Case: 1:20-cv-05753 Document #: 1 Filed: 09/23/20 Page 1 of 14 PageID #:1

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION

RECEIVED
sEP 2 I 20205H
(Enter above the fLrll name
of tlre plaintiff or plaintiffs in .'IHEUfrBf*[YEBU*'
this actiorr)

Case No:
(To be supplied by tlre Clerk of tlris CoLrrt)
l. gp(}ql( oq[; (t .#/
G^olrl o(,.* +ra

(Enter above the fLrll narne of ALL

1:20-cv-5753
defendants in this action. Do rrot
Judge Mary M. Rordand
use "et al.")
Magisilnate Judge Sunil R. HarJani
CHECK ONtr ONLY: PC4

COMPLAINT UNDER THE CIVIL RIGHTS ACT, TITLE 42 SECTION I983

U.S. Code (state, county. or municipal defendarrts)

COMPLAINT UNDER THE CONSTITUTION (''BIVENS'' ACTION), TITLE

28 SECTION 1331 U.S. Code (federal defendants)

OTI-IER (cite statute, if known)

BEFORE FILLING OUT TTIIS CO]UTPLAINT, PLEASE REFER TO "INSTRUCTIONS FOR

FILING. " FOLLOLY TTIESE INSTRUCTIONS CAREFULLI'.

\)ie c\\L dn \otK J'* A

XN6{.L
o-[ Gr'l-\?, 5- do no !
\o-rG"u\ t
\.,ou t- GCc*.sS Sf"y. };o'^l-.,
 Case: 1:20-cv-05753 Document #: 1 Filed: 09/23/20 Page 2 of 14 PageID #:2

Plaintiff(s):

A. Name:

B List all aliases:

C P ri sone l- idertificatiorr rrumber: S - Cl ..tt t

D. f
Place o pres ent confine,r.n,, C un !.o\', Co a t-' Cn tt'{ t'-
^
E, Acldres S: P, b, a8c(

(ll.ther,e is rnore tlran one plaintiff, then eacli plaintiff mLrst list his or he r llarlle. aliases'
I'D'
nuurber, place of confitletnetrt, atrcl currellt adclresS accOrding tO the above fOrmat On a

separate slreet of paPer.)

II. Defendant(s):
(lrr A belorv, place tlre firll name of the first defendant in the first blank, Iiis or her olficial
position iti the second blanlt, arrd lris or her place of etnployment in the third blanl<' Space
B and C.)

Title: (h,co,qt)
ptaceof Errptoy',en,, Q AD rN\, K,qZ,'r 5t' 5',\< 900- IL
I

boBl
B. Deferrdant:

Title: k 0(
Sur e\^,cq Y c)
Nl, --l-L'
Place of E,mploynierrt (rt) (oD1

C Deferrdaiit:

Title:

PIace of Employment:

(lfyoLr have more tharr three defendants, tlrerr all additional defendarrts must be listed
according to the above lormat on a separate slreet of paper.)

Rev ised 9/2007

 Case: 1:20-cv-05753 Document #: 1 Filed: 09/23/20 Page 3 of 14 PageID #:3

if any) have filed in any state or federal

III. List ALL lawsuits you (and your co-plaintiffs'
court in the Unit.ed States:

pf case Pnd docket trlttnber:

Ll(p I
A. Nanre
Vr+ r , L)--

Approxirrate clate of filing lawsitit:

any aliases: Altl ^ -(
C List all plaintiffs (if yoLr had co-plairrtiflfs). i,cluding

D. List all defendants: V* l' AJ'...'

^'

filed 1if federal colu1, nanre the district; if state

coLIrt'
E. court in which the lawsprit yvas
rrarrre the courrty):',flr l-l-1.^'\' ttt'tl-
F. Narne ofjLrdge to whom case was assignecl: d''n I K^'')

G. Basic clairn ,rua., iTlqr\'. f'-'r'^r rvr'i Acl"q tt''/'t t

^l

Was it appealed?
H. Disposition of tlris case (lor.exantple: Was the case clisrnissed?
ls iistill penclirig?): I 5ft, K<

Approxirr-iate date of dispositio,-,t l0 / ?

IFYoUI-IAVEFILTDMoRnTHANONIILAWSUIT,THENYoUMUSTDESCRIBETHE SAME
ADDITIONAL LAWSUITS ON ANOTI{ER PIECE. OF PAPER' USING TFIIS
FILED'
FORMAT. RIIGARDLESS OF IIOW MANY CASES YOU HAVE PREVIOUSLY
YOU WILL NOT BE EXCUSED FROM FILLING OUT THIS SECTION COMPLETELY'
AND FAILURE 'I'O DO SO MAY RI,SULT IN DISMISSAL OF YOUR CASE' CO-
PLAINTIFFS MUST ALSO LIST ALI. CASES THEY HAVB FILED.

Iievised 9/2Ci07
 Case: 1:20-cv-05753 Document #: 1 Filed: 09/23/20 Page 4 of 14 PageID #:4

IV. Statement of Claim:

eachdefendant is
facts of your case' Describe how
state here as briefly as possible the arguments or cite any
inclr-rding nu,r"r, dates. and plu."r. io not give any legal
involved,
casesorstatutes. Ifyoui'tendtoallegeanumberofrelatedclairns'nltlnberatrdsetforthextra sheets
(Use as muchspace as you treed' Attaclr
each clainr in a separate paragraph.
if necessarY.)
',C o/
/o /, h
r(h
/ me,

OL)
S< t)

V^ \)o p
U
Tlrt< .-k
lrlr
/U , s5,ss yr

Cq
e{rn<
O.
Jnrf ?'r
€('L/ T5ulk

Revised 9/2007
Case: 1:20-cv-05753 Document #: 1 Filed: 09/23/20 Page 5 of 14 PageID #:5

Revised 9/2(J07
 Case: 1:20-cv-05753 Document #: 1 Filed: 09/23/20 Page 6 of 14 PageID #:6

V. Relief:
cout-t to do for you. Malte no legal argrrme nts' Cite
State briefly exactlY what you want tlre
no cases or statutes'

autr, ktl t;

" tt f',t e{A t4 [7

The plairrtilf detnands tlrat the case be tr-ied by a
jLrry' {,,, tr NO
VI.

CERTIFICATION

By signing this Conrplaint, I certify that the facts stated ir-r tlris
ilrlorrnatiotr atrd
Complairrt are true to the best of my l<nowledge'
I rnay be
belief. I r-rnderstand that if this certificatiorr is trot correct'
subject to sanctiotls by the Coud'

Sigrred t
q'! day of 2.o

(SignatLrre of plaintiff or plaintiffs)

(Print rrarne)

,,.O
^u,"'.,'r?, 0,, RaX J 7i /
Cr n {.o\', o.
-r r- b 366 I

(Address)

*.".r.O 9720f)7
 Case: 1:20-cv-05753 Document #: 1 Filed: 09/23/20 Page 7 of 14 PageID #:7
JOIN RIVERFRONT TIMES PRESS CLUB. BECAUSE NO NEWS IS BAD NEWS.

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Joker Bites His Wife's Face, Tells Cops

He's Batman
Posted By Keegan Hamilton on Thu, Jul 23, 2009 at 1:09 pm

scrapetv. com

"Never start with the head, the victim gets

all fu2ry."
You know, criminals in this town used to believe in things. Honor.
Respect. Look at Granite City resident Thomas Byrd. What does he believe in?

According to a story in this morning's Belleuille Neras-Democrat, face-biting:

homas Byrd, 32, was sentenced to 24 years in prison Wednesday after

lOleadinS guilty to a July 20O8 attack that a prosecutor described as
i"something out of a horror film." Byrd pleaded guilty to charges of
ggravated kidnapping and home invasion in connection with the attack on
estranSed wife.
Nhis
I
IByrd was under a restraining order to stay away from the victim, who had
i
perved him with divorce papers. He had already been convicted of domestic
Ihaftcrv and hrrrclerv affer sfcalinp itpms frrim hpr and hcr darrphter
 Case: 1:20-cv-05753 Document #: 1 Filed: 09/23/20 Page 8 of 14 PageID #:8
the kidnapping He threw paving stone through the grass
door of the
,v-ictim's Granite crty home and went up
the stairs, breaking into her
pedrooin. He disarmed her and attacked her,
then forced her into a car and
ld.or* into St. Louis.
I

*ccording to Granite city porice Detective

Mike parkinson, Byrd tord the
yictim he was going to kiil her. That,s
when she grabbed the wheer and
itried to crash the car. Byrd stopped in St.
Louis and attacked her, biting a
thunk out of her face.

Byrd treated the investigation as ,,a

iflfi:::;:,ff:,:n" foke," giving

C'mon Detective parkinson, '"\ilhy

so serious?,,

Tags: News, Crirm, lmage

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and beyond.

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- and wr? rike to keep it that$/ay, because
now more than ever, ev€ryore deserves we berieve,
acceis to accurate, independent coverage
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 Case: 1:20-cv-05753 Document
Husband charged #: 1 Filed:
with sexual assault 09/23/20
I Suburban Joumals ofPage
Greater 9
St.of 14I s{today.com
Louis PageID #:9

Husband charged wit{r sexual assaultsuARE THts

https://www.stltoday.com/suburban-joumals/husband-charged-with-sexual-assaulVarticle_e14a4882-e6da-5688-
9d a b -f3 9ed 227 cc7 c.html

Husband charged with sexual assault

Faces other charges

By Michael Heil
)ul 20,2008

Subscription sale! $5/5 months

 Case: 1:20-cv-05753 Document
Husband charged with sexual #: 1 Filed:
assault 09/23/20
I Suburban Page
Journals of Greater10
St. of 14I stltoday.com
Louis PageID #:10

ARE THIS )t0

#' ','u*
ryr

rts
tort
fl
Ilt

H
*

Thomas E. Byrd

A Granite City woman is recovering from injuries she sustained during an incident
lft in which she was allegedly sexually assaulted by her husband, Thomas E. Byrd.,
during a home invasion.

The victim is separated from Byrd and is in the process of divorcing him, according to
Granite City Police Chief Maj.JeffConnor.

The victim had obtained an order of protection prior to the alleged home invasion.

The victim did not sustain life-threatening injuries. She was treated at a St. Louis-area
hospital and released, Connor said.
9t6t2020 Case: 1:20-cv-05753 Document
Husband chargred with sexual #: 1 Filed:
assault 09/23/20
I Suburban Journals ofPage
Greater11 of 14
St Louis PageID #:11
I sdtoday.com

Byrd,al,of Hazlehurst,Miss.,*ft i,il1pfng$.J#ltLtlB,Y**f, gIl$9H,,,.-

with two counts of aggravated kidnapping, one count of home invasion
of criminal sexual assault. All are felony charges.

Bail was set at $3oo,ooo by Judge Charles Romani.

The alleged sexual assault and home invasion took place on July 11. At that time, Byrd
allegedly kidnapped his estranged wife, taking her to St. l,ouis.

"During an interview, it was learned that the suspect broke into the victim's home
during the night and attacked her," Connor said. "\{hile in the car, the suspect bit the
victim in the face and continued to beat her. She was able to free herself and flag down
people who contacted St. Louis police."

Connor said the victim was forced in the car from her home in the 9oo block of Fisher
Court.

The St. [,ouis Police Department notified Granite City authorities, saylng that it had a
woman at the Police Department who said she resided in Granite Crty.
 Case: 1:20-cv-05753 Document
Husband charged with sexual#: 1 Filed:
assault 09/23/20 Page 12 of 14 PageID #:12
I Suburban Journals of Greater St. Louis I stltoday.com

Granitp,city. authorities, connor_qai.d, w-ent to st.,Louis to talk to the wo

HusbSnd charged with sexual a*sauftSHanr rHtS )to
"We learned that the victim (the woman) was the same victim of burglaries in Granite
City, and that the suspect was once again Byrd," Connor said.

The burglaries took place at the victim's home on June 23-24, Connor said.

On July tt, the same day he allegedly broke into the victim's home and sexually abused
and kidnapped her, Byrd was charged in Madison County Circuit Court with felony
residential burglary, according to the Madison County State's Attorney office.

The home invasion and kidnapping took place after the charge was filed and Byrd had
been released from Madison County Jail after pleading guilty to the burglary charge.

Byrd received two year's probation.

On July tz, the day after he was released from jail, Byrd was arrested in St. Louis by
U.S. Marshals, Connor said, on the criminal sexual assault, aggravated kidnapping and
home invasion charges.

Byrd is awaiting extradition from St. Louis to Madison County on the charges, Connor
said.
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Case: 1:20-cv-05753 Document #: 1 Filed: 09/23/20 Page 14 of 14 PageID #:14