Case 2:19-cv-00626 Document 4 Filed 08/30/19 Page 1 of 17 PageID #: 25

IN THE UNITED STATES DISTRICT COURT FOR THE

SOUTHERN DISTRICT OF WEST VIRGINIA
AT CHARLESTON

TRAVIS RHODES, as Personal

Representative of the Estate of
TIMOTHY E. RHODES,

Plaintiff,

v. Civil Action No. 2:19-cv-626

DEPUTY SHERIFF MICHAEL KING,

and the ROANE COUNTY
COMMISSION,

Defendants.

AMENDED COMPLAINT

Travis Rhodes, as Personal Representative of the Estate of Timothy E. Rhodes, deceased,

for his Amended Complaint against Defendants Deputy Sheriff Michael King and the Roane

County Commission, states as follows:

1. Plaintiff Travis Rhodes is a resident and citizen of Jackson County, West

Virginia, and is the duly appointed and acting Personal Representative of the Estate of Timothy

E. Rhodes (“Timmy” or “Timmy Rhodes”).

2. Defendant Deputy Sheriff Michael King (“Defendant King”), upon information

and belief, is a resident of Roane County, West Virginia, and is employed by the Roane County

Commission.

3. Defendant Roane County Commission ("Defendant RCC") employed, at all times

relevant herein, Defendant King and Sheriff Todd Cole to engage in law enforcement duties in

Roane County, West Virginia, and as such, Defendant RCC is liable for the negligent and

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reckless conduct, acts, and omissions of Defendant King and Sheriff Cole, as well as for its own

and its other employees’ acts of negligence and recklessness.

JURISDICTION AND VENUE

4. Plaintiff’s claims in this matter arise out of a horrific and entirely unnecessary

shooting incident that occurred in the afternoon hours of February 22, 2019, on Ambler Ridge

Road in Roane County, West Virginia. Plaintiff’s decedent—unarmed on his own property—

was tragically and fatally shot by Defendant King without justification. This Court has original

jurisdiction over this matter pursuant to federal question jurisdiction codified at 28 U.S.C.A. §

1331 because Plaintiff asserts a violation of Timmy Rhodes’ rights under 42 U.S.C.A. § 1983.

This Court has supplemental jurisdiction over Plaintiff’s state law claims pursuant to 28

U.S.C.A. § 1367.

5. Venue is proper in this Court in accordance with 28 U.S.C.A. § 1391 because the

causes of action arose in Roane County, West Virginia, and all Defendants routinely transact

business in Roane County, a county within this Court’s district and division.

FACTS

6. On February 22, 2019, Timmy Rhodes and his fiancé, Tammy Nichols (“Tammy”

or “Ms. Nichols”), both residents of Roane County, West Virginia, drove to Timmy Rhodes’

childhood home on Ambler Ridge Road (the “Rhodes Home”) to collect mail and other items.

7. The long-established and accepted entrance to the Rhodes Home is through use of

a roadway that passes in front of the neighboring home of Beth and Robert Young (the “Young

Home”).

8. When Mr. Rhodes turned his vehicle onto the roadway to proceed to the Rhodes

Home, he necessarily passed the Young Home. According to Mrs. Young, Mr. Rhodes’ truck

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tires spun in the roadway and kicked up rocks as the vehicle proceeded forward, and Mrs. Young

called 911 to complain about the matter.

9. During Mrs. Young’s call to 911, she did not indicate that Mr. Rhodes had been

aggressive in any way, only that his driving had caused the tires of his truck to spin and kick up

rocks on the Young’s property.

10. The 911 operator told Mrs. Young that a deputy would be dispatched.

11. Meanwhile, Timmy Rhodes drove away from the Young Home to his family

property, and Timmy exited the vehicle to retrieve some items from the house, while Ms.

Nichols remained in the vehicle.

12. Minutes later and while acting within the scope of his employment to address

what was, at most, a possible minor property damage claim, Defendant King responded to Mrs.

Young’s 911 call and arrived on the property.

13. Defendant King was not wearing his Sheriff’s uniform. Instead, he was casually

dressed wearing blue jeans, a white t-shirt, and a bullet proof vest. He was armed with a

shotgun, which had to be set down or held with two hands. Upon information and belief,

Defendant King was not wearing his sheriff’s duty belt, did not have his badge displayed, did not

have handcuffs, and did not have a handgun or holster.

14. While Defendant King observed the scene from a distance, Timmy returned to the

vehicle and was scared in light of, among other things, Defendant King’s reputation for using

unnecessary force. Timmy informed Tammy that Defendant King had arrived on the property

and was located behind their truck holding something.

15. Tammy then turned and saw Defendant King leaning against a tree with an object

in his hand.

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16. For unknown reasons, Defendant King then advanced quickly onto the Rhodes’

property and pointed the shotgun at Timmy and Tammy and shouted orders at them to exit the

truck and get on the ground. From the beginning, Defendant King’s entire approach to the

situation was wholly improper and in violation of commonly accepted law enforcement practices

and procedures as well as Timmy’s rights afforded under West Virginia law, and the

Constitutions of West Virginia and the United States.

17. Tammy exited the truck through the passenger-side door and knelt on the ground

beside the truck.

18. Defendant King continued to approach the truck, screaming at Timmy to exit the

truck and get on the ground. Timmy also complied and exited the vehicle.

19. Scared and confused, Timmy asked Defendant King why Defendant King was

ordering them out of their vehicle, because he was peacefully on his family’s property.

20. Defendant King continued to advance toward Timmy, aggressively screaming at

him to get on the ground. Defendant King threatened Timmy and told Timmy that it would not

bother him to “blow your fucking brains out” if Timmy did not comply.

21. While Timmy was standing beside the driver’s side door, Defendant King, who is

physically much bigger and stronger than Timmy, shoved Timmy to the ground.

22. Timmy Rhodes did not resist Defendant King in any way.

23. Defendant King then walked around the vehicle and positioned himself so that he

could see both Timmy and Tammy at the same time.

24. Defendant King continued to point his shotgun at Timmy and aggressively

ordered Timmy to remain on the ground. Tammy could see that Timmy was lying on his back.

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25. Timmy pulled his legs up in a motion that appeared to Tammy as though he was

going to try to stand up. However, Timmy did not present any physical threat to Defendant King

or attempt to take Defendant King’s shotgun at any time. Defendant King fired his shotgun at

close range, shooting Timmy in his face. Timmy was unarmed, was not lawfully under arrest,

and was in a completely defenseless position.

26. Tammy asked Defendant King if Timmy was dead. Defendant King replied, “Not

yet, but he will be.”

27. Defendant King then directed his attention to Tammy. He ordered her to stay on

the ground. At some point later, he directed her to stand up and walk to the rear of the vehicle

facing away from him, to kneel and place her hands on her head. Despite her grief and concern

for Timmy, Tammy complied in fear for her life.

28. Tammy waited with her hands above her head, while Timmy suffered and bled to

death only feet away.

29. Minutes after Timmy was shot, Defendant King called-in to 911 dispatch and

reported that Timmy was still breathing.

30. After suffering devastating injuries from the shotgun blast, Timmy died.

31. As a direct and proximate cause of Defendant King’s unwarranted and

unprovoked use of deadly force, Timmy Rhodes was killed.

32. Upon information and belief, prior to the death of Timmy Rhodes, Sheriff Cole

and Defendant RCC had received numerous complaints from citizens about other instances of

excessive force and threats of lethal force by Defendant King, thereby alerting RCC and Sheriff

Cole that Defendant King was routinely not following proper protocol regarding the use of force

and threats of lethal force during his encounters with members of the community.

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33. Upon information and belief, in at least one complaint, in the autumn of 2018,

Sheriff Cole was specifically advised by a man that Defendant King had unnecessarily pulled his

weapon while apprehending the man’s son. The man asked Sheriff Cole who Defendant King’s

supervisor was, and Sheriff Cole said that he himself was. The man asked why Sheriff Cole was

letting Defendant King pull his weapon and threaten people all over the county without

justification. Sheriff Cole told the man that he would “handle it.”

34. Upon information and belief, Sheriff Cole did not handle it. In fact, upon

information and belief, Sheriff Cole did not investigate the man’s allegations regarding

Defendant King’s treatment of his son, which were full of proof, as a proper investigation would

have revealed, including hospital records and photographs concerning the laceration on the

man’s son’s forehead from where Defendant King had forcefully placed his weapon against the

man’s head and struck him with it. Sheriff Cole did not take any corrective action with respect to

Defendant King.

35. Upon information and belief, other instances and citizen complaints of the use of

excessive force, excessive threats, and dangerous conduct by Defendant King occurred on the

premises of the Sheriff’s Department, and still others were witnessed by other members of the

Sheriff’s Department.

36. One such complaint relates to an incident occurring on 10 April, 2013, when

Defendant King pulled over School Bus # 6, which was then en route to Roane County High

School.

37. Defendant King detained a minor child, without charge, taking physical custody

of him by removing him from the school bus and placing him in his cruiser because the child’s

hat had flown out of the school bus window.

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38. Defendant King did not call parents during or after the time that he took physical

custody of their child by removing him from the school bus.

39. In his written complaint to Defendant RCC and Sheriff Cole, the minor relates

that he felt scared and was intimidated by Defendant King.

40. Sheriff Cole and Defendant RCC had a duty to investigate Defendant King’s role

in detaining the minor child, an incident which constituted an unreasonable seizure of his person

and a violation of his rights.

41. Instead, Sheriff Cole’s investigation of the complaint relating to Defendant King’s

unlawful detention of the minor child culminated in a letter to Defendant RCC concluding that

Defendant King had “every right to perform a traffic stop on the school bus” to investigate a

“criminal violation” of “WV Code 17C-14-14.”

42. Defendant King’s conduct in detaining the child and removing him from the bus

was in violation of clearly established laws, notwithstanding the possibility that misdemeanor

littering may have occurred. Defendant King had not witnessed the actual act, and the

presumption of both relevant littering statutes is that the operator of a motor vehicle is

responsible for the littering. Defendant King had no authority to do anything other than issue a

citation and summons to the minor child even if he had suspicion or probable cause to believe

that a (very minor, if that) misdemeanor act of littering had occurred.

43. W. Va. Code confers no authority on law enforcement officers such as Defendant

King to either detain or arrest any citizen on suspicion of littering from a moving vehicle.

44. Defendant RCC has also had in its custody, since April 2014, records relating to a

formal complaint against Defendant King by a woman who called 911 to report that Defendant

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King was—for no lawful purpose—commanding her to leave the premises of Walton Middle

School where her child was attending a dance.

45. In her call to 911, the mother relates that Defendant King had his hand on his gun,

that he was commanding that she leave school property, and that he was physically preventing

her from obeying the unlawful command that he was yelling at her.

46. In her subsequent written complaint to the Roane County Sheriff’s Department,

the mother relates that she was scared Defendant King’s actions towards her made her feel

unsafe.

47. This was the second formally documented incident in a single year involving

Defendant King’s practice of threatening and intimidating a law-abiding citizen pursuant to no

lawful authority, with no probable cause to either detain or arrest them, and in connection with

no law-enforcement purpose.

48. The incident complained of by the mother was the second incident in a single year

that would have alerted Defendant RCC and Sheriff Cole to Defendant King’s pattern and

practice of using the authority of his position as a police officer, and in this case his ready access

to his service firearm, to issue verbal commands to citizens who were clearly not committing

crimes.

49. Sheriff Cole failed to adequately investigate this incident. Instead, he made

inquiries with an assistant principal of the school who had interviewed a child present, as well as

the second-hand information provided to him by the parent of a child present and concluded that

Defendant King had not “used profanity or said anything inappropriate” and dismissed the

mother’s complaint by declaring that it was “without merit and shall be unfounded.” Sheriff

Cole’s investigation also turned up that Defendant King had ordered the mother to leave the

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premises and that the mother was in the act of picking up her child from a dance and was

actually attempting to keep peace between her child and a friend of another child of hers, who

were having a dispute. In other words, Sheriff Cole learned that Defendant King was issuing

unlawful orders with no basis. Defendant King only happened to be present because his child

attended the same dance. He had not been called to the scene and there was no suspicion or

reason to believe that any criminal conduct was occurring or had occurred that required law

enforcement intervention.

50. Upon information and belief, Sheriff Cole and Defendant RCC failed to take any

action in response to the complaints received regarding Defendant King’s repeated and negligent

and reckless use of excessive force.

51. As a direct and proximate cause of Sheriff Cole’s and Defendant RCC’s failure to

act with regard to their actual knowledge of Defendant King’s past failures to follow established

law enforcement procedures and protocols prohibiting the use and threatened use of such

dangerous and excessive force during routine interrogations and arrests, Defendant King was

permitted to respond to the property incident on Ambler Ridge Road on February 22, 2019, and

permitted to again use unwarranted and unprovoked excessive force causing the death of Timmy

Rhodes, an unarmed individual.

COUNT I – STATE-LAW NEGLIGENT AND RECKLESS CONDUCT IN VIOLATION

OF CLEARLY ESTABLISHED LAWS – DEFENDANT KING

52. Plaintiff repeats and realleges the allegations contained in paragraphs 1-51 of this

Complaint as if set forth fully herein.

53. Defendant King was negligent and reckless in the manner in which he approached

Timmy Rhodes—wielding a shotgun, dressed in civilian clothes with a bullet-proof vest, not

identifying his reason for approaching Timmy, and threatening to blow Timmy’s “fucking brains

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out”—while on Timmy’s own property in response to a 911 call and complaint that, if true,

constitutes at most misdemeanor misconduct. Defendant King’s approach created reasonable fear

and apprehension in Timmy Rhodes given that Timmy knew he had not done anything to

warrant such an approach, and increased the likelihood of a misunderstanding, as well as

increasing the likelihood of a lethal shooting through accident, misunderstanding, or impulse.

54. Defendant King was negligent and reckless in shoving Timmy to the ground when

Timmy asked why he was being asked to get on the ground but made no aggressive move or step

or action towards Defendant King.

55. Defendant King was negligent and reckless in shooting Timmy in the face while

Timmy was in a defenseless and non-threatening position.

56. Defendant King is an agent and employee of Defendant RCC. At all times

referenced herein, Defendant King was acting within the scope of his agency or employment

with Defendant RCC. Accordingly, Defendant RCC is strictly and vicariously liable for the acts

of Defendant King pursuant to W. Va. Code § 29-12A-1 et seq. as referenced by the above facts

and allegations in this Complaint.

57. These acts and omissions of Defendant King violated Timmy Rhodes’

constitutional rights, including, but not limited to, the right to be free from unreasonable searches

and seizures and the right to due process prior to the deprivation of life and liberty protected by

the West Virginia Constitution, Article III, Sections 2, 3, and 6, and also protected by the Fourth

and Fourteenth Amendments of the United States Constitution.

58. These constitutional provisions and long-standing and clearly established cases

and precedent from the Supreme Courts of West Virginia and the United States interpreting them

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provide the right to persons to be free from the use of excessive force by law enforcement

officers during police investigations, interrogations, and apprehensions.

59. These constitutional provisions and long-standing and clearly established cases

and precedent from the Supreme Courts of West Virginia and the United States interpreting them

provide the right to persons to be free from the use of lethal force by law enforcement except

when justified by the circumstances surrounding an interrogation, confrontation, or arrest.

60. Any reasonable and reasonably well-trained law enforcement officer would know

that approaching an unarmed man suspected, at most, of a misdemeanor, with a shotgun, on the

man’s own property, demanding that he get on the ground, refusing to explain the reason for the

officer’s presence, and then shoving him to the ground under these circumstances constitutes

excessive force, an unreasonable seizure, and a deprivation of liberty without due process in

violation of the West Virginia and United States Constitutions.

61. Any reasonable and reasonably well-trained law enforcement officer would know

that discharging a shotgun into the face of an unarmed man suspected, at most, of a

misdemeanor, on the man’s own property, while the man is in a defenseless position, under these

circumstances constitutes excessive force, an unreasonable seizure, and a deprivation of life

without due process in violation of the West Virginia and United States Constitutions, whether or

not that man made a non-aggressive motion that might indicate an intent to stand up.

62. Timmy Rhodes was shot in the face and killed, and suffered prior to dying, as a

direct and proximate result of the negligence and recklessness of Defendant King and the violation

of his constitutional rights by Defendant King.

COUNT II – STATE-LAW NEGLIGENT AND RECKLESS CONDUCT IN VIOLATION

OF CLEARLY ESTABLISHED LAWS – DEFENDANT RCC

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63. Plaintiff repeats and realleges the allegations contained in paragraphs 1-62 of this

Complaint as if set forth fully herein.

64. Defendant King is an agent and employee of Defendant RCC. At all times

referenced herein, Defendant King was acting within the scope of his agency and employment

with Defendant RCC. Accordingly, Defendant RCC is strictly and vicariously liable for the acts

of Defendant King pursuant to W. Va. Code § 29-12A-1 et seq. as referenced by the above facts

and allegations in this Complaint.

65. Roane County Sheriff Todd Cole is an agent and employee of Defendant RCC.

At all times referenced herein, Cole was acting within the scope of his agency and employment

with Defendant RCC. Accordingly, Defendant RCC is strictly and vicariously liable for the acts

of Cole pursuant to W. Va. Code § 29-12A-1 et seq. as referenced by the above facts and

allegations in this Complaint.

66. Defendant RCC is liable for the negligent and reckless acts of Defendant King and

Cole set forth in this Complaint, all of which occurred within the scope of their employment.

67. Sheriff Cole, and, independent of the conduct of Defendant King and Cole,

Defendant RCC were negligent and reckless in several aspects, including but not limited to the

following acts:

a. failing to properly interview, evaluate, and screen Defendant King prior to hiring;

b. failing to properly train Defendant King in proper police procedures and response

procedures, including but not limited to, responding to property damage and

nuisance/disturbance reports;

c. failing to properly monitor and supervise Defendant King;

d. negligently retaining Defendant King and keeping Defendant King employed; and

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e. failing to follow adopted and implemented policies and procedures for Defendant

RCC with regard to investigation of multiple citizen complaints about Defendant

King’s pattern of use of excessive force and failing to take remedial action with

regard to the complaints; and

f. implementing customs, policies, and procedures, whether written or unwritten,

condoning, encouraging, and demonstrating indifference to the use of excessive

force by deputies, including Defendant King.

68. Any reasonable and reasonably well-trained law enforcement supervisor would

recognize that failing to take action to correct, discipline, or remove Defendant King based on

the proven and alleged dangerous misconduct involving the unnecessary use of force and

unnecessary threats of lethal force by Defendant King that occurred prior to the Timmy Rhodes

shooting—and of which Sheriff Cole and RCC had knowledge—was likely to enable and

encourage Defendant King in his excessive use of force and his continued and excessive threats

of the use of non-lethal force, and would one day result in the unnecessary and unconstitutional

killing of a citizen in violation of clearly established laws and constitutional provisions.

69. Any reasonable and reasonably well-trained law enforcement supervisor would

recognize that failing to take action to correct, discipline, or remove Defendant King based on

the proven and alleged dangerous misconduct involving the unnecessary use of force and

unnecessary threats of lethal force by Defendant King that occurred prior to the Timmy Rhodes

shooting—and of which Sheriff Cole and RCC had knowledge—was itself a violation of clearly

established laws and constitutional provisions.

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70. Timmy Rhodes was shot in the face and killed, and suffered prior to dying, as a

proximate result of the negligence and recklessness of Sheriff Cole and RCC and the violation of

his constitutional rights by Sheriff Cole and RCC.

COUNT III – DEPRIVATION OF RIGHTS IN VIOLATION OF 42 U.S.C. § 1983 –

ALL DEFENDANTS

71. Plaintiff repeats and realleges all of the allegations contained in paragraphs 1-70

as if set forth verbatim herein.

72. The allegations specifically set forth in Count I, above, not only state a claim for

relief against Defendant King under the laws of the State of West Virginia, but also under 42

U.S.C. § 1983, provided that Defendant King was acting under color of law at the time.

73. Defendant King, at all times relevant to the allegations set forth in this Complaint,

was acting under the color of his law enforcement duties as empowered by the Roane County

Sheriff’s Department and Defendant RCC.

74. The allegations pertaining to Defendant RCC specifically set forth in Count II,

above, not only state a claim for relief against Defendant RCC under the laws of the State of

West Virginia, but also under 42 U.S.C. § 1983, because Defendant King’s conduct not only

occurred while acting under the aegis of the RCC, but also, upon information and belief, resulted

directly from the express written or unwritten customs and policies of RCC.

75. Sheriff Cole and Defendant RCC had actual knowledge through citizen

complaints of a pattern of use of excessive force and threats by Defendant King.

76. Upon information and belief, Sheriff Cole and Defendant RCC took no remedial,

adverse, or other action against Defendant King in response to the excessive force complaints

lodged by citizens against Defendant King.

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77. In taking no action against Defendant King in response to the excessive force

complaints lodged by citizens against and about Defendant King, Sheriff Cole and Defendant

RCC created a custom of acceptance and encouragement of the use of excessive force.

78. As a direct and proximate result of the Defendants’ actions in deprivation of the

rights and privileges secured by the Constitution and laws of the United States, Timmy Rhodes

was shot in the face and killed, and suffered prior to dying.

79. Defendants’ acts and omissions, in violating Timmy Rhodes’s rights, make

Defendants liable to Plaintiff for compensatory and punitive damages, prejudgment and post-

judgment interest, and an award of attorney fees and costs pursuant to 42 U.S.C. § 1983.

PRAYER FOR RELIEF AND DEMAND FOR JURY TRIAL

WHEREFORE, the conduct described herein of the Defendants, individually and

collectively, served as the direct and proximate cause of the death of Timmy Rhodes. Therefore,

Plaintiff demands judgment against the Defendants for all recoverable damages, including

without limitations those damages permitted and set forth pursuant to the West Virginia

Wrongful Death Act, W. Va. Code § 55-7-5 and § 55-7-6, and all damages available under 42

U.S.C. § 1983, including but not limited to:

a. Damages in compensation for sorrow, mental anguish and solace which may

include society, companionship, comfort, guidance, kindly office and advice

of the decedent;

b. Damages in compensation for the reasonably expected loss of (i) income of

the decedent, and (ii) services, protection, care and assistance provided by the

decedent;

c. Damages in compensation for pain and suffering prior to death;

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d. Damages in compensation for loss of enjoyment of life;

e. Expenses for the care, treatment and emergency response personnel incident

to the shooting death of the decedent;

f. Reasonable funeral expenses;

g. Punitive damages;

h. Prejudgment and post-judgment interest;

i. Attorney fees and costs; and

j. Such other and further relief as may seem fair and just.

PLAINTIFFS DEMAND A TRIAL BY JURY ON ALL ISSUES.

TRAVIS RHODES, as Personal Representative

of the Estate of TIMOTHY E. RHODES,
By counsel

s/Benjamin D. Adams
L. Dante’ diTrapano, Esq. (WVSB #6778)
Alex McLaughlin, Esq. (WVSB #9696)
Benjamin D. Adams, Esq. (WVSB #11454)
Calwell Luce diTrapano PLLC
500 Randolph Street
Charleston, West Virginia 25302
(304) 400-6558/(304) 344-3684
dditrapano@cldlaw.com
amclaughlin@cldlaw.com
badams@cldlaw.com

and

R. Booth Goodwin II, Esq. (WVSB #7165)

Benjamin B. Ware, Esq. (WVSB #10008)
Stephanie H. Daly, Esq. (WVSB #8835)
Goodwin & Goodwin, LLP
300 Summers Street, Suite 1500
Charleston, West Virginia 25301
(304) 346-7000/(304) 344-9692
rbg@goodwingoodwin.com

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bbw@goodwingoodwin.com
shd@goodwingoodwin.com

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