[2025-CM-184512-GD] Jay Son v. Los Santos Department of Corrections

[Jay Son]

What type of complaint are you filing?: General Dispute

Plaintiff: Jay Son
Are you self representing?: No
Lawyers Name: Bradley Cooper

Respondent: Los Santos Department of Corrections

Claim:
On April 22nd, around 10:00am EST, Kate Beers (Collector) was incarcerated at Bollingbroke State Penitentiary. She had engaged in conversation with Senior Officer Michael North of the Department Of Corrections. Senior Officer North had a whip visible on his person, and asked the plaintiff to show him the gardening in the facility. The plaintiff obliged, and began walking Senior Officer North through the steps. The plaintiff realised partway through that her time was up and she had served her sentence.

She informed Senior Officer North that she wouldn't be finishing the gardening as she was due for release and that the next inmate could do it. Senior Officer North told her "You're going to finish what you started and finish the garden before you leave". The plaintiff began to argue with this as she was not under any legal obligation to complete said task and was due for release, meaning she was to be processed and free to leave. Senior Officer North then cracked the whip on his person audibly and told her "This isn't a happy hotel I'd do what I say".

Now having been threatened with violence and fearful for her safety, the plaintiff completed the task which took her between 4-6 months. Ms Beers was subjected to assault by Senior Officer North with the whip and threatened with the implication he would use it unless she complied with his demands. For this period, the plaintiff was under imprisonment without legal justification by Senior Officer North as she was being released and there was therefore no legal justification, making this an arbitrary arrest and imprisonment/wrongful detention, violating Ms Beers' civil rights and subjecting her to willful and malicious assault by the corrections officer.

Without remedy, corrections officers will continue to subject inmates to unlawful detention and assault, violate their rights and cause undue harm to the very people they have a legal obligation for the care of.

Demand:
$50,000 for violation of rights
$50,000 in punitive damages
Mandatory training of officer found to be liable in the processing and handling of inmates due for release
Mandatory training of officer found to be liable in lawful orders and unlawful orders and use of force
A 200 word essay on the definition of Habeas Corpus to be completed by officer found to be liable and presented to the courts in private, sealed email.

Witnesses: Michael North, Kate Beers
Any (non-testimonial) evidence: CCTV footage, in the possession of the State (To be introduced in Discovery)
Internal Affairs report (To be introduced in Discovery)

[Dean Cooper]

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