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Daniel Snyder, OSB No. 78385

dansnyder@lawofficeofdanielsnyder.com
Carl Post, OSB No. 06105
carlpost@lawofficeofdanielsnyder.com
Cynthia Gaddis, OSB No. 113907
cindygaddis@lawofficeofdanielsnyder.com
LAW OFFICES OF DANIEL SNYDER
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205
Telephone: (503) 241-3617
Facsimile: (503) 241-2249
Of Attorneys for the plaintiff
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF OREGON
PORTLAND DIVISION

Case No.

PHILIP WOLFE,
Plaintiff,

3:12-cv-2035

COMPLAINT

v.

(Title II of the ADA, 42 U.S.C. 1983)

CITY OF PORTLAND, a municipal

corporation, LISA TURLEY, and MICHAEL
REESE, individuals,

JURY TRIAL DEMANDED

Defendants.
I. PRELIMINARY STATEMENT
1. This action is an action for damages, injunctive, declaratory and equitable relief, including
compensatory damages, punitive damages, and attorney fees and costs, to redress violations of the
Americans With Disabilities Act ("ADA"), 42 U.S.C. 12101 et seq., and violations of federal
statutory rights pursuant to 42 U.S.C. 1983.

PAGE 1 COMPLAINT
Law Offices of Daniel Snyder
Attorneys At Law
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205
(503) 241-3617 Fax (503) 241-2249

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II. JURISDICTION
2. Jurisdiction is conferred upon this Court by 28 U.S.C. Section1331, federal question
jurisdiction and 28 U.S.C. Sections 1331, 1332, and 1343 civil rights jurisdiction.
3. Plaintiff requests this Court invoke its supplemental jurisdiction pursuant to 28 U.S.C.
Section 1367 with respect to all causes of action based on Oregon statutory provisions or common
law as the state claims arise from the same nucleus of operative facts as the federal claims.
4. Venue is in the District of Oregon pursuant to 28 U.S.C. Section 1391(b) because the claim
arose in this Judicial District.
5. On May 4, 2012, Plaintiff complied with the Oregon Tort Claims Act by completing a form
"Claim Against The City of Portland" which he gave to the City of Portland Risk Management.
III. PARTIES
6. Plaintiff Philip J. Wolfe (hereafter Plaintiff) is a citizen of the United States of America.
At all times relevant, Plaintiff was a resident of Portland, Multnomah County, Oregon. Plaintiff is
a qualified individual with a disability. Plaintiff has been deaf since birth. Plaintiff communicates
through American Sign Language (ASL).
7. Defendant City of Portland (hereafter Defendant City) is a municipal corporation within
Multnomah County, State of Oregon. At all times material, Defendant City and its employees
provided local government services to residents of the City of Portland, including, but not limited
to, 911 emergency dispatch services to residents of Portland, Oregon through its Bureau of
Emergency Communications, as well as law enforcement and police services through its Portland
Police Bureau (PPB).
8. At all times material, Defendant Lisa Turley, was the Director of the City of Portland,
PAGE 2 COMPLAINT
Law Offices of Daniel Snyder
Attorneys At Law
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205
(503) 241-3617 Fax (503) 241-2249

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Bureau of Emergency Communications. Defendant Turley was responsible for setting policies and
procedures for the Bureau of Emergency Communications concerning people with disabilities
who contact the Bureau through the 911 number or its equivalent, including deaf crime victims.
9. At all times material, Defendant Michael Reese was the Chief of Police for Defendant
Citys PPB. Defendant Reese was responsible for setting policies and procedures for people with
disabilities who encounter Portland police officers, including people who are deaf who encounter
Portland police officers, as well as for providing American Sign Language interpreters.
10. At all times material, John Doe and Jane Doe, were dispatchers employed by Defendant
City in its Bureau of Emergency Communications.
11. At all times material, Joseph Cook DPSST #48042, Brandon Cox DPSST #50231, Paul
Valdez DPSST #40188, and Heidi Brockman DPSST #35449 were police officers employed by
Defendant City through the PPB.
12. All acts of the police officers and 911 emergency dispatchers employed by Defendant City
as alleged herein were within the course and scope of their employment with Defendant City.
IV. GENERAL FACTUAL ALLEGATIONS
13. At all times material, when a 911 call for assistance is made by a deaf crime victim or
person, employees at Defendant City's Bureau of Emergency Communications do not provide,
dispatch, or arrange for qualified American Sign Language (ASL) interpreters to assist the deaf
crime victim or person when dispatching police officers to the call.
14. At all times material, Defendant City's PPB does not provide qualified ASL interpreters to
deaf crime victims.
15. At all times material, Defendant City's Portland Police Bureau Manual of Policy and
Procedure (PPB Manual) does not contain policy and procedures for police officers to follow
PAGE 3 COMPLAINT
Law Offices of Daniel Snyder
Attorneys At Law
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205
(503) 241-3617 Fax (503) 241-2249

!aaassseee 333:::111222---cccvvv---000222000333555---PPPKKK

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when contacting or interviewing people with disabilities, including when interviewing people who
are deaf. The PPB Manual does not instruct officers to call for ASL interpreters to assist deaf crime
victims. To Plaintiff's best knowledge, the PPB has not issued any directives to officers providing
procedures, protocols, or policy concerning providing ASL interpreters to deaf people when
providing police services.
16. On April 9, 2012, Plaintiff lived at 5819 NE Glisan St., Apartment 311, Portland, Oregon.
17. On April 9, 2012, Plaintiff was in a domestic relationship with Aaron Renner ("Renner")
who also lived in said apartment with Plaintiff. Renner is now deceased.
18. On April 9, 2012, Renner attacked Plaintiff at Plaintiff's apartment in two separate
incidents.
19. In the first incident, in the early morning of April 9, 2010, Renner grabbed Plaintiff by both
of his ankles and rapidly with strong force dragged Plaintiff, causing Plaintiff's head to hit the
ground and scratching and scraping Plaintiff's back and torso.
20. Plaintiff fled from the apartment to escape the abuse after securing the door to his bedroom.
Renner then locked Plaintiff out of the apartment. Because Plaintiff's mobile telephone was almost
out of power, Plaintiff sent a telephone text message to his friend Erin Dunn ("Dunn"), who is also
deaf, to contact 911 for him. Dunn contacted Defendant City's Bureau of Emergency
Communications. Through a video relay operator, Ms. Dunn communicated with an employee of
Defendant City at the Bureau of Emergency Communications who answered the 911 call ("the 911
operator."). Dunn told the 911 operator that Plaintiff was deaf and had been attacked by his
roommate. Dunn reported that Plaintiff needed an ASL interpreter. The 911 operator said that the
police officers would get an interpreter if necessary. Dunn reiterated that Plaintiff was deaf and
needed an interpreter. When Dunn asked for the 911 operator's name, the 911 operator said he was
PAGE 4 COMPLAINT
Law Offices of Daniel Snyder
Attorneys At Law
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205
(503) 241-3617 Fax (503) 241-2249

!aaassseee 333:::111222---cccvvv---000222000333555---PPPKKK

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disconnecting.
21. Portland Police officers arrived at Plaintiff's apartment without an ASL interpreter.
Plaintiff requested that the police provide an ASL interpreter to assist him in communicating with
the police. The police did not provide a qualified ASL interpreter to facilitate communication. The
police found Renner inside Plaintiff's bedroom, which Renner had broken into. During Plaintiff's
contact with the police, he was overwhelmed, disoriented and hurt. Plaintiff was unable to
understand the police officers clearly. Plaintiff tried to use laptop computer to communicate with
the police, but he could not get it to work because Renner had damaged it during the attack.
Plaintiff did not know then that Renner had removed the hard drive to the computer. Plaintiff did
not understand that he could have Renner arrested and that Renner could be required to stay away
from Plaintiff. The police did not arrest Renner. The police left the apartment.
22. On the afternoon of April 9, 2012, Renner confronted Plaintiff in the apartment a second
time. Renner made a threatening gesture toward Plaintiff as if to strike him, and then handed
Plaintiff the hard drive to Plaintiff's laptop which Renner had previously removed. Renner left the
apartment and Plaintiff reinstalled the hard drive to the computer. Renner returned later that
evening in an intoxicated state with two friends. Renner began to verbally abuse Plaintiff, causing
Plaintiff to feel unsafe. Plaintiff went into his bedroom and locked the door.
23. Renner made his friends leave the apartment and kicked in Plaintiff's locked bedroom door.
Renner grabbed Plaintiffs laptop and threw it on the floor, then pounced on Plaintiff and tried to
choke him. After the struggle, Renner grabbed Plaintiffs comforter and dragged it out of
Plaintiffs bedroom. Plaintiff ran out of his bedroom in an attempt to escape. Renner broke a lamp,
threw glasses at Plaintiff and threatened to kill Plaintiff if he left. Plaintiff again sent a telephone
text message to Dunn, requesting that she contact 911. Renner continued to behave in a violent
PAGE 5 COMPLAINT
Law Offices of Daniel Snyder
Attorneys At Law
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205
(503) 241-3617 Fax (503) 241-2249

!aaassseee 333:::111222---cccvvv---000222000333555---PPPKKK

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manner, chasing Plaintiff around the apartment. Renner tripped during the chase and Plaintiff fled
the apartment a second time.
24. Dunn contacted the 911 system again and asked the 911 operator to send police to
Plaintiff's address because Renner had broken into Plaintiff's bedroom and Plaintiff was scared.
Dunn again reported that Plaintiff was deaf and might need an interpreter.
25. In the evening of April 9, 2012, when Plaintiff ran out into the street, he met the police,
who were just arriving. The responding police officers were some of the same officers who had
responded to the first call involving Renner and knew that Plaintiff is deaf. As before, Plaintiff
requested that the police provide an ASL interpreter. Defendant City and its employees did not
provide a qualified ASL interpreter. Plaintiff tried telling the police that Aaron Renner had
attacked him. Plaintiff was aware that Aaron Renner was talking to the police but he couldn't
understand what Renner said. At some point Officer Brockman arrived. Officer Brockman signed
to Plaintiff that she was a beginner at ASL and apologized to Plaintiff for her lack of ASL skills.
Due to her lack of skills, Officer Brockman was unable to adequately assist Plaintiff. Plaintiff
struggled to communicate with the police. The police took photographs of Plaintiff's injuries. The
police eventually arrested Renner.
VI. CLAIMS
FIRST CLAIM FOR RELIEF
(Americans With Disabilities Act-Title II: 42 U.S.C. 12131 et seq.-Against Defendant City)
26. Plaintiff re-alleges all relevant prior paragraphs.
27. At all times material, Defendant City is a public entity for the purpose of, and subject to,
the Americans with Disabilities Act (ADA). Defendant provides public services.

PAGE 6 COMPLAINT
Law Offices of Daniel Snyder
Attorneys At Law
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205
(503) 241-3617 Fax (503) 241-2249

!aaassseee 333:::111222---cccvvv---000222000333555---PPPKKK

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28. Plaintiff has physical impairments that substantially limit one or more of his major life
activities. Plaintiff is hearing impaired and has been deaf since birth. Plaintiff is a qualified
individual with a disability under the ADA.
29. At all relevant times, Defendant City was aware of Plaintiffs physical disabilities, namely
that Plaintiff was deaf.
30. Defendant City discriminated against Plaintiff because it excluded him participation in or
denied the benefits of the services, programs, or activities of Defendant City, and subjected him to
discrimination.
31. Defendant City denied Plaintiff the benefits of defendants services and programs by
failing to provide adequate communication services through a qualified American Sign Language
interpreter.
32. Defendant Citys actions were intentional and/or conducted with a deliberate indifference
to Plaintiffs rights.
33. Defendant Citys actions constitute discrimination under Title II of the ADA.
34. As a result Defendant Citys unlawful actions, Plaintiff suffered and continues to suffer
humiliation, anxiety, distress, and impairment of his personal dignity and right to be free from
discrimination or interference with his statutory rights. Plaintiff suffered, and continues to suffer,
economic damages, including, but not limited to, medical bills, moving expenses, and and other
expenses. Plaintiffs economic damages are not expected to exceed $5,000. Plaintiff reserves the
right to amend this amount prior to or during trial, as the evidence requires.
35. Plaintiff is entitled to injunctive relief, including, but not limited to, an order prohibiting
Defendant City from continued discrimination against people with disabilities by refusing to
provide adequate interpretation services to deaf persons and an order mandating full compliance
PAGE 7 COMPLAINT
Law Offices of Daniel Snyder
Attorneys At Law
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205
(503) 241-3617 Fax (503) 241-2249

!aaassseee 333:::111222---cccvvv---000222000333555---PPPKKK

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with Title II of the ADA. Defendant City should also be required to establish uniform policy and
procedures in both the Bureau of Emergency Communication and the PPB establishing protocols
and procedures for supplying ASL interpreters whenever a deaf crime victim or deaf crime witness
makes a report, requests assistance, is to be interviewed by the police, or when someone makes a
report for that person.
36. Plaintiff is entitled to compensatory damages for emotional pain, suffering, inconvenience,
mental anguish, loss of enjoyment of life, and other nonpecuniary losses in an amount to be proved
at trial.
37. Defendant's conduct was with malice or reckless indifference to Plaintiffs federally
protected rights and punitive damages should be awarded against Defendant.
38. To the extent any amount awarded to Plaintiff is for damages occurring prior to the entry of
judgment, Plaintiff is entitled to an award of prejudgment interest at the legal rate from the date the
damage occurred until the date of judgment.
39. Pursuant to 42 U.S.C. 1988 and 2000e-5, Plaintiff is entitled to an award of attorneys
fees, expert witness fees and costs incurred.
40. Plaintiff is entitled to post judgment interest on all damages, costs, expenses, and fees from
the date of judgment until the date paid.
SECOND CLAIM FOR RELIEF
(Violation of Federal Law Pursuant to 42 U.S.C. 1983 - Against Defendant City, and
Defendants Lisa Turley and Michael Reese, in their Personal Capacities)
41. Plaintiff re-alleges all relevant paragraphs.
42. Plaintiff is a qualified individual under Title II of the ADA, 42 U.S.C. 12132, because he
has been deaf since birth.
PAGE 8 COMPLAINT
Law Offices of Daniel Snyder
Attorneys At Law
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205
(503) 241-3617 Fax (503) 241-2249

!aaassseee 333:::111222---cccvvv---000222000333555---PPPKKK

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43. Defendant City was acting under the color of law when it provided emergency police
services to Plaintiff on April 9, 2012.
44. The 911 operators followed an official policy or a longstanding custom or practice when
they denied Plaintiffs two requests for an ASL interpreter and failed to provide Plaintiff with an
ASL interpreter.
45. The police officers followed an official policy or a longstanding custom or practice when
they failed to provide Plaintiff with an ASL interpreter.
46. Failing to provide an ASL interpreter to Plaintiff deprived him of his rights to participate in
and enjoy the benefits of Defendant Citys public services and to be free from discrimination by
Defendant City.
47. Defendant Lisa Turley was acting under the color of law when she created, adopted, and
implemented a policy for providing emergency police services to disabled persons.
48. Defendant Michael Reese was acting under the color of law when he created, adopted, and
implemented a policy for providing emergency police services to disabled persons.
49. Defendants Turley and Reese knew or should have known that creating, adopting, and
implementing policies for providing emergency police services to disabled persons that do not
include providing ASL interpreters to deaf individuals who call 911 and/or are the victims of
crimes would violate federal laws prohibiting disability discrimination.
50. Plaintiffs federal rights to participate in and enjoy the benefits of the City of Portlands
public services and to be free from discrimination were violated by Defendant Turleys and
Defendant Reeses creation, adoption, and implementation of policies for providing emergency
services to disabled persons.

PAGE 9 COMPLAINT
Law Offices of Daniel Snyder
Attorneys At Law
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205
(503) 241-3617 Fax (503) 241-2249

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51. As a result Defendants unlawful actions, Plaintiff suffered and continues to suffer
humiliation, anxiety, distress, and impairment of his personal dignity and right to be free from
discrimination or interference with his statutory rights. Plaintiff suffered, and continues to suffer,
economic damages, including, but not limited to, damages alleged above. Plaintiffs economic
damages are not expected to exceed $5,000. Plaintiff reserves the right to amend this amount prior
to or during trial, as the evidence requires.
52. Plaintiff is entitled to compensatory damages for emotional pain, suffering, inconvenience,
mental anguish, loss of enjoyment of life, and other nonpecuniary losses in an amount to be proved
at trial.
53. Plaintiff is entitled to a declaration that Defendant Turleys and Defendant Reeses conduct
violated Plaintiffs federal statutory rights.
54. Plaintiff is entitled to compensatory damages for emotional pain, suffering, inconvenience,
mental anguish, loss of enjoyment of life, and other nonpecuniary losses in an amount to be proved
at trial.
55. Plaintiff is entitled to pre and post judgment interest on all damages, costs, expenses, and
fees from the date of harm until the date paid.
56. Plaintiff is entitled to recover her reasonable attorney fees and costs, including expert
witness fees.
PRAYER FOR RELIEF
Plaintiff prays for the following judgment against Defendants:
WHEREFORE, the Plaintiff seeks judgment against Defendant, jointly and severally as
follows:

PAGE 10 COMPLAINT
Law Offices of Daniel Snyder
Attorneys At Law
1000 S.W. Broadway, Suite 2400
Portland, Oregon 97205
(503) 241-3617 Fax (503) 241-2249

!aaassseee 333:::111222---cccvvv---000222000333555---PPPKKK

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Injunctive, declaratory, and equitable relief as the court deems appropriate,

including but not limited to, an Order requiring Defendant City to provide qualified American
Sign Language interpreters and auxiliary aids;
2.

A sum which will fully compensate Plaintiff for his non-economic damages in a

sum that is just as determined by a jury;

3.

A sum which will fully compensate Plaintiff for his economic damages in a sum

that is just as determined by a jury;

4.

Liquidated damages;

5.

Punitive damages against Defendant City on the First Claim for Relief to be

determined by a jury;
6.

Plaintiffs costs and disbursements incurred herein;

7.

Plaintiffs attorney fees; and

8.

For such other and further relief as the Court may deem just and equitable.

Plaintiff demands a trial by Jury.

DATED this 13th day of November, 2012.
Law Offices of Daniel Snyder
/s Daniel Snyder____________
Daniel Snyder, OSB No. 783856
dansnyder@lawofficeofdanielsnyder.com
Carl Post, OSB No. 06105
carlpost@lawofficeofdanielsnyder.com
Cynthia Gaddis, OSB No. 113907
cindygaddis@lawofficeofdanielsnyder.com
Telephone: (503) 241-3617
Facsimile: (503) 241-2249
Of Attorneys for Plaintiff

PAGE 11 COMPLAINT

LAW OFFICES OF DANIEL SNYDER

1000 S W Broadway
Suite 2400
Portland, Oregon 97205
(503) 241-3617 Fax (503) 241-2249

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