Case 1:15-cv-11777-RGS Document 1 Filed 05/05/15 Page 1 of 15

UNITED STATES DISTRICT COURT

DISTRICT OF MASSACHUSETTS
__________________________________________
)
ALICE SWIRIDOWSKY-MUCKLE,
)
as Personal Representative of the estate of
)
Alyssa Marie Brame,
)
)
Plaintiff,
)
)
v.
)
Civil Action No. 15-11777
)
THOMAS SIOPES, MICHAEL KILMARTIN,
)
JAMES FAY, MICHAEL GIUFFRIDA, FRANCIS )
NOBREGA, WILLIAM FLORENCE, ROBERT )
DYER, CHARLES PAPPACONSTANTINOU,
)
KEVIN LOMBARD, and SHAWN
)
TETREAULT in their individual capacities,
)
and THE CITY OF LOWELL,
)
)
Defendants.
)
__________________________________________)
COMPLAINT
INTRODUCTION
1.

This is a civil rights and wrongful death action for the failure of Lowell police

supervisors, police officers, and detention attendants to provide medical care for Alyssa Brame
despite an obvious medical emergency. Ms. Brame was intoxicated when Lowell police officers
arrested her on January 12, 2013. Shortly after she arrived at the police station, her condition
deteriorated from being intoxicated to being unconscious. Despite a formal written policy requiring
medical attention for any prisoner who was unconscious, Ms. Brame was placed in a cell alone
without any medical screening. When she went into the cell she was not responsive to stimuli but
she was still alive. No one checked on her for an hour and six minutes. More than an hour later
when someone finally checked on her condition she was dead.
2.

Although the cause of Ms. Brames death was alcohol intoxication, she died because

numerous Lowell police officers were deliberately indifferent to her serious medical needs. Had

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Defendants provided Ms. Brame with medical attention shortly after she arrived at the police
station, she would have survived. After investigations of this incident by the Middlesex District
Attorneys office and the Lowell Police Department, Lowell Police Superintendent William Taylor
said in a memo to all staff that Ms. Brame was not given the proper medical attention that she was
in obvious need of while in the custody of the Lowell Police Department. He also said that, in his
opinion, some Lowell police employees displayed conduct which could be described as
deliberate indifference for Ms. Brame and that such conduct should shock the conscience of us all.
3.

The City of Lowell is sued for allowing a custom or practice of deliberate

indifference to the serious medical needs of intoxicated persons to exist within the Lowell Police
Department. Five supervisory officers saw that Ms. Brame was unconscious yet none of them
ordered medical care; they all permitted Ms. Brame to be locked in a cell while unconscious. This
custom or practice had taken the place of the departments formal written policy.
JURISDICTION
4.

This action is brought pursuant to 42 U.S.C. 1983 and 1988 and the Fourth and

Fourteenth Amendments to the United States Constitution. Title 28 U.S.C. 1331 and 1343
provide federal question jurisdiction over all federal claims, and 28 U.S.C. 1367 provides
supplemental jurisdiction over the state law claims.
PARTIES
5.

Plaintiff Alice Swiridowsky-Muckle is the duly appointed personal representative of

the estate of Alyssa Marie Brame. She was appointed by the Middlesex Probate Court on December
23, 2014. She is a resident of Connecticut. Alyssa Marie Brame was her daughter.
6.

Defendants Thomas Siopes, Michael Kilmartin, James Fay, Michael Giuffrida,

Francis Nobrega, William Florence, Robert Dyer, and Charles Pappaconstantinou were at all times
relevant to this complaint duly appointed police officers of the Lowell Police Department. Their
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actions alleged in this complaint were taken under color of the laws of the Commonwealth of
Massachusetts and the City of Lowell. They are sued in their individual capacities.
7.

At the time of Ms. Brames death, Defendant Thomas Siopes was a Lowell police

lieutenant. He was the officer in charge of the Lowell police station when Ms. Brame arrived in
custody. Defendant Siopes was responsible for supervising the other police officers at the station
and for assuring that prisoners received needed medical attention. Defendant Michael Kilmartin also
was a Lowell police lieutenant. Defendants James Fay, Michael Giuffrida, and Francis Nobrega were
Lowell police Sergeants. Defendants William Florence, Robert Dyer, and Charles
Pappaconstantinou were Lowell police officers.
8.

Defendants Kevin Lombard and Shawn Tetreault were at all times relevant to this

complaint employed by the City of Lowell as Lowell Police Department detention attendants. Their
actions alleged in this complaint were taken under color of the laws of the Commonwealth of
Massachusetts and the City of Lowell. They are sued in their individual capacities.
9.

Defendant City of Lowell is a duly organized municipal corporation under the laws

of the Commonwealth of Massachusetts. The Police Superintendent is the City of Lowells final
policymaker for the Lowell Police Department.
FACTS
10.

In January 2013 Alyssa Marie Brame was thirty-one years old. She had moved from

Maine to Lowell, Massachusetts, a few months earlier.

11.

Ms. Brame was struggling with alcohol addiction and other problems. She hoped to

obtain services to help with her difficulties. She wanted to turn her life around.
12.

At approximately 10:30 p.m. on January 12, 2013, Defendants Charles

Pappaconstantinou and Robert Dyer arrested Ms. Brame in Lowell. They alleged she was offering
sex for money.
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13.

According to Defendants Pappaconstantinou and Dyer, Ms. Brame was obviously

intoxicated at the time of the arrest but she was still able to communicate and stand on her own.
14.

Defendant William Florence transported Ms. Brame to the Lowell police station in a

police wagon. The wagon arrived at the station at about 10:40 p.m. About two minutes later,
Defendant Florence tried to remove Ms. Brame from the wagon. She was sitting upright and
speaking, but mumbling her words. Defendant Florence determined that she was extremely
intoxicated.
15.

Ms. Brame was unable to exit the police wagon on her own. Defendant Florence and

Defendant Kevin Lombard carried her out of the wagon and placed her on the ground in a semiseated positon.
16.

Defendant Francis Nobrega, a sergeant, entered the police garage and viewed Ms.

Brame. He felt that she was extremely intoxicated. Defendant Nobrega felt Ms. Brame was so
intoxicated that he questioned how she could have been able to commit the crime charged. He
informed the lieutenant-in-charge, Defendant Thomas Siopes, of this concern.
17.

Defendants Florence and Lombard, along with a UMass Lowell police officer,

carried Ms. Brame to the stairway leading into the police station from the garage. They put her on
the ground in a seated position at the base of the stairs.
18.

Defendant Siopes came to the staircase landing to view Ms. Brame. Defendants

Michael Kilmartin, Michael Giuffrida, and James Fay also came to the stairway to view Ms. Brame.
They all saw that she was extremely intoxicated. At this point, Ms. Brames eyes were open and she
was speaking but her speech was slurred and her words did not make sense.
19.

After viewing Ms. Brame, Defendant Siopes ordered the arresting officers,

Defendants Pappaconstantinou and Dyer, to come to the police station and explain how Ms. Brame
could have committed the crime charged.
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20.

At approximately 10:47 p.m., Ms. Brame laid on the floor. Defendant Lombard said

he heard her snoring. At this point, she was unconscious due to alcohol intoxication. She never
regained consciousness.
21.

Defendant Lombard, a civilian detention attendant, asked Defendant Fay if they

were going to call an ambulance for Ms. Brame. Defendant Lombard saw that Ms. Brames
condition required her to be evaluated by a medical professional.
22.

Despite Ms. Brames obvious and serious need for emergency medical attention,

Defendant Fay told Defendant Lombard that an ambulance would not be called.
23.

Had an ambulance been called, firefighters trained to handle medical emergencies

would have arrived from the Lowell fire station within one to two minutes. The fire station is
located next door to the police station. An ambulance could have promptly transported Ms. Brame
to a local hospital for emergency medical treatment which would have saved her life.
24.

At approximately 10:50 p.m., Defendant Pappaconstantinou, one of the arresting

officers, entered the stairway landing and saw Ms. Brame. He said her condition had deteriorated
drastically since she had been arrested. He said she appeared to be passed out. She was
unconscious due to alcohol poisoning.
25.

Although Defendant Pappaconstantinou saw that Ms. Brame had a serious medical

need, he did nothing to provide her with medical care.

26.

At approximately 10:52 p.m., Defendant Giuffrida returned to the stairway and

observed Ms. Brame. He saw that her condition had deteriorated while she was at the police station.
She was no longer talking. She was lying on her back. Defendant Giuffrida ordered Defendants
Florence and Lombard to remove Ms. Brames handcuffs. Ms. Brame was not responsive to stimuli
as the officers moved her around to remove the handcuffs and open her jacket.

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27.

Defendant Giuffrida saw that Ms. Brame was experiencing a medical emergency but

did nothing to help her or get help for her. He saw that Ms. Brame was unresponsive and later said
he checked Ms. Brame for vital signs. He said he determined that Ms. Brame was still alive because
she had a pulse and was breathing. According to Defendant Giuffrida, the only possibly voluntary
response Ms. Brame made while he checked her pulse was briefly opening and closing her eyes.
28.

Defendant Giuffrida did not check to see if Ms. Brame could be roused; she did not

speak or make a sound during his brief evaluation. Ms. Brame was unconscious due to alcohol
poisoning. It would have been obvious to a reasonable police officer or even a reasonable civilian
that Ms. Brame, while still alive, was experiencing a serious medical emergency requiring immediate
evaluation and treatment. Defendant Giuffrida did nothing to obtain medical attention for Ms.
Brame.
29.

Defendant Giuffrida left the police station without informing anyone about his

observations of Ms. Brames condition.

30.

At about 10:55 p.m., Defendant Fay ordered that Ms. Brame be brought to the

booking room, located at the bottom of the staircase. Defendants Florence and Lombard along with
Defendant Fay carried Ms. Brame down the stairs and into the booking room. They carried her by
her arms and legs. Ms. Brames eyes were closed and she was not speaking. She was not responsive
to the jostling of being carried. She was unconscious due to alcohol poisoning. At this point, Ms.
Brame had not had a voluntary movement or communicated with anyone for approximately nine
minutes. She had not moved her body during this time other than briefly opening and closing her
eyes as described above.
31.

In the booking room, Defendants Fay, Florence, and Lombard placed Ms. Brame on

the floor lying on her back with her face up. She was unconscious. Although it would have been
obvious to a reasonable police officer or even a reasonable civilian that Ms. Brame, while still alive,
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had a serious medical need that required immediate medical evaluation and treatment, neither Fay,
Florence, nor Lombard took any steps to obtain medical attention for Ms. Brame.
32.

Defendant Shawn Tetreault, a detention attendant, was in the booking room when

the officers carried in Ms. Brame. He saw that she was motionless and unresponsive on the floor.
He assisted Defendant Florence in removing Ms. Brames shoes, belt, and items from her pockets.
33.

Defendant Dyer entered the booking room and saw Ms. Brame lying face up on the

floor. She appeared to him to be unconscious. He saw that her condition was much worse than it
had been when he participated in her arrest. Although it would have been obvious to a reasonable
police officer or even a reasonable civilian that Ms. Brame, while still alive, had a serious medical
need that required immediate medical evaluation and treatment, Defendant Dyer, like the other
Defendants, did not take any steps to obtain medical attention for Ms. Brame.
34.

Ms. Brame was unable to participate in the booking process; she could not answer

questions or stand for a booking photo. She was unconscious. She remained motionless on the
booking room floor.
35.

Although Ms. Brame was unconscious, Defendants Lombard, Tetreault, and

Florence carried her to a cell. They laid her on her side on a metal bench. She was unconscious and
unresponsive when they moved her. Although it would have been obvious to a reasonable police
officer or even a reasonable civilian that Ms. Brame was experiencing a medical emergency requiring
immediate evaluation and treatment, none of these Defendants took any steps to obtain medical
care or evaluation for Ms. Brame.
36.

Defendant Siopes came to the door of the cell. He observed Ms. Brame in the cell.

She was unconscious. As the lieutenant-in-charge, Defendant Siopes was responsible for the care
and custody of prisoners held at the police station that evening. Although it would have been
obvious to a reasonable police officer or even a reasonable civilian that Ms. Brame, while still alive,
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had a serious medical need requiring immediate medical attention, Defendant Siopes did nothing to
obtain medical attention for Ms. Brame before she was locked in a cell by herself.
37.

Defendants Lombard, Tetreault, Florence, and Siopes were present when the cell

door was closed at approximately 10:58 p.m. Ms. Brame had been in Lowell police custody for
approximately twenty-eight minutes. Her condition had deteriorated during that time.
38.

Defendant Siopes left the police station about eleven minutes after Ms. Brame was

locked in the cell. Defendant Kilmartin became the officer in charge of the station at that point.
39.

Although he had responsibility for the safety of prisoners in the police station,

Defendant Kilmartin did not take any action with regard to Ms. Brames serious medical needs. He
did not even bother to make sure the required cell checks took place.
40.

The Lowell Police Departments formal written policies required Defendants

Lombard and Tetreault, the detention attendants, to check on prisoners every thirty minutes. They
had the authority to check on prisoners more frequently but did not. Nor did they check on Ms.
Brame after thirty minutes. As a result, no one checked on Ms. Brame until 12:05 a.m.over an
hour after she had been placed in the cell while unconscious.
41.

Although Defendant Lombard had asked Defendant Fay earlier if an ambulance

should be called for Ms. Brame, Lombard ignored her need for medical attention once the cell door
was closed. He spent time in the booking room watching TV and using the computer.
42.

Defendant Tetreault also ignored Ms. Brames need for medical attention after she

was locked in the cell. At 11:14 p.m., Tetreault, Lombard, and Florence were in the booking room
watching TV. Defendant Tetreault entered the cell block area twiceat 11:24 and 11:25 p.m.to
bring Ms. Brames jacket and some paperwork to the cell block. He did not bother to check on Ms.
Brames condition either time.

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43.

At about 12:05 a.m., one hour and six minutes after locking Ms. Brame in the cell,

Defendant Lombard did a cell check. He banged on Ms. Brames cell door. She was unresponsive.
Defendants Lombard and Tetreault entered the cell and found Ms. Brame had no pulse; she was not
breathing and had become cyanoticthat is, her skin had become blue and purple.
44.

No one called an ambulance until thirteen minutes later, at 12:18 a.m., when

Defendant Lombard contacted dispatch to request an ambulance. Firefighters arrived within

approximately one minute to provide medical assistance. Fire Lieutenant Jose Rivera determined
that CPR should not be initiated because it was too late. Ms. Brame was dead.
45.

When an ambulance with paramedics arrived at 12:23 a.m. they unsuccessfully

attempted CPR.
46.

The events described above were captured by surveillance cameras at the Lowell

Police Department.
47.

An autopsy concluded that Ms. Brame died of alcohol poisoning.

48.

Alcohol poisoning is a serious medical condition. Because police officers frequently

encounter people who are under the influence of alcohol as part of their work, they should be
trained that alcohol, if consumed in sufficient quantity, can cause death.
49.

At the time of Ms. Brames death, and for many years before, the formal written

policies and procedures of the Lowell Police Department stated that people who are unconscious
should not be placed in a cell. Instead, an unconscious person must be evaluated by medical
personnel.
50.

The purpose of this rule was to prevent the death of a prisoner.

51.

Despite this longstanding rule, none of the individual Defendants knew there was a

formal written policy prohibiting locking an unconscious person in a cell without first having her
examined by medical personnel. The two Defendant lieutenants did not know the rule; nor did the
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three Defendant sergeants, nor did the Defendant patrol officers or the detention attendants who
saw Ms. Brame while she was unconscious.
52.

Instead of following the formal written rules, Lowell police officers followed an

unwritten practice or custom of placing intoxicated people who were unconscious in a lockup cell at
the police station without any medical evaluation. Defendant City of Lowell had allowed this custom
or practice to develop among its police officers.
53.

Lowell police officers came to believe that the treatment for people who were

intoxicated was to have them sleep it off even when the intoxicated person was unconscious or
semi-conscious. Lowell police officers wrongly claimed that medical personnel at hospitals in Lowell
would not examine or treat intoxicated patients.
54.

Had Defendants requested medical attention for Ms. Brame when she first lost

consciousness, her life could have been saved.

55.

Once Ms. Brame was in police custody, the individual Defendants and Defendant

City of Lowell assumed responsibility for providing her with medical care. Failing to provide this
medical care resulted in an unreasonable seizure of her person in violation of the Fourth
Amendment to the U.S. Constitution.
56.

Lowell Police Department general orders require formal training for detention

attendants when they are hired as well as in-service training during their employment. Detention
attendants in Lowell are supposed to be trained and certified as first responders and in first aid,
CPR, and use of a defibrillator (AED). The certifications for these trainings expire after two years
and must be renewed.
57.

Defendant Tetreault, who was hired as a detention attendant on August 8, 2008, was

not trained in CPR or AED before this incident. His first aid and first responder certification had
expired in October 2010more than two years before Ms. Brames death. All of Defendant
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Lombards certifications had expired in October 2011. Neither Lombard nor Tetreault was properly
certified in January 2013 when this incident took place.
58.

Defendant City of Lowell provided Defendants Lombard and Tetreault with little or

no formal training for the position of detention attendant.

59.

Ms. Brame was not the first person to die in Lowell police custody after being placed

in a cell while intoxicated and without receiving medical attention. In 2007 Walter Scott Paine was
placed in a lockup cell while intoxicated without being medically evaluated. He died in the cell.
60.

In the 1980s Michael Eagan, a young man who was unconscious, intoxicated, and

suffering from a subdural hematoma, was placed in a lockup cell at the Lowell police station without
being medically evaluated. The next morning he was found dead in the cell.
61.

Lowell Police Superintendent William Taylor ordered an investigation into Ms.

Brames death and convened a Board of Inquiry. The Board of Inquiry concluded that, once Ms.
Brame lost consciousness, all of the Defendant officers were obligated to seek medical attention for
[her] yet none was called.
62.

After the investigation, Superintendent Taylor sent a memo about this incident to all

Lowell police personnel dated February 13, 2014. He said the investigations by the District Attorney
and the Police Department determined Ms. Brame was not given the proper medical attention that
she was in obvious need of while in the custody of the Lowell Police Department.
63.

Superintendent Taylor also said, Some Lowell Police employees displayed, in my

opinion, conduct which could be described as deliberate indifference for Ms. Brame and that such
conduct should shock the conscience of us all.
64.

As a result of Defendants actions and failures to act, Alyssa Marie Brame died in a

detention cell in the Lowell police station. Her mother and her husband forever lost her assistance,
society, companionship, and comfort.
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CLAIMS
COUNT I

42 U.S.C. 1983 Claim Against Defendants Siopes, Kilmartin, Fay, Giuffrida,

Nobrega, Florence, Dyer, Pappaconstantinou, Tetreault and Lombard

65.

The above paragraphs are incorporated by reference.

66.

Defendants Siopes, Kilmartin, Fay, Giuffrida, Nobrega, Florence, Dyer,

Pappaconstantinou, Tetreault, and Lombard caused the death of Alyssa Marie Brame by violating
her clearly established constitutional rights to be free from an unreasonable seizure of her person
and to be free from deliberate indifference to her serious medical needs under the Fourth
Amendment to the United States Constitution as applied under the Fourteenth Amendment and her
right to due process of law under the Fourteenth Amendment.
67.

As a direct and proximate result of Defendants actions, Plaintiff suffered the

damages described above.

COUNT II

M.G.L. ch. 229, 2, Wrongful Death Claim Against Defendants Siopes,

Kilmartin, Fay, Giuffrida, Nobrega, Florence, Dyer, Pappaconstantinou,
Tetreault and Lombard

68.

The above paragraphs are incorporated by reference.

69.

Defendants Siopes, Kilmartin, Fay, Giuffrida, Nobrega, Florence, Dyer,

Pappaconstantinou, Tetreault, and Lombard caused Alyssa Marie Brames death by willful, wanton,
or reckless acts.
70.

Ms. Brames next of kin are entitled to compensation for the loss of the reasonably

expected net income, services, protection, care, assistance, society, companionship, comfort,
guidance, counsel, and advice of Ms. Brame.
COUNT III 42 U.S.C. 1983 Claim Against Defendant City of Lowell
71.

The above paragraphs are incorporated by reference.

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72.

Police officers have a constitutional obligation of reasonableness when they seize a

person and place the person in custody. This includes the obligation to provide medical attention to
people in custody, who are not free to seek medical attention themselves.
73.

Police officers have a constitutional obligation to avoid deliberate indifference to the

serious medical needs of a person in their custody.

74.

The formal written policy of the Lowell Police Department required that an

unconscious prisoner be examined medically. The written policy said unconscious prisoners should
not be placed in a cell. However, well before this incident, Defendant City of Lowell allowed an
unwritten practice or custom to develop in the Lowell Police Department of placing unconscious
prisoners in a cell without any medical evaluation. This unwritten practice or custom became the
way things were done at the Lowell Police station.
75.

Five of the individual Defendants in this case were supervisory officerstwo

lieutenants (Siopes and Kilmartin) and three sergeants (Fay, Giuffrida and Nobrega). These
supervisory officers are responsible for knowing and following the Lowell Police Departments
policies and procedures and for assuring that patrol officers follow those procedures.
76.

All five supervisory Defendants knew that Ms. Brame was unconscious, but none of

them requested medical attention for her or asked another employee to call for a medical evaluation.
None of the five supervisory Defendants objected to placing an unconscious person in a cell. They
did not object because placing unconscious people in cells without bothering to conduct a medical
evaluation was the unwritten rule of the Lowell Police Department.
77.

When civilian detention attendant Lombard asked Defendant Fay if he should call an

ambulance for Ms. Brame, Sergeant Fay told him not to. This was the only time any Lowell police
employee considered providing medical attention for a prisoner who was unconscious. Sergeant Fay
was acting in accordance with the custom or practice of the Lowell Police Department.
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78.

Defendant Siopes was the officer in charge of the Lowell Police Department during

most of this incident. He saw Ms. Brame lying unconscious in the stairway and again in the cell
before the cell door was closed. He did not request medical attention.
79.

The failure of five supervisory officers on the same shift to order medical attention

for a prisoner who displayed an obvious, serious medical need could not have occurred unless this
failure stemmed from the unwritten practice or custom followed by Lowell police officers.
80.

The City of Lowell Police Department had a practice or custom of deliberate

indifference to the serious medical needs of intoxicated people in the custody of the Lowell Police
Department who were to be placed in holding cells. This practice or custom was the moving force
behind Ms. Brames death.
81.

Defendants and other police officers and employees in the Lowell Police

Department developed a practice or custom of failing to provide medical attention to intoxicated

prisoners based in part on the false belief that medical personnel in local hospitals would not treat
patients who are intoxicated. The Lowell Police Department fostered this unreasonable claim.
82.

As a direct and proximate result of the practices or customs of the City of Lowell,

Plaintiff suffered the damages described above.

83.

As a direct and proximate result of the practices or customs of the City of Lowell,

Ms. Brame did not receive life-saving medical care while her life could have been saved. Instead she
died in a Lowell police cell.
WHEREFORE, Plaintiff requests that this Court:
1.

Award compensatory damages;

2.

Award punitive damages against Defendants Thomas Siopes, Michael Kilmartin,

James Fay, Michael Giuffrida, Francis Nobrega, William Florence, Robert Dyer, Charles
Pappaconstantinou, William Florence, Robert Dyer, Kevin Lombard and Shawn Tetreault;
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3.

Award the costs of this action, including reasonable attorneys fees; and,

4.

Award such other further relief as this Court may deem necessary and appropriate.
JURY DEMAND

A trial by jury is hereby demanded.

RESPECTFULLY SUBMITTED,
For the Plaintiff,
By her attorneys,
/s/ Howard Friedman
Howard Friedman, BBO #180080
Drew Glassroth, BBO #681725
Law Offices of Howard Friedman, PC
90 Canal Street, Fifth Floor
Boston, MA 02114-2022
(617) 742-4100
[email protected]
[email protected]
Date: May 5, 2015

CERTIFICATE OF SERVICE
I certify that on this day I caused a true copy of the above
document to be served upon the attorney of record
for all parties via CM/ECF.
Date: May 5, 2015

/s/ Howard Friedman

Howard Friedman

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