any evidence supporting such a determination.
122. In his Affidavit of Complaint, Ford references five (5) handguns allegedly confiscated from
Plaintiffs’ property on April 28, 2017. [See id.]. Ford claims these handguns “were confirmed to be stolen.”
[Id.].
123. Prior to the April 28, 2017, search, Plaintiffs were not in possession of any firearms (other
than the handgun housed at B. Craig’s business).

124. Upon information and belief, Defendants planted these handguns on Plaintiffs’ property so
as to “confiscate” these handguns as further “evidence” of Plaintiffs’ wrongdoing.
125. In the alternative, Ford lied about the handguns in the Affidavit of Complaint in order to obtain
a warrant to search J. Craig’s residence.
126. The May 3, 2017, search warrant limits Defendants’ search of J. Craig’s residence to: (i)
electronic devices capable of storing images; (ii) computer, cellphones, and other media capable of storing
electronic information; (iii) books, ledgers, and papers related to the sale of vehicles and/or parts; and (iv)
addresses and telephone numbers of coconspirators.
127. Despite the clearly defined parameters of the search warrant, Does employed by BPD also
seized: (i) a motor; and (ii) another boat from B. Craig’s property.
128. As evidenced above, Defendants did not intend to adhere to the strict parameters of the
search warrant.
I. May 5, 2017: Defendant SCSD arrests J. Craig.
129. On May 5, 2017, a Doe employed by SCSD arrested J. Craig.
130. At the time of his arrest, SCSD failed to inform J. Craig of the charges against him. Instead,
SCSD simply stated, “Washington County wants you picked up” – or words to that effect.
131. Once J. Craig arrived at the Sullivan County Jail (“Jail”), SCSD officials advised J. Craig he
was “charged with everything.”
132. J. Craig was in custody for five (5) days and four (4) nights.
133. During his time at the Jail, SCSD forced J. Craig to sleep on the floor of his holding cell and
refused to provide hygiene products.
134. Moreover, SCSD also refused to administer J. Craig’s medically-necessary blood thinners
to combat blood clots arising from J. Craig’s heart stent.

J. May 15, 2017: Defendants search B. Craig’s residence.
135. On May 15, 2017, Ford applied for (and obtained) a warrant to search Plaintiff B. Craig’s
residence. [See Exhibit “5,” attached hereto and incorporated herein by reference].
136. However, the Search Warrant describes B. Craig’s three (3) bedroom residence as an
“outbuilding.” [Id.].
137. In his application for the search warrant, Ford relies heavily on: (i) items confiscated during
the April 28, 2017, search; and (ii) personal observations arising from the April 28, 2017, search. [Id.].
a. Plaintiffs “have been suspects in numerous criminal investigations.” [Id.].
i. Prior to the instant matter, no Defendant has ever questioned or investigated

Plaintiffs with respect to any theft or other criminal enterprise.
b. “As of 05/10/2017, approximately fifty two [sic] vehicles that have been inventoried have
been confirmed stolen.” [Id.].
i. Defendants confiscated approximately ten (10) to twelve (12) vehicles from

Plaintiffs’ property during previous searches. Accordingly, Defendants could not
have possibly identified fifty-two (52) stolen vehicles.
c. “Paperwork found in Bradley Craig’s name includes several fraudulent insurance cards
and at least one fraudulent certificate of title.” [Id.].
i. B. Craig was not in possession of “fraudulent documentation to include titles

and insurance cards.” Defendants confiscated Plaintiffs’ actual insurance cards
and titles. Ford has singularly concluded this documentation is “fraudulent”
absent any evidence supporting such a determination.
d. “Numerous vehicles…appear to be missing several body parts…your affiant [sic]

believes …[Plaintiffs] are ‘chopping’ these vehicles and selling the parts online.” [Id.].
i. Plaintiff B. Craig owned and operated a legitimate family business specializing

in automobile “bodywork” and repair. Accordingly, Plaintiff B. Craig regularly
purchased vehicles to use them for their parts. Ford singularly concluded
Plaintiffs were “chopping” vehicles and selling the parts online absent any
evidence supporting such a hypothesis.

139. Moreover, during the search, Doe(s): (i) entered Plaintiff B. Craig’s bedroom; (ii) emptied his
dresser drawers onto the floor; (iii) removed certain pieces of lingerie belonging to B. Craig’s wife; and (iv)
laid those items of lingerie on B. Craig’s bed as though a woman was wearing them.
IV. CAUSES OF ACTION ARISING FROM THE AERIAL SURVEILLANCE
COUNT I
Unreasonable Search – Aerial Surveillance

Defendants Widener & Blevins
(U.S. Const. amend. IV and XIV and 42 U.S.C. § 1983)
141. Plaintiffs plead additionally and alternatively to all other causes of action set forth herein.
142. On April 27, 2017, Defendants Widener and Blevins conducted a warrantless aerial
surveillance of Plaintiffs’ property.
143. Defendants Widener and Blevins flew so low as to render the pilot eye-level with Plaintiffs’
sixty (60) foot tree line.
144. Defendants Widener and Blevins flew so low that the “rotor wash” from the helicopter blades
disrupted Plaintiffs’ property and otherwise interfered with Plaintiffs’ normal use of the premises.
145. In United States v. Saltzman, the Sixth Circuit Court of Appeals upheld the district court’s
decision to suppress evidence arising from a warrantless aerial surveillance conducted at seventy-five (75)
to one hundred twenty-five (125) feet above ground. 1993 U.S. App. LEXIS 7850 (6th Cir. Apr. 5, 1993).
146. Thus, according to the court in Saltzman, Plaintiffs have a reasonable expectation of privacy
in the seventy-five (75) to one hundred twenty-five (125) feet of airspace above their property. See id. at *7.
147. In the present matter, Defendants Widener and Blevins hovered less than sixty (60) feet
above Plaintiffs’ property without a warrant, thereby unlawfully invading Plaintiffs’ reasonable expectation(s)
of privacy.

148. This warrantless invasion is a gross violation of the protections afforded by the Fourth and
Fourteenth Amendments to the United States Constitution.
149. As a direct and proximate result of Defendants Widener’s and Blevins’s warrantless invasion
of Plaintiffs’ reasonable expectation(s) of privacy, Plaintiffs have suffered injuries and damages and are
entitled to the relief set forth more fully herein.
COUNT II
Unreasonable Search and Seizure

All Individual Defendants
152. On or about April 28, 2017, Defendant Ford obtained a warrant to conduct a search of
Plaintiffs’ property.
153. In the Affidavit of Complaint supporting Defendant Ford’s application for a search warrant,
he relies heavily on the footage/images captured during the warrantless aerial surveillance on April 27, 2017.
154. As averred more fully herein, the warrantless aerial surveillance was an unreasonable
search in violation of the Fourth and Fourteenth Amendments to the United States Constitution.
155. Without the initial, illegal flight, Defendant Ford would not have applied for a search warrant.
156. Alternatively, without the initial, illegal flight, Defendant Ford would not have had sufficient
probable cause (which Plaintiffs vehemently dispute) to support the issuance of a search warrant.
157. The April 28, 2017, search was a “fruit of the poisonous tree,” and the search warrant did
not attenuate the taint. See Brown v. Illinois, 422 U.S. 590, 598-99 (1975); Wong Sun v. United States, 371
U.S. 471, 486 (1963); Saltzman, 1993 U.S. App. LEXIS 7850 at *7.

158. Although the exclusionary rule’s primary function is the suppression of evidence during a
criminal proceeding, Plaintiffs draw an analogy to the present matter: without the unlawful aerial surveillance,
Defendant Ford would not have had sufficient (or any) probable cause to justify the issuance of the April 28,
2017, search warrant.
159. Accordingly, Defendants Ford, Widener, Blevins, Leichliter, Sargent, Hayes, Murray, Price,
and Doe(s) lacked sufficient probable cause to conduct the search of Plaintiffs’ property on April 28, 2017.
160. By conducting the April 28, 2017, search absent probable cause, Defendants Ford, Widener,
Blevins, Leichliter, Sargent, Hayes, Murray, Price, and Doe(s) violated the protections afforded by the Fourth
and Fourteenth Amendments to the United States Constitution.
161. As a direct and proximate result of Defendants’ unlawful search of Plaintiffs’ property on April
28, 2017, Plaintiffs have suffered injuries and damages and are entitled to the relief set forth more fully herein.
COUNT III

Defendants Leichliter, Price, and Doe(s)
164. On or about May 3, 2017, Defendant Leichliter obtained a warrant to conduct a search of
Plaintiff B. Craig’s workshop.
165. In the Affidavit of Complaint supporting Defendant Leichliter’s application for a search
warrant, he relies heavily on the evidence obtained during the April 28, 2017, search of Plaintiffs’ property.
166. As averred more fully herein, the April 28, 2017, search constituted an unreasonable search
and seizure in violation of the Fourth and Fourteenth Amendments to the United States Constitution.

167. Without the initial, illegal search, Defendant Leichliter would not have applied for a search
warrant.
168. Alternatively, without the initial, illegal search, Defendant Leichliter would not have had
sufficient probable cause (which Plaintiffs vehemently dispute) to support the issuance of a search warrant.
169. The May 3, 2017, search was a “fruit of the poisonous tree,” and the search warrant did not
attenuate the taint. See Brown, 422 U.S. at 598-99; Wong Sun, 371 U.S. at 486; Saltzman, 1993 U.S. App.
LEXIS 7850 at *7.
criminal proceeding, Plaintiffs draw an analogy to the present matter: without the unlawful search on April 28,
2017, Defendant Leichliter would not have had sufficient (or any) probable cause to justify the issuance of
the May 3, 2017, search warrant.
171. Accordingly, Defendants Leichliter, Price, and Doe(s) lacked sufficient probable cause to
conduct the search of Plaintiff B. Craig’s workshop on May 3, 2017.
172. By conducting the May 3, 2017, search absent probable cause, Defendants Leichliter, Price,
and Doe(s) violated the protections afforded by the Fourth and Fourteenth Amendments to the United States
Constitution.
173. As a direct and proximate result of Defendants’ unlawful search of Plaintiff B. Craig’s
workshop on May 3, 2017, Plaintiff B. Craig has suffered injuries and damages and is entitled to the relief set
forth more fully herein.
COUNT IV

Defendants Ford and Doe(s)

176. On or about May 3, 2017, Defendant Ford obtained a warrant to conduct a search of Plaintiff
J. Craig’s residence.
he relies heavily on the evidence obtained during April 28, 2017, search of Plaintiffs’ property.
178. As discussed more fully herein, the April 28, 2017, search constituted an unreasonable
search and seizure in violation of the Fourth and Fourteenth Amendments to the United States Constitution.
179. Without the initial, illegal search, Defendant Ford would not have applied for a search
warrant.
180. Alternatively, without the initial, illegal search, Defendant Ford would not have had sufficient
probable cause (which Plaintiffs vehemently dispute) to support the issuance of a search warrant.
181. The May 3, 2017, search was a “fruit of the poisonous tree,” and the search warrant did not
attenuate the taint. See Brown, 422 U.S. at 598-99; Wong Sun, 371 U.S. at 486; Saltzman, 1993 U.S. App.
LEXIS 7850 at *7.
criminal proceeding, Plaintiffs draw an analogy to the present matter: without the unlawful search on April 28,
2017, Defendant Ford would not have had sufficient (or any) probable cause to justify the issuance of the
May 3, 2017, search warrant.
183. Accordingly, Defendants Ford and Doe(s) lacked sufficient probable cause to conduct the
search of Plaintiff J. Craig’s residence on May 3, 2017.
184. By conducting the May 3, 2017, search absent probable cause, Defendants Ford and Doe(s)
violated the protections afforded by the Fourth and Fourteenth Amendments to the United States
Constitution.

185. As a direct and proximate result of Defendants’ unlawful search of Plaintiff J. Craig’s
residence on May 3, 2017, Plaintiff J. Craig has suffered injuries and damages and is entitled to the relief set
COUNT V

Defendant Ford and Doe(s)
188. On or about May 15, 2017, Defendant Ford obtained a warrant to conduct a search of
Plaintiff B. Craig’s residence.
he relies heavily on the evidence obtained during April 28, 2017, and May 3, 2017, searches of Plaintiffs’
property.
190. As averred more fully herein, the April 28, 2017, and May 3, 2017, searches constituted
unreasonable searches and seizures in violation of the Fourth and Fourteenth Amendments to the United
States Constitution.
191. Without the initial, illegal searches, Defendant Ford would not have applied for a search
warrant.
192. Alternatively, without the initial, illegal searches, Defendant Ford would not have had
sufficient probable cause (which Plaintiffs vehemently dispute) to support the issuance of a search warrant.
193. The April 28, 2017, and May 3, 2017, searches were the “fruit of the poisonous tree,” and
the search warrant did not attenuate the taint. See Brown, 422 U.S. at 598-99; Wong Sun, 371 U.S. at 486;
Saltzman, 1993 U.S. App. LEXIS 7850 at *7.

criminal proceeding, Plaintiffs draw an analogy to the present matter: without the unlawful searches on April
28, 2017, and again on May 3, 2017, Defendant Ford would not have had sufficient (or any) probable cause
to justify the issuance of the May 15, 2017, search warrant.
search of Plaintiff B. Craig’s residence on May 15, 2017.
196. By conducting the May 15, 2017, search absent probable cause, Defendants Ford and
Doe(s) violated the protections afforded by the Fourth and Fourteenth Amendments to the United States
Constitution.
residence on May 15, 2017, Plaintiff B. Craig has suffered injuries and damages and is entitled to the relief
set forth more fully herein.
V. CAUSES OF ACTION ARISING FROM THE SEARCH ON APRIL 28, 2017
COUNT VI
Unreasonable Search and Seizure – Misstatement of Fact in Affidavit

Plaintiffs’ property.
201. As averred in Paragraph 64, herein, the Affidavit of Complaint supporting Defendant Ford’s
application for a search warrant contains numerous inaccuracies and blatant misrepresentations.

202. As the applicant, Ford knowingly and intentionally made false statements in the Affidavit of
Complaint.
203. In the alternative, Ford made false statements with a reckless disregard for the truth.
204. The offending information is essential to a determination of probable cause.
205. After excising the false statements, no probable cause exists to justify the issuance of a
search warrant.
206. Accordingly, Defendants Ford, Widener, Blevins, Leichliter, Sargent, Hayes, Murray, Price,
and Doe(s) lacked sufficient probable cause to conduct the search of Plaintiffs’ property on April 28, 2017.
207. By conducting the April 28, 2017, search absent probable cause, Defendants Ford, Widener,
Blevins, Leichliter, Sargent, Hayes, Murray, Price, and Doe(s) violated the protections afforded by the Fourth
and Fourteenth Amendments to the United States Constitution.
208. As a direct and proximate result of Defendants’ unlawful search of Plaintiffs’ property on April
28, 2017, Plaintiffs have suffered injuries and damages and are entitled to the relief set forth more fully herein.
COUNT VII
Unreasonable Search and Seizure – Seizing Items Not Specified

211. The explicit language of the April 28, 2017, search warrant limited Defendants’ search to: (i)
the six (6) missing John Deere lawnmowers; (ii) keys to the lawnmowers; (iii) “universal keys used in the
thefts”; and (iv) “[b]urglary tools including bolt cutters and grinders to cut the locks and fencing.” [See Exhibit
1].

212. However, Defendants Ford, Widener, Blevins, Leichliter, Sargent, Hayes, Murray, Price, and
Doe(s) did not limit their search to the unambiguous parameters of the search warrant.
213. As averred in Paragraph 67, herein, Defendants Ford, Widener, Blevins, Leichliter, Sargent,
Hayes, Murray, Price, and Doe(s) also confiscated an tremendous quantity of Plaintiffs’ personal property.
214. Neither the search warrant nor the Affidavit of Complaint specifically enumerated the items
Defendants confiscated from Plaintiffs’ residences.
215. Moreover, the unlawfully confiscated items did not constitute other fruits, instruments, and/or
evidence of a crime (known or unknown).
216. Accordingly, by unlawfully confiscating the items identified herein, Defendants Ford,
Widener, Blevins, Leichliter, Sargent, Hayes, Murray, Price, and Doe(s) violated the protections afforded by
the Fourth and Fourteenth Amendments to the United States Constitution.
217. As a direct and proximate result of Defendants’ unlawful seizure of Plaintiffs’ property on
April 28, 2017, Plaintiffs have suffered injuries and damages and are entitled to the relief set forth more fully
herein.
COUNT VIII
Deprivation of Property without Due Process of Law

(U.S. Const. amend. V and XIV and 42 U.S.C. § 1983)
220. At all times material hereto, Defendants Ford, Widener, Blevins, Leichliter, Sargent, Hayes,
Murray, Price, and Doe(s) lacked probable cause to search (and seize) Plaintiffs’ property.
221. In the alternative, Defendants Ford, Widener, Blevins, Leichliter, Sargent, Hayes, Murray,
Price, and Doe(s) seized items outside the scope of the search warrant.

222. By seizing Plaintiffs’ property absent probable cause, Defendants Ford, Widener, Blevins,
Leichliter, Sargent, Hayes, Murray, Price, and Doe(s) deprived Plaintiffs of their property without due process
of law and in violation the protections afforded by the Fifth and Fourteenth Amendments to the United States
Constitution.
223. In the alternative, by seizing items outside the scope of the search warrant, Defendants Ford,
Widener, Blevins, Leichliter, Sargent, Hayes, Murray, Price, and Doe(s) deprived Plaintiffs of their property
without due process of law and in violation the protections afforded by the Fifth and Fourteenth Amendments
to the United States Constitution.
224. As a direct and proximate result of Defendants’ deprivation of Plaintiffs’ property without due
process of law, Plaintiffs have suffered injuries and damages and are entitled to the relief set forth more fully
herein.
COUNT IX

property belonging to B. Craig and J. Craig.
228. Ford obtained no warrant permitting a search of property owned by G. Craig.
229. Notwithstanding the foregoing, Defendants Ford, Widener, Blevins, Leichliter, Sargent,
Hayes, Murray, Price, and Doe(s) conducted a warrantless search of G. Craig’s garage.

230. By conducting the April 28, 2017, search absent either probable cause or a valid search
warrant, Defendants Ford, Widener, Blevins, Leichliter, Sargent, Hayes, Murray, and Doe(s) violated the
protections afforded by the Fourth and Fourteenth Amendments to the United States Constitution.
231. As a direct and proximate result of Defendants’ unlawful search of G. Craig’s garage on April
28, 2017, G. Craig has suffered injuries and damages and is entitled to the relief set forth more fully herein.
COUNT X

234. At all times material hereto, Defendants Ford, Widener, Blevins, Leichliter, Sargent, Hayes,
Murray, Price, and Doe(s) did not possess a valid warrant permitting a search of any property owned by G.
Craig.
235. Despite the foregoing, Defendants Ford, Widener, Blevins, Leichliter, Sargent, Hayes,
Murray, Price, and Doe(s) seized items from G. Craig’s garage.
236. By seizing Plaintiff G. Craig’s property absent either probable cause or a valid search
warrant, Defendants Ford, Widener, Blevins, Leichliter, Sargent, Hayes, Murray, Price, and Doe(s) deprived
Plaintiff G. Craig of his property without due process of law and in violation the protections afforded by the
Fifth and Fourteenth Amendments to the United States Constitution.
237. As a direct and proximate result of Defendants’ deprivation of Plaintiff G. Craig’s property
without due process of law, Plaintiff G. Craig has suffered injuries and damages and is entitled to the relief

VI. CAUSES OF ACTION ARISING FROM THE SEARCH OF B. CRAIG’S BUSINESS
ON MAY 3, 2017
COUNT XI
Unreasonable Search and Seizure – Misstatement of Fact in Affidavit

240. On or about May 3, 2017, Defendant Leichliter obtained a warrant to conduct a search of
Plaintiff B. Craig’s business.
241. As averred in Paragraph 79, herein, the Affidavit of Complaint supporting Defendant
Leichliter’s application for a search warrant contains numerous inaccuracies and blatant misrepresentations.
242. As the applicant, Leichliter knowingly and intentionally made false statements in the Affidavit
of Complaint.
243. In the alternative, Leichliter made false statements with a reckless disregard for the truth.
search warrant.
246. Accordingly, Defendants Leichliter, Price, and Doe(s) lacked sufficient probable cause to
conduct the search of Plaintiff B. Craig’s business on May 3, 2017.
247. By conducting the May 3, 2017, search absent probable cause, Defendants Leichliter, Price,
and Doe(s) violated the protections afforded by the Fourth and Fourteenth Amendments to the United States
Constitution.

business on May 3, 2017, Plaintiff B. Craig has suffered injuries and damages and is entitled to the relief set
COUNT XII
Unreasonable Search and Seizure – Seizing Items Not Specified

Defendants Leichliter, Price and Doe(s)
250. Plaintiffs plead additionally and alternatively to all other causes of action contained herein.
251. The explicit language of the May 3, 2017, search warrant limited Defendants’ search to: (i)
stolen motor vehicles and motorcycles; (ii) motor vehicle parts; (iii) previously removed VIN plates and
markings; (iv) tools and instruments used to remove motor vehicle parts and VIN plates/markings; (v) golf
cart parts; (vi) number punches used to fabricate VIN plates/markings; (vii) tools that could be used to illegally
enter motor vehicles (“slim jims”); and (viii) frame rails with VIN numbers. [See Exhibit 3].
252. However, Defendants Leichliter, Price, and Doe(s) did not limit their search to the
unambiguous parameters of the search warrant.
253. As averred in Paragraph 85, herein, Defendants Leichliter, Price, and Doe(s) also
confiscated items outside the scope of the search warrant.
254. Neither the search warrant nor the Affidavit of Complaint specifically enumerated the
additional items Defendants Leichliter, Price, and Doe(s) confiscated from Plaintiff B. Craig’s business.
255. Moreover, the unlawfully confiscated items did not constitute other fruits, instruments, and/or
evidence of a crime (known or unknown).

256. Accordingly, by unlawfully confiscating the items identified herein, Defendants Leichliter,
Price, and Doe(s) violated the protections afforded by the Fourth and Fourteenth Amendments to the United
States Constitution.
257. As a direct and proximate result of Defendants’ unlawful seizure of Plaintiff B. Craig’s
property on May 3, 2017, Plaintiff B. Craig has suffered injuries and damages and is entitled to the relief set
COUNT XIII

260. At all times material hereto, Defendants Leichliter, Price, and Doe(s) lacked probable cause
to search (and seize) Plaintiff B. Craig’s property.
261. In the alternative, Defendants Leichliter, Price, and Doe(s) seized items outside the scope
of the search warrant.
262. By seizing Plaintiff’s property absent probable cause, Defendants Leichliter, Price, and
Doe(s) deprived Plaintiff B. Craig of his property without due process of law and in violation of the protections
afforded by the Fifth and Fourteenth Amendments to the United States Constitution.
263. In the alternative, by seizing items outside the scope of the search warrant, Defendants
Leichliter, Price, and Doe(s) deprived Plaintiff B. Craig of his property without due process of law and in
violation the protections afforded by the Fifth and Fourteenth Amendments to the United States Constitution.

264. As a direct and proximate result of Defendants’ deprivation of Plaintiff B. Craig’s property
without due process of law, Plaintiff B. Craig has suffered injuries and damages and is entitled to the relief
VII. CAUSES OF ACTION ARISING FROM THE SEARCH OF J. CRAIG’S RESIDENCE

ON MAY 3, 2017
COUNT XIV
Unreasonable Search and Seizure – Insufficient Warrant

267. On or about May 3, 2017, Defendant Ford obtained a warrant to conduct a search of Plaintiff
J. Craig’s residence.
Complaint.
search warrant.
search of Plaintiff J. Craig’s residence on May 3, 2017.

274. By conducting the May 3, 2017, search absent probable cause, Defendants Ford and Doe(s)
violated the protections afforded by the Fourth and Fourteenth Amendments to the United States
Constitution.
275. As a direct and proximate result of Defendants’ unlawful search of Plaintiff J. Craig’s
residence on May 3, 2017, Plaintiff J. Craig has suffered injuries and damages and is entitled to the relief set
COUNT XV

278. At all times material hereto, Defendants Ford and Doe(s) lacked probable cause to search
(and seize) Plaintiff J Craig’s property.
279. By seizing Plaintiff’s property absent probable cause, Defendants Ford and Doe(s) deprived
Plaintiff J. Craig of his property without due process of law and in violation of the protections afforded by the
280. As a direct and proximate result of Defendants’ deprivation of Plaintiff J. Craig’s property
without due process of law, Plaintiff J. Craig has suffered injuries and damages and is entitled to the relief

VIII. CAUSES OF ACTION ARISING FROM J. CRAIG’S ARREST ON MAY 5, 2017
COUNT XVI
Unreasonable Seizure
Defendant Doe
283. On May 5, 2017, a Doe employed by SCSD arrested J. Craig without notifying J. Craig of
any charges against him.
284. Several hours later, Sullivan County Jail officials advised J. Craig he was “being charged
with everything.”
285. However, to date, neither SCSD nor any other law enforcement agency has charged J. Craig
with “everything” or anything related thereto.
286. Upon information and belief, Defendant Doe possessed neither probable cause nor an arrest
warrant to justify arresting J. Craig on May 5, 2017, and, instead, used the arrest as a mere intimidation tactic.
287. By arresting Plaintiff J. Craig absent probable cause, Defendant Doe violated the protections
afforded by the Fourth and Fourteenth Amendments to the United States Constitution.
288. As a direct and proximate result of Defendant’s unlawful seizure of J. Craig on May 5, 2017,
Plaintiff J. Craig has suffered injuries and damages and is entitled to the relief set forth more fully herein.
COUNT XVII
Deprivation of Liberty without Due Process of Law

Defendant Doe

291. At all times material hereto, Defendant Doe lacked probable cause to arrest J. Craig for
“everything” – however designated.
292. By placing J. Craig under arrest absent probable cause, Defendant Doe deprived J. Craig
of his liberty without due process of law and in violation of the protections afforded by the Fifth and Fourteenth
Amendments to the United States Constitution.
293. As a direct and proximate result of Defendant’s deprivation of J. Craig’s liberty without due
process of law, Plaintiff J. Craig has suffered injuries and damages and is entitled to the relief set forth more
fully herein.
IX. CAUSES OF ACTION ARISING FROM THE SEARCH ON MAY 15, 2017
COUNT XVIII
Unreasonable Search and Seizure – Insufficient Warrant

296. On or about May 15, 2017, Defendant Ford obtained a warrant to conduct a search of
Plaintiff B. Craig’s residence.
Complaint.

search warrant.
search of Plaintiff B. Craig’s residence on May 15, 2017.
303. By conducting the May 15, 2017, search absent probable cause, Defendants Ford and
Doe(s) violated the protections afforded by the Fourth and Fourteenth Amendments to the United States
Constitution.
residence on May 15, 2017, Plaintiff B. Craig has suffered injuries and damages and is entitled to the relief
COUNT XIX

307. At all times material hereto, Defendants Ford and Doe(s) lacked probable cause to search
(and seize property from) Plaintiff B. Craig’s residence.
308. By seizing Plaintiff’s property absent probable cause, Defendants Ford and Doe(s) deprived
Plaintiff B. Craig of his property without due process of law and in violation the protections afforded by the
309. As a direct and proximate result of Defendants’ deprivation of Plaintiff B. Craig’s property
without due process of law, Plaintiff B. Craig has suffered injuries and damages and is entitled to the relief

X. CAUSES OF ACTION ARISING FROM DEPARTMENT POLICY AND PROCEDURE
COUNT XX
Deliberate Indifference
Defendants SCSD, BPD, and WCSD
(42 U.S.C. § 1983)
312. By: (i) intentionally including misstatement(s) of material fact in the Affidavit(s) of Complaint;
(ii) unlawfully seizing mass quantities of property outside the scope of the search warrant(s); (iii) seizing items
absent probable cause; (iv) searching Plaintiffs’ property and residences absent probable cause; (v) depriving
Plaintiffs of their property without due process of law; (vi) conducting a warrantless, low-flying aerial
surveillance; and (vii) arresting J. Craig absent either probable cause or a valid arrest warrant, Defendants
Ford, Widener, Blevins, Leichliter, Sargent, and Doe(s) behaved in an objectively unreasonable manner.
313. As evidenced by the alarming number of civil rights complaints filed against SCSD, BPD,
and WCSD, the misconduct of Defendants Ford, Widener, Blevins, Leichliter, Sargent, Hayes, Murray, Price,
and Doe(s) is part of the unspoken policy(ies) and practice(s) of SCSD, BPD, and WCSD.
314. As a matter of practice, by failing to adequately train, supervise, and control their deputies
and officers, SCSD, BPD, and WCSD directly encourage (and are thereby the moving force behind) the very
type of misconduct alleged herein.
315. Such failures manifest deliberate indifference to the rights of citizens such as Plaintiffs.
316. By failing to adequately discipline deputies and officers who have committed prior instances
of similar misconduct, SCSD, BPD, and WCSD cause their deputies and officers to believe their actions will
not be scrutinized and, in that way, directly encourage abuses such as those to which Plaintiffs were
subjected.

317. By abusing citizens in the manner averred herein absent any finding of wrongdoing, SCSD,
BPD, and WCSD have compromised their respective government policies and thereby given license to the
wrongdoers to continue their misconduct with impunity.
318. By having actual (or constructive) notice of their respective unconstitutional practices, yet
failing to correct them, SCSD, BPD, and WCSD have exhibited deliberate indifference to the constitutional
rights of citizens like Plaintiffs.
319. As a direct and proximate result of Defendants’ respective deliberate indifference, Plaintiffs
have suffered injuries and damages and are entitled to the relief set forth more fully herein.
COUNT XXI
Failure to Train and/or Supervise

322. SCSD, BPD, and WCSD have failed to adequately train their deputies and officers as to the
requirements for a proper investigation, including, without limitation: (i) factors to consider when making a
probable cause determination; (ii) omitting inaccurate (or unsupported) factual allegations from an Affidavit
of Complaint; (iii) abiding by the strictly-defined parameters of a search warrant; (iv) the protections
guaranteed by the Fourth, Fifth, and Fourteenth Amendments; and (v) obtaining a proper warrant before
conducting a search.
323. This failure to adequately train deputies and officers with respect to the foregoing
constitutional requirements (without limitation) presents the obvious potential for false arrest(s), deprivation(s)
of property and liberty absent due process of law, unconstitutional search(es), and unconstitutional
seizure(s).

324. By failing to adequately train Defendants Ford, Widener, Blevins, Leichliter, Sargent, Hayes,
Murray, Price, and Doe(s) as to the proper way to conduct the type of investigation(s) described herein,
SCSD, BPD, and WCSD were reckless and/or grossly negligent, respectively, thereby creating an
environment conducive to inevitable official misconduct and constitutional violations.
325. Without proper training as to: (i) constitutional requirements; (ii) the rights of citizens to be
free from unreasonable searches and seizures; and (iii) the protections afforded by the Fifth and Fourteenth
Amendments, Defendants’ collective tirade of unconstitutional searches and seizures is virtually certain to
continue.
326. As a direct and proximate result of Defendants’ respective failures to train and/or supervise,
Plaintiffs have suffered injuries and damages and are entitled to the relief set forth more fully herein.
COUNT XXII
Failure to Implement Appropriate Policies, Customs, and Practices

(42 U.S.C. § 1983)
329. SCSD, BPD, and WCSD have implicitly or explicitly adopted and/or implemented careless
and reckless policies, customs, or practices, including, without limitation: (i) arresting individuals absent
probable cause (or a warrant); (ii) conducting searches absent probable cause (or a warrant); (iii) seizing
property absent probable cause (or a warrant); (iv) lying in Affidavit(s) of Complaint; (v) depriving persons of
their property without due process of law; and (vi) depriving persons of their liberty without due process of
law.

330. By failing to implement appropriate policies, customs, and practices, SCSD, BPD, and
WCSD have been reckless and/or grossly negligent, respectively, thereby creating an environment conducive
to inevitable official misconduct and constitutional violations.
331. As a direct and proximate result of Defendants’ failure to implement appropriate policies,
customs, and practices, Plaintiffs have suffered injuries and damages and are entitled to the relief set forth
more fully herein.
COUNT XXIII
Ratification
334. SCSD, BPD, and WCSD have ratified and acquiesced to the unlawful conduct of Defendants
Ford, Widener, Blevins, Leichliter, Sargent, Hayes, Murray, Price, and Doe(s) by allowing said individuals to
unlawfully search and seize Plaintiffs and their property in violation of respective Department policies and
procedures absent any type of reprimand or mandatory retraining.
335. SCSD, BPD, and WCSD have ratified and acquiesced to the unlawful conduct of Defendants
Ford, Widener, Blevins, Leichliter, Sargent, Hayes, Murray, Price, and Doe(s) by allowing said individuals to
unlawfully search and seize Plaintiffs and their property in violation of the United States Constitution and the
Tennessee Constitution absent any type of reprimand or mandatory retraining.
336. By failing to reprimand Defendants Ford, Widener, Blevins, Leichliter, Sargent, Hayes,
Murray, Price, and Doe(s), Defendants SCSD, BPD, and WCSD have ratified unconstitutional policies,
procedures, and unspoken customs of their respective deputies and officers, thereby ratifying the reckless
and/or grossly negligent practices of these individuals.

337. Such ratification is so grossly negligent as to demonstrate a willful disregard for the
protections of the Tennessee and United States Constitutions.
338. As a result of this ratification, Plaintiffs have fallen victim to the constitutional violations
alleged herein.
339. As a direct and proximate result of Defendants’ ratification, Plaintiffs have suffered injuries
and damages and are entitled to the relief set forth more fully herein.
XI. CAUSES OF ACTION - SUPPLEMENTAL STATE LAW CLAIMS
COUNT XXIV
Intentional Infliction of Emotional Distress

342. As averred herein, the conduct of Defendants Ford, Widener, Blevins, Leichliter, Sargent,
Hayes, Murray, Price, and Doe(s) was intentional or reckless and so outrageous as to not be tolerated by a
civilized society.
343. The foregoing conduct constitutes intentional infliction of emotional distress inflicted upon
Plaintiffs by Defendants Ford, Widener, Blevins, Leichliter, Sargent, Hayes, Murray, Price, and Doe(s).
344. As a direct and proximate result of Defendants’ intentional infliction of emotional distress,
Plaintiffs have suffered mental injury and damages and are entitled to the relief set forth more fully herein.
COUNT XXV
False Imprisonment
Defendant Doe

347. On May 5, 2017, a Doe employed by SCSD arrested J. Craig without notifying J. Craig of
any charges against him.
348. Sullivan County Jail officials eventually advised J. Craig he was “charged with everything.”
349. J. Craig remained in custody for four (4) days and five (5) nights without appearing before a
judiciary.
350. On the fourth day, Sullivan County Jail released J. Craig after J. Craig posted bond.
351. To date, SCSD has failed to charge J. Craig with a crime.
352. Upon information and belief, Defendant Doe lacked probable cause to arrest J. Craig.
353. By arresting J. Craig without probable cause, Defendant Doe unlawfully restrained J. Craig
against his will.
354. The foregoing constitutes false imprisonment of Plaintiff J. Craig by Defendant Doe.
355. As a direct and proximate result of Defendant Doe’s false imprisonment of J. Craig, Plaintiff
J. Craig suffered mental and physical injury and damages and is entitled to the relief set forth more fully
herein.
COUNT XXVI
Negligence Per Se
(Tenn. Code Ann. § 39-14-403)
358. Pursuant to Tenn. Code Ann. § 39-16-403, it is unlawful for a public servant acting under
color of office or employment to: (i) intentionally detain, arrest and/or mistreat another individual with

knowledge that the conduct is unlawful; and/or (ii) intentionally impede another individual in their enjoyment
of any right with knowledge the conduct is unlawful.
359. Defendants Ford, Widener, Blevins, Leichliter, Sargent, Hayes, Murray, Price, and Doe(s)
intentionally impeded Plaintiffs’ right to quiet enjoyment of their property by: (i) lying on the Affidavit(s) of
Complaint; (ii) seizing property grossly outside the scope of the search warrant(s); and (iii) conducting a
warrantless aerial surveillance; and (iv) conducting four (4) searches of Plaintiffs’ property absent probable
cause.
360. Defendants impeded Plaintiffs’ right to quiet enjoyment under color of employment and with
knowledge their conduct was improper and/or unlawful.
361. Moreover, Defendant Doe intentionally detained, arrested and mistreated Plaintiff J. Craig
under color of employment and with knowledge his conduct was improper and/or unlawful.
362. At the time of Plaintiff J. Craig’s arrest, Defendant Doe was unable to provide J. Craig with
a reason for his arrest.
363. The foregoing conduct constitutes negligence per se by Defendants Ford, Widener, Blevins,
Leichliter, Sargent, Hayes, Murray, Price, and Doe(s).
364. As a direct and proximate cause of Defendants’ negligence per se in violation of Tenn. Code
Ann. § 39-16-403, Plaintiffs have suffered injuries and damages and are entitled to the relief set forth more
fully herein.
COUNT XXVII
Conversion

367. Between April 28, 2017, and May 15, 2017, Defendants Ford, Widener, Blevins, Leichliter,
Sargent, Hayes, Murray, Price, and Doe(s) confiscated hundreds of items from Plaintiffs’ properties that: (i)
were not contemplated by the various search warrants; (ii) were not evidence of the commission of a crime;
(iii) were not fruits of a crime; and (iv) did not constitute means of committing a crime.
368. Despite the foregoing, to date, Defendants have failed to return a single item confiscated
from Plaintiffs’ properties.
369. Upon information and belief, Defendants Ford, Widener, Blevins, Leichliter, Sargent, Hayes,
Murray, Price, and Doe(s) confiscated these items for their own personal use and benefit, as evidenced by
their exercise of dominion and control over Plaintiffs’ personal property in blatant defiance of Plaintiffs’
property rights.
370. The foregoing conduct constitutes civil conversion by Defendants Ford, Widener, Blevins,
Leichliter, Sargent, Hayes, Murray, Price, and Doe(s).
371. As a direct and proximate of Defendants’ civil conversion, Plaintiffs have suffered injuries
and damages and are entitled to the relief set forth more fully herein.
XII. DAMAGES
373. As a direct and proximate result of each of the foregoing acts, conduct, and violations of the
law alleged herein, Plaintiffs have suffered damages in an amount and according proof including, without
limitation, medical bills, pain and suffering, emotional distress, inconvenience, embarrassment, humiliation,
loss of enjoyment of life – both past and future, loss or impairment of future earning capacity, and other
incidental and consequential damages.

374. The conduct of Defendants Ford, Widener, Blevins, Leichliter, Sargent, Hayes, Murray,
Price, and Doe(s), as alleged herein, was intentional, fraudulent, malicious and/or reckless. Accordingly,
Plaintiffs seek an award of punitive damages under applicable law in an amount to be determined by a jury.
375. Plaintiffs are entitled to, and seek, recovery of their reasonable attorneys’ fees and costs
pursuant to 42 U.S.C. § 1988.
XIII. PRAYER FOR RELIEF
WHEREFORE, Plaintiffs pray for judgment against Defendants as follows:
1. Compensatory damages in an amount to be awarded by a jury, not less than ONE
HUNDRED FIFTY MILLION DOLLARS AND 00/100 ($150,000,000.00);
2. Punitive damages in an amount to be awarded by a jury, not less than THREE HUNDRED
FIFTY MILLION DOLLARS AND 00/100 ($350,000,000.00);
3. Reasonable attorneys’ fees and costs;
4. Incidental and/or consequential damages in an amount to be determined by a jury; and
5. Any and all further relief this Honorable Court deems just and appropriate.
Respectfully submitted, this 3rd day of April 2018.
BRADLEY CRAIG, GARY CRAIG, and JERRY CRAIG
By: /s/ James Friauf

James W. Friauf (#027238)
Ariana E. L. Mansolino (#035237)
LAW OFFICE OF JAMES W. FRIAUF, PLLC
9724 Kingston Pike, Suite 104
Knoxville, Tennessee 37922
Tele: (865) 236-0347
Fax: (865) 512-9174
Email: james@friauflaw.com
Our File No.: 18-013-CIV
Attorneys for Plaintiffs Bradley Craig, Gary Craig, Jerry Craig

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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TENNESSEE

BRADLEY CRAIG, GARY CRAIG, and JERRY CRAIG, }

Case 2:18-cv-00051-PLR-MCLC Document 1 Filed 04/03/18 Page 1 of 49 PageID #: 1

1 through 50 (“Doe(s)”) (collectively, “Defendants”) aver as follows:

Blountville, Tennessee 37617.

Center Building, 1 Government Center Place, Suite A, Abingdon, Virginia 24210.

Case 2:18-cv-00051-PLR-MCLC Document 1 Filed 04/03/18 Page 2 of 49 PageID #: 2

Abingdon, Virginia 24210

Abingdon, Virginia 24210

Highway 126, Suite 206, Blountville, Tennessee 37617.

S. Venable, 3411 Highway 126, Suite 206, Blountville, Tennessee 37617.

Case 2:18-cv-00051-PLR-MCLC Document 1 Filed 04/03/18 Page 3 of 49 PageID #: 3

Venable, 3411 Highway 126, Suite 206, Blountville, Tennessee 37617.

Highway 126, Suite 206, Blountville, Tennessee 37617.

Jack Young, 801 Anderson Street, Bristol, Tennessee 37620.

Case 2:18-cv-00051-PLR-MCLC Document 1 Filed 04/03/18 Page 4 of 49 PageID #: 4

paragraphs 1-15 herein, inclusive.

Tennessee common law. 28 U.S.C. § 1367.

County, Tennessee. Venue is proper. 28 U.S.C. § 1391(b)(2).

III. GENERAL ALLEGATIONS

paragraphs 1-19 herein, inclusive.

business specializing in automobile “bodywork” and repair.

employed by Defendants WCSD, SCSD, and BPD.

Abingdon, Virginia 24210 (Washington County).

Case 2:18-cv-00051-PLR-MCLC Document 1 Filed 04/03/18 Page 5 of 49 PageID #: 5

“1,” attached hereto and incorporated herein by reference].

Meade Tractor in two (2) places. [See id.].

Helton (“Mr. Helton”).

Virginia, County of Washington.

Case 2:18-cv-00051-PLR-MCLC Document 1 Filed 04/03/18 Page 6 of 49 PageID #: 6

37. Mr. Helton passed away shortly thereafter.

C. Defendant WCSD contacts Defendant BPD to assist with the investigation.

Tahoe.” [See id.].

vehicle similar thereto.

Old Thomas Bridge Road, Bluff City, Tennessee 37618.

46. In response, owner Darrell Proffitt (“Mr. Proffitt”) contacted BPD.

Case 2:18-cv-00051-PLR-MCLC Document 1 Filed 04/03/18 Page 7 of 49 PageID #: 7

they did not commit.

previously stolen a Chevrolet truck from Bristol Motor Speedway in 2008.

helicopter was in the normal flight zone.” [See id.].

pilot was eye-level with the tree line.

Case 2:18-cv-00051-PLR-MCLC Document 1 Filed 04/03/18 Page 8 of 49 PageID #: 8

one (1) year prior to April 27, 2017.

identified the Toyota Sequoia as missing its front end.

completely rectangular; and (ii) contains a side door.

forty-two (42) feet in length.

the surveillance footage(s).

Case 2:18-cv-00051-PLR-MCLC Document 1 Filed 04/03/18 Page 9 of 49 PageID #: 9

E. April 28, 2017: Defendants search the Craigs’ properties.

b. “Detective Eric Sargent…provided that…[Plaintiffs] had a vehicle matching the black

c. “Detective Eric Sargent…told…[Detective William Ford] and the Washington County

e. During the aerial surveillance, “Lieutenant Blevins and Detective Widener…observed

Case 2:18-cv-00051-PLR-MCLC Document 1 Filed 04/03/18 Page 10 of 49 PageID #: 10

i. Defendants identified a 2002 Chevrolet Trailblazer dissimilar in appearance to

i. Defendants identified a 2002 Toyota Sequoia. The Toyota Sequoia is

did not limit their search whatsoever.

a. 2012 Ranger z520 (Boat);

Case 2:18-cv-00051-PLR-MCLC Document 1 Filed 04/03/18 Page 11 of 49 PageID #: 11

d. A nearly new Wildwood Camper (and its Bill of Sale);

e. Four (4) box trailers stocked with various mechanic’s tools;

f. Three (3) portable Honda generators;

h. Various hand tools;

j. Five (5) golf carts (and their Bill(s) of Sale);