Case 1:02-at-06000-UN Document 630 Filed 07/10/20 Page 1 of 58

UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF PENNSYLVANIA

---------------------------------------------------------------X
SHERELLE THOMAS, ADMINISTRATOR OF :
THE ESTATE OF TERELLE THOMAS :
:
and : CIVIL NO. ____________
:
T.T., a minor, individually, as child of decedent :
Terelle Thomas and as his sole survivor, : JURY TRIAL DEMANDED
:
Plaintiffs :
:
v. :
:
:
HARRISBURG CITY POLICE DEPARTMENT :
OFFICER DARIL FOOSE :
OFFICER SCOTT JOHNSEN :
OFFICER ADRIENNE SALAZAR :
OFFICER TRAVIS BANNING :
OFFICER BRIAN CARRIERE :
HARRISBURG CITY POLICE DEPT :
JOHN DOE POLICE OFFICERS 1 – 5 :
:
and :
:
DAUPHIN COUNTY :
DAUPHIN COUNTY ADULT PROBATION :
JOHN DOE SUPERVISORY OFFICERS 1-5 :
DAUPHIN COUNTY PRISON JOHN DOE :
PRISON OFFICIALS 1-5 :
PROBATION OFFICER DAN KINSINGER :
:
Defendants :
---------------------------------------------------------------X

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COMPLAINT

JURISDICTION AND VENUE

1. This action is brought pursuant to 42 U. S. C. §1983, the Fourth and Fourteenth

Amendments to the United States Constitution, the Constitution of the

Commonwealth of Pennsylvania, and Pennsylvania Law.

2. This Middle District of Pennsylvania Court has original jurisdiction over the

Plaintiffs’ federal law claims pursuant to 28 U. S. C. §§1331 and 1343, in that the

claims raise questions of federal law, and jurisdiction over the pendent State Law

claims pursuant to 28 U. S. C. §1367(a) where the state claims are so related to

federal claims in the action within this Court’s original jurisdiction that they form

part of the same case or controversy under Article III of the United States

Constitution.

3. Venue is proper in this Middle District of Pennsylvania pursuant to 28 U. S. C.

§1391(b)(1) where all the Defendants reside in the Commonwealth of

Pennsylvania and 28 U. S. C. §1391(b)(2) where a substantial part of the events

or omissions giving rise to the Plaintiffs’ federal claims occurred within the

geographical limits of this District.

4. This action is also brought under the laws of The Commonwealth of

Pennsylvania as Wrongful Death, Survival, and Negligence actions pursuant to

claims arising from Defendants’ deliberate and malicious indifference and

negligence in failing to train its various personnel in the recognition and treatment

of medical and mental health issues in arrestees and inmates and further in

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depriving decedent Terelle Thomas of his rights to both due process and equal

protection constitutionally guaranteed him, all of which eventually led to his death

at the young age of thirty-one (31) years old.

PARTIES

5. Plaintiff Sherelle Thomas, Administrator of the Estate of Terelle Thomas, as

Administrator of the said Estate of Terelle Thomas, brings this action pursuant to

42 Pa. C. S. A. §8302 (Survival).

6. Administrator Sherelle Thomas was appointed Administrator by the Dauphin

County Register of Wills on the 11th day of March 2020, under Administrative File

Number 2220-0262.

7. Plaintiff T.T., a minor, is the decedent’s natural daughter and only survivor, and

she resides in Harrisburg, Pennsylvania. Because the decedent was single and

had no other survivors, the Plaintiff brings this action on her own behalf as the

only person entitled to recover as the decedent’s survivor pursuant to 42 Pa. C.

S. A. §8301 (Wrongful Death).

8. Plaintiffs’ Decedent is Terelle Thomas, who died in Harrisburg, Pennsylvania on

December 17, 2019 as the direct and proximate result of the Defendants’

individual and joint actions and omissions, all of which occurred in the City of

Harrisburg, Dauphin County, Pennsylvania.

9. A Defendant is Dauphin County, PA (“Dauphin County”), a county, political

subdivision, and governmental entity in the Commonwealth of Pennsylvania,

organized and existing under the laws of the Commonwealth of Pennsylvania,

with a principal place of business at 101 Market Street, Harrisburg, PA 17101. At

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all times relevant hereto, Defendant Dauphin County was responsible for

Dauphin County Adult Probation and Dauphin County Judicial Center. Dauphin

County Judicial Center houses the Central Booking Facility (“Booking Center”) for

all police departments in Dauphin County. Defendant Dauphin County employed

and was responsible for training and supervising the probation officers and prison

officials who daily engaged probationers and persons taken into custody, and

who participated in and were the cause of decedent Terelle Thomas’s death.

10. One or more Defendants are Dauphin County Adult Probation John Doe

Supervisory Officers (“DCAP John Doe(s)”) 1 - 5, having a place of business at

917 Gibson Blvd. in Steelton, PA 17113. At all times relevant hereto, DCAP

John Does participated in and was/were the cause of decedent Terelle Thomas’s

death.

11. One or more Defendants are Dauphin County Prison John Doe Prison Officials

(“DCP John Doe(s)”) 1 - 5, having a place of business at 451 Mall Blvd. in

Harrisburg, PA 17111. At all times relevant hereto, DCP John Does participated

in and was/were the cause of decedent Terelle Thomas’s death.

12. A Defendant is Dan Kinsinger, an Adult Probation Officer with Dauphin County

Adult Probation, having a main place of business at 917 Gibson Blvd, Steelton,

PA, 17113. At all times relevant hereto, said Probation Officer participated in and

was the cause of decedent Terelle Thomas’s death.

13. A Defendant is the Harrisburg City Police Department (“Harrisburg Police”),

having a main place of business at 123 Walnut Street, Harrisburg, PA, 17110. At

all times relevant hereto, Defendant Harrisburg Police employed, trained and

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supervised the several police officers that participated in and were the cause of

decedent Terelle Thomas’s death. Defendant Harrisburg Police failed to

adequately train its police personnel in recognizing and identifying arrestees with

serious mental health issues requiring diversion to a hospital or mental health

facility.

14. A Defendant is Daril Foose, a Police Officer with Harrisburg Police, having a

main place of business at 123 Walnut Street, Harrisburg, PA, 17110. At all times

relevant hereto, said Police Officer participated in and was the cause of decedent

Terelle Thomas’s death.

15. A Defendant is Scott Johnsen, a supervisory Police Officer with Harrisburg

Police, having a main place of business at 123 Walnut Street, Harrisburg, PA,

17110. At all times relevant hereto, said Police Officer participated in and was

the cause of decedent Terelle Thomas’s death.

16. A Defendant is Adrienne Salazar, a Police Officer with Harrisburg Police, having

a main place of business at 123 Walnut Street, Harrisburg, PA, 17110. At all

times relevant hereto, said Police Officer participated in and was the cause of

decedent Terelle Thomas’s death.

17. A Defendant is Travis Banning, a Police Officer with Harrisburg Police, having a

main place of business at 123 Walnut Street, Harrisburg, PA, 17110. At all times

relevant hereto, said Police Officer participated in and was the cause of decedent

Terelle Thomas’s death

18. A Defendant is Brian Carriere, a Police Officer with Harrisburg Police, having a

main place of business at 123 Walnut Street, Harrisburg, PA, 17110. At all times

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relevant hereto, said Police Officer participated in and was the cause of decedent

Terelle Thomas’s death.

19. One or more Defendants are Harrisburg Police Department John Doe Police

Officers (Harrisburg John Doe(s)) 1 - 5, having a main place of business at 123

Walnut Street, Harrisburg, PA, 17110. At all times relevant hereto, said

Harrisburg John Does participated in and were the cause of decedent Terelle

Thomas’s death.

20. The complained-of acts and failures to act by Harrisburg Police supervisory and

non-supervisory Defendants herein were objectively unreasonable and were

malicious and sadistic and intended to cause harm.

21. The acts and failures to act by DCAP John Does and non-supervisory

Defendants herein were objectively unreasonable and were malicious and

sadistic and intended to cause harm.

22. At all times relevant hereto, the within described corporate, departmental and

individual Defendants were acting under color of law, and the individual

Defendants were acting in the course and scope of their duties with their

respective corporate or departmental employers, to wit, the Harrisburg Police

Department and Dauphin County, and in furtherance of those corporate or

departmental employers’ business objectives and purposes.

23. At all times relevant hereto, the within described corporate and/or departmental

employers, to wit, Harrisburg Police and Dauphin County, were liable for the acts

and failures to act of the individual Defendants, both known and unknown to

Plaintiffs, under theories of agency, master-servant, respondeat superior and/or

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control or right of control.

24. Plaintiffs bring this action in part under and by virtue of the Pennsylvania

Wrongful Death Act, 42 Pa. C.S.A. §8301, and the Survival Act, 42 Pa. C.S.A.

§8302, to recover damages legally appropriate thereunder, including, but not

limited to damages for all hospital, medical, funeral, burial and estate

administration expenses incurred, loss of support and contribution which the

family would have received from the decedent from the time of his death for the

duration of his work life expectancy; compensated for the pecuniary value of the

services, society and comfort he would have given to his daughter had he lived;

and compensated for the loss of the services the decedent would have

contributed to his daughter, and also for the net amount of money the decedent

would have earned from the date of his death and would have earned between

that date and the end of his life work expectancy; compensation for the mental

and physical pain and suffering and inconvenience the decedent endured from

the moment of his injury to the moment of his death.

25. Plaintiffs’ decedent did not bring an action during his lifetime for actual injuries or

damages sought here.

26. At all times relevant hereto, Defendants individually and jointly, and at each

successive stage from his initial arrest to his incarceration at the Dauphin County

Booking Center, were under a duty and obligation to recognize and identify that

decedent Terelle Thomas had serious medical health problems and to divert him

from a prison environment to a hospital so that he might receive treatment

instead of punishment.

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27. At all times relevant hereto, Defendants individually and jointly breached that

duty by failing to recognize and identify that decedent Terelle Thomas had

serious medical problems and failing to divert him from a prison environment to a

hospital at which he would have received treatment instead of incarceration.

28. As a direct and proximate result of that breach, decedent Terelle Thomas died on

December 17, 2019 at the age of thirty-one (31) years old.

29. At all times relevant hereto, Defendants also breached that duty by treating

decedent Terelle Thomas unreasonably and inhumanely and denying him

emergency medical treatment as described herein, and by further failing to

properly document or record their contact with decedent Terelle Thomas.

30. As a direct and proximate result of said unreasonable and inhumane treatment

and denial of emergency medical treatment as described herein to which he was

subjected at the hands of the Defendants, individually and/or jointly, Terelle

Thomas died on December 17, 2019 at the age of thirty-one (31) years old.

31. All Defendants, with the exception of Harrisburg Police Department and Dauphin

County, are being sued in their individual capacity.

OPERATIVE FACTS

32. On or about December 14, 2019, at approximately 6:15 PM, Defendant Foose

observed Decedent Thomas and another male walk from the area of a bar and

enter a vehicle as passengers.

33. The two men were walking, laughing, and conversing with each other when

observed by Defendant Foose.

34. Shortly thereafter, Defendant Foose began to follow the vehicle.

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35. Defendant Foose initiated a traffic stop at the intersection of South 17th Street

and Holly Street.

36. Upon initiating contact with Decedent Thomas, Defendant Foose observed that

Decedent Thomas had a large amount of something inside of his mouth.

37. Defendant Foose notified her partner Defendant Kinsinger that she believed

Decedent Thomas was concealing something in his mouth.

38. According to her report, Defendant Foose made observations that led her to

believe that Decedent Thomas had ingested a large amount of cocaine. Those

observations included Decedent Thomas’ lips being pasty white; Decedent

Thomas’ tongue and spit were white; a large amount of paste inside of Decedent

Thomas’ mouth; and Decedent Thomas’ face was covered with a white powdery

substance. See Exhibit A, page 6.

39. At approximately 6:22 p.m., Defendant Johnsen arrived at the location of the

traffic stop.

40. Upon his arrival, Defendant Johnsen was informed by Defendant Kinsinger that

Decedent Thomas had ingested crack cocaine. See Exhibit A, page 8.

41. At approximately 6:22 p.m., Defendant Salazar arrived at the location of the

traffic stop.

42. Upon her arrival, Defendant Salazar was informed by Defendant Foose that

Decedent Thomas had ingested crack cocaine.

43. Defendant Salazar observed a white powder substance covering Decedent

Thomas’ lips. See Exhibit A, page 9.

44. At approximately 6:22 p.m., Defendant Banning arrived at the location of the

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traffic stop.

45. Defendant Banning observed a large amount of white residue around and on

Decedent Thomas’ lips.

46. Defendant Foose advised Defendant Banning that she believed Decedent

Thomas had eaten crack cocaine. See Exhibit A, page 10.

47. At approximately 6:47 p.m., Defendant Carriere transported Decedent Thomas

from the area South 17th Street and Holly Street to the Dauphin County Booking

Center.

48. Prior to transporting Decedent Thomas, Defendant Carriere was informed by

Defendant Foose that she suspected Decedent Thomas had swallowed crack

cocaine. See Exhibit A, page 11.

49. During the time he was being transported by Defendant Carriere, Decedent

Thomas’ face had white residue on it.

50. Upon arrival at the Dauphin County Booking Center, Defendant Carriere

informed DCP John Doe(s) and Dauphin County Prison medical staff that

Decedent Thomas had swallowed crack cocaine. See Exhibit A, page 11.

51. Upon his arrival at Dauphin County Booking Center, DCP John Doe(s) and

medical staff noted that Decedent Thomas had white powder on his lips.

52. Despite the suspicions of numerous law enforcement personnel that Decedent

Thomas had swallowed a dangerous drug, Decedent Thomas was never

transferred from the Dauphin County Booking Center to the nearest hospital for

emergency medical treatment.

53. At that time, defendant police officers, Defendant Kinsinger and DCP John Does,

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should have recognized that Decedent Thomas was in the midst of a health crisis

and needed emergency medical treatment, and should therefore have taken him

to a hospital for observation and treatment.

54. Instead of taking Decedent Thomas to a hospital or other medical facility, and

because they had been poorly trained to recognize dangerous health issues, all

of the individual police and probation officers involved in the arrest of Decedent

Thomas ignored police and county protocol that called for Decedent Thomas to

be taken to the hospital for emergency medical care and instead Defendant

Carriere took Decedent Thomas to the Dauphin County Booking Center at

Dauphin County Jail.

55. In failing to train its police, probation officers, and prison officials in detecting and

recognizing medical emergencies among the people its officers arrested,

Defendants Harrisburg Police and Dauphin County exposed its deliberate

indifference to the medical needs of people its officers might be called upon to

arrest.

56. Defendants Harrisburg Police, Dauphin County and their officers were under a

duty to obtain for Decedent Thomas and other arrestees medical attention when

it appeared they needed it, but said Defendants made no effort to train their

officers to detect or recognize medical emergencies in the people their officers

arrested or to provide or obtain any medical attention for Decedent Thomas.

57. At approximately 7:13 p.m. Decedent Thomas was placed in a cell at Dauphin

County Booking Center.

58. At approximately 8:04 p.m. Decedent Thomas is seen on surveillance video

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falling backwards on to the floor and hitting his head. Decedent Thomas then

suffered cardiac arrest and “coded” on the floor of the Booking Center cell.

59. Shortly thereafter, DCP John Doe(s) and Dauphin County Prison medical staff

arrived to find Decedent Thomas with white powder still on his lips. Decedent

Thomas was unresponsive, pulseless and apneic.

60. Decedent Thomas falling backwards on to the floor during cardiac arrest was

recorded on a Booking Center camera.

61. At approximately 8:24 p.m. Decedent Thomas was transported by emergency

medical technicians to UPMC Pinnacle Harrisburg Hospital for medical treatment.

62. Decedent Thomas remained hospitalized at UPMC Pinnacle Harrisburg Hospital

until December 17, 2019.

63. At approximately 5:05 p.m. on December 17, 2019, Decedent Thomas died, and

after an autopsy was performed, the cause of death was determined to be

cocaine and fentanyl toxicity.

64. On December 14, 2019, after denying Decedent Thomas the urgent medical care

he needed, Defendant Foose prepared and signed an Affidavit of Probable

Cause alleging that she observed Decedent Thomas consume crack cocaine and

criminally charged him with Tampering with Evidence. See Exhibit B, page 4.

65. On December 27, 2019, Defendant Harrisburg Police, in an attempt to obtain

negative information regarding Decedent Thomas, directed a police Sargent to

the home of Decedent Thomas’ sister Sherelle Thomas where she was coerced

to sign a consent form to search the contents of Decedent Thomas’ cellular

phone.

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66. In an article published by Penn Live on January 17, 2020, Harrisburg Mayor Eric

Papenfuse admitted that it is Harrisburg Police Department policy to take a

person to the hospital rather than the booking center if they have consumed

illegal narcotics in a way that could jeopardize their health and welfare. Mayor

Papenfuse is quoted as saying Decedent Thomas “should have received urgent

medical care, and I deeply regret that he did not.” See Exhibit C.

FEDERAL CLAIMS

COUNT I: Sherelle Thomas, Administrator of the Estate of Terelle Thomas,

Deceased -v- Defendants Officer Daril Foose, Probation Officer Dan Kinsinger,
Officer Scott Johnsen, Officer Adrienne Salazar, Officer Travis Banning, Officer
Brian Carriere, Harrisburg Police John Does and DCP John Does.
(Deprivation of Rights Guaranteed Under the 4th and 14th Amendments to the U. S.
Constitution, addressable via 42 U. S. C. §1983; Conspiracy)

67. The Allegations contained in all preceding Paragraphs are here incorporated and

included by reference as if fully set forth here.

68. At all times relevant hereto, Defendants Officer Daril Foose, Probation Officer

Dan Kinsinger, Officer Scott Johnsen, Officer Adrian Salazar, Officer Travis

Banning and Officer Brian Carriere (collectively “Harrisburg Police Officers”),

Harrisburg John Doe Police Officers 1 – 5 (collectively “Harrisburg John Does”),

and DCP John Doe Prison Officials 1-5 (collectively “DCP John Does”)

individually and/or jointly were, at all times relevant hereto, acting under color of

law and were aware that Decedent Thomas had a serious medical need,

specifically that Decedent Thomas had swallowed dangerous narcotics.

69. Despite knowing of the decedent’s serious medical needs, the Harrisburg Police

Officers, Harrisburg John Does, and DCP John Does were each deliberately and

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maliciously indifferent to those medical needs of Decedent Thomas and agreed

and conspired among themselves to deny him adequate care, and then to cover

and conceal their efforts.

70. In furtherance of their agreement and conspiracy, Defendants Harrisburg Police

Officers, Harrisburg John Does, and DCP John Does failed to obtain for him

adequate medical care.

71. Defendants Harrisburg Police Officers, Harrisburg John Does, and DCP John

Does, in so agreeing and conspiring to deny Decedent Thomas adequate

medical care, despite knowing of his serious medical needs, and then actually

denying him adequate medical care, were so outrageous and malicious and

sadistic that it would utterly shock the conscience of a reasonable individual.

72. As a direct and proximate result of said Defendants’ individual and/or joint

deliberate and malicious indifference to the serious medical needs of Decedent

Thomas, and the conspiracy and agreement among them, Decedent Thomas

was held in the Booking Center, instead of being sent to a hospital, denied

proper care and eventually died.

73. Defendants Harrisburg Police Officers, Harrisburg John Does, and DCP John

Does acts and failures to act, under color of law, violated Decedent Thomas’s

rights under the Fourth and Fourteenth Amendments to the United States

Constitution and the laws of the United States of America and the

Commonwealth of Pennsylvania and are redressed here pursuant to 42 U. S. C.

§1983.

WHEREFORE, Plaintiff demands judgment in its favor and against Defendants

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Harrisburg Police Officers, Harrisburg John Does, and DCP John Does, individually

and/or jointly, and requests all appropriate relief in an amount in excess of FIVE

MILLION ($5,000,000.00) DOLLARS, including, but not limited to, compensatory

damages, court costs, punitive damages, attorneys fees and all other relief as the Court

deems appropriate.

COUNT II: Sherelle Thomas, Administrator of the Estate of Terelle Thomas,

Deceased -v- Defendants Officer Daril Foose, Probation Officer Dan Kinsinger,
Officer Scott Johnsen, Officer Adrienne Salazar, Officer Travis Banning, Officer
Brian Carriere, Harrisburg Police John Does, and DCP John Does.
(Deprivation of Rights Guaranteed Under the 4th and 14th Amendments to the U. S.
Constitution, addressable via 42 U. S. C. §1983; Failure to Intervene)

74. The Allegations contained in all preceding Paragraphs are here incorporated and

included by reference as if fully set forth here.

75. As indicated above, Harrisburg Police Officers, Harrisburg John Does, and DCP

John Does individually and/or jointly, denied the decedent emergency medical

care.

76. As the denial of medical treatment continued, none of the individuals present

intervened to stop the denial of medical care or otherwise bring it to a halt.

77. This failure to intervene in the denial of emergency medical treatment was so

malicious and objectively unreasonable that it would shock the conscience of a

reasonable person.

78. Defendants’ failure to intervene exceeded the normal standards of decent

conduct, and was willful, malicious, oppressive, outrageous, and unjustifiable.

Therefore, punitive damages are necessary and appropriate.

79. As a direct and proximate result of Defendants’ failure to intervene as more

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particularly described above, Decedent Thomas’s rights protected under the

Fourth and Fourteenth Amendments were violated, and the decedent suffered

injury as a result.

80. Defendants subjected Decedent Thomas to these deprivations of rights

unreasonably, intentionally, wantonly, outrageously, and with conscious and

reckless disregard for whether decedent’s rights would be violated by their

actions.

81. As a direct and proximate result of Defendants’ failure to intervene, Decedent

Thomas suffered deprivations of his rights, physical injuries, pain and suffering,

emotional distress, and mental anguish, all to decedent’s great detriment and

loss.

WHEREFORE, Plaintiff demands judgment in its favor and against Defendants

Harrisburg Police Officers, Harrisburg John Does, and DCP John Does, individually

and/or jointly, and requests all appropriate relief in an amount in excess of FIVE

MILLION ($5,000,000.00) DOLLARS, including, but not limited to, compensatory

damages, court costs, punitive damages, attorneys fees and all other relief as the Court

deems appropriate.

COUNT III: Sherelle Thomas, Administrator of the Estate of Terelle Thomas,

Deceased -v- Dauphin County, DCAP John Doe Supervisory Officers, DCP John
Doe Prison Officials
(Deprivation of Rights Guaranteed Under the 4th and 14th Amendments to the U. S.
Constitution, addressable via 42 U. S. C. §1983; Failure to Train, Supervise,
Control or Discipline)

82. The Allegations contained in all preceding Paragraphs are here incorporated and

included by reference as if fully set forth here.

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83. Dauphin County and DCAP John Doe Supervisory Officers, have exclusive

management and control of the policies and practices of Dauphin County Adult

Probation regarding the method and manner of recognizing individuals in custody

whom require emergency medical care and are responsible for insuring that

members of the Dauphin County Adult Probation otherwise conduct themselves

in a lawful manner in undertaking and performing their duties. Defendants

Dauphin County and DCAP John Does are vested with the authority to establish

policies or customs, practices and usages of Dauphin County Adult Probation

through training, supervision, discipline and otherwise controlling the officers of

Dauphin County Adult Probation.

84. Dauphin County and DCP John Doe Prison Officials, have exclusive

management and control of the policies and practices of Dauphin County

Booking Center regarding the method and manner of recognizing individuals in

custody whom require emergency medical care and are responsible for insuring

that corrections officers working in the Booking Center otherwise conduct

themselves in a lawful manner in undertaking and performing their duties.

Defendants Dauphin County and DCP John Does are vested with the authority to

establish policies or customs, practices and usages of the Booking Center

through training, supervision, discipline and otherwise controlling the officers of

Booking Center.

85. Defendants Dauphin County, DCAP John Does, and DCP John Does violated

the Decedent’s rights by the custom and practice of failing to train, instruct,

supervise, control and discipline the probation officers of Dauphin County Adult

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Probation and the corrections officers of Dauphin County Prison in recognizing

individuals in custody whom require emergency medical care. Said customs,

practice and usage caused the deprivation of decedent’s rights secured under

the Fourth and Fourteenth Amendments to the United States Constitution, other

laws of the United States, and the laws of the Commonwealth of Pennsylvania.

86. There exists within Dauphin County Adult Probation and the Dauphin County

Booking Center policies or customs, practices and usages that are so pervasive

that they constitute the policies of the Probation Department and Booking Center,

such that they are and were the moving force behind and thereby caused the

constitutional deprivations of the Decedent as have been set forth herein.

87. The polices, customs, practices and usages that exist include the following:

• The officers of DCAP conduct traffic stops without regard for the lack of

reasonable suspicion or probable cause, or without regard for the legality

of the stop;

• The officers of DCAP and the Dauphin County Booking Center fail to

render emergency medical care to persons in custody without regard for

whether the individual faces imminent death;

• The officers of DCAP engage in conduct that violates the constitutional

rights of citizens with whom they come in contact, including, but not limited

to arresting, and detaining people in violation of the constitution and laws,

both by the acts and means by which they are accomplished;

• The officers of DCAP and the Dauphin County Booking Center conspire

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with Harrisburg police officers to “cover” for and protect one another from

criminal and/or civil sanctions that might arise from the violation of the

constitutional rights of a citizen.

88. As a result of Dauphin County, DCAP John Does, and DCP John Does’ failure to

train, discipline or supervise their officers, they deprived Terelle Thomas of his

rights to be from the denial of medical care and unlawful and unreasonable

seizure in violation of the Fourth and Fourteenth Amendments to the Constitution

of the United States and remediable under 42 U.S.C. §1983.

WHEREFORE, Plaintiff demands judgment in its favor and against Defendants

Dauphin County, DCAP John Does, and DCP John Does individually and/or jointly, and

requests all appropriate relief in an amount in excess of FIVE MILLION ($5,000,000.00)

DOLLARS, including, but not limited to, compensatory damages, court costs, punitive

damages, attorneys fees and all other relief as the Court deems appropriate.

COUNT IV: Sherelle Thomas, Administrator of the Estate of Terelle Thomas,

Deceased -v- Harrisburg City Police Department, Harrisburg Police John Does
(Deprivation of Rights Guaranteed Under the 4th and 14th Amendments to the U. S.
Constitution, addressable via 42 U. S. C. §1983; Failure to Train, Supervise,
Control or Discipline)

89. The allegations contained in all preceding Paragraphs are here incorporated and

included by reference as if fully set forth here.

90. Harrisburg Police and Harrisburg Police John Does, have exclusive management

and control of the policies and practices of the Harrisburg Police Department

regarding the method and manner of recognizing individuals in custody whom

require emergency medical care and are responsible for insuring that members

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of the Harrisburg Police Department otherwise conduct themselves in a lawful

manner in undertaking and performing their duties. Defendants Harrisburg Police

and Harrisburg Police John Does are vested with the authority to establish

policies or customs, practices and usages of the Harrisburg Police Department

through training, supervision, discipline and otherwise controlling the officers of

Harrisburg Police Department.

91. Defendants Harrisburg Police and Harrisburg Police John Does violated the

Decedent’s rights by the custom and practice of failing to train, instruct,

supervise, control and discipline the officers of the Harrisburg Police Department

in recognizing individuals in custody whom require emergency medical care. Said

customs, practice and usage caused the deprivation of decedent’s rights secured

under the Fourth and Fourteenth Amendments to the United States Constitution,

other laws of the United States, and the laws of the Commonwealth of

Pennsylvania.

92. There exists within Harrisburg Police Department policies or customs, practices

and usages that are so pervasive that they constitute the policies of the

Harrisburg Police Department, such that they are and were the moving force

behind and thereby caused the constitutional deprivations of the Decedent as

have been set forth herein.

93. The polices, customs, practices and usages that exist include the following:

• The officers of the Harrisburg Police Department conduct traffic stops

without regard for the lack of reasonable suspicion or probable cause, or

without regard for the legality of the stop;

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• The officers of the Harrisburg Police Department fail to render emergency

medical care to persons in custody without regard for whether the

individual faces imminent death;

• The officers of the Harrisburg Police Department engage in conduct that

violates the constitutional rights of citizens with whom they come in

contact, including, but not limited to arresting, and detaining people in

violation of the constitution and laws, both by the acts and means by

which they are accomplished;

• The officers of the Harrisburg Police Department conspire with officers of

DCAP and the Dauphin County Booking Center to “cover” for and protect

one another from criminal and/or civil sanctions that might arise from the

violation of the constitutional rights of a citizen.

94. As a result of Harrisburg Police and Harrisburg Police John Does’ failure to train,

discipline or supervise their officers, they deprived Terelle Thomas of his rights to

be from the denial of medical care and unlawful and unreasonable seizure in

violation of the Fourth and Fourteenth Amendments to the Constitution of the

United States and remediable under 42 U.S.C. §1983.

WHEREFORE, Plaintiff demands judgment in its favor and against Defendants

Harrisburg Police and Harrisburg Police John Does, individually and/or jointly, and

requests all appropriate relief in an amount in excess of FIVE MILLION ($5,000,000.00)

DOLLARS, including, but not limited to, compensatory damages, court costs, punitive

damages, attorneys fees and all other relief as the Court deems appropriate.

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 Case 1:02-at-06000-UN Document 630 Filed 07/10/20 Page 22 of 58

COUNT V: Sherelle Thomas, Administrator of the Estate of Terelle Thomas,

Deceased -v- All Defendants
(Failure to Render Medical Care)

95. The Allegations contained in all preceding Paragraphs are here incorporated and

included by reference as if fully set forth here.

96. At all times mentioned herein, the failure to render medical care to Terelle

Thomas by Defendants Daril Foose, Dan Kinsinger, Scott Johnsen, Adrienne

Salazar, Travis Banning, Brian Carriere, and Harrisburg Police John Does was a

violation of Decedent’s constitutional rights in that it amounted to a deprivation of

health life, and property in violation of the Fourth Amendment and the Due

Process Clause of the Fourteenth Amendment to the Constitution of the United

States, in each and all of the following ways:

• By performing their duties as police officers and first responders

with deliberate indifference for the serious medical condition of

Terelle Thomas;

• By failing to take appropriate steps to protect Terelle Thomas from

a known danger when the defendants were aware of a substantial

risk of serious injury from Terelle Thomas’ symptoms.

• By failing to make medical observations (check his breathing or

pulse) or perform treatments (first aid or CPR) when Terelle

Thomas’ condition was so obvious that even a layperson would

easily recognize the necessity for medical attention.

• By failing to take the appropriate steps when the failure to treat

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 Case 1:02-at-06000-UN Document 630 Filed 07/10/20 Page 23 of 58

Terelle Thomas’ medical condition could and did result in further

significant injury and the unnecessary and wanton infliction of

death;

• By failing to take the appropriate steps when the existence of

Terelle Thomas’ medical condition was such that a reasonable

police officer would find it important and worthy of comment or

treatment;

• By failing to take the appropriate steps to protect Terelle Thomas

when he was in danger;

• By refusing to diagnose and treat Terelle Thomas’ serious medical

condition while he was in custody, causing him to suffer and sustain

permanent injury and death;

• By failing and refusing to call for emergency medical help for

symptoms that defendants could not or would not treat;

• By deliberately denying decedent medical attention and causing

decedent’s death;

• By failing to follow the policies and procedures of Harrisburg Police

Department and/or Dauphin County Adult Probation ;

97. At all times mentioned herein Defendants Daril Foose, Dan Kinsinger, Scott

Johnsen, Adrienne Salazar, Travis Banning, Brian Carriere, Harrisburg Police

John Does, Dauphin County, DCAP John Does, and DCP John Does individually

and/or jointly were deliberately indifferent to the serious medical condition of

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 Case 1:02-at-06000-UN Document 630 Filed 07/10/20 Page 24 of 58

Decedent Terelle Thomas, notwithstanding notice and actual knowledge thereof.

WHEREFORE, Plaintiff demands judgment in its favor and against Defendants

Harrisburg Police Officers, Harrisburg John Does, Dauphin County, DCAP John Does,

and DCP John Does, individually and/or jointly, and requests all appropriate relief, in an

amount in excess of FIVE MILLION ($5,000,000.00) DOLLARS, including, but not

limited to, compensatory damages, court costs, punitive damages, attorneys fees and

all other relief as the Court deems appropriate.

STATE LAW CLAIMS

COUNT VI: Sherelle Thomas, Administrator of the Estate of Terelle Thomas,

Deceased -v- All Defendants
(Negligence)

98. The Allegations contained in all preceding Paragraphs are here incorporated and

included by reference as if fully set forth here.

99. At all times relevant hereto, all Defendants individually and/or jointly, were under

a duty and obligation to recognize and identify that Decedent Thomas had

serious medical problems and then to divert him from a prison environment to a

hospital so that he might receive treatment instead of punishment.

100. At all times relevant hereto, said Defendants individually and jointly breached that

duty by failing to act on the knowledge that Decedent Thomas faced serious

medical issues and failing to divert him from a prison environment to a hospital at

which he would have received treatment instead of incarceration. Defendants

acted unlawfully, wantonly, unreasonably, maliciously, unnecessarily and/or with

deliberate and reckless indifference to the health and welfare of the Decedent.

101. As a direct and proximate result of that breach, decedent Terelle Thomas

24
 Case 1:02-at-06000-UN Document 630 Filed 07/10/20 Page 25 of 58

suffered deprivations of his rights, physical injuries, pain and suffering, emotional

distress, mental anguish, and eventually death on December 17, 2019 at the age

of thirty-one (31) years old.

WHEREFORE, Plaintiff demands judgment in its favor and against Defendants,

individually and/or jointly, and requests all appropriate relief, in an amount in excess of

FIVE MILLION ($5,000,000.00) DOLLARS, including, but not limited to, compensatory

damages, court costs, punitive damages, attorneys fees and all other relief as the Court

deems appropriate.

COUNT VII: Plaintiff T.T., a minor -v- All Defendants

(Wrongful Death)

102. The Allegations contained in all preceding Paragraphs are here incorporated and

included by reference as if fully set forth here.

103. Decedent’s sole survivor is his daughter, T.T., a minor, who is entitled to recover

damages for his death, and on whose behalf this action is brought pursuant to

the Pennsylvania Wrongful Death Act 42 Pa.C.S.A. Section 8301 et seq.

104. Decedent’s death was caused by the intentional, malicious, and/or grossly

negligent conduct of Defendants, individually and/or jointly.

105. As described above, Defendants unlawfully, wantonly, unreasonably, maliciously,

unnecessarily and/or with deliberate and reckless indifference to the health and

welfare of the Decedent and the Plaintiffs, caused the death of decedent, Terelle

Thomas, by denying him emergency medical care.

106. As a direct and proximate result of Defendants’ individual and joint actions,

decedent Terelle Thomas was unnecessarily caused extreme physical pain,

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 Case 1:02-at-06000-UN Document 630 Filed 07/10/20 Page 26 of 58

mental anguish and suffering, and death, and was deprived of the enjoyment and

pleasure of life.

107. As a further direct and proximate result of Defendants’ actions, decedent’s

survivor has suffered serious emotional pain and economic loss due to the

wrongful death of her father, Terelle Thomas.

108. As a direct and proximate result of defendant’s actions, decedent’s daughter is

entitled to recover damages for:

(a) the loss of the value of decedent’s services;

(b) loss of decedent’s comfort and society;

(c) contributions decedent would have made to the plaintiffs from his

labor;

(d) all damages recoverable under the statute.

WHEREFORE, Plaintiff T.T., a minor, demands judgment in her favor and

against Defendants, individually and/or jointly, and request all appropriate relief,

including, in an amount in excess of FIVE MILLION ($5,000,000.00) DOLLARS,

including but not limited to, compensatory damages, court costs, attorneys fees and all

other relief as the Court deems appropriate.

COUNT VIII: Estate of Terelle Thomas -v- All Defendants

(Survival Action)

109. The Allegations contained in all preceding Paragraphs are here incorporated and

included by reference as if fully set forth here.

110. As a direct and proximate result of Defendants’ actions as described herein,

Terelle Thomas suffered grievous bodily injury, and mental and physical pain and

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 Case 1:02-at-06000-UN Document 630 Filed 07/10/20 Page 27 of 58

suffering.

111. From the time of his arrest until the time of his death, and throughout his

detention, Decedent Thomas was conscious and aware of the beatings and other

harmful acts to which he was subjected by Defendants, individually and/or jointly,

and felt extreme pain and suffering as a result thereof.

112. On behalf of the Estate of Terelle Thomas, Sherelle Thomas, Administrator of the

Decedent’s Estate, brings this action under the Pennsylvania Survival Act, 42 Pa.

C.S.A. Section 8302, and claims for Terelle Thomas’s Estate compensation for

all damages suffered by Terelle Thomas and recoverable under the statute by

reason of the grievous bodily injury, mental and physical pain and suffering

caused him by the Defendants as described above.

WHEREFORE, the Estate of Terelle Thomas demands judgment in its favor and

against Defendants, individually and/or jointly, and requests all appropriate relief, in an

amount in excess of FIVE MILLION ($5,000,000.00) DOLLARS, including, but not

limited to, compensatory damages, court costs, attorneys fees and all other relief as the

Court deems appropriate.

Respectfully submitted,

MINCEY FITZPATRICK ROSS, LLC

/s/ Kevin V. Mincey

Kevin V. Mincey

/s/ Riley H. Ross III

Riley H. Ross III
Date: July 10, 2020 Attorneys for Plaintiffs

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Case 1:02-at-06000-UN Document 630 Filed 07/10/20 Page 28 of 58

EXHIBIT A
 Ci of Ha
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123
Waln S
Ha i b g PA, 17101
717-255-3131
Ca e N mbe : 19-1214-033-002 ORI #: PA0220200

Loca ion of Occ ence A in e ec ion of S 15TH ST / SWATARA ST (DJ: 12-2-05; Zone: 513)

Da / Da e / Time ( Re o ed ) Da / Da e ( of Occ ence )

Sa da , Decembe 14, 2019 18:22 Sa da , Decembe 14, 2019 18:22 To: Sa da , Decembe 14, 2019 19:09
Re o ing Office : FOOSE, DARIL Follo ?: Co ie To:

Ca e S a : OPEN Ye Folde
No De ec i e

Highe Ranked C ime: 780-113-A30 CSDDCA-MAN/DEL/POSS W INT TO DEL SUB, BEING UNREG J . P ob.
D. A.

O he :

Vic im

O gani a ion Name

1
COMMONWEALTH OF PA
Vic im of : 1: 780-113-A30 CSDDCA-MAN/DEL/POSS W INT TO DEL SUB, BEING UNREG
2: 780-113-A31II CSDDCA-POSS SM AMT MARIJUANA FOR DIST/NOT SALE
3: 780-113-A32 CSDDCA-USE/POSS W INT USE DRUG PARAPHERNALIA
4: 4910-1 TAMPER WITH OR FABRICATE PHYS EVID-ALTER/DESTROY

Di e

Name - ( La , Fi , Middle )
1
HENDERSON, THERESEA N

Men ioned

Name - ( La , Fi , Middle )
1
THOMAS, TONYKA

Name - ( La , Fi , Middle )
2
THOMAS, MARY

Pa enge

Name - ( La , Fi , Middle )
1
WILKERSON, JAY

Page 1 of 13
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Ca e N mbe : 19-1214-033-002 ORI #: PA0220200

1 A e ee

1 Name - ( La , Fi , Middle ) Occ a ion: Social Sec i # Ci i en hi

THOMAS, TERELLE L 198-68-3431
Add e 323 S 18TH ST Phone( ) Di e Licen e Info. ( S a e / # / Cla )
HARRISBURG, PA 17104 PA / 28792614

Hai : BROWN Race: BLACK OR AFRICAN AMERICAN Heigh : 6-02

Age: 31 D. O. B.: 1/12/1988 E e : BROWN Se : F Weigh : 230

A e ed Fo : 1: 780-113-A30 CSDDCA-MAN/DEL/POSS W INT TO DEL SUB, BEING UNREG Da e A e ed 12/14/2019

2: 780-113-A31II CSDDCA-POSS SM AMT MARIJUANA FOR DIST/NOT SALE A e ed B : 1: DARIL FOOSE [033]
3: 780-113-A32 CSDDCA-USE/POSS W INT USE DRUG PARAPHERNALIA
4: 4910-1 TAMPER WITH OR FABRICATE PHYS EVID-ALTER/DESTROY

Page 2 of 13
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717-255-3131
Ca e N mbe : 19-1214-033-002 ORI #: PA0220200

Po e

Role: EVIDENCE
Ca ego : CREDIT CARDS AND CHECKS
T e:
#' A icle B and / Model Se ial #/NIC # Colo Q an i Val e

I em 4. De c i ion: $360.00 US 1 $0.00

CURRENCY (1) $50.00 (14) $20.00 (3)
1 61420170110103 $10.00

Tag # dlf33 Loca ion Sei ed B FOOSE, DARIL

1521-MAIN EV-DMV

Role: EVIDENCE
Ca ego : DRUG CLASS
T e:
#' A icle B and / Model Se ial #/NIC # Colo Q an i Val e

I em 1. De c i ion: LOOSE CRACK 0 $0.00

COCAINE
1 61420170110102

Tag # dlf33 Loca ion Sei ed B FOOSE, DARIL

1021-MAIN EV-DMV

I em 5. De c i ion: MARIJUANA INSIDE 0 $0.00

CLEAR PLASTIC BAGGIE
1 61420170110103

Tag # dlf33 Loca ion Sei ed B FOOSE, DARIL

1021-MAIN EV-DMV

Role: EVIDENCE
Ca ego : DRUG PARAPHERNALIA
T e:
#' A icle B and / Model Se ial #/NIC # Colo Q an i Val e

I em 2. De c i ion: CLEAR PLASTIC 1 $0.00

BAGGIE
1 61420170110103

Tag # dlf33 Loca ion Sei ed B FOOSE, DARIL

211-MAIN EV

Role: EVIDENCE
Ca ego : DRUG PARAPHERNALIA
T e: MISCELLENOUS
#' A icle B and / Model Se ial #/NIC # Colo Q an i Val e

I em 3. De c i ion: DIGITIAL SCALE WITH 1 $0.00

COCAINE RESIDUE
1 61420170110103

Tag # dlf33 Loca ion Sei ed B FOOSE, DARIL

211-MAIN EV

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717-255-3131
Ca e N mbe : 19-1214-033-002 ORI #: PA0220200

Role: EVIDENCE
Ca ego : ELECTRONICS
T e:
#' A icle B and / Model Se ial #/NIC # Colo Q an i Val e

I em 6. De c i ion: SAMSUNG CELL 1 $0.00

PHONE
1 61420170110103

Tag # dlf33 Loca ion Sei ed B FOOSE, DARIL

211-MAIN EV

Role: EVIDENCE
Ca ego : MISC
T e:
#' A icle B and / Model Se ial #/NIC # Colo Q an i Val e

I em 11. De c i ion: WATCHGUARD 1 $0.00

VIDEO UNIT 206 12/14/19
1 1 000101420

Tag # hk164 Loca ion Sei ed B

FORENSICS

Role: RECOVERED
Ca ego : CLOTHING, FURS
T e: JACKET
#' A icle B and / Model Se ial #/NIC # Colo Q an i Val e

I em 8. De c i ion: BLACK JACKET 1 $0.00

1 1 002102044

Tag # DMC60 Loca ion Sei ed B CRISTILLO, DOMINIC

4001-MAIN EV-RM 17

Role: RECOVERED
Ca ego : CLOTHING, FURS
T e: SHIRT
#' A icle B and / Model Se ial #/NIC # Colo Q an i Val e

I em 9. De c i ion: SWEATSHIRT Mfg.: NIKE BLACK 1 $0.00

1 1 002102045

Tag # DMC60 Loca ion Sei ed B CRISTILLO, DOMINIC

Role: RECOVERED
Ca ego : CLOTHING, FURS
T e: SHOES
#' A icle B and / Model Se ial #/NIC # Colo Q an i Val e

I em 7. De c i ion: BOOTS Mfg.: TIMERLAND TAN 1 $0.00

1 1 002102043

Tag # DMC60 Loca ion Sei ed B CRISTILLO, DOMINIC

4001-MAIN EV-RM 17

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123
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717-255-3131
Ca e N mbe : 19-1214-033-002 ORI #: PA0220200

Role: RECOVERED
Ca ego : CLOTHING, FURS
T e: SOCKS
#' A icle B and / Model Se ial #/NIC # Colo Q an i Val e

I em 10. De c i ion: PAIR OF SOCKS BLACK 1 $0.00

1 1 002102046

Tag # DMC60 Loca ion Sei ed B CRISTILLO, DOMINIC

4001-MAIN EV-RM 17

Page 5 of 13
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Na a i e( )

A igned: 12/14/2019 19:20:42 o office : FOOSE, DARIL

A o ed: b :,

**INITIAL CRIME REPORT** 12/14/19@1822HRS DFOOSE

C19-1214-033-002

On 12/14/19, I as in f ll SCU niform of the da operating an nmarked Harrisb rg Cit Police Vehicle. M
partner for this date as APO Kinsinger.

At appro imatel 1815HRS, I obser ed a Jeep parked at the intersection of S 15th ST/ S atara Street. A male
e ited the passenger seat and alked est bo nd on S atara Street. As I circled the area to see if this male as
meeting ith someone, I as tra eling north bo nd on Dais Street and obser ed the male, ho as later
identified as Ja Wilkerson, alking back to ards the Jeep after lea ing the area to the rear of Q eenies Bar.
Immediatel after seeing this male, I obser ed another male, later identified as Terelle Thomas, alking q ickl
from the rear of Q eenies Bar as ell. When Wilkerson as lea ing, it appeared as if he as la ghing and ha ing
a con ersation ith Thomas. I as able to position m ehicle to tra el so th bo nd on S 15th St, to ards
S atara Street. In doing so, I obser ed the Jeep fail to come to a complete stop at the stop sign at S 15th ST/
S atara Street. A traffic stop as cond cted in the area of S 17th ST/ Holl Street.

Upon approach, the dri er as identified as Theresea Henderson. The passenger as identified as Ja
Wilkerson. As I ent to identified Terelle Thomas, he spoke to me like he had "cotton mo th". When I asked him
his name, he talked as if he had a large amo nt of an nkno n item inside of his mo th. As I looked at him, I
co ld see strands, almost g m and paste like, forming in his mo th as he is talking to me. From m kno ledge,
training, and e perience, this beha ior is common for indi id als ho ha e ingested an item to conceal it from
police. I notified m partner, APO Kinsinger, that I belie ed Thomas as concealing something in his mo th and
to detain him. APO Kinsinger as able to detain Thomas and elled for him to spit o t the items inside of his
mo th. Where Thomas did spit as a hite liq id that resembled crack cocaine attempted to be s allo ed. As
other nits arri ed on scene, both Wilkerson and Henderson ere detained.

After Henderson and Wilkerson ere detained, I as able to go and speak to Thomas. Thomas's mo th indicted
to me that he had ingested a large amo nt of cocaine. His lips ere completel pasted hite. His tong e and spit
ere hite and forming a large amo nt of paste inside of his mo th. Thomas's face appeared to be co ered in a
hite po der s bstance. I did erball mirandi e Thomas, to hich he stated he nderstood his rights. Thomas
stated the onl dr g's he had on him as a small amo nt of marij ana. He stated that he j st ate a cand
cigarette and that is h his lips ere so hite. As APO Kinsinger as searching Thomas, he n ipped his black
hoodie in m presence. In doing so, small crack cocaine rocks did fall o t of Thomas's shirt.

I did erball mirandi e Wilkerson. He ad ised he nderstood his rights. Wilkerson stated that he did not ha e
an thing illegal on his person and ad ised that there as nothing illegal inside the ehicle. Wilkerson did gi e
erbal consent to search his person, to hich nothing as fo nd.

I did erball mirandi e Henderson, to hich she stated she nderstood her rights. Henderson stated she did not
kno of an dr gs inside the ehicle. She did gi e erbal consent to search the ehicle, hich is registered to her.
Henderson also pro ided erbal consent to search her person, hich no illegal items ere fo nd.

A search of the ehicle as cond cted. Where Thomas as sitting, m ltiple crack cocaine rocks ere located on
the seat and on the floor. These rocks ere collected for e idence.

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F rthermore on Thomas, the follo ing items ere located:

- In his hand hen APO Kinsinger as detaining him, $130.00 in US c rrenc (5) $20.00; (3) $10.00.
- In his pocket $230.00 in US c rrenc (1) $50.00; (9) $20.00
- One Sams ng cell phone
- One digital scale ith cocaine resid e, f nctioning.
- One clear plastic baggie
- One clear plastic baggie ith marij ana inside of it

It sho ld be noted that d ring the search of the ehicle and all occ pants of the ehicle, there as no
paraphernalia that s ggested crack cocaine se (IE crack pipes, p sh rods, chor bo ). F rthermore, there ere
no cand cigarettes inside the ehicle or on an occ pants.

Thomas as transported to the Central Booking Center b Officer Carriere. Prior to transport, Cpl Johnsen
ad ised that Thomas ad ised him that he did not eat an illegal items.

At base, all e idence as logged into secondar e idence. The dr gs ill be sent to PSP lab for f rther anal sis
and official eight. The cell phone ill be kept in e idence for a search arrant to be cond cted. The mone
fo nd on Thomas ill be sent for ION scan.

Thomas ill be charged ith the follo ing offense:

PWI-crack
Possession of Small Amo nt of Marij ana
Possession of Dr g Paraphernalia
Tampering ith E idence

After Thomas as transported to the Central Booking Center, I as ad ised that he had a sei re and needed to
go to the Harrisb rg Hospital. I as ad ised that Lifeteam personal that the had s cked 40ml of cocaine o t of
Thomas hile enro te to the hospital that he had ingested.

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A igned: 12/14/2019 20:48:06 o office : JOHNSEN, SCOTT

A o ed: b :,

SUPPLEMENTAL REPORT

On 12/14/19 at abo t 1822 ho rs I responded to the area of S 17th and Holl streets to assist on a traffic stop
cond cted b Officer Foose. Upon arri al I fo nd that Probation Officer Dan Kinsinger had the rear seat
passenger detained ho as Terelle Thomas. Officer Foose as in the process of detaining the dri er, Theresa
Henderson. Officer Foose req ested that the front seat passenger, Ja Wilkerson also be detained.

PO Kinsinger ad ised that he tho ght Thomas had ingested crack cocaine d e to a hite po der s bstance
aro nd Thomas's mo th. There as also crack remnants in the back seat of the ehicle. I asked Thomas m ltiple
times if he ingested an thing and he insisted that he did not and that the hite on his mo th as from a cand
cigarette. I ad ised him that if he did ingest something e needed to kno so that e co ld inform medical staff
beca se he co ld possibl die. Thomas again insisted that he did not ingest an thing.

I also spoke ith Wilkerson and Henderson. Both indi id als stated that the did not see Thomas ingest an thing
and did not kno that he had crack.

I remained on scene ntil Thomas as transported b Officer Carriere. At that time Henderson and Wilkerson
ere free to lea e.

On 12/15/19 at abo t 1420 ho rs Ton ka L garo came into the lobb stating that she as Thomas's sister. She
as req esting Thomas's propert . I told her that an propert e did ha e o ld be na ailable ntil d ring the
eek. She nderstood. She also asked hat happened beca se she did not kno . I ad ised her on the basics of
the incident. She also pro ided me ith her mothers information, Mar Thomas in case an one needed to be
contacted again. I as then able to look p the case and also spoke to Officer Foose. All of the propert that as
in Thomas' possession is e idence in this case. I called Ton ka back and ad ised her of this information.

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A igned: 12/14/2019 21:55:47 o office : SALAZAR, ADRIENNE

A o ed: b :,

**S R ** 12/14/2019 2222

19-1214-033-002

On 12/14/2019 I as on d t in f ll niform assigned to the Harrisb rg Police Ho sing Unit and operating marked
police ehicle 297. At appro imatel 1822 ho rs, I responded S. 17th St. and Holl St. to assist PO Foose ith a
traffic stop. Upon arri al I assisted APO Kinsinger ith sec ring Terelle Thomas as he cond cted a search of his
person.

I as ad ised b PO Foose that she belie ed Mr. Thomas ingested crack cocaine and he erball denied it
se eral times hen asked in m presence. A small bag of s spected marij ana b ds and a digital scale ith hite
po der resid e on it ere located in Mr. Thomas' pockets. I remained ith Mr. Thomas as officers cond cted a
search of the ehicle. I obser ed a hite po der s bstance co ering Mr. Thomas' lips and he contin ed to den
ha ing ingested crack cocaine. I informed him that it as important for s to kno hat he ingested for his safet
in the e ent that it o ld ha e an ill affect on his health. He ref sed to tell me hat he ingested.

D ring m interaction ith Mr. Thomas he appeared conscio s and as able to speak ith me in a coherent
manner. I asked him on t o separate occasions if he as feeling oka and he stated that he as oka . I closel
obser ed him hile on scene and his condition did not appear to orsen. It as determined that PO Carriere
o ld transport Mr. Thomas to the Da phin Co nt Booking Center and I bro ght him to the caged compartment
of marked police ehicle 206. This concl ded m interaction ith Mr. Thomas and I cleared from the scene. There
is nothing f rther at this time.

End 123 .

Page 9 of 13
 Ci of Ha
Case 1:02-at-06000-UN i b g,
Document 630B Filed
ea 07/10/20
of Police
Page 38 of 58
123
Waln S
Ha i b g PA, 17101
717-255-3131
Ca e N mbe : 19-1214-033-002 ORI #: PA0220200

A igned: 12/14/2019 21:55:54 o office : BANNING, TRAVIS

A o ed: 12/18/2019 15:00:06 b : JOHNSEN, SCOTT

*S R * 12/14/19 1822 hrs

19-1214-033-002

On Sat rda 12/14/19, I as orking in f ll Police niform operating marked nit 207 assigned to
District 7 of Harrisb rg Cit . At aro nd 1822 hrs I responded to the area of N 17th and Holl Sts to
assist Officer Foose ith a traffic stop. Upon arri al Officer Foose had 3 indi id als detained for a dr g
in estigation after the stop. Officer Foose as q estioning a TerelleThomas ho as a passenger
ithin the ehicle. I obser ed that Thomas had a large amo nt of hite resid e aro nd and on his lips.
Officer Foose ad ised me that she belie ed that Thomas had eaten crack cocaine. She ad ised me that
Thomas had told her that the hite resid e on his lips as from him eating cand cigarettes. I asked
Thomas hat the s bstance on his lips as again, and he stated "cand cigarettes, the kind that come
in a bo ". I assisted Officer Foose ith completing the search of the ehicle. Crack cocaine as in plain
ie on the rear passenger seat. There as no bo of cand cigarettes to m kno ledge that ere
located inside of the ehicle or on Thomas' person. While I as on scene, Thomas ne er stated that he
ate crack cocaine, and he did not act as if he as nder the infl ence of an thing, or seemed to
becoming ill. I cleared the scene and this ended m in ol ement ith this incident.

175 tjb

Page 10 of 13
 Ci of Ha
Case 1:02-at-06000-UN i b g,
Document 630B Filed
ea 07/10/20
of Police
Page 39 of 58
123
Waln S
Ha i b g PA, 17101
717-255-3131
Ca e N mbe : 19-1214-033-002 ORI #: PA0220200

A igned: 12/14/2019 21:55:57 o office : CARRIERE, BRIAN

A o ed: 12/16/2019 18:39:38 b : GALKOWSKI, JAMES THOMAS

*T R * 12/14/19 18:47
19-1214-033-002

On Sat rda 12/14/19 at 1847 hrs, I transported Terelle Thomas from the area of S 17th St and Holl St to the
Da phin Co nt Booking Center. I as in f ll Police niform. I as orking on Patrol as the district 6 Officer. I
as operating nit 206.

Prior to the prisoner transport, Officer Foose ad ised me that the prisoner, Terelle Thomas, ma ha e ingested
crack-cocaine, b t he had been den ing do so. I took possession of Thomas. I asked him if he ingested crack-
cocaine and he told me that he did not. I placed him in the rear prisoner compartment of nit of 206. He told me
that he as hot and asked me to lo er the indo for him. I did so. I ens red that the camera as acti ated. He
as handc ffed behind his back. I did not sec re him ith a seat belt beca se the seat belt receptacle is not
f nctional. I started the transport at 1847 hrs. The starting mileage as 14625.9. I arri ed at the booking center at
1853 hrs. The ending mileage as 14627.9. I contin ed to check on Thomas thro gho t the transport. He told me
that he as oka . I asked him if he had medical conditions. Thomas ad ised me that he s ffers from a sei re
disorder.

Once at the booking center, I ad ised the booking staff of Thomas' conditions. I ad ised that ma ha e
s allo ed crack-cocaine. He as seen b medical staff at the booking center and as cleared to sta . The
booking staff asked him se eral times if he ingested crack-cocaine. Again, he denied doing so.

Later in the e ening, I as ad ised that Thomas had a medical emergenc at the booking center and as
transported to Harrisb rg Hospital. I sent an email to Sergeant Abromitis and req ested for the transport ideo to
be sa ed.

This ended m in ol ement in this case.

End Carriere 163

Page 11 of 13
 Ci of Ha
Case 1:02-at-06000-UN i b g,
Document 630B Filed
ea 07/10/20
of Police
Page 40 of 58
123
Waln S
Ha i b g PA, 17101
717-255-3131
Ca e N mbe : 19-1214-033-002 ORI #: PA0220200

A igned: 12/14/2019 23:54:59 o office : MCNAUGHTON, MARC

A o ed: b :,

12/14/19 2330 S R M N #411

On this date, at the req est of Sgt Meik I responded to 323 s 18th St to attempt to make contact
ith Linda Thomas, the sister of Terrel Thomas. (Note: Sgt Meik req ested 1st Platoon assist d e to street
crimes ending their shift and he had to start the do nto n detail)
.
I arri ed at 323 S 18th St along ith PO Restrepo and knocked on the door as ell as the porch indo
n mero s times ith no response. No lights ere on in the residence at the time, nor as an mo ement seen or
heard. PO Restrepo as obser ing the second floor area of the residence hile attempted contact and also sa
no lights nor mo ement d ring o r attempted contact.
.
Upon clearing I pdated Sgt Meik to the negati e contact at the residence. This ends m in ol ement ith this
incident.
.
MM/411

Page 12 of 13
 Ci of Ha
Case 1:02-at-06000-UN i b g,
Document 630B Filed
ea 07/10/20
of Police
Page 41 of 58
123
Waln S
Ha i b g PA, 17101
717-255-3131
Ca e N mbe : 19-1214-033-002 ORI #: PA0220200

A igned: 12/15/2019 04:56:21 o office : CRISTILLO, DOMINIC M

A o ed: 12/18/2019 02:03:26 b : MCNAUGHTON, MARC

SUPPLEMENTAL REPORT UNIT 206 DISTRICT 6

12/15/2019 SUNDAY @0430 HOURS
19-1214-033-002

On 12/15/2019, I as in f ll police niform operating police SUV 206. I as assigned to district 6 in

the Cit of Harrisb rg. I as tasked b CPL McNa ghton to retrie e prisoner propert from the booking
center for a Terelle Thomas.

I arri ed to the booking center at aro nd 0430 ho rs and made contact ith the on staff s per isor
ho ga e me Thomas' propert . I ret rned to base ith the prisoner propert , hich incl ded the
follo ing items: A black jacket, a black Nike s eatshirt, a pair of black socks, and Timberland boots. All
of these items ere packaged, placed and logged into the secondar e idence room, stored in locker
23. The propert log as pdated appropriatel .

This concl des m in ol ement in this case.

END DMC 60

Page 13 of 13
 Ci of Ha
Case 1:02-at-06000-UN i b g,
Document 630B Filed
ea 07/10/20
of Police
Page 42 of 58
123
Waln S
Ha i b g PA, 17101
717-255-3131
Ca e N mbe : 19-1214-033-002 ORI #: PA0220200

T ec c fide ia e a i f ai fa i e ic i i hi e , hi i ed d c e i c di g, b i i ed , a add e , e e h e be , d i e ' ice e Ide ifica i Ca d be , cia

ec i be , da e f bi h, e c..., i be de ed he a e e .

1 Vic im

1 O gani a ion Name

COMMONWEALTH OF PA
Add e Phone
123 WALNUT ST BUSINESS: 1-(717) 558-6900
HARRISBURG, PA 17101
2 Di e

2 Name - ( La , Fi , Middle ) Occ a ion Social Sec i # Ci i en hi

HENDERSON, THERESEA N
Add e Phone Di e Licen e Info. ( S a e / # / Cla )
2330 MAGNOLIA TERRACE
HARRISBURG, PA 17110

Hai : BROWN Race: BLACK OR AFRICAN AMERICAN Heigh : 5-07

Age: 34 D. O. B.: 10/15/1985 E e : BROWN Se : F Weigh : 200

3 Men ioned

3 Name - ( La , Fi , Middle ) Occ a ion Social Sec i # Ci i en hi

THOMAS, TONYKA
Add e Phone Di e Licen e Info. ( S a e / # / Cla )
207 ORANGE ST HOME: 1-(717) 343-2085
SELINSGROVE, PA 17870

Hai : Race: Heigh :

Age: UNK D. O. B.: E e : Se : Weigh :

4 Name - ( La , Fi , Middle ) Occ a ion Social Sec i # Ci i en hi

THOMAS, MARY
Add e Phone Di e Licen e Info. ( S a e / # / Cla )
1201 N FRONT ST
APT 401

Hai : Race: Heigh :

Age: UNK D. O. B.: E e : Se : Weigh :

5 Pa enge

5 Name - ( La , Fi , Middle ) Occ a ion Social Sec i # Ci i en hi

WILKERSON, JAY 190-66-7029
Add e Phone Di e Licen e Info. ( S a e / # / Cla )
5032 WYNNEWOOD RD PA / 28363389
HARRISBURG, PA 17109

Hai : BLACK Race: BLACK OR AFRICAN AMERICAN Heigh : 5-09

Age: 33 D. O. B.: 8/25/1986 E e : BROWN Se : M Weigh : 200
Case 1:02-at-06000-UN Document 630 Filed 07/10/20 Page 43 of 58

EXHIBIT B
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EXHIBIT C
 Harrisburg police took man who swallowed crack to jail but he ‘should have received urgent medical careʼ mayor - pennlive.com.pdf
Case 1:02-at-06000-UN
SavedDocument 630
to Dropbox • Mar Filed
24, 2020, 11H03 07/10/20
AM Page 53 of 58

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Pennsylvania Real-Time News

Harrisburg police took man who swallowed crack

to jail but he ‘should have received urgent medical
care’: mayor
Updated Jan 17, 2020; Posted Jan 17, 2020

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1.5k were scheduled for

Terelle L. Thomas, 31, died Dec. 17. His funeral services
shares
Christmas Eve.

By Christine Vendel | cvendel@pennlive.com

A Harrisburg police officer took a man who was “observed
Case 1:02-at-06000-UN Document 630 Filed 07/10/20 Page 54 of 58
swallowing crack cocaine” to jail last month instead of to a
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hospital, an apparent violation of department policy.

Terelle Thomas, 31, spent nearly an hour at the Dauphin Meet Pretty Asian
Women In
County booking center before he collapsed. He was then Philadelphia
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taken to a hospital, where he died three days later.

An autopsy was performed, but the coroner is awaiting

Woman hit, killed by
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A police spokesman told PennLive last month that Thomas This!
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appeared to have something in his mouth during the traffic
stop Dec. 14 at 15th and Swatara streets. Thomas had small
amounts of crack cocaine on his shirt and clothing, police What if Pennsylvania
residents are ordered
said. to ‘shelter-in-place?’
Pennlive

When the officer asked Thomas asked if he had swallowed

anything or needed to go to a hospital, he said “no” to both Promoted Links by Taboola

questions, the spokesman told PennLive.

PennLive obtained the criminal affidavit written by the Advertisement

officer to support a felony drug trafficking charge against
Thomas, and it said Thomas “was found in possession of
crack cocaine inside of his mouth and where he was seated
inside the vehicle.”

Further, the officer justified a misdemeanor tampering

charge against Thomas by writing that he “was observed
consuming crack cocaine in order to conceal it from police.”

So if he was found in possession of crack inside his mouth

and “observed consuming crack,” why wasn’t he taken to a
hospital, as prescribed by department policy?
 Case 1:02-at-06000-UN Document 630 Filed 07/10/20 Page 55 of 58
Advertisement

It is widely considered best practice to seek immediate

medical treatment for people suspected of ingesting illegal
drugs.

Harrisburg police declined to answer follow-up questions

about why police would believe Thomas’ denials about
ingesting drugs when an officer apparently saw otherwise.
County officials declined to answer specific questions about
how Thomas was allowed to spend nearly an hour at the
booking center and whether employees saw the paperwork
to support his entry that said he consumed crack cocaine.

It was the fifth in-custody death connected to the Dauphin

County jail in 2019.

“Because it’s an active investigation, District Attorney Fran

Chardo would be the most appropriate person to speak to at
this time,” said Amy Richards, the county spokeswoman, in
response to questions.

Chardo told PennLive he was reviewing the incident for any

possible criminal charges so he could not answer questions
at this time.

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Harrisburg Mayor Eric Papenfuse told PennLive it is

department policy to take someone to a hospital rather than
Case 1:02-at-06000-UN
the booking center Document
if they have consumed 630 Filed
illegal narcotics in 07/10/20 Page 56 of 58
a way that could jeopardize their health and welfare.

“The death is a tragedy and I feel very sorry for Mr. Thomas’
family,” Papenfuse said. “In retrospect, he should have
received urgent medical care, and I deeply regret that he did
not.”

Papenfuse said Thomas denied consuming drugs, and

“given that denial, the officer exercised her best judgment as
to how to proceed. She clearly felt there was enough
evidence to seek charges but not enough to seek immediate
medical attention. Those types of calls can be difficult but
must be made by officers every day in Harrisburg.

“I am not going to second-guess their decisions or question

whether their judgments were made in good faith,” he said.
“We should, however, endeavor to learn from difficult
experiences like these and strive to handle such situations
differently in the future.”

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Thomas’ sister told PennLive that they were seeking

additional information on what happened to her brother.
Thomas would have turned 32 last week.

“He had family and people who loved him,” she said in a
phone call, declining to provide her name. “He had his
diploma. He was very intelligent and he was working toward
goals. That’s all anyone needs to know.”

Thomas had been paroled Aug. 19 from a 5- to 12-year

prison sentence for illegal gun possession in Dauphin
County. His maximum sentence would have expired on Oct.
31, 2025. He had three prior drug convictions.

Ryan Marino, an emergency room doctor and medical

toxicologist at Cleveland University Hospitals, said crack
Case
cocaine can be 1:02-at-06000-UN
deadly to ingest, just likeDocument 630 Filed 07/10/20 Page 57 of 58
cocaine. Although
people typically smoke crack to get high, he said it can get
into a person’s system through swallowing.

“The way he collapsed, it definitely sounds like drug toxicity,

not alcohol or benzos or opioids,” he said. “One hour would
be enough time for the effects to be noticeable…that does fit
the window for toxicity.”

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Some drug couriers carry drugs inside their bodies, but they
usually try to package the drugs securely in advance to
avoid leakages. But that’s not the case for people who
swallow drugs during a traffic stop or while running from
police, Marino said.

“They’re usually not secured at all,” he said. “There is usually

less of an amount, but it is less secure.”

Cocaine can have many harmful effects on a body, Marino

said.

“In a big ingestion, you can see increased blood pressure,

bleeding in the brain and brain death, bleeding in internal
organs, organs can die, coronary arteries can clamp down,
there can be increased clotting,” he said. “There are a lot of
different scenarios. It can wreak havoc on all parts of
someone’s body.”

In Thomas’ case, once it was determined he could not

survive his injuries, his body was kept alive so he could
donate his organs. Marino said cocaine eventually leaves the
body and unaffected organs could be donated.

The previous in-custody deaths in Dauphin County last year

were:
 Advertisement
Case 1:02-at-06000-UN Document 630 Filed 07/10/20 Page 58 of 58

Maliaka Evans, 53, who died Feb. 2, 2019 of natural causes, which
prison officials described as a pulmonary embolism.
Emily E. Endrizzi, 39, who died March 11, 2019 of suicide.
James Macaulay, 45, who died March 21, 2019 of suicide.
Ty’rique Riley, 21, who died July 1, 2019, from an illness he had prior to
his arrest. The coroner ruled the death “natural” from: cerebral
vasculitis/encephalitis, thromboemboli and rhabdomyolysis. The
vasculitis to the brain was consistent with cocaine usage or infection,
according to officials.

READ: Half of last year’s killings in Harrisburg went unsolved

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