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Stucky v. Conlee, Parsell, and The City of Nita
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A particularly timely file in today's charged relationship between law enforcement and persons of color, Stucky v. Conlee, Parsell, and Nita City is a civil rights action for damages arising out of alleged racial profiling giving rise to a traffic stop. Plaintiff Clayton Stucky is an African-American who works as a trooper with the Nita State Police. While off duty and driving his personal vehicle, Stucky was pulled over by two City of Nita police officers, who then sought consent to search the car.
Officers Conlee and Parsell, both Caucasian, allege that Stucky was driving over fifty miles per hour on a city street zoned for twenty-five miles per hour. Conlee and Parsell issued Stucky a citation for driving at an unsafe speed. Following a hearing, the district justice found Stucky not guilty of the charged traffic offense.
Stucky asserts that he was driving the speed limit and alleges that Conlee and Parsell pulled him over for "driving while black." He sued Conlee and Parsell for damages caused by their violation of Stucky's right to be free from an unreasonable seizure and his right to the equal protection of the laws.
Stucky also named Nita City as a defendant, alleging that Nita City Police Chief Kurt Lieber's training and supervision of Conlee and Parsell was deliberately indifferent with respect to the risk of racial profiling and that Lieber's deliberate indifference was a cause of Conlee and Parsell's stopping Stucky without probable cause and based upon Stucky's race. There are three witnesses for each side. Additionally, a racial profiling expert and a medical expert are available for both the plaintiff and defendants. The updated version includes electronic exhibits such as text messages and the Facebook page of one of the witnesses. Digital versions of the exhibits are available online.
Table of contents
ACKNOWLEDGEMENTS
CASE SUMMARY
INSTRUCTIONS FOR USE AS A FULL TRIAL
COMPLAINT
ANSWER
STIPULATIONS
STIPULATED SUMMARY OF MEDICAL EXPENSES
DEPOSITIONS
Clayton Stucky
Shelley Elliot
Nelson Digby
Eric Conlee
Lance Parsell
Kurt Lieber
EXPERT REPORTS
Report of Plaintiff's Expert Dr. Thomas Goforth
Curriculum Vitae of Dr. Thomas A. Goforth
Report of Defendants' Expert Professor Neil Ellman
Curriculum Vitae of Professor Neil Ellman
MEDICAL EXPERT REPORTS
Report of Plaintiff's Medical Expert Dr. Leslie Collins
Curriculum Vitae of Dr. Leslie Collins
Report of Defendants' Medical Expert Dr. Jeremiah Guttman
Curriculum Vitae of Dr. Jeremiah Guttman
EXHIBITS
Exhibit 1—Photo of Stucky's vehicle
Exhibit 2—Google Maps diagram map of the East Market Street area
Exhibit 3, 3-A—Google Earth overhead maps of East Market Street area
Exhibit 4—Google Earth street view map of railroad tracks on East Market Street
Exhibit 5—Street view photo of East Market Street, looking west from where Stucky was stopped
Exhibit 6—Street view of East Market Street where Stucky was stopped
Exhibit 7—Close-up street view of East Market Street where Stucky was stopped
Exhibit 8—Photo of door showing address at point of stop
Exhibit 9—Traffic Citation
Exhibit 10—Transcript of Preliminary Hearing
Exhibit 11—Bill from Attorney Clinton T. Manges
Exhibit 12—Note from Dr. Stovall excusing Stucky from work
Exhibit 13—Note from Dr. Collins excusing Stucky from work
Exhibit 14—Note from Dr. Collins releasing Stucky for work
Exhibit 15—Excerpts from Shelley Elliot's Facebook page
Exhibit 16—Nita City Police Department Traffic Enforcement Training Manual
Exhibit 17—Conlee Performance Evaluations from NITA Township for the category "Lack of Prejudice"
Exhibit 18—Text message from Lance Parsell to Officer Paget, August 5, YR-2
Exhibit 19—Text message from Officer Paget to Lance Parsell, August 5, YR-2
Exhibit 20—Excerpts from Nita City Police Department Rules, Polices, and Procedures Manual
Exhibit 21—Nita City Police Department Traffic Study
Exhibit 22—Article from Nita Gazette, May 4, YR-1
Exhibit 23—TruWeather Report
FINAL JURY INSTRUCTIONS
FINAL VERDICT FORM
