New York, NY – April 18, 2025 — In a sweeping and detailed complaint filed with the U.S. Equal Employment Opportunity Commission (EEOC), veteran NYPD Police Officer Frankie F. Palaguachi has accused the New York City Police Department and its drug-testing contractor, Psychemedics Corporation, of operating a racially biased and scientifically flawed testing methodology that disproportionately impacts officers of color—particularly Latino and Black members of the service—through the use of controversial Radioimmunoassay of Hair () hair-based drug testing.

The administrative charge, filed under Title VII of the Civil Rights Act of 1964 and its state and local equivalents, outlines a deeply troubling pattern: facially neutral drug testing methods implemented without oversight, scientific validation, or legal compliance, resulting in discriminatory outcomes, career-altering punishments, and retaliation against officers who raise concerns. The complaint names both the NYPD and Psychemedics as respondents, citing their interdependent roles in administering, interpreting, and enforcing drug test results without safeguards, procedural fairness, or adherence to federal regulatory standards.

“What we see here is not mere oversight—it’s institutional insensitivity. The NYPD has allowed flawed science and opaque processes to dictate discipline without regard for fairness, accuracy, or humanity. Officers of color are disproportionately harmed, yes—but this regime endangers all officers, regardless of race. It’s a system cloaked in the false legitimacy of ‘randomness,’ while political insiders are protected and outsiders are punished. That’s not justice—it’s structural betrayal.”
— Eric Sanders, President of ¸ŁŔűź§.

“I saw this coming years ago when I was president of the Guardians Association of the Police Department City of New York. Even then, when the Department first proposed using hair testing, the scientific and civil rights concerns were already obvious. Since that time, researchers and members of the scientific community have repeatedly confirmed what many of us warned: this method is unreliable, racially biased, and ripe for abuse. Frankly, I’m stunned that the unions haven’t mounted a serious challenge. This isn’t just a policy failure—it’s a betrayal of the very people who risk everything in uniform, says Sanders.”

A “Random” Drug Test That Was Anything But

According to the charge, Officer Palaguachi—a decorated officer with no history of misconduct—was notified on February 22, 2024, that he had been selected for a “random” drug test. However, the selection was not announced via the NYPD’s Finest Message system, which is the standard method for notifying members of service about random drug screenings. Instead, the notice came via an undocumented phone call. Palaguachi, who had recently raised internal concerns about discriminatory treatment and testing practices within the department, immediately questioned the timing and legitimacy of the selection.

Upon arrival at the NYPD Medical Division, Palaguachi was subjected not to a standard urinalysis test, but to radioimmunoassay of hair (RIAH)—a method of drug testing that analyzes strands of hair to detect drug metabolites over a 90-day window. While marketed as more comprehensive than urine screening, RIAH has never been approved by the Substance Abuse and Mental Health Services Administration () for use in federal workplace testing due to its inability to distinguish between environmental contamination and ingestion, its destructive testing method, and well-documented racial disparities in drug retention among darker-haired individuals.

Palaguachi’s sample was analyzed by Psychemedics Corporation, the City’s long-time testing vendor. The results, according to the charge, were inconsistent with science-based cutoff levels and later contradicted by multiple independent drug screenings, a polygraph, and a court-admissible toxicology exam. Nonetheless, the NYPD used the test to suspend Palaguachi without pay, demote him, and begin disciplinary proceedings.

Racial Bias Baked Into the Science—and Ignored by the NYPD

As the charge outlines, RIAH testing has long been criticized in the scientific community for its racialized outcomes. —the pigment that gives hair its dark color—has a high affinity for certain drug compounds, such as cocaine and THC. Studies have shown that individuals with darker, coarser hair, such as African American and Hispanic populations, are more likely to bind drug residues even from passive exposure, resulting in a higher rate of false positives when compared to those with lighter hair.

This biological disparity is not hypothetical. In , 845 F.3d 28 (1st Cir. 2016), the U.S. Court of Appeals permitted a Title VII disparate impact claim to proceed after finding statistical and scientific evidence that the Boston Police Department’s use of hair testing disproportionately harmed Black officers. In that case, the court acknowledged the unreliability of hair testing in distinguishing between actual use and surface contamination, particularly in racially diverse populations.

The EEOC charge filed by Palaguachi explicitly references this case and similar scientific literature, noting that the NYPD continues to use RIAH testing despite the lack of federal endorsement, the known bias against officers of color, and the destructive, non-verifiable nature of the method. No split sample is retained. No DNA authentication is performed. And officers are not permitted to verify the results through reanalysis or appeal independently.

Pattern or Practice of Discrimination and Retaliation

The charge further alleges that the NYPD’s testing program is not merely flawed—it is systematically discriminatory. The Department does not conduct statistical monitoring of testing outcomes by race, sex, or ethnicity, as required by the Uniform Guidelines on Employee Selection Procedures (), 29 C.F.R. § 1607. Nor does it provide employees with access to the algorithm that determines who is selected for testing. The entire process, according to the charge, is shrouded in secrecy and devoid of procedural safeguards.

The EEOC filing identifies a broader pattern of misconduct:

• Officers of color are subjected to hair testing at higher rates than white officers.

• Unequal disciplinary outcomes for similarly situated employees—some white officers with positive results reinstated quietly, while officers of color are demoted or terminated.

• Refusal by the NYPD to disclose comparator data or trial decisions, thereby obstructing efforts to challenge discriminatory enforcement.

• Use of the drug testing program as a mechanism of retaliation against officers who question internal practices, raise discrimination claims, or advocate for reform.

Palaguachi’s case, the charge asserts, is not an isolated incident but part of a “pattern or practice” of using drug testing as a proxy for racial targeting, political suppression, and retaliation against dissenters.

Psychemedics: The Silent Gatekeeper

While the NYPD carries out the disciplinary action, the charge squarely names Psychemedics as a co-respondent. The Texas-based laboratory, a major player in the hair testing industry, is the City’s exclusive vendor for RIAH screening. It conducts the initial screening, confirmatory testing, and issues the final report that often forms the basis for career-ending decisions.

Critically, Psychemedics operates behind closed doors. The cutoff thresholds it uses are proprietary. The sample is consumed during testing, eliminating any opportunity for independent verification. And officers have no right to challenge the lab’s methods or demand a third-party review. This lack of transparency, the charge argues, creates a due process vacuum—one that disproportionately affects officers of color and whistleblowers.

Under Title VII and UGESP, employers cannot delegate away their responsibility to ensure that testing methods are valid, nondiscriminatory, and scientifically sound. Nor can they rely on third-party vendors whose practices have not been independently audited or validated for fairness and compliance.

Yet, according to the charge, the City of New York has done precisely that—outsourcing life-altering decisions to a private contractor whose procedures remain shielded from scrutiny.

Legal Framework: Title VII, § 1983, NYSHRL, NYCHRL—and More

The legal claims asserted in the charge are far-reaching. They include:

• Title VII: Disparate impact and disparate treatment based on race and national origin; hostile work environment; retaliation.

• 42 U.S.C. § 1983: Equal Protection Clause violations for race-based selective enforcement; First Amendment retaliation for protected whistleblowing.

• New York State Human Rights Law (NYSHRL): Discrimination and retaliation based on race and ethnicity.

• New York City Human Rights Law (NYCHRL): Broad anti-discrimination protections, including perceived political belief discrimination.

• New York Labor Law § 740 and Civil Service Law § 75-b: Retaliation for protected whistleblowing.

• Marijuana Regulation and Taxation Act (MRTA): Unlawful adverse employment action based solely on metabolite presence in the absence of impairment.

The charge further references , Inc., 22 N.Y.3d 1 (2013), in support of the claim that Psychemedics. However, a third party may be held liable under New York law for negligently issuing drug test results with disciplinary consequences.

Remedy Sought: Accountability and Structural Reform

Palaguachi seeks not only individual remedies—including back pay, reinstatement, and compensatory damages—but also institutional change. His complaint calls on the EEOC to investigate the NYPD’s drug testing program as a systemic violation of civil rights laws and to order comprehensive reforms, including:

• The suspension of hair-based drug testing until it is scientifically validated and free of racial bias.

• Implementation of procedural safeguards, including sample verification, DNA authentication, and appeal rights.

• Transparent auditing of testing outcomes by race, gender, and national origin, as required under UGESP.

• Disclosure of selection algorithms and documentation used in the random testing process.

• Public reporting of disciplinary outcomes to prevent selective enforcement and ensure accountability.

A Call to Action

“Too often, civil rights violations within law enforcement go unchallenged because of the blue wall of silence,” said Sanders. “But Officer Palaguachi is standing up—not just for himself, but for every officer who has been targeted, retaliated against, or silenced. This case is about justice, science, and the pursuit of fairness. And the law is on his side.”

The EEOC will now investigate the claims and may issue a determination. If the agency finds reasonable cause to believe discrimination occurred, it may initiate conciliation or issue a right-to-sue letter permitting civil litigation in federal court.

In the meantime, this case puts the NYPD and its private testing partner on notice: institutional discrimination and scientifically unsound policies will no longer go unchallenged.

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The post Exposed: NYPD’s ‘Random’ Drug Testing Disproportionately Hits Officers of Color, Says Federal Complaint first appeared on ¸ŁŔűź§..

New York, N.Y. — Today, April 17, 2025, in a harrowing civil rights lawsuit filed in the United States District Court for the Eastern District of New York, Brooklyn resident Keyanna Moody, a Black mother and lawful e-bike operator, alleges she was violently assaulted, unlawfully arrested, racially abused, and denied medical care by members of the New York City Police Department (NYPD) on June 11, 2024. The federal complaint, filed under 42 U.S.C. § 1983 and the New York City Human Rights Law (NYCHRL), details a traumatic encounter that began with a routine family outing and ended in physical and psychological trauma.

The lawsuit names as defendants Lieutenant Daniel Lacalamita, Sergeant Stanislav Zubyk, Police Officers Michael R. Moran, Alvin M. Nieves, Jared W. Cordero, and John Does 1 through 5, as well as the City of New York. The Complaint asserts claims under the First, Fourth, and Fourteenth Amendments, including excessive force, false arrest, racial profiling, retaliation, denial of medical care, and Monell liability.

What Began as a Family Ride Ends in Brutality

According to the complaint, Moody and her husband began their evening ride at Canarsie Pier, each operating a street-legal electric bicycle. Moody rode a Z6 Fly E-Bike, while her husband rode a Venom Fly E-Bike—neither of which requires registration, licensing, or insurance under New York law. While at the pier, they encountered two other individuals on motorcycles, and the group decided to head to Coney Island together. The plan was simple: Moody wanted to buy cotton candy for their five-year-old daughter, while the others planned to stop at Nathan’s Famous.

As they traveled, Moody and her husband followed the designated bike paths, while the motorcyclists took the highway route. By approximately 9:05 P.M., after retrieving the cotton candy, the group reunited near Surf Avenue and West 15th Street in Coney Island, chatting and exchanging contact information before preparing to leave.

At that moment, multiple NYPD officers—some in an unmarked vehicle and others on a police scooter—suddenly surrounded them. As indicated in the complaint, the officers aggressively approached without warning or legal justification. Officer Nieves allegedly snatched the e-bike keys from Moody’s ignition and demanded her license and registration. The complaint asserts that Moody had violated no law, and she calmly explained that her vehicle did not require documentation. Nevertheless, Lieutenant Lacalamita, the highest-ranking officer present, ordered her arrest without probable cause.

Tackled, Tased, and Thrown Face-First into a Police Vehicle

The complaint paints a harrowing picture of escalating brutality. After allegedly ordering Moody’s arrest without probable cause, Lacalamita watched as Officers Moran and Cordero tackled her to the ground. Officer Nieves attempted to tase her multiple times; when unsuccessful, he joined in physically restraining her. As Moody lay prone and handcuffed on the pavement, Moran stepped on her back and legs, while Nieves dug his knee and hands into her spine.

The officers then allegedly forced her face-first into the backseat of a patrol vehicle. During this, her foot became trapped in the doorframe. She screamed in pain, but officers ignored her cries for help before finally releasing her foot.

Adding to the trauma, Lieutenant Lacalamita allegedly berated Moody with racial slurs—calling her a “Black bitch,” attempting to slap and kick her, and ordering officers to “put that bitch in a cage.” She was then placed into another patrol car equipped with a prisoner partition and transported to the 60th Precinct, where the abuse continued.

Still handcuffed, Moody was brought before an unidentified desk officer. There, Lieutenant Lacalamita allegedly kicked her to the floor and stood over her yelling, “Get the f* up**,” while none of the officers present intervened. Despite the presence of a female officer, male officers conducted a full-body search, allegedly making inappropriate contact with Moody’s breasts, buttocks, thighs, and vaginal area. Her repeated demands to know the charges against her were met with silence.

Denied Medical Care, Misled at the Hospital, and Deprived of Property

Despite visible injuries—bleeding knees, torn clothing, and a dirt-covered body—Moody was allegedly denied medical attention for over five hours while detained at the 60th Precinct. Her repeated pleas to Officers Nieves and Cordero were ignored. Only after she refused to provide fingerprints were paramedics finally summoned.

Moody was transported to South Shore Brooklyn Hospital, where EMTs performed only a cursory evaluation. While in the resuscitation area, Lieutenant Lacalamita allegedly reappeared, lied about his identity, stating “I’m not him. I wasn’t there,” and fled when confronted. According to the complaint, Dr. Spencer Doblin Kim, the attending physician, refused to examine her, withheld discharge paperwork, and handed the documents to the NYPD escort instead of giving them to Moody herself. She only discovered the doctor’s identity later via a MyChart notification.

After her release from the hospital, Moody was returned to the 60th Precinct and later transferred to Brooklyn Central Booking, where the District Attorney declined to prosecute her case. However, the ordeal did not end there. Despite her charges being dropped, NYPD officers refused to return her property—including her Z6 Fly e-bike, phone, jewelry, ID, keys, and cash—even after she presented a DA-issued property release form. Instead, she was allegedly told the form was “meaningless” and was threatened with arrest if she did not leave the precinct.

A Pattern of Institutional Failure

The federal complaint does not isolate misconduct to a few rogue actors—it exposes systemic failures within the New York City Police Department in training, supervising, and disciplining officers with well-documented records of abuse. Each of the named officers in the lawsuit—Lieutenant Lacalamita, Sergeant Zubyk, and Officers Moran, Nieves, and Cordero—has been previously implicated in allegations of misconduct. Yet, the City of New York has continued to employ and promote them, emboldening unconstitutional policing.

• Lieutenant , who allegedly directed and physically participated in the violent arrest of Keyanna Moody, has faced multiple CCRB complaints in past years, including allegations of abuse of authority and excessive force. The complaint states that Lacalamita’s use of racial slurs, physical violence, and retaliatory threats against Moody highlights a longstanding pattern of misconduct, exacerbated by the NYPD’s refusal to hold him accountable.

• Sergeant allegedly stood by as a supervisor, watching the illegal arrest and use of force unfold without taking action. According to the lawsuit, Zubyk’s inaction reflects not only personal indifference but also a broader NYPD failure to empower supervisors to prevent or report unlawful conduct.

• Officer , accused of initiating the stop by allegedly seizing Moody’s e-bike keys illegally, has a documented history of civil rights complaints, including alleged unlawful stops and unreasonable searches. The lawsuit states that Nieves attempted to tase Moody multiple times and later participated in violently restraining her, even as she screamed in pain with her foot caught in the patrol car door.

• Officer is alleged to have stepped on Moody’s legs and shoved her into a police vehicle, later participating in a full-body search by male officers despite the presence of a female colleague. Past CCRB records cite Moran for use of force and discourtesy, and the complaint argues that his behavior toward Moody is part of a pattern of racial and gender-based abuse.

• Officer is accused of violently tackling Moody to the ground, ignoring her requests for medical care, and refusing to return her property even after she obtained a DA-issued release form. The lawsuit contends that Cordero’s conduct shows deliberate indifference to both constitutional rights and human dignity.

Despite these officers’ disciplinary histories and prior complaints, the City of New York continues to place them in active field roles, with supervisory backing. The lawsuit alleges that the NYPD has repeatedly ignored red flags, failed to remove problem officers, and allowed racial and gender bias to flourish unchecked.

This institutional failure, the complaint contends, is what made the violent and baseless arrest of Keyanna Moody not only possible but predictable.

A Pattern of Abuse: NYPD’s Troubling History of Civil Rights Violations

The misconduct alleged in Moody’s federal complaint is not an aberration—it reflects a deeply entrenched pattern of unconstitutional policing long associated with the New York City Police Department (NYPD). For decades, civil rights attorneys, independent monitors, and oversight bodies have documented pervasive problems involving racial profiling, excessive force, retaliatory arrests, denial of medical care, and unlawful stops, particularly targeting communities of color.

Ms. Moody’s experience—being tackled to the ground, called a racial slur, handcuffed, physically abused, denied medical care, and detained without cause—is emblematic of the broader institutional culture that the lawsuit seeks to expose. Her case follows a well-documented history in which Black and Latino New Yorkers are disproportionately targeted, with little to no accountability for officers who engage in misconduct.

This complaint does not merely assert individual wrongdoing. It highlights a systemic failure of supervision, training, and accountability, alleging that the City of New York has knowingly allowed officers with documented misconduct histories to continue policing without intervention, discipline, or retraining.

Notable Parallel Cases of NYPD Misconduct

The experiences described in Moody’s lawsuit mirror other high-profile NYPD misconduct cases that have drawn national attention:

• Eric Garner (2014): Died after being placed in a banned chokehold by Officer Daniel Pantaleo while under arrest for allegedly selling untaxed cigarettes. The incident, captured on video as Garner repeatedly said “I can’t breathe,” triggered national protests. The City paid $5.9 million in a wrongful death settlement.

• Delrawn Small (2016): Shot and killed in a Brooklyn road rage incident by off-duty Officer Wayne Isaacs within seconds of approaching Isaacs’ vehicle. Video evidence contradicted Isaacs’ self-defense claims. Although acquitted at trial, the case raised questions about internal NYPD discipline and prosecutorial accountability.

• Kawaski Trawick (2019): Shot inside his own Bronx apartment by officers who entered without a warrant. Trawick was not a threat, and yet no meaningful discipline was imposed, raising concerns about NYPD responses to mental health crises and officer accountability.

• Dounya Zayer (2020): Thrown to the ground by an NYPD officer during a protest in Brooklyn, suffering a traumatic brain injury. The incident was recorded and widely shared, prompting over 60 disciplinary findings against NYPD personnel for misconduct related to protests.

These incidents—like Moody’s—are not outliers. They are part of a systemic failure to uphold constitutional protections. In each case, officers acted outside department policy or legal limits, and supervisory failures allowed the misconduct to go unchecked.

NYPD Oversight Data Corroborates Systemic Abuse

The lawsuit draws on the findings of the —published as part of ongoing federal oversight under the Floyd v. City of New York litigation—to contextualize Ms. Moody’s experience. Among the report’s key findings:

• Black New Yorkers accounted for 29.8% of all NYPD vehicle stops in Q4 2024, despite comprising only 22.7% of the City’s population;

• White residents, who make up 35.9% of the population, were stopped only 17.8% of the time;

• Neighborhood Safety Teams (NSTs) engaged in unconstitutional stops more than 25% of the time;

• Supervisors approved 99.1% of all stop reports, regardless of their legality.

Moody’s encounter—initiated over an e-bike that did not legally require documentation—fits this pattern precisely. Her stop was not supported by probable cause, and her attempts to calmly assert her rights were met with retaliation, racial hostility, and force. The failure to discipline involved officers, despite clear violations of NYPD policies, reinforces the systemic failures identified in the Floyd Monitor’s review.

Legal Claims and Relief Sought

Moody’s federal lawsuit brings claims under the:

• First Amendment (retaliation for asserting legal rights),

• Fourth Amendment (unlawful seizure, excessive force),

• Fourteenth Amendment (due process, equal protection, denial of medical care),

• 42 U.S.C. § 1983 (civil rights violations),

• New York City Human Rights Law (NYCHRL) § 8-107(17) (racial profiling and discriminatory policing), and

• Monell liability against the City of New York for failing to train, supervise, and discipline officers.

She seeks compensatory damages, punitive damages, declaratory relief, and attorneys’ fees and costs.

Eric Sanders: “We Will Not Be Silent”

Eric Sanders, Esq., of ¸ŁŔűź§., who represents Ms. Moody, issued the following statement:

“What happened to Mrs. Moody is disgraceful. For doing nothing more than purchasing cotton candy for her child, she was dehumanized, brutalized, and unlawfully imprisoned by NYPD officers who acted with impunity. This lawsuit isn’t just about seeking justice for her—it’s about exposing the systemic rot that continues to define policing in communities of color. We demand accountability. We demand change.”

Contact:

For media inquiries, legal commentary, or to support Mr. Ryan’s case, contact:

¸ŁŔűź§.
30 Wall Street, 8th Floor
New York, NY 10005
ąĘłó´Ç˛Ôąđ:Ěý212-652-2782

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NEW YORK, NY — April 16, 2025 — In a sweeping federal civil rights lawsuit filed in the United States District Court for the Southern District of New York, a 21-year-old Black man from the Bronx has accused multiple members of the New York City Police Department (NYPD) of unlawful seizure, racial discrimination, excessive force, and falsification of legal documents—all stemming from a late-night police encounter that ended with a fractured jaw, a false arrest, and a cascade of lasting trauma.

The complaint, filed by New York civil rights attorney Eric Sanders of ¸ŁŔűź§., on behalf of Mr. Jaylin Ryan, follows the timely service of a Notice of Claim with the New York City Comptroller’s Office and alleges that NYPD officers engaged in a racially motivated and retaliatory use of force, fabricating a criminal summons in an attempt to cover up their misconduct.

At the heart of the case is a disturbing narrative: a young man standing on a Bronx sidewalk is punched in the face by a police sergeant while restained and being handcuffed, then falsely accused of a crime, denied timely medical care, and forced to defend himself in criminal court—only to have the case summarily dismissed weeks later for lack of legal merit.

The Incident: From Routine Concern to Police Violence

On December 28, 2024, at approximately 12:25 AM, Mr. Ryan stood beside his mother’s 2017 Mercedes-Benz GLS SUV, which was briefly double-parked outside 187 East 188th Street in the Bronx. According to the complaint, Mr. Ryan was not driving the vehicle but was standing nearby to ensure that his female friend, Carolyn Martinez, made it safely into her building. His younger sister sat in the front passenger seat.

What began as an act of caution quickly devolved into an alleged act of police aggression. A group of 4 to 6 NYPD officers, including Sergeant Brian P. Mahon, Sergeant Joel K. Ayala, and Police Officer James G. Geberth, approached Ryan and demanded identification. When Ryan calmly asked, “What did I do wrong?”, officers slammed him against the SUV. While he was handcuffed and physically restrained by multiple officers, Sergeant Ayala allegedly punched Ryan in the face with a closed fist, causing immediate and severe pain.

Ryan was placed in Mahon’s police vehicle and transported to the 46th Precinct. During the ride, Mahon allegedly turned and told Ryan:

“This is what happens if you do not give the police what they ask for; you’ll get punched in the face.”

At the precinct, when confronted by Ryan’s mother, Nazima Royster, Mahon allegedly justified the violence with another racially charged remark:

“He’s a Black kid driving a Mercedes-Benz, and the windows are all tinted. Vehicles like that—they [police] search for drugs and guns.”

Fabricated Summons and Legal Misconduct

Despite the absence of probable cause, NYPD officers escalated the misconduct rather than voiding the arrest in accordance with department policy.

Geberth issued Summons No. 4447558422 charging Ryan with Disorderly Conduct under Penal Law § . In the sworn factual section, Geberth alleged that Ryan had refused to provide his driver’s license and stated that he had a license but would not present it. The complaint asserts that this narrative was fabricated, that Ryan never made such statements, and that even if true, such behavior would not meet the statutory elements of Disorderly Conduct, which requires a person to create a “hazardous or physically offensive condition” without a legitimate purpose.

Later that morning, after Ryan had been taken into custody, Officer Patrick Jean issued two additional traffic summonses—one for double parking and one for parking near a fire hydrant. The federal complaint characterizes these charges as retaliatory, written not for public safety, but to lend retroactive legitimacy to an otherwise baseless arrest.

On January 16, 2025, a Bronx Criminal Court judge dismissed the Disorderly Conduct charge outright, finding that the factual allegations—even if accepted as accurate—did not establish a violation of law.

Physical Injuries, Medical Neglect, and Psychological Trauma

After his release from custody, Mr. Ryan sought emergency medical care at Lincoln Hospital, where doctors diagnosed a fractured jaw—a serious injury consistent with blunt force trauma. Despite Ryan’s visible facial injuries and repeated pleas for medical attention while in police custody, officers allegedly delayed summoning an ambulance. When emergency medical personnel eventually arrived, Geberth allegedly discouraged treatment, stating that Ryan would soon be released.

Left to seek care on his own, Ryan was discharged with pain medication, dietary restrictions, and instructions to follow up with a maxillofacial specialist. He continues to suffer from chronic pain, difficulty chewing, facial numbness, and disrupted sleep.

However, the complaint also chronicles emotional and psychological fallout. Ryan, who was once outgoing and social, has become withdrawn and anxious. He describes himself as a “workaholic,” using long hours at his part-time job to distract from intrusive memories of the incident. He avoids public places where police officers may be present and no longer feels safe in his neighborhood.

“I was just trying to make sure my friend got inside safely,” Ryan told his attorney. “They treated me like I didn’t belong in my own skin.”

A Pattern of Institutional Failure

The complaint does not stop at individual misconduct. It details the NYPD’s systemic failure to supervise, discipline, or retrain officers with repeated histories of abuse. All named defendants have been subject to prior civilian complaints and civil rights lawsuits.

• Sergeant  has at least 12 civilian complaints and 10 lawsuits involving allegations of excessive force, false statements, and racial bias. He is listed on the NYPD’s “Adverse Credibility” list.

• Sergeant has 20 civilian complaints, 74 allegations, and over $600,000 in settlements related to misconduct, racial profiling, and excessive force.

• Officer , despite a short tenure, has already been the subject of multiple complaints and lawsuits, including one resolved for $85,000.

• Officers , , and have all been cited in lawsuits or CCRB complaints for abuse of authority, unlawful stops, and constitutional violations.

Despite this extensive history of misconduct, the City of New York employs these officers, often in supervisory roles. The complaint asserts that the NYPD has deliberately ignored red flags, fostering a culture where abuse is tolerated and accountability is elusive.

A Pattern of Abuse: NYPD’s Troubling History of Civil Rights Violations

The misconduct alleged in Mr. Ryan’s federal lawsuit is not an aberration—it echoes a deeply entrenched and well-documented pattern within the New York City Police Department (NYPD). For years, civil rights advocates, legal monitors, and independent oversight bodies have identified widespread issues of excessive force, racial profiling, retaliatory arrests, and falsified documentation, particularly in neighborhoods of color.

Mr. Ryan’s experience—being physically assaulted while handcuffed, falsely charged with disorderly conduct, and denied prompt medical care—fits squarely within a broader institutional context. Over the past decade, the NYPD has repeatedly been at the center of high-profile incidents that mirror the constitutional violations alleged in this case. These incidents have sparked public outrage and led to massive taxpayer-funded settlements and federal court oversight.

Notable Parallel Cases of NYPD Misconduct:

• Eric Garner (2014): Garner, a 43-year-old Black man, died after former NYPD Officer Daniel Pantaleo placed him in a banned chokehold during an arrest for allegedly selling untaxed cigarettes. Video footage captured Garner saying, “I can’t breathe” eleven times before losing consciousness. His death ignited national protests and remains one of the most well-known examples of deadly police misconduct. Despite the public outcry, no officer was criminally charged, and the City later paid $5.9 million to settle a wrongful death lawsuit.

• Delrawn Small (2016): A 37-year-old Black man was shot and killed by off-duty NYPD Officer Wayne Isaacs in a Brooklyn road rage incident. Surveillance footage showed Small being shot within seconds of approaching Isaacs’ vehicle, contradicting the officer’s self-defense claims. Although Isaacs was prosecuted, he was ultimately acquitted. The case fueled further debate over the NYPD’s culture of impunity and the failure of internal discipline systems to hold officers accountable.

• Kawaski Trawick (2019): Trawick, a 32-year-old Black man and aspiring dancer, was shot and killed inside his own Bronx apartment by NYPD officers. Officers forced entry without a warrant, and within two minutes of arrival, fatally shot Trawick—despite clear signs that he was not a threat. The NYPD refused to discipline the officers involved, prompting demands for an independent investigation and raising alarms over mental health-related encounters with police.

• Dounya Zayer (2020): During the George Floyd protests in Brooklyn, Zayer, a young woman of Middle Eastern descent, was violently shoved to the ground by an NYPD officer. She suffered a severe head injury and required hospitalization. The attack, captured on viral video, became emblematic of the NYPD’s aggressive response to peaceful demonstrators, with more than 60 officers later found to have committed misconduct during the 2020 protests.

These cases, like Ryan’s, reflect a broader systemic breakdown, where bias, aggression, and retaliation are not aberrations but recurring features of daily policing in marginalized communities. Civil rights experts argue that the absence of meaningful accountability mechanisms, coupled with a culture of silence and institutional protection, has allowed patterns of abuse to persist across multiple precincts and leadership changes.

In Ryan’s case, the officers involved have prior histories of misconduct, ranging from excessive force and racial profiling to untruthful statements and false arrests. Yet, they remain on active duty, illustrating what many advocates describe as the NYPD’s ongoing failure to police itself.

The lawsuit, therefore, does not merely seek redress for one young man’s suffering—it exposes deep-seated structural flaws in law enforcement that continue to place Black and Latino New Yorkers at disproportionate risk of harm.

Legal Framework: Arlington Heights, Floyd, and Monell Liability

The federal complaint draws on established constitutional doctrine to support its claims. It invokes the Supreme Court’s decision in , 429 U.S. 252 (1977) to argue that Mahon’s racially charged statements—coupled with procedural deviations and retaliatory actions—demonstrate intentional discriminatory enforcement in violation of the Equal Protection Clause.

Further, it cites , 436 U.S. 658 (1978), to establish municipal liability, alleging that the NYPD’s customs and practices—ranging from unlawful stops to falsification of summonses—were the driving force behind Ryan’s rights violation.

The complaint is also bolstered by findings from the , which revealed that:

• Only 58% of frisks and 54% of NYPD Neighborhood Safety Team searches were lawful.

• Over 90% of stops involved Black or Latino individuals;

• Supervisors approved 99.1% of all stop reports, even when they were unconstitutional.

These findings align with the experiences of Mr. Ryan and support the lawsuit’s core contention: that his arrest was not an aberration, but a symptom of an institutional culture of racialized over-policing.

Relief, Reckoning, and the Road to Accountability

The federal lawsuit names the City of New York as defendants, along with Sergeant Brian P. Mahon, Sergeant Joel K. Ayala, Officer James G. Geberth, Officer Crystal L. Dones, Officer John Michael B. Medina, Officer Patrick Jean, and five unidentified officers referred to as John Does 1–5. Each is alleged to have participated in, enabled, or failed to prevent the unlawful arrest, excessive use of force, and racially discriminatory treatment inflicted upon Mr. Ryan.

Under federal and municipal civil rights frameworks, the complaint seeks various legal remedies, including compensatory and punitive damages, declaratory relief, and attorneys’ fees. It asserts violations of 42 U.S.C. § 1983 and claims under the New York City Human Rights Law, which prohibits bias-based profiling and unequal treatment by public servants, including law enforcement.

But the case does more than allege civil infractions—it demands criminal accountability. According to Eric Sanders, the conduct described in the complaint—punching a restrained person in the face, lying under oath, fabricating citations, and failing to intervene or report obvious misconduct—crosses the line into criminality. He has formally called on the U.S. Attorney for the Southern District of New York and the Bronx County District Attorney’s Office to investigate the officers involved.

“This is not just a civil rights lawsuit—it’s a criminal matter,” Sanders said. “Punching a handcuffed person in the face, lying under oath, and fabricating citations to cover it up—those are crimes. And the people who committed them should be prosecuted, not protected.”

This lawsuit represents a rare opportunity for Sanders and his client to hold individuals and an entire system accountable. It tells a larger story—one about how unchecked police authority, racial profiling, and institutional silence can intersect to devastate the life of someone who was trying to make sure a friend got home safely.

“Jaylin wasn’t a threat,” Sanders said. “He was a young man with no criminal record, acting out of care and caution. Instead of being protected, he was assaulted, arrested under pretenses, and then abandoned by the very institutions meant to uphold justice.”

The complaint lays out the brutality of the individual encounter and a broader failure of constitutional governance: where suspicion substitutes for probable cause, where race dictates response, and where retaliatory charges are filed to shield officers from scrutiny. As the lawsuit emphasizes, these are not isolated lapses—they are the logical outcome of a system where misconduct goes unchecked, and repeat offenders remain on patrol.

Whether Jaylin Ryan’s case will catalyze broader institutional change remains to be seen. But as Sanders notes, the suit serves as a legal and moral blueprint—a roadmap for how victims of racialized policing can fight back through the courts and the public sphere. It is also a warning: until meaningful accountability is enforced, constitutional rights remain paper promises for far too many Americans.

“This case is about truth,” Sanders said. “It’s about exposing the lie that equal protection applies to everyone. And it’s about making clear—to the public and to the courts—that if justice means anything, it has to mean something for Black and brown people stopped on the street for doing nothing wrong.”

Contact:

For media inquiries, legal commentary, or to support Mr. Ryan’s case, contact:

¸ŁŔűź§.
30 Wall Street, 8th Floor
New York, NY 10005
ąĘłó´Ç˛Ôąđ:Ěý212-652-2782

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Read the Federal Complaint

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Mayor Eric Adams, Chief Maddrey, and Chief Iglesias Accused of Ratifying Constitutional Violations After Reviewing Body Camera Footage

NEW YORK, NY — Today, April 15, 2025, New York civil rights attorney Eric Sanders of ¸ŁŔűź§. has filed a federal civil rights complaint in the United States District Court for the Southern District of New York on behalf of Messrs. Benjamin A. Trye, Alister Alexander, Wilfred R. Trye, and Harold B. Thomas against multiple officers of the New York City Police Department (NYPD), as well as high-ranking City officials including Mayor Eric L. Adams, former NYPD Chief of Department Jeffrey B. Maddrey, and former Internal Affairs Chief Miguel A. Iglesias. The suit arises from a December 7, 2024, incident in Queens County and alleges systemic racial profiling, excessive force, false arrest, and deliberate municipal inaction.

Incident Overview: A Pattern, Not an Aberration

In the early hours of December 7, 2024, four unarmed Black men—Benjamin A. Trye (driver), Alister Alexander, Wilfred R. Trye, and Harold B. Thomas—were subjected to an unlawful and racially charged stop by officers of the New York City Police Department’s 114th Precinct while traveling through an industrial corridor of Queens, according to the federal complaint. The justification offered for the stop was an alleged violation of Vehicle and Traffic Law § 375(12-a)(2) for excessively tinted windows. However, no tint meter substantiated the claim, violating state law and NYPD policy.

As indicated in the complaint, the officers instead relied solely on subjective visual estimation—a method long criticized for enabling racial profiling—and quickly escalated the encounter into a violent and constitutionally suspect use of force. Mr. Harold B. Thomas, seated in the rear passenger area, was forcibly dragged from the vehicle and thrown to the ground. While restrained, according to the complaint, he was repeatedly punched by Officers Brian A. Guzman and Anthony N. Riccardi. Supervisory officers, including Lieutenant Andrew C. Dickson and former Sergeant Eumir M. Ferrer, stood nearby and took no action to prevent the assault or provide medical aid.

Simultaneously, Mr. Benjamin A. Trye was handcuffed with excessive force, resulting in pain and possible nerve injury. Despite committing no offense, as indicated in the complaint, he was later issued a post-arrest summons for the alleged tint violation—again, without any supporting tint meter measurement. Both Trye and Thomas were allegedly unlawfully detained at the 114th Precinct, and Thomas was subsequently held at Queens Central Booking for several hours. Meanwhile, Mr. Thomas was charged with Obstructing Governmental Administration and Resisting Arrest. These charges were ultimately dismissed via an Adjournment in Contemplation of Dismissal (ACD), entered without his consent.

As indicated in the complaint, before Mr. Benjamin A. Trye and Mr. Thomas were arrested, Mr. Alister Alexander, who was attempting to record the incident on his cell phone, was retaliated against. Officers shined flashlights into his eyes and obstructed his view, while others either deactivated or failed to activate their body-worn cameras, further undermining transparency and compliance with NYPD protocol.

Later that day, retired Detective First Grade Harold Thomas, Sr.—father of Plaintiff Thomas—allegedly contacted Mayor Eric L. Adams, Chief of Department Jeffrey B. Maddrey, and Chief of Internal Affairs Miguel A. Iglesias. According to the complaint, these top City officials acknowledged that Messrs. Benjamin A. Trye, Alexander, Trye, and Thomas had committed no crime and had personally reviewed body-worn camera footage confirming as much. Yet none of them acted. No arrests were voided, no discipline was imposed, and no referrals were made to prosecutorial authorities. As the complaint indicates, Messrs. Benjamin A. Trye, Alexander, Trye, and Thomas contend that this deliberate failure to intervene amounts to official ratifying unlawful conduct.

Messrs. Benjamin A. Trye, Alexander, Trye, and Thomas further allege that the traffic stop and violent arrest were motivated by racial bias, a claim allegedly supported by both direct and circumstantial evidence in line with the framework outlined in Village of Arlington Heights v. Metropolitan Housing Development Corp., 429 U.S. 252 (1977). The complaint cites the stark racial disparities in NYPD traffic enforcement, well-documented histories of misconduct by the officers involved, and the deviation from established legal procedures—all of which, according to them, form a compelling inference of discriminatory intent.

As the complaint indicates, this incident is far from being an isolated occurrence, reflecting systemic failures deeply embedded within the NYPD. The Floyd Monitor’s 23rd Report found that Black residents made up nearly 30% of NYPD vehicle stops in Q4 2024—despite comprising just 22.7% of the city’s population—while white residents accounted for over a third of the population but were stopped less than 18% of the time. Moreover, supervisors routinely approved deficient stop reports and allowed officers with long misconduct records to operate in frontline enforcement roles without accountability.

In this context, as alleged, the December 7, 2024, events are not merely troubling—they are tragically predictable. They mirror the same patterns of racialized policing and institutional inaction that contributed to the deaths and injuries of other New Yorkers, including Eric Garner, Delrawn Small, Kawaski Trawick, Dounya Zayer, and, more recently, Jaylin Ryan, according to the complaint. Like those cases, this encounter began with a minor pretext, escalated without justification, and was followed by silence at the highest levels of City leadership.

Post-Incident Ratification by City Leadership

What unfolded after the December 7 incident was as telling as the violence itself. Within hours of the unlawful arrest and alleged assault, Mr. Thomas’s parents—both longtime, now retired NYPD veterans—reached out to the highest levels of city government. Retired Detective First Grade Harold Thomas, Sr., and retired Detective Second Grade Ila Thomas made direct contact with Mayor Eric L. Adams, NYPD Chief of Department Jeffrey B. Maddrey, and Chief of Internal Affairs Miguel A. Iglesias.

According to the federal complaint, each official acknowledged having reviewed body-worn camera footage from the incident. Each confirmed, at least privately, that Messrs. Benjamin A. Trye, Alexander, Trye, and Thomas had not committed any crime. Despite this, none of the officials took meaningful corrective action. The arrests were not voided. The officers involved were not disciplined. No internal or external investigations were launched. No referrals were made to the Queens District Attorney’s Office or federal authorities. The City remained silent.

The complaint asserts that this inaction constitutes more than just bureaucratic passivity—it represents deliberate indifference and official ratification of unconstitutional conduct. Messrs. Benjamin A. Trye, Alexander, Trye, and Thomas argue that the decision to do nothing in the face of clear evidence transformed what might have been an individual act of misconduct into a systemic constitutional failure.

NYPD Statistical Data Reveal Racial Disparities

The allegations in the lawsuit are not occurring in a vacuum. They are consistent with—and supported by—publicly available NYPD data revealing persistent racial disparities in traffic enforcement. According to NYPD’s Q4 2024 vehicle stop statistics:

• Although black residents comprised only 22.7% of the city’s population, they accounted for 29.8% of all traffic stops.

• By contrast, white residents constituted 35.9% of the population but were the subject of just 17.8% of such stops.

• Hispanic residents represented 28.4% of the population and were stopped at a proportional rate of 29%.

• Asian residents, comprising 14.6% of the population, were stopped at a slightly lower rate of 12.3%.

The complaint alleges that this pattern of racial disparity in enforcement reflects a longstanding institutional problem within the NYPD. These disparities are not simply numerical—they represent the lived experiences of communities subjected to disproportionate suspicion, detention, and violence. When stops are initiated not based on behavior but on race and location, the legal framework collapses into systemic bias.

Floyd Monitor’s 23rd Report: Systemic Failures Within the NYPD

Further, allegedly bolstering the complaint’s claims is the from the court-appointed monitor in Floyd v. City of New York, tracking NYPD stop-and-frisk practices since the landmark litigation declared them unconstitutional in 2013. The findings of the most recent report are alarming:

• Only 75% of NYPD Neighborhood Safety Team (NST) stops were deemed lawful, compared to 92% of stops by regular patrol officers.

• Just 54% of NST searches were supported by legal justification, meaning nearly half were unconstitutional.

• An overwhelming 95% of documented stops and 93% of corresponding body-worn camera footage involved Black or Latino individuals.

• Despite this, NYPD supervisors approved 99.1% of stop reports as lawful—even when independent audits flagged serious constitutional issues.

• Notably, 70% of NST stops were self-initiated, often without oversight, suggesting a broader culture of unsupervised discretion and abuse.

Messrs. Benjamin A. Trye, Alexander, Trye, and Thomas argue that the Floyd Monitor’s findings provide a damning institutional context for the December 7 stop. What happened to them, they contend, was not an isolated act—it was emblematic of a system where unconstitutional conduct is predictable, normalized, and tacitly approved.

Officers’ Histories Reveal Pattern of Misconduct

The complaint also details the troubling disciplinary histories of the individual officers involved, raising serious questions about the NYPD’s commitment to accountability and supervision:

Lieutenant Andrew C. Dickson
Named in at least two federal lawsuits, was accused of excessive force, including drawing a weapon on unarmed teenagers and engaging in a violent takedown involving kicking and stomping. Internal disciplinary action, if any, has been minimal. Despite the severity of these allegations, Dickson remains in a leadership position and was present at the scene of the December 7 incident as a supervising officer.

Lieutenant (formerly Sergeant) Eumir M. Ferrer
Eumir M. , now promoted to Lieutenant, has accumulated a troubling record of 22 misconduct allegations over his NYPD career, six substantiated by oversight authorities. These include findings of unlawful vehicle stops, improper searches, and the issuance of retaliatory summonses. Ferrer has also been named in multiple civil rights lawsuits involving allegations of excessive force and false arrest. In one particularly egregious incident, he allegedly pulled a man from a tow truck and detained him on fabricated grounds. Despite the seriousness of these claims and confirmed policy violations, Ferrer has faced minimal consequences—limited mainly to command discipline and retraining. His recent promotion underscores what Messrs. Benjamin A. Trye, Alexander, Trye, and Thomas describe as a culture of impunity within the NYPD.

Officer Brian A. Guzman
The initiating officer of the December 7 stop, , has faced at least four official complaints and been named in two civil lawsuits, resulting in settlements totaling $45,000. Allegations against him include the use of force against Black and Hispanic individuals, including an incident where a vehicle was allegedly used as a weapon. None of these complaints resulted in meaningful disciplinary consequences.

Officer Anthony N. Riccardi
¸éžąłŚłŚ˛š°ůťĺžąâ€™s includes several misconduct complaints, including excessive force, refusal to provide identification under the Right to Know Act, and discourteous conduct during vehicle stops. Although one allegation was substantiated, no significant penalties were imposed. Riccardi remains in uniform and was directly involved in the alleged assault and fabrication of charges against Mr. Thomas.

“These are not isolated actors,” Eric Sanders noted. “Each officer has a documented history of complaints, and each was empowered—rather than restrained—by the NYPD. That’s not just negligence. That’s institutional failure.”

Claims and Remedies Sought

The federal civil rights complaint, filed in the United States District Court for the Southern District of New York, brings multiple claims against the individual officers, supervisors, and the City of New York. These include:

• Violations of the First, Fourth, and Fourteenth Amendments to the U.S. Constitution under 42 U.S.C. § 1983, including unlawful search and seizure, excessive force, fabrication of evidence, equal protection violations, and retaliation for protected activity;

• Municipal liability under Monell v. Department of Social Services for the NYPD’s failure to train, supervise, and discipline officers known to engage in misconduct;

• Violations of the New York City Human Rights Law (Administrative Code § 8-107(17)) for bias-based profiling and racially discriminatory enforcement;

• Requests for declaratory relief, compensatory and punitive damages, attorneys’ fees and costs under 42 U.S.C. § 1988 and NYC Admin. Code § 8-502(f), and injunctive relief to ensure oversight and compliance with constitutional standards.

Call to Action

“This case is about more than one night of abuse,” said New York civil rights attorney Eric Sanders. “It is about the architecture of impunity that allows unlawful stops, violent takedowns, and retaliatory arrests to go unpunished. We cannot tolerate a system where misconduct is seen, acknowledged, and ignored by those with the power to act.”

He continued, “Mayor Adams saw the footage. He knew what had happened. And yet, he chose silence. That silence is not just political—it is constitutional.”

Contact Information

¸ŁŔűź§.
30 Wall Street, 8th Floor
New York, NY 10005
ąĘłó´Ç˛Ôąđ:Ěý212-652-2782

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Read the Federal Complaint

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Legal Filing Alleges NYPD Officers Used Excessive Force and Unlawful Detention Over E-Bike Stop

New York, NY – February 22, 2025, A Brooklyn woman, Keyanna Moody, has filed an Amended Notice of Claim against the City of New York and multiple NYPD officers, alleging that she was unlawfully arrested, physically assaulted, subjected to racial slurs, and denied medical care after purchasing cotton candy for her five-year-old daughter in Coney Island on June 11, 2024. The claim asserts that officers wrongfully accused Moody of operating an unregistered vehicle, violently tackled her to the ground, and detained her under inhumane conditions.

The claim names several NYPD officers from the 60th Precinct, including Lieutenant Special Assignment Daniel Lacalamita, Sergeant Stanislav Zubyk, Police Officer Michael R. Moran, Police Officer Alvin M. Nieves, and Police Officer Jared W. Cordero, as individuals responsible for violating Moody’s constitutional rights.

Cotton Candy Purchase Leads to Brutal Arrest

According to the claim, on June 11, 2024, at approximately 8:15 PM, Moody and her husband rode their e-bikes at Canarsie Pier before deciding to head to Coney Island to buy cotton candy for their daughter. Moody operated a Z6 Fly E-Bike, a high-performance electric bike that did not require a license or registration under New York law.

At approximately 8:40 PM, after purchasing the cotton candy, the claim states that an unmarked NYPD vehicle and a police scooter aggressively maneuvered to block Moody’s movement. Officers allegedly exited their vehicles and immediately confronted Moody with hostility.

As detailed in the claim, Officer Nieves unlawfully seized Moody’s e-bike keys from the ignition without explanation, demanding license and registration—documents not legally required for her Z6 Fly E-Bike. The claim asserts this was an unlawful deprivation of property and an abuse of authority.

Recognizing the officers’ aggressive behavior, as alleged in the claim, Moody’s husband urged her to sit down to de-escalate the situation, which she did. As indicated in the claim, despite Moody’s compliance, officers continued to insist she provide documentation that was not required by law. The claim states that Lieutenant Lacalamita threatened Moody with arrest, and when she reiterated that the documents were unnecessary, he immediately ordered her arrest.

Allegations of Excessive Force and Racial Slurs

According to the claim, Officers Moran and Cordero violently tackled Moody to the ground without justification, injuring her knees, back, and arms. The claim further states that Officer Nieves attempted to deploy his Taser multiple times but, when unsuccessful, joined in physically restraining Moody by placing his knee on her back. At the same time, Officer Moran stepped on her legs.

The claim alleges that at least five additional officers stood by and failed to intervene while this occurred.

As Moody was being pulled toward a patrol car, the claim asserts that Lieutenant Lacalamita called her a ‘black bitch’ and attempted to slap and kick her before forcefully pulling her head and neck downward toward the vehicle. The claim further states that Moody was thrown face-first into the backseat—a practice inconsistent with NYPD guidelines prohibiting placing handcuffed individuals in a prone position due to the risk of positional asphyxia.

Post-Arrest Assault and Medical Neglect at the 60th Precinct

The claim details that at the 60th Precinct, Moody was brought before a desk officer while still handcuffed, where Lieutenant Lacalamita suddenly kicked her to the floor without provocation. The claim states that while she lay on the floor, Lacalamita stood over her and ordered her to ‘get the f* up’**, while the desk officer failed to intervene.

Despite the presence of a female officer, the claim alleges that male officers conducted a full-body search, making inappropriate physical contact with her breasts, vaginal area, buttocks, and thighs. Moody’s repeated requests to know the charges against her were ignored.

Five-Hour Denial of Medical Care

According to the claim, Moody’s visible injuries included bleeding knees, ripped clothing, and dirt stains. Yet, she was denied medical attention and placed in a holding cell for over five hours, during which she repeatedly requested medical care from Officers Cordero and Nieves but was ignored.

Only after she refused to provide her fingerprints were paramedics finally called. Upon assessment, EMTs determined Moody needed medical treatment for her injuries.

Hospital Misconduct and Lack of Medical Examination

The claim states that Moody’s vitals were taken at South Shore Brooklyn Hospital, and she was placed in the resuscitation area. However, Lieutenant Lacalamita reappeared, approaching her from behind. When Moody saw him, she allegedly voiced her fear and demanded that he leave, to which he falsely responded, “I’m not him. I wasn’t there.”

The claim further alleges that after approximately two hours, a doctor abruptly discharged Moody without conducting a complete examination. When she requested discharge papers, the doctor refused, handing them to the NYPD officer escorting her. Moody later discovered through medical records that her treating physician was Dr. Spencer Doblin Kim.

Charges Dismissed, But Police Made Property Retrieval Difficult

According to the claim, Moody was transported back to the 60th Precinct at approximately 3:30 AM and later transferred to Brooklyn Central Booking at 10:00 AM.

When she appeared before a judge, her attorney was absent, and the District Attorney vaguely stated the charges as ‘something about numbers’ before the judge dismissed the case.

Despite the dismissal, the claim asserts that Moody faced significant obstacles in retrieving her personal property, including her Z6 Fly E-Bike, money, jewelry, phone, and ID. When she presented a property release form issued by the DA’s Office, officers at the 60th Precinct refused to release her belongings, falsely claiming she needed a license, registration, and insurance for her e-bike. They then threatened her with arrest if she did not leave the precinct immediately.

NYPD Statistical Data Confirms Pattern of Racial Profiling

The Floyd Monitor’s 23rd Report provides compelling evidence that the NYPD disproportionately targets Black and Latino individuals. Recent NYPD statistical data confirms that:

• Black residents (22.7% of NYC’s population) account for 29.8% of NYPD vehicle stops, while
• White residents (35.9% of NYC’s population) account for only 17.8% of stops.
• Neighborhood Safety Teams (NSTs) conduct unlawful stops at a rate of 25%—far higher than standard NYPD patrols.

The claim states that these disparities support allegations of racial profiling, unlawful search and seizure, and excessive force.

Pattern of NYPD Misconduct and Similar Cases of Civil Rights Violations

The NYPD has a long and documented history of excessive force, racial profiling, and unconstitutional policing—particularly in communities of color. Mrs. Moody’s case is not an isolated incident but rather part of a systemic problem that has resulted in wrongful deaths, excessive force incidents, and legal settlements costing taxpayers millions of dollars.

Notable similar cases include:

• Eric Garner (2014): Died after NYPD Officer Daniel Pantaleo placed him in a prohibited chokehold while arresting him for allegedly selling loose cigarettes. His final words, “I can’t breathe,” became a national rallying cry against police brutality.
• Delrawn Small (2016): Shot and killed by an off-duty NYPD officer during a road rage incident. Video evidence contradicted the officer’s self-defense claims, yet no conviction followed.
• Kawaski Trawick (2019): Shot and killed inside his apartment after NYPD officers entered without cause and escalated a non-threatening situation into a fatal encounter.
• Dounya Zayer (2020): Knocked to the ground by an NYPD officer during the George Floyd protests, resulting in severe head trauma.
• Jaylin Ryan (2024): Ryan alleges false arrest, excessive force, and racial discrimination after officers handcuffed and punched him in the face, fracturing his jaw during a December 28, 2024, incident in the Bronx.
• Harold Thomas (2024): The legal filing alleges that Harold B. Thomas was unlawfully stopped, assaulted, and subjected to excessive force by NYPD officers, resulting in severe injuries.

Legal Action and Call for Reform

Moody seeks damages for medical expenses, pain and suffering, emotional distress, and punitive damages for violating her civil rights. The City of New York is also implicated in failing to train, supervise, and discipline officers engaged in unconstitutional conduct.

Eric Sanders, Esq., of ¸ŁŔűź§., stated:

“This case is yet another disturbing example of how unchecked police power leads to the mistreatment of innocent civilians. Mrs. Moody was violently arrested, humiliated, and denied basic medical care—for operating an E-Bike. This is a clear abuse of authority and highlights the systemic issues of racial profiling, excessive force, and lack of accountability within the NYPD. We will not stop until justice is served and those responsible are held accountable.”

Contact Information:

¸ŁŔűź§.
30 Wall Street, 8th Floor
New York, NY 10005
Phone: 212-652-2782

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Read Amended Notice of Claim

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Veteran NYPD Lieutenant Files EEOC Charge Alleging Racial Discrimination, Retaliation, and Corruption Within the Department 

New York, NY – February 13, 2025, Lieutenant Emelio C. Rodrigues, a decorated officer with over two decades of service in the New York City Police Department (NYPD), has filed a Charge of Discrimination with the United States Equal Employment Opportunity Commission (EEOC) against the City of New York – NYPD Legal Bureau. The charge, filed under EEOC Charge Number: 520-2025-03104, alleges that the NYPD engaged in racial discrimination, subjected him to a hostile work environment, and retaliated against him for exposing corruption and misconduct within the department.

Rodrigues asserts that he became the target of systematic retaliation after refusing to comply with selective enforcement practices that shielded certain nightlife establishments from legal scrutiny due to their connections with high-ranking NYPD officials. He further contends that his refusal to participate in these corrupt practices resulted in an ongoing campaign of intimidation, professional sabotage, and efforts to destroy his career.

According to the charge, Rodrigues witnessed a coordinated effort by senior officials, including Commanding Officer Aneudy Castillo, Executive Officer Erickson Peralta, Special Operations Lieutenant Michael J. Disanto, and Former Administrative Lieutenant Jonathan Cruz, within the 34th Precinct, which covers Washington Heights, to selectively enforce or ignore laws based on personal relationships and undisclosed financial interests. He specifically alleges that James Caban, the twin brother of former Police Commissioner Edward A. Caban, maintained an undisclosed relationship with Castillo. This resulted in regular phone calls and in-person meetings where selective enforcement decisions were made. These discussions allegedly determined which businesses and individuals within the Washington Heights area were subject to police action and which were shielded from enforcement. As a result, certain nightclubs and lounges with ties to the former commissioner’s family were deliberately exempted from law enforcement oversight, regardless of the volume of complaints or criminal activities reported at those locations.

Rodrigues claims that officers were explicitly ordered to disregard violations and close out 311 complaints about these establishments without taking action. Despite numerous reports involving crimes such as noise violations, illegal activities, and disturbances, Castillo and Disanto directed officers to refrain from enforcement efforts and suppress any police response. Rodrigues, responsible for overseeing operations, questioned these unlawful practices, which he believes led to immediate retaliation against him.

The charge details a pattern of financial misconduct within the department, including manipulating overtime assignments for personal gain. Rodrigues states that Castillo ensured that Lieutenant Disanto and Officer Vincent G. Bracco were granted no less than 40 hours of overtime per month despite not performing legitimate law enforcement duties. Overtime codes intended for specific events, including Israeli protests, were misused to funnel taxpayer money into the paychecks of favored officers. Disanto received a discretionary promotion to Lieutenant Special Assignment in exchange for their loyalty, while Castillo was overlooked despite expecting his promotion. Rodrigues contends that his refusal to participate in these fraudulent practices led to further targeting by Castillo and his associates.

The charge also alleges that Rodrigues endured a hostile work environment, where Castillo and Disanto openly referred to themselves as “the mafia” and warned him that if one of them had a problem with him, the entire “family” did. This workplace hostility escalated after Rodrigues went out on medical leave due to a cardiac condition. During this time, Castillo called him repeatedly, accusing him of “playing sick” and demanding that he work from home despite his medical restrictions. On several occasions, Castillo launched profanity-laced tirades over the phone, which were overheard by Rodrigues’ ten-year-old child, causing lasting emotional distress. When Rodrigues resisted these demands, Castillo took further retaliatory action by making false allegations about his mental health, which resulted in the unjust removal of his firearm and his placement on restricted duty.

Rodrigues’ EEOC filing details how Castillo and his associates deliberately undermined his career by blocking his overtime, reassigning him to the midnight shift, and falsely reporting him as insubordinate to superior officers. Castillo allegedly contacted Rodrigues’ new command and instructed them not to extend him any professional courtesies, ensuring his reputation was tarnished. His opportunities for advancement within the NYPD were severely limited.

In addition to the financial misconduct and retaliation, the charge outlines allegations of sexual misconduct within the department, specifically involving Lieutenant Disanto and Former Domestic Violence Sergeant Christina Ortiz. Rodrigues, as alleged in the charge, claims that Disanto and Ortiz engaged in an inappropriate sexual relationship within 34th Precinct offices, including the Domestic Violence Office and the Commanding Officer’s Office, with clear evidence left behind, such as broken nails found in offices where these encounters occurred. Rodrigues contends that Castillo was fully aware of this misconduct but chose to ignore it, further reinforcing the department’s corruption culture, as alleged in the charge.

Despite meeting all qualifications necessary for reinstatement to full duty, Rodrigues remains unjustly restricted with no explanation. The charge states that his prolonged restriction is a direct act of retaliation designed to diminish his career and silence his ongoing concerns regarding NYPD misconduct. The refusal to reinstate him to full duty has negatively impacted his ability to earn overtime, pursue promotions, and perform his responsibilities as a law enforcement officer.

Through his EEOC charge, Rodrigues seeks multiple remedies, including full reinstatement to duty, removal of all retaliatory employment actions from his record, compensatory damages for lost wages and emotional distress, and an independent federal investigation into the NYPD’s systemic corruption and selective enforcement practices.

His attorney, Eric Sanders, Esq., stated, “Lieutenant Rodrigues has dedicated over two decades to protecting and serving the people of New York, only to be repaid with retaliation, racial discrimination, and workplace harassment for doing the right thing. His case is a glaring example of the corruption within the NYPD’s upper ranks. No officer should be punished for refusing to engage in selective enforcement, payroll fraud, and cover-ups. We are calling for a full federal investigation into the practices of the NYPD and those responsible for Lieutenant Rodrigues’ mistreatment.”

The EEOC has officially acknowledged receipt of the charge and notified the City of New York—NYPD Legal Bureau. Under federal guidelines, the NYPD has ten days to respond. The case may also be referred to state and local Fair Employment Practices Agencies (FEPAs) for concurrent investigation.

Contact:

For media inquiries, legal commentary, or to support Mr. Rodriques’s case, contact:

¸ŁŔűź§.
30 Wall Street, 8th Floor
New York, NY 10005
ąĘłó´Ç˛Ôąđ:Ěý212-652-2782

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EEOC Charge of Discrimination

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Four Men File Notice of Claim Alleging NYPD Officers Targeted Them Without Cause, Assaulted One, and Attempted to Obstruct Evidence

New York, NY – February 9, 2025 – A Notice of Claim has been formally filed with the New York City Comptroller’s Office on behalf of Claimants Benjamin A. Trye, Alister Alexander, Wilfred R. Trye, and Harold B. Thomas, alleging racially discriminatory policing practices, unconstitutional stops, excessive force, and wrongful arrests by officers of the New York City Police Department (NYPD). The filing details a December 7, 2024, incident in Queens where Claimants were unlawfully stopped, physically assaulted, and detained without legal justification.

Allegations in the Notice of Claim

The Notice of Claim alleges that on December 7, 2024, at approximately 4:00 a.m., Claimants Benjamin A. Trye, Alister Alexander, Wilfred R. Trye, and Harold B. Thomas were legally traveling in a 2021 Mercedes-Maybach Sedan S580 with New York Registration KZY 2940 in Queens when they became the targets of an unlawful and discriminatory police stop. The claim asserts that the Claimants had recently patronized Starlet’s of New York, located at 49-09 25th Avenue, Woodside, NY 11377, and were proceeding northwest on 25th Avenue toward 49th Street when they were subjected to what they describe as a racially motivated pretextual stop.

According to the Notice of Claim, Claimant Trye, the driver, observed an unmarked dark vehicle ahead of him and another behind him, maneuvering in a manner that appeared to box in his vehicle. Upon reaching the traffic light at 49th Street, Claimant Trye initiated a right turn onto 49th Street, heading northeast. Immediately after completing the turn, the dark vehicles suddenly activated their emergency lights, signaling for Claimant Trye to stop.

The Notice of Claim asserts that this vehicle stop was unlawful and racially motivated, lacking reasonable suspicion or probable cause.

The claim further states that an unidentified male approached the driver’s side window and declared that the tint on the windows was too dark. The individual, later identified as Police Officer Brian A. Guzman (Shield No.: 22997, Tax Registry No.: 971080), then ordered Claimant Trye to exit the vehicle. However, Officer Guzman failed to use a tint meter to measure the visible light transmission (VLT%) of the windows, as required under New York Vehicle and Traffic Law (VTL) § 375(12-a)(2), rendering any issued citation unenforceable and unconstitutional.

The Claimants allege that this traffic stop was pretextual and based solely on an officer’s subjective visual estimation, which does not meet the legal standard for enforcement. The Notice of Claim alleges that the NYPD routinely applies window tint laws disproportionately against Black and Latino drivers as a justification for stops, searches, and interrogations in a pattern of racial profiling.

Escalation and Use of Excessive Force

As the stop escalated, Sergeant Eumir M. Ferrer (Shield No.: 2512, Tax Registry No.: 943232) approached the passenger side and aggressively ordered Claimant Alexander to exit the vehicle, shouting, “Get the f* out of the car.”** Claimant Harold N. Thomas, not understanding what was occurring, attempted to display Police Benevolent Association (PBA) cards, which Sergeant Ferrer discarded.

At that moment, Claimant Alexander heard a commotion and observed Claimant Thomas falling out of the vehicle and landing on the ground near the curb. He saw multiple NYPD officers surrounding Claimant Thomas, who was facedown on the pavement, while Police Officer Guzman and Police Officer Anthony N. Riccardi (Shield No.: 13105, Tax Registry No.: 970134) repeatedly punched him in the head, face, and body.

The Notice of Claim further alleges that while this assault occurred, Sergeant Ferrer and Lieutenant Andrew C. Dickson (Tax Registry No.: 943170) stood idly by and did not intervene.

Claimant Alexander, who was recording the incident, asserts that several officers, including Sergeant Ferrer, used flashlights to obstruct his camera view. Additionally, officers allegedly turned off their body-worn cameras to conceal their actions.

The Notice of Claim also states that Lieutenant Dickson falsely denied that officers had struck Claimant Thomas.

False Arrest and Prolonged Detention

The Notice of Claim states that the driver, Claimant Trye, was handcuffed and ultimately issued a summons for a VTL § 375(12-a)(2) window tint violation despite Police Officer Guzman failing to measure the tint with a legally required tint meter.

Claimant Thomas was charged with Obstructing Governmental Administration and Resisting Arrest despite not physically interfering with police activity.

Claimant Trye, the driver, and Claimant Thomas were transported to the 114th Precinct, where Trye was detained in a holding cell for several hours before being released with a universal summons. Thomas was allegedly held for 7.5 hours in a holding cell before being transferred to Queens Central Booking, where he remained for an additional 10 hours.

At Claimant Thomas’s arraignment before the Honorable Edward Daniel in Criminal Court, Part AR3, Docket No.: CR-042168-24QN, his case was adjourned in contemplation of dismissal (ACD) without his consent.

Harold Thomas Transcript- 12.7.24

Post-Arrest Allegations and City’s Response

The Notice of Claim alleges that on the morning of December 7, 2024, Claimant Thomas’s mother, retired NYPD Detective Second Grade Ila Thomas (Quality Assurance), was denied visitation at the 114th Precinct in what is described as an attempt to suppress evidence of the brutal police assault.

Later that afternoon, Claimant Thomas’s father, retired NYPD Detective First Grade Harold Thomas Sr. (Joint Terrorism Task Force), engaged in discussions with Mayor Eric L. Adams, former Chief of Department Jeffrey B. Maddrey, and former Chief of Internal Affairs Miguel A. Iglesias. These officials allegedly admitted to reviewing multiple body-worn camera (BWC) videos, including footage from Police Officer Riccardi, and confirmed that none of the Claimants had violated any laws. However, despite acknowledging the lack of any legal justification for the arrests or use of force, no action was taken against the officers, and the matter was not referred to the Queens District Attorney’s Office – Public Corruption Bureau or the U.S. Attorney’s Office for the Eastern District of New York.

Officer Profiles

The Notice of Claim details prior documented misconduct allegations against the officers involved in the incident:

• Lieutenant Andrew C. Dickson has a history of excessive force complaints, racial bias, and lawsuits related to civil rights violations.
• Sergeant Eumir M. Ferrer has had multiple substantiated allegations of excessive force, unlawful stops, and retaliatory summonses.
• Police Officer Brian A. Guzman has been named in multiple lawsuits with financial settlements related to excessive force and civil rights violations.
• Police Officer Anthony N. Riccardi has been accused of failure to provide legally required identification and excessive force, reinforcing patterns of misconduct.

NYPD Statistical Data

An analysis of NYPD vehicle stops in Q4 2024 reveals stark racial disparities:

• Black individuals accounted for 29.8% of all stops despite comprising only 22.7% of NYC’s population.
• White individuals accounted for only 17.8% of stops despite making up 35.9% of the population.
• Neighborhood Safety Team (NST) officers were responsible for a disproportionate number of unlawful stops, with 42% of their searches ruled unconstitutional.

These Claimants allege that the statistics support the assertion that the NYPD engages in racial profiling and selective enforcement.

Findings from the Floyd Monitor’s 23rd Report

The Floyd Monitor’s 23rd Report, which evaluates NYPD compliance with court-ordered reforms, found:

• 95% of stop reports and 93% of body-worn camera (BWC) footage involved Black or Hispanic individuals.
• 42% of frisks and 46% of searches were unlawful.
• Supervisors failed to intervene in cases of racial profiling, approving 99.1% of stop reports as ‘lawful’ even when unconstitutional.

Pattern of NYPD Misconduct and Similar Cases of Civil Rights Violations

The NYPD has a long and documented history of excessive force, racial profiling, and unconstitutional policing—particularly in communities of color. Mr. Ryan’s case is not an isolated incident but rather part of a systemic problem that has resulted in wrongful deaths, excessive force incidents, and legal settlements costing taxpayers millions of dollars.

Notable similar cases include:

• Eric Garner (2014): Died after NYPD Officer Daniel Pantaleo placed him in a prohibited chokehold while arresting him for allegedly selling loose cigarettes. His final words, “I can’t breathe,” became a national rallying cry against police brutality.
• Delrawn Small (2016): Shot and killed by an off-duty NYPD officer during a road rage incident. Video evidence contradicted the officer’s self-defense claims, yet no conviction followed.
• Kawaski Trawick (2019): Shot and killed inside his apartment after NYPD officers entered without cause and escalated a non-threatening situation into a fatal encounter.
• Dounya Zayer (2020): Knocked to the ground by an NYPD officer during the George Floyd protests, resulting in severe head trauma.
• Jaylin Ryan (2024): Ryan alleges false arrest, excessive force, and racial discrimination after officers handcuffed and punched him in the face, fracturing his jaw during a December 28, 2024, incident in the Bronx.

Legal Claims Asserted Under:

1. Federal Laws:

• Fourth Amendment Violations – Unlawful Search & Seizure, Excessive Force (42 U.S.C. § 1983)
• Fourteenth Amendment Violations – Equal Protection, Due Process (42 U.S.C. § 1983)
• False Arrest and Unlawful Detention – (42 U.S.C. § 1983)
• Excessive Force and Police Brutality – (42 U.S.C. § 1983)
• Racial Profiling and Selective Enforcement – (42 U.S.C. § 1983) Violation of Equal Protection Clause
• Failure to Intervene – (42 U.S.C. § 1983) Liability for officers who failed to stop excessive force
• Malicious Prosecution – Fourth and Fourteenth Amendments (42 U.S.C. § 1983)
• Retaliation for Exercising Constitutional Rights – First Amendment Violation (42 U.S.C. § 1983)
• Monell Monell Liability (Municipal Liability) – City of New York: Failure to Train, Supervise and Discipline permitting a pattern of unconstitutional conduct.

2. New York City Local Laws:

• New York City Human Rights Law (Administrative Code § 8-107) – Discriminatory Policing and Racial Profiling

Call For Immediate Action

¸ŁŔűź§. demands immediate accountability for the NYPD’s egregious civil rights violations. The brutal assault, false arrests, and racial profiling detailed in this case reflect a systemic failure in policing and oversight. We call upon:

• Mayor Eric L. Adams and NYPD Commissioner Jessica A. Tisch to launch an independent investigation into the involved officers and their supervisors.
• The Queens District Attorney and the U.S. Attorney’s Office for the Eastern District of New York to pursue criminal charges against officers who engaged in or facilitated the assault and false arrests.
• The New York City Council and State Legislature to strengthen oversight and pass reforms preventing racial profiling and excessive force.
• Community members and civil rights advocates demand transparency, justice, and systemic change.

We will not tolerate unchecked police violence and will pursue every legal avenue to hold the City of New York accountable.

STATEMENT FROM THE SANDERS FIRM, P.C.

Eric Sanders, Esq., of ¸ŁŔűź§., stated:

“The violent and unconstitutional treatment of these four men by the NYPD is a direct violation of their civil rights and another glaring example of racial profiling and police brutality. The officers involved acted with impunity, escalating a baseless stop into a violent assault, while supervisors failed to intervene. This case is not an isolated incident—it is part of a deeply entrenched pattern of misconduct. The failure to discipline or prosecute officers who engage in excessive force and false arrests only emboldens further violations. We will fight relentlessly for justice, accountability, and civil rights protection for all New Yorkers.”

Contact:

For media inquiries, legal commentary, or to support Mr. Ryan’s case, contact:

¸ŁŔűź§.
30 Wall Street, 8th Floor
New York, NY 10005
ąĘłó´Ç˛Ôąđ:Ěý212-652-2782

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New York City Comptroller’s Notice of Claim 

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