Stucky v. Conlee, Parsell, and The City of Nita is a civil rights action for damages arising out an alleged instance of 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. On August 5, YR-2, Stucky was off duty and was driving his personal car when he was pulled over by City of Nita Police Officer Eric Conlee and Officer Lance Parsell. Both officers are Caucasian. Conlee and Parsell allege that Stucky was driving over fifty miles per hour in a twenty-five miles per hour zone. 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 at the speed limit and alleges that Conlee and Parsell pulled him over for "driving while black." Stucky sued Conlee and Parsell for damages for 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 the City of Nita as a defendant. Stucky alleges that City of Nita Police Chief Kurt Lieber was deliberately indifferent with respect to the training and supervision of Conlee and Parsell as to the risk of racial profiling, and that Lieber's deliberate indifference was a cause of Conlee and Parsell's stop of 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. Digital versions of the exhibits are provided on the accompanying CD.
Table of Contents
STIPULATED SUMMARY OF MEDICAL EXPENSES
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
Exhibit 1: Photo of Stucky's vehicle
Exhibit 2: Photo of street where stop occurred
Exhibit 3: Photo of street where stop occurred
Exhibit 4: Photo of street where stop occurred
Exhibit 5: Photo of street where stop occurred
Exhibit 6: Traffic Citation
Exhibit 7: Transcript of Preliminary Hearing
Exhibit 8: Bill from Attorney Clinton T. Manges
Exhibit 9: ACCU Weather Report
Exhibit 10: Excerpts from City of Nita Police Department Rules, Policies, and Procedures Manual
Exhibit 11: City of Nita Police Department Traffic Enforcement Training Manual
Exhibit 12: City of Nita Police Department Traffic Study
Exhibit 13: Conlee Performance Evaluations from NITA Township for the category "Lack of Prejudice"
Exhibit 14: Article from Nita Gazette, May 4, YR-2
Exhibit 15: Note from Dr. Stovall excusing Stucky from work
Exhibit 16: Note from Dr. Collins excusing Stucky from work
Exhibit 17: Note from Dr. Collins releasing Stucky for work
FINAL JURY INSTRUCTIONS
FINAL VERDICT FORM