The Sanchez [in photo] complaint states:
On March 16, 2019, while in the City of Albany, New York, officers responded to a call of a noise complaint concerning a residence located at or around 523 First Street.
On said date, having committed no crime, Sanchez was lawfully in the City of Albany, New York, in the vicinity of 523 First Street, in a private home. With no warrant or lawful cause to do so, officers Seeber, Deer and an unknown number of Doe officers approached the residence and demanded that the door be opened.
The door was a wooden-framed door with glass panes which allowed the officers to see directly into the residence. An occupant of the residence, Lee Childs, spoke to officers Seeber, Deer and unknown Doe officers through the closed door of the residence, asked the officers for a warrant and was told there was none.
Although observing no unlawful activity, defendant Seeber kicked open the door to the residence and sprayed pepper spray into the residence.
Officers Deer, Seeber, and unknown Doe officers immediately proceeded to tackle, beat, punch and kick Mr. Childs. officers Deer, Seeber, and unknown Doe officers proceeded to place Mr. Childs under arrest and into custody, without legal cause.
Thereafter, all occupants of the residence were ordered by unknown defendant officers to vacate the premises. officers Deer, along with unknown defendant officers then present, escorted Mr. Childs into the street, some 50 feet away, to a location near a waiting patrol car.
Sanchez, having committed no illegal acts, obeyed the officers’ orders and exited the residence and walked into the street in front of the residence, where he was further ordered by an unknown defendant to “Go! Get the fuck out!”
Sanchez complied with Doe officers’ directives and continued to walk away, backwards, with his open hands raised above his head.
Defendant Deer, standing with several other defendant officers and Mr. Childs some 50 feet away by a patrol car, without reasonable suspicion of any criminal activity having been committed by Sanchez or any other good cause, suddenly turned and charged at Sanchez without warning or explanation.
While running towards Sanchez, defendant Deer began yelling at Sanchez: “Get the fuck out of here! Go! Now!” At all times relevant, defendant Deer possessed an expandable police baton.
While running toward Sanchez, defendant Deer armed himself by placing the expandable police baton into his right hand. While proceeding at a run directly toward Sanchez, defendant Deer punched
Sanchez in the neck with his open left hand, knocking Sanchez onto the ground onto his back, some 8 feet away from defendant Deer. Sanchez stood up, but before he had a chance to move further, defendant Deer charged at Sanchez again.
Defendant Deer, without pausing while charging and gripping his police baton as a cudgel, struck Sanchez repeatedly in the face and head. During the assault by defendant Deer with the police baton, Sanchez continued to walk backward until the repeated blows by Deer knocked Sanchez onto his back on the street again.
Defendant Deer then immediately leapt upon Sanchez while Sanchez lay in the street on his back. Defendant Deer resumed beating Sanchez in the face and head, using his collapsed baton as a cudgel.
Defendant Deer struck Sanchez repeatedly with the police baton.Defendant Deer then extended his expandable police baton and used the butt end of the baton to strike Sanchez repeatedly in the head, using a stabbing motion.
At all times, Sanchez did not resist the actions of defendant Deer in any way. officers Deer, Seeber and unknown Doe officers then placed handcuffs on Sanchez.
Defendant Deer thereafter forcibly pulled Sanchez into a standing position by yanking on Sanchez’s dreadlocks and handcuffed wrists.
The lawsuit says the psychopathic attack caused substantial pain and physical injury to Sanchez, including but not limited to bruising, contusions, lacerations, shoulder injury, wrist injury, nerve damage, concussion, post-concussive syndrome, chronic pain and psychological and emotional trauma.