CLEVELAND, OHIO—Today, Lucille Dumas, a Cuyahoga County, OH resident, filed a complaint in state court arising from a brutal attack she suffered at the hands of former Cuyahoga County Corrections Officer Madeline Chappell, while Dumas was being booked on January 14, 2015 at Euclid City Jail for a traffic offense. The complaint quotes a Sheriff's Department report that in turn quotes three Cuyahoga County corrections officers' witness statements about Chappell's attack on Ms. Dumas.

According to the sheriff's report, Chappell and Dumas were engaged in an "animated" oral exchange before Chappell "ran around the [booking] desk" to punch Dumas, tackle her to the ground, and spray her in the face with pepper spray, despite the fact that Dumas never physically threatened Chappell. Chappell proceeded to secure Dumas to a restraint chair.

Corrections officer Delonte Brown, an eyewitness, reported that Chappell then "struck Ms. Dumas 3 times in the face and while being punched Ms. Dumas was defenseless and was not able to protect herself."

Corrections officer Macarthur Williams, also an eyewitness, reported that, "while [Ms. Dumas was] in the restraint chair he saw Corporal Chappell punch Ms. Dumas 3 times with a closed fist ... to her face and that it was full blown strikes ... [to] the eye and cheek."

A third eyewitness, corrections officer Cheryl Mott, reported that Chappell proceeded to "unnecessarily drench [Ms. Dumas] with water in an aggressive manner," and then "str[uck] Ms. Dumas in the face with [a] Tupperware container causing it to break."

According to Officer Williams, "Chappell took the bucket and slapped Dumas upside the head with a back hand slapping motion[.] [T]his cracked the [container] down the middle[.] Ms. Dumas was in restraints in the restraint chair at this time."

The complaint alleges that Chappell then deleted Officer Mott's written report of the incident, and replaced it with a false account of events.

The complaint further alleges that Cuyahoga County officials were aware of Chappell's propensity toward violence, yet negligently and recklessly retained her as a Corrections Department employee. The complaint cites a November 2013 report written by Cuyahoga County Sheriff's Sergeant Patrick Leahy, who stated in an interview of Chappell: "How many times have I had to have you relieved from an incident because of your screaming and swearing, inciting the inmate, instead of de-escalating the situations? Have I not had you relieved from an incident several times in the past?" Chappell was suspended in December 2013 for four separate incidents in October and November 2013, including two incidents of displaying "unprofessional, disrespectful, threatening and profane language toward inmates,"

Chappell was indicted on charges of kidnapping, tampering with records, assault, and unlawful restraint, and, as part of her guilty plea, resigned her employment as a corrections officer and agreed that she would not seek further employment in law enforcement.

Dumas is African-American. Chappell is white.

Ms. Dumas's suit was filed in the Cuyahoga County Court of Common Pleas, and alleges claims for violations of the U.S. Constitution, including for excessive force and denial of equal protection based on race under the 4th and 14th Amendments, as well as claims for assault, intentional infliction of emotional distress, negligent and reckless hiring and retention, and malicious attempt to influence public officials under R.C. 2921.03. Ms. Dumas is represented by Subodh Chandra and Peter Pattakos of the Chandra Law Firm, as well as Christopher Thomarios.

Chandra said, "For a corrections officer to attack a woman who represents no physical threat is is an affront to human dignity and violates our Constitution. Ms. Dumas wants to ensure that those who are sworn to uphold the law do not act so lawlessly—and that this does not happen to anyone else."

Click here 2016-01-12-Complaint-Case-No-CV-16-857117.pdf to view official complaint