
DOJ CIVIL RIGHTS COMPLAINT
(Copy and paste into https://civilrights.justice.gov)
Category to Select in the DOJ Portal:
“Law Enforcement Misconduct” → False Arrest / Abuse of Authority
Narrative Description
Complainant:
Jason Karimi
Sioux Falls, South Dakota
Email: [your email]
Phone: [your phone number]
Summary of Complaint
I am filing this civil rights complaint regarding my arrest and jailing for an alleged violation of a Temporary Protection Order (TPO) that was legally invalid and unenforceable at the time of my arrest. The arrest violated my Fourth and Fourteenth Amendment rights because law enforcement lacked probable cause and acted under color of law to deprive me of liberty without a valid legal basis.
Agencies Involved
Arresting Agency: [Name of Police Department or Sheriff’s Office] County: [Hanson County / Minnehaha County – specify which made the arrest] Prosecuting Authority: [County State’s Attorney Office] Jail Facility: [Name of jail where you were booked]
Timeline of Events
Date of TPO Issuance: [date] Date of Alleged Violation: [date] Date of Arrest: [date] Date TPO Was Dismissed or Found Invalid: [date] Charges Filed: Violation of Protection Order Outcome: Charges were dismissed after judicial review
Facts of the Violation
A Temporary Protection Order was filed against me in Hanson County, South Dakota. The order was procedurally and legally defective and did not meet statutory requirements for enforcement. Despite this, law enforcement treated the order as valid. I was arrested by [agency] based solely on an alleged violation of this TPO. At the time of my arrest, the underlying order was either void on its face, or legally insufficient to support probable cause. Law enforcement failed to conduct any reasonable investigation into the validity of the order before arresting me. I was jailed, booked, and detained based on an order that was not legally enforceable. The criminal charge for TPO violation was later dismissed because the order was not valid. Despite the ultimate dismissal, I suffered loss of liberty, reputational harm, emotional distress, and financial damages.
Constitutional Rights Violated
The actions of the involved officials violated:
Fourth Amendment: Unreasonable seizure / false arrest without probable cause Fourteenth Amendment: Deprivation of liberty without due process Civil rights protections under 42 U.S.C. §1983
Evidence Available
I can provide the following documentation:
Arrest report Probable cause affidavit TPO filings and court records Court order dismissing the TPO and/or criminal charge Jail booking records Body camera footage Dispatch and 911 logs Emails and correspondence with law enforcement Court docket showing lack of legal basis for arrest
Requested Action
I respectfully request that the U.S. Department of Justice:
Investigate whether the involved law enforcement agencies engaged in unconstitutional arrest practices; Determine whether there is a pattern or practice of enforcing invalid protection orders; Review whether my arrest constituted a civil rights violation; Take appropriate enforcement action or refer the matter for federal investigation.
Impact on Complainant
As a direct result of this unlawful arrest I experienced:
Loss of liberty and wrongful detention Emotional distress and anxiety Legal expenses Reputational harm Disruption of employment and personal life
Closing Statement
This arrest occurred not because I committed a crime, but because officials enforced an invalid court order without verifying its legal sufficiency. No person in the United States should be jailed based on a void order or without probable cause.
I ask the Department of Justice to review this matter and protect the civil rights guaranteed to me under the Constitution.
Submitted by:
Jason Karimi
[Date]
Attachments to Upload with the Complaint
When submitting, attach:
Copy of the TPO Arrest report Booking sheet Dismissal order Court docket Any bodycam requests Emails showing the order was invalid
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