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Castro v Salinas First Amended Complaint 2019-03-28

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IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF TEXAS
SAN ANTONIO DIVISION
JOANNA CASTRO,
PLAINTIFF
V.
ALBERT SALINAS,
DEFENDANT
Case No. 5:18-CV-312
PLAINTIFF’S FIRST AMENDED COMPLAINT
& JURY DEMAND
Introduction
This civil action arises from Defendant’s violations of Plaintiff’s civil rights on or about February 20, 2018, in Austin, Texas. This action is brought pursuant to 42 U.S.C. § 1983, 42 U.S.C. §1988, and the United States Constitution. This is a civil rights action challenging as unconstitutional the above-named Defendant’s intentional violation of Plaintiff’s First Amendment right to film the police in public, Defendant’s retaliation against Plaintiff for exercising her First Amendment rights by filing a false misdemeanor charge against her, and Defendant’s excessive force used against Plaintiff. Plaintiff Castro seeks damages from Defendant, in his individual capacity as he acted under color of law, for depriving Plaintiff of her First, Fourth, and Fourteenth Amendment rights under the United States Constitution. Plaintiff also seeks declaratory relief pursuant to 28 U.S.C. §2201 that the Defendant violated rights arising under the Constitution.
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Liz
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