by Pam Zubeck
DATE: September 21, 2015Council decided today to provide city legal representation for the officers.
TO: Colorado Springs City Council
FROM: Office of the City Attorney
SUBJECT: Grant Bloomquist v. Jeremy Sheldon, John Ireland, Nathan Johnson, Felix
Juliano, Jordan Leffler, Rafael Chanza, David Rosenhoflj Jim Jeffcoa1,
and John Garza; Case No. 15-cv-01398-RPM-NYW
This memorandum is to apprise you of the facts alleged in the above-referenced case
as you consider the claims made against the Officers involved, and the
recommendation of the Civil Action Investigation Committee.
NATURE OF THE CASE
Plaintiff, Grant Bloomquist, has brought this action in the United States District Court for
the District of Colorado alleging that the named officers falsely arrested him, used
excessive force, violated his free speech rights and maliciously prosecuted him.
Plaintiff alleges, in his complaint, that on July 4, 2013, at about 12:50 a.m., he exited
Cowboy’s nightclub. At this time he witnessed two officers engaged in a physical
altercation with a man. Plaintiff alleges that he approached the altercation, and without
making any physical contact, and maintaining a distance of several feet, asked the
officers to get off the man. Plaintiff then alleges that he was struck in the face by
another officer. Plaintiff then alleges that he was taken into custody and falsely
Plaintiff is seeking an unspecified amount of money for his claimed damages to include
emotional pain, suffering, inconvenience, mental anguish, loss of enjoyment of life,
medical bills, other non-pecuniary losses, punitive damages, interest, and fees and
costs. Plaintiff is also seeking injunctive relief to include an apology from each
Defendant, policy changes, a prohibition against retaliating against Plaintiff and
disciplinary action against Defendants.
According to the reports, and an interview with Plaintiff just hours after the incident,
several patrons from Cowboy’s nightclub were removed from Cowboys. Upon leaving
the premises, the patrons and others continued to cause problems on Tejon Street.
While the Officers attempted to control the situation, which involved numerous people
and was dangerous, Plaintiff approached the situation involving the aforementioned
30 S. Nevada Avenue, Suite 501 • TEL 719-385-5909 FAX 719-385-5535
Mailing Address: Post Office Box 1575 Colorado Springs, CO 80901-1575
CITY OF COLORADO SPRINGS
Plaintiff did not ask the Officers to get off the man. Plaintiff said nothing. Rather, Plaintiff inserted himself into the situation, went over the back of an Officer, grabbed the man and began pulling the man away from the Officers. While Plaintiff denied having contact with the Officers, he admitted to saying nothing and grabbing and pulling the
man away. Plaintiff was then subdued, taken into custody, and charged with obstructing a peace officer.
The Civil Action Investigation Committee met on September 15, 2015, and has
recommended that the City represent the Officers as required by the Colorado
Governmental Immunity Act and the Peace Officer’s Liability Act. The Officers were
acting in the course and scope of their employment and not in a willful and wanton
manner. As usual, it is recommended that the City reserve the right to not pay any award of punitive damages.