Case 1:24-cv-00993-MAD-CFH Document 1 Filed 08/13/24 Page 1 of 12

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF NEW YORK

BRADLEY W. CRANNELL and

MICHAEL P. LLOYD,

Plaintiffs, Case No. 1:24-cv-993 (MAD/CFH)

v.
42 U.S.C. § 1983 COMPLAINT
FOR DAMAGES

SARATOGA COUNTY,
SARATOGA COUNTY SHERIFF’S USE OF EXCESSIVE FORCE
DEPARTMENT and SARATOGA COUNTY
SHERIFF DEPUTY ALEXANDER RONEY, UNREASONABLE SEARCH AND
SEIZURE

Defendant. MONELL LIABILITY

DEMAND FOR JURY TRIAL

HACKER MURPHY, LLP

James C. Knox, Esq.
Bar Roll No. 517109
Attorneys for Plaintiffs
28 Second Street
Troy, New York 12180
Telephone: (518) 274-5820

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NOW COMES plaintiffs BRADLEY W. CRANNELL and MICHAEL P. LLOYD, by

and through their attorneys, HACKER MURPHY, LLP, complaining of defendants

SARATOGA COUNTY, SARATOGA COUNTY SHERIFF’S DEPARTMENT and

SARATOGA COUNTY SHERIFF DEPUTY ALEXANDER RONEY alleging as follows:

BACKGROUND AND JURISDICTION

1. This is an action for money damages bought pursuant to 42 U.S.C. §§ 1983 and

1988 and the Fourth and Fourteenth Amendments to the United States Constitution. Jurisdiction

is based upon 28 U.S.C. §§ 1331 and 1343.

2. Defendants made an unreasonable seizure of plaintiffs in violation of their rights

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

violated those same Amendments by using excessive force against plaintiffs.

PARTIES

3. Plaintiffs are residents of the State of New York.

4. At all relevant times, defendant SARATOGA COUNTY is a municipality with

authority over defendant SARATOGA COUNTY SHERIFF’S DEPARTMENT and its officers,

including defendants SARATOGA COUNTY SHERIFF DEPUTY ALEXANDER RONEY

5. At all relevant times, defendant SARATOGA COUNTY SHERIFF DEPUTY

ALEXANDER RONEY (hereinafter “RONEY”) was a duly-appointed and acting law

enforcement officer of the sheriff’s department of the defendants COUNTY OF SARATOGA and

COUNTY OF SARATOGA SHERIFF’S DEPARTMENT, acting under color of the statutes,

ordinances, regulations, policies, customs, practices and usages of the COUNTY OF SARATOGA

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and COUNTY OF SARATOGA SHERIFF’S DEPARTMENT.

DEMAND FOR JURY TRIAL

6. Plaintiffs demand a jury trial on all causes of action.

FACTS

7. On July 10, 2023, plaintiffs BRADLEY W. CRANNELL (hereinafter

“CRANNELL”) and MICHAEL P. LLOYD (hereinafter “LLOYD”) were lawfully at their

residence located at , Ballston Spa, New York.

8. At approximately 10:00 p.m. on said date, in the course of his employment,

defendant RONEY traveled to plaintiff CRANNELL’s property where plaintiffs reside in response

to a third-party report of a disturbance.

9. Dispatch called out over the radio that several individuals were fighting or arguing

in front of the residence at .

10. Defendant RONEY pulled up to the property without active emergency lights or

sirens.

11. Defendant RONEY did not observe any individuals in front of the residence.

There did not appear to be any disturbance and there were no signs of fighting or arguing.

12. Defendant RONEY did not knock on the front door of the residence.

13. Defendant RONEY did not call out to see if anyone had requested police.

14. Defendant RONEY made an independent decision to enter the curtilage of the

property, without a warrant or probable cause to believe that a crime was in progress.

15. Defendant RONEY never announced himself as a police officer nor indicated his

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purpose.

16. Defendant RONEY proceeded into the backyard of the residence, shining his police

style, high powered flashlight in front of him.

17. When defendant RONEY entered the backyard of the residence, he shined the light

in the faces of plaintiff CRANNELL.

18. Plaintiff CRANNELL, not knowing who defendant RONEY was or that he was a

law enforcement officer – and believing him to be an unlawful intruder (which he in fact was) –

yelled to defendant RONEY to get out of the yard, and ran towards RONEY.

19. Defendant RONEY never identified himself, and instead drew his taser and

deployed it at plaintiff CRANNELL, causing him to fall to the ground, sustaining cuts, bruises and

a broken nose.

20. Defendant RONEY continued to activate the taser for almost 10 seconds, even

though plaintiff CRANNELL was on the ground and immobilized.

21. Defendant RONEY kept his flashlight trained on plaintiff CRANNELL’s face, and

still never announced that he was a law enforcement officer.

22. At this time, seeing only that plaintiff CRANNELL had been attacked by defendant

RONEY, plaintiff LLOYD ran up to give plaintiff CRANNELL aid, and, although presenting no

threat to defendant RONEY, defendant RONEY deployed a second set of barbs from his taser into

plaintiff LLOYD, shocking him and causing him to fall to the ground and become injured.

23. As a direct and proximate result of defendant’s use of unnecessary and excessive

force, plaintiffs CRANNELL and LLOYD were caused to incur personal and permanent injuries,

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loss of enjoyment of life, pain and suffering and medical expenses.

24. In order to justify his illegal entry and unreasonable use of force, defendant

RONEY filed charges against plaintiff CRANNELL knowingly and falsely alleging that plaintiff

had committed violations of Resisting Arrest (Penal Law §205.30), Obstructing Governmental

Administration 2d (Penal Law §195.05) and Harassment in the Second Degree (Penal Law

§240.26) and charges against plaintiff LLOYD alleging Obstructing Governmental Administration

2d (Penal Law §195.05).

25. Thereafter, defendant RONEY caused plaintiffs to be imprisoned.

26. Defendant knowingly filed these charges against plaintiffs without probable cause

and with the intent to justify his use of excessive force upon plaintiff and his unlawful arrest and

imprisonment of plaintiffs.

27. Thereafter, after appearing in court upon said charges and upon due consideration,

all charges against plaintiffs were dismissed in the interest of justice.

28. At all relevant times, defendants SARATOGA COUNTY and SARATOGA

COUNTY SHERIFF’S DEPARTMENT exercised deliberate indifference by failing to train

SARATOGA COUNTY SHERIFF’S DEPARTMENT members, including, but not limited to,

defendant RONEY, to not unlawfully enter private property, without a warrant, an exception to

the warrant requirement, or probable cause, in violation of the Fourth and Fourteenth Amendments

to the United States Constitution.

29. At all relevant times, defendants SARATOGA COUNTY and SARATOGA

COUNTY SHERIFF’S DEPARTMENT exercised deliberate indifference by failing to train

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SARATOGA COUNTY SHERIFF’S DEPARTMENT members, including, but not limited to,

defendant RONEY, to not use excessive force against civilians in violation of the Fourth and

Fourteenth Amendments to the United States Constitution.

30. At all relevant times, defendants SARATOGA COUNTY and SARATOGA

COUNTY SHERIFF’S DEPARTMENT knew to a moral certainty that department members,

including, but not limited to, defendant RONEY, would experience situations in which they may

be required to determine whether they might lawfully enter private property.

31. At all relevant times, defendants SARATOGA COUNTY and SARATOGA

COUNTY SHERIFF’S DEPARTMENT knew to a moral certainty that department members,

including, but not limited to, defendant RONEY, would experience situations in which they may

be required to use force against civilians.

32. At all relevant times, defendants SARATOGA COUNTY and SARATOGA

COUNTY SHERIFF’S DEPARTMENT knew to a moral certainty that defendant SARATOGA

COUNTY SHERIFF’S DEPARTMENT members, including, but not limited to, defendant

RONEY, would face choices about the legal requirements to enter private property that training or

supervision by defendants SARATOGA COUNTY and SARATOGA COUNTY SHERIFF’S

DEPARTMENT would make less difficult.

33. At all relevant times, defendants SARATOGA COUNTY and SARATOGA

COUNTY SHERIFF’S DEPARTMENT knew to a moral certainty that defendant SARATOGA

COUNTY SHERIFF’S DEPARTMENT members, including, but not limited to, defendant

RONEY, would face choices about the amount of force required when interacting with civilians

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that training or supervision by defendants SARATOGA COUNTY and SARATOGA COUNTY

SHERIFF’S DEPARTMENT would make less difficult.

34. Upon information and belief, there is a history or pattern of defendant

SARATOGA COUNTY SHERIFF’S DEPARTMENT members, including, but not limited to,

defendant RONEY, who have unlawfully entered private property, which has frequently caused

and continues to cause the deprivation of civilians’ rights under the Fourth and Fourteenth

Amendments to the United States Constitution. Defendant RONEY specifically has unlawfully

entered private property on June 17, 2022, in Saratoga County. See NDNY Case No. 1:23-cv-

232.

35. Upon information and belief, there is a history or pattern of defendant

SARATOGA COUNTY SHERIFF’S DEPARTMENT members, including, but not limited to,

defendant RONEY, who have used excessive force when interacting with civilians which has

frequently caused and continues to cause the deprivation of civilians’ rights under the Fourth and

Fourteenth Amendments to the United States Constitution. Defendant RONEY specifically has

used excessive force on June 17, 2022, in Saratoga County. See NDNY Case No. 1:23-cv-232.

36. Upon information and belief, the history or pattern of defendant SARATOGA

COUNTY SHERIFF’S DEPARTMENT members, including, but not limited to, defendant

RONEY of the unlawful entry of private property and of the use of excessive force against civilians

in violation of their rights under the Fourth and Fourteenth Amendments to the United States

Constitution is permanent and widespread.

37. Upon information and belief, defendants SARATOGA COUNTY and

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SARATOGA COUNTY SHERIFF’S DEPARTMENT, with knowledge of said history, pattern,

practice and custom of the use of force by members of the defendant SARATOGA COUNTY

SHERIFF’S DEPARTMENT, have failed to take necessary steps to correct, change or alter such

pattern, practice and custom.

38. Upon information and belief, defendants SARATOGA COUNTY and

SARATOGA COUNTY SHERIFF’S DEPARTMENT have tolerated, fostered, permitted, been

deliberately indifferent to and/or encouraged such pattern, practice and custom of use of unlawful

entry into private property and excessive force by department members.

39. Upon information and belief, defendants SARATOGA COUNTY and

SARATOGA COUNTY SHERIFF’S DEPARTMENT have created, permitted, tolerated and

encouraged said custom, culture, and practice of the use of excessive force by department officers,

including defendant RONEY, by the above detailed actions and by, among other things:

a. Routinely and deliberately hiring and retaining officers, like defendant RONEY,

who were known to have repeatedly unlawfully entered private property and to

have used excessive force in the past;

b. Routinely and deliberately failing to or refraining from investigating allegations of

officer misconduct and the use of excessive force;

c. Routinely and deliberately failing to or refraining from disciplining officers who

have committed misconduct, including unlawfully entering private property and

using excessive force;

d. Routinely and deliberately failing to or refraining from training officers to avoid

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the unlawful entry into private property and the use of excessive force; and

e. Routinely and deliberately rewarding and promoting department members who

engaged in the unlawful entry into private property and the use of excessive force.

40. Defendants actions caused plaintiffs to suffer damages which include personal and

permanent injuries, loss of use and motion, loss of liberty, pain and suffering and emotional and

psychological trauma; as well as economic loss, including medical expenses and lost wages.

COUNT ONE
42 U.S.C. §1983
Use of Excessive Force

41. Plaintiffs repeat and reallege each and every allegation above as if set forth fully

herein.

42. Defendant RONEY, by the actions described above, used excessive force against

plaintiffs in violation of their rights under the Fourth and Fourteenth Amendments to the United

States Constitution.

43. As a direct and proximate result of the use of excessive force by defendant RONEY,

plaintiffs were injured and damaged by said defendant.

44. These damages include personal and permanent injuries, loss of use and motion,

pain and suffering and emotional and psychological trauma; as well as economic loss, including

medical expenses and lost wages.

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COUNT TWO
42 U.S.C. § 1983
Unreasonable Search and Seizure in Violation of the
Fourth and Fourteenth Amendments of the United States Constitution

45. Plaintiffs repeat and reallege each and every allegation above as if set forth fully

herein.

46. Acting without probable cause and without a warrant, and subject to no exception

to the warrant requirement, defendant RONEY unlawfully entered the constitutionally protected

area of plaintiffs’ home, in violation of plaintiffs’ right to be free from unreasonable search.

47. Thereafter, even though plaintiffs committed no crime, defendant RONEY, acting

without probable cause, falsely arrested and unlawfully imprisoned plaintiffs.

48. As a direct and proximate result of plaintiffs’ false arrest and unlawful

imprisonment by defendant RONEY, plaintiffs were injured and damaged by defendants.

49. These damages include personal and permanent injuries, loss of use and motion,

pain and suffering and emotional and psychological trauma; as well as economic loss, including

medical expenses and lost wages.

COUNT THREE
42 U.S.C. § 1983
Monell Liability

50. Plaintiffs repeat and reallege each and every allegation above as if set forth fully

herein.

51. Defendants SARATOGA COUNTY and SARATOGA COUNTY SHERIFF’S

DEPARTMENT by the actions detailed above created, fostered, permitted and maintained a

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pattern and practice that members of defendant SARATOGA COUNTY SHERIFF’S

DEPARTMENT violate civilians’ right to be free from excessive force granted by the Fourth and

Fourteenth Amendments to the United States Constitution, including the actions detailed herein of

defendant RONEY.

52. Defendants SARATOGA COUNTY and SARATOGA COUNTY SHERIFF’S

DEPARTMENT by the actions detailed above were deliberately indifferent to the unlawful entry

into private property and the excessive use of force by department members, including the actions

detailed herein of defendant RONEY against plaintiffs.

53. Defendants SARATOGA COUNTY and SARATOGA COUNTY SHERIFF’S

DEPARTMENT by the actions detailed above had a policy or custom that members of defendant

SARATOGA COUNTY SHERIFF’S DEPARTMENT violate civilians’ right to be free from

unreasonable search and seizure and excessive force granted by the Fourth and Fourteenth

Amendments to the United States Constitution, including through the actions detailed herein of

defendant RONEY.

54. As a direct and proximate result of defendants SARATOGA COUNTY and

SARATOGA COUNTY SHERIFF’S DEPARTMENT’s unconstitutional policies, practices or

customs, department members, including RONEY, were hired, trained, encouraged, permitted,

and/or expected to unlawfully enter the property of and use excessive force upon plaintiffs, causing

them injuries and damage, as detailed herein.

55. These damages include, but are not limited to, serious physical and permanent

injuries, loss of use and motion, loss of physical liberty, pain and suffering and psychological and

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emotional trauma as well as economic losses, including medical expenses and lost wages.

WHEREFORE, plaintiffs request that this Court:

a. Award compensatory damages to plaintiffs, separately and individually, against

defendants;

b. Award punitive damages against defendants, as determined by a jury;

c. Award reasonable attorney’s fees to plaintiffs on all counts;

d. Award costs of this action to plaintiffs; and

e. Award plaintiffs, separately and individually, such other and further relief as this

Court may deem appropriate.

Dated: August 12, 2024 HACKER MURPHY, LLP

By :/s/ James C. Knox

James C. Knox
Bar Roll No. 517109
Attorneys for Plaintiffs
28 Second Street
Troy, New York 12180
Telephone: (518) 274-5820

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1:24-cv-993

$405.00 MAD CFH

ANYNDC-6833045