2.

The Grape Street Crips are an emerging gang in Chattanooga with a presence

in the East Lake area of Chattanooga. The gang has between 15-20 members

and the original Grape Street Crips began in the Watts section of Los Angeles,

California.

3. In the areas described in Section IX of this Petition as the Safety Zones,

The Gangster Disciples and the Grape Street Crips regularly sell illegal drugs in

plain view on public streets and engage in other crimes to the detriment of the

neighborhoods. The crimes committed by members of each gang include various

drug offenses, robberies, attempted homicides, homicides, aggravated assaults and

domestic violence.

4.
Despite the concerted efforts of law enforcement, the illegal activities of The

Gangster Disciples and the Grape Street Crips continue unabated.

5.
The level of unlawful activity and lack of respect for the law by The Gangster

Disciples and The Grape Street Crips keeps other residents in the Safety Zones from

the free exercise of their rights as property owners, tenants, and citizens; and keeps

the owners of East Lake Courts and surrounding areas, including businesses, from

engaging in their lawful business to the fullest extent possible.

6.
This Petition seeks to declare the Gangster Disciples and the Grape Street

Crips a public nuisance and to abate such nuisance by enjoining the Gangster

Disciples and the Grape Street Crips from participating in activities in the Safety

Zones, all as set forth herein.

II. JURISDICTION AND VENUE

7.
Jurisdiction to declare a criminal gang a public nuisance is proper in this

Court pursuant to Tenn. Code Ann. 29-3-102.

8.
Venue is proper in the Court because the nuisance activity from which the

Petitioner seeks relief occurs in Hamilton County. State ex. rel. v. Scott, 176 Tenn.

145 S.W.2d 765 (1940).

III. PARTIES

9.
The Petitioners in this matter are the People of the State of Tennessee, acting

by and through Neal Pinkston, the District Attorney General for the Eleventh Judicial

District.

10. The Respondents in this matter are the Gangster Disciples and the Grape

Street Crips. They are criminal gangs with a physical presence in the City of

Chattanooga. These criminal gangs are subject to suit in the State of Tennessee. The

individual members of these gangs either live in or frequent particular areas

described in Section IX of this Petition as the Safety Zones.

IV. SERVICE

11. Despite being a criminal enterprise without a lawful purpose, the

Gangster Disciples and the Grape Street Crips are similarly situated to an

unincorporated association conducting business primarily in the State of Tennessee.

12. Criminal gangs are legal bodies capable of being served in a manner

consistent with an unincorporated association. People ex. rel. Totten v.

Colonia Chiques, 156 Cal. App. 4th 31, 38 (2007).

13. Service is also proper by delivering a copy of the summons and of the

complaint, this Petition, to a partner or managing agent of the partnership or to

an officer or managing agent of the association, or to an agent authorized by

appointment or by law to receive service on behalf of the partnership or

association. See Tenn. R. Civ. Pro. 4.04.

14. In the present case, the Tennessee Secretary of State does not have an

authorized representative listed for the Gangster Disciples or the Grape Street Crips

nor any other aliases as pleaded in this Petition.

15. This Petition and Summons will be served upon at least one of the partners

and/or managing agents of the Gangster Disciples and the Grape Street Crips.

16. Service will also be accomplished by posting notice at two locations in

each of the Safety Zones which are frequented by these criminal gangs.

V. OVERVIEW OF THE USE OF GANG INJUNCTIONS

17. Combating urban street gangs with nuisance abatement lawsuits originated

in Los Angeles, California with People v. Playboy Gangster Crips, No. WEC 118860

(Cal. Super. Ct. Los Angeles County Dec. 11, 1987).

18. Over the past twenty-five years, the practice has become a common tool for

law enforcement in several states across the United States to include Minnesota,

Illinois, Florida, Utah, North Carolina, Texas and Tennessee.

19. The most prevalent use of gang injunctions remains in California, a state

that is severely afflicted by gang activity. California courts have upheld the use of

gang injunctions. People ex rel. Gallo vs. Acuna, 14 Cal.4th 1090 (Cal. 1997).

20. Gang injunctions have been utilized in Tennessee in the cities of Nashville

and Memphis. While municipalities must seek the injunctions, the Tennessee

General Assembly has enacted statutory definitions of public nuisance

specifically related to gang activity. This statutory authority for a nuisance

allows the Court to abate the nuisance without requiring the State to prove

deleterious effect on the community as required by a common law nuisance.

21. These new statutes are a signal that states are beginning to embrace

this type of public remedy. A criminal court in Davidson County, Tennessee

issued Tennessees first gang injunction in March 2013. Courts in Shelby

County, Tennessee have issued injunctions against the Riverside Rolling

90s in September 2013, Dixie Homes Murda Gang/47 Neighborhood Crips

in October 2014, and the FAM Mob Gang in December 2014.

VI. TENNESSEE LAW ON GANG INJUNCTIONS

A. Criminal Gangs are a Statutory Nuisance

22. In 2009, the Tennessee General Assembly amended the nuisance

statute to include criminal gangs.

23. The statute creates a per se nuisance subject to a permanent injunction

for a criminal gang that regularly engages in gang related conduct.

Tenn. Code Ann. 29-3-101 (a)(2)(B) (emphasis added).

24. A criminal gang is defined as a group with three or more members who

has:


As one (1) of its activities the commission of criminal acts; and


Two (2) or more members who, individually and collectively, engaged

or have engaged in a pattern of gang activity;

Tenn. Code Ann. 40-35-121 (2013) (emphasis added).


25. A pattern of criminal gang activity is

(A) "Pattern of criminal gang activity" means prior convictions for the commission
or attempted commission of, facilitation of, solicitation of, or conspiracy to commit:


( i) Two (2) or more criminal gang offenses that are classified as felonies; or

( ii) Three (3) or more criminal gang offenses that are classified as
misdemeanors; or

( iii) One (1) or more criminal gang offenses that are classified as felonies and
two (2) or more criminal gang offenses that are classified as misdemeanors; and

( iv) The criminal gang offenses are committed on separate occasions; and

( v) The criminal gang offenses are committed within a five-year period;

Tenn. Code Ann. 40-35-121 (2013).

26. The statute defines a criminal gang offense as:

( 3) "Criminal gang offense" means:

( A) A criminal offense committed prior to July 1, 2013 that:

( i) During the perpetration of which the defendant knowingly causes, or
threatens to cause, death or bodily injury to another person or persons and
specifically includes rape of a child, aggravated rape and rape; or

( ii) Results, or was intended to result, in the defendant's receiving income,
benefit, property, money or anything of value from the commission of any
aggravated burglary, or from the illegal sale, delivery, or manufacture of a controlled
substance, controlled substance analogue, or firearm; or

( B) The commission or attempted commission, facilitation of, solicitation of, or
conspiracy to commit any of the following offenses on or after July 1, 2013:

( i) First degree murder, as defined in 39-13-202;

( ii) Second degree murder, as defined in 39-13-210;

( iii) Voluntary manslaughter, as defined in 39-13-211;

( iv) Assault, as defined in 39-13-101;

( v) Aggravated assault, as defined in 39-13-102;

( vi) Kidnapping, as defined in 39-13-303;

( vii) Aggravated kidnapping, as defined in 39-13-304;


( viii) Especially aggravated kidnapping, as defined in 39-13-305;

( ix) Robbery, as defined in 39-13-401;

( x) Aggravated robbery, as defined in 39-13-402;

( xi) Especially aggravated robbery, as defined in 39-13-403;

( xii) Carjacking, as defined in 39-13-404;

( xiii) Rape, as defined in 39-13-503;

( xiv) Aggravated rape, as defined in 39-13-502;

( xv) Rape of a child, as defined in 39-13-522;

( xvi) Aggravated burglary, as defined in 39-14-403;

( xvii) Especially aggravated burglary, as defined in 39-14-404;

( xviii) Aggravated criminal trespass, as defined in 39-14-406;

( xix) Coercion of witness, as defined in 39-16-507;

( xx) Retaliation for past action, as defined in 39-16-510;

( xxi) Riot, as defined in 39-17-302;

( xxii) Aggravated riot, as defined in 39-17-303;

( xxiii) Inciting to riot, as defined in 39-17-304;

( xxiv) The illegal sale, delivery or manufacture of a controlled substance or
controlled substance analogue, as defined in 39-17-417 and 39-17-454;

( xxv) Possession of a controlled substance or controlled substance analogue
with intent to sell, deliver, or manufacture, as defined in 39-17-417(a)(4) and
39-17-454;

( xxvi) Unlawful carrying or possession of a weapon, as defined in 39-17-
1307;

( xxvii) Trafficking for commercial sex acts, as defined in 39-13-309;

Tenn. Code Ann. 40-35-121 (2013).


27. The statute defines gang related conduct as:

(i) Intimidating, harassing, threatening, stalking, provoking or assaulting any
person;

( ii) Possessing weapons prohibited under 39-17-1302 and 39-17-1307,
knowingly remaining in the presence of anyone who is in possession of such
weapons, or knowingly remaining in the presence of such weapons;

( iii) Unlawfully damaging, defacing or marking any public or private property
of another or possessing tools for the purpose of unlawfully damaging, defacing or
marking any public or private property of another;

( iv) Selling, possessing, manufacturing or using any controlled substance, drug
paraphernalia, as defined in 39-17-402, or controlled substance analogue, as
defined in 39-17-454, knowingly remaining in the presence of anyone selling,
possessing, manufacturing or using any controlled substance, controlled substance
analogue or drug paraphernalia, knowingly remaining in the presence of any
controlled substance, controlled substance analogue or drug paraphernalia, driving
under the influence of any controlled substance or controlled substance analogue in
violation of 55-10-401, or being under the influence of any controlled substance or
controlled substance analogue in public in violation of 39-17-310;

( v) Using, consuming, possessing or purchasing alcoholic beverages unlawfully,
including, but not limited to, public intoxication in violation of 39-17-310 or
driving under the influence of alcohol in violation of 55-10-401;

( vi) Criminal trespassing in violation of 39-14-405;

( vii) Taking any action to recruit gang members or making any threats or
promises to shoot, stab, strike, hit, assault, injure, disturb the peace or destroy the
personal property of anyone as an incentive to join a gang;

( viii) Taking any action to stop a gang member from leaving a gang or making
any threats or promises to shoot, stab, strike, hit, assault, injure, disturb the peace or
destroy the personal property of anyone as an incentive not to leave a gang;

( ix) Engaging in a criminal gang offense as defined by 40-35-121(a);

( x) Disorderly conduct in violation of 39-17-305; or

( xi) Contributing to or encouraging the delinquency or unruly behavior of a
minor in violation of 37-1-156;

Tenn. Code Ann. 29-3-101 (2013).






B. Criminal Gangs can also constitute a common law public nuisance

28. A criminal gang may constitute a nuisance subject to abatement under

traditional common law nuisance jurisprudence.

29. Under traditional common law, a nuisance is anything which annoys or

disturbs the free use of ones property, or which renders its ordinary use or physical

occupation uncomfortable. Caldwell v. Knox Concrete Products, Inc., 54 Tenn.

App. 393, 402 (Ct. App. 1964).

30. The Restatement of Torts defines a public nuisance as an unreasonable

interference with a right common to the general public. Restatement (Second)

of Torts 821B (1979).

31. When determining whether an unreasonable interference with a public


right exists, courts should consider:


(a) Whether the conduct involves a significant interference with the public

health, the public safety, the public peace, the public comfort or the public

convenience, or

(b) whether the conduct is proscribed by a statute, ordinance or

administrative regulation, or

(c) whether the conduct is of a continuing nature or has produced a
permanent or long-lasting effect, and, as the actor knows or has reason to
know, has a significant effect upon the public right.

Restatement (Second) of Torts 821B (1979).

32. A criminal gang, such as the Gangster Disciples, engages in activities that

significantly interfere with the public rights of those who live and do business in

their territory. In the present case, these criminal gangs maintain a presence in

the Safety Zones with open displays of narcotics dealing, intimidation, and other

activity prohibited by statute.


VII. GANGSTER DISCIPLES

33. The Gangster Disciples are a violent, drug dealing, organized street gang

which has taken over the Safety Zones for the purpose of committing criminal

acts. This section will outline how the Gangster Disciples are a criminal gang

that has engaged in and continues to perpetuate criminal activity in the Safety

Zones.

34. Petitioners re-allege and incorporate herein each of the preceding

paragraphs as if stated verbatim.

35. As of July 2016, the Gangster Disciples have over 30 members

who, individually and collectively, engage in criminal gang activity in the

Safety Zones.

36. The Gangster Disciples are rather organized, have extensive rules,

regulations, weekly meetings and payment of dues. Members operate under

structured chain of command to include positions known as 1st Coordinator,

Secretary, Chief of Security and Chief Enforcer.

37. Detailed information about Gangster Disciples leaders and their criminal

gang activity follows:

a.
Monte Lamar Brewer Jr

2104 Foust Street

Chattanooga Tennessee 37407


He has convictions for seven cases of criminal trespassing and simple

10

possession of marijuana out of Hamilton County General Sessions Court and

convictions for robbery, theft and reckless endangerment out of Hamilton
County Criminal Court.

He has pending charges of driving on revoked, possession of drugs and
possession of a firearm with intent to go armed.

Brewer is a validated Gangster Disciple. He has self-admitted to his gang
involvement, wears gang colors, flashes gang signs and is known to have
contact with other gang members and also pose for gang related photos.


b.

Lee Antonio Clements

1908 Foust Street
Chattanooga, TN
He has convictions for possession of controlled substance, possession of drug
Paraphernalia,and driving without a license out of Hamilton County General
Sessions Court and convictions for possession of a firearm and simple
possession of marihuana out of Hamilton County Criminal Court.

He is a validated Gangster Disciple. He has self-admitted to his gang
involvement, and is known to have contact with other known gang members
and was validated as a gang member by an outside law enforcement agency.

c.
Keenan Ivory Cooley

1904 E. 25th St. Place

Chattanooga, TN


He has multiple convictions for criminal trespassing out of Hamilton County

General Sessions Court as well as evading arrest and possession of controlled

substance. In addition, Cooley has been convicted of aggravated assault,

reckless aggravated assault and possession of a firearm with prior felony

conviction out of Hamilton County Criminal Court.


He is a validated Gangster Disciple. He has self-admitted belonging to the

Gangster disciples. He has gang tattoos and often uses gang symbols and

colors, and has participated in photographs with other confirmed gang
members.

11




d.












e.













f.

Nitorius Montel Cooley

2257 E. 25th Street
Chattanooga TN
His criminal history includes a conviction for criminal trespassing and
pending charges of drugs, possession of controlled substance and
resisting arrest.
He is a validated Gangster Disciple. Cooley is known to have a gang tattoo
Wacky Mac, and uses gang symbols and clothing, and has contact with
known gang members as he was present when his brother Keenan Cooley
was arrested for outstanding warrants.
Ronnie Dyrail Dobbins, Jr
1408 Carousel Road
Chattanooga, TN
He has convictions for assault, domestic assault, failure to appear, possession
of a firearm, escape, criminal trespassing, aggravated criminal trespassing,
and public intoxication out of Hamilton County General Sessions Court. He
has new pending charges include trespassing, possession of controlled
substance and possession of a firearm. Several of his arrests have
occurred within the proposed safety zone.
He is a validated Gangster disciple and admitted joining the gang at the age
of 15. Dobbins also has a gang tattoo and wears gang clothing.
Jeramie Lamont Hawthorne
3003 E. 34th Street
Chattanooga, Tennessee
He has Hamilton County General Sessions convictions for possession of a
controlled substance, evading arrest, theft, domestic assault , vandalism
and possession of crack cocaine. Hawthorne has Hamilton County Criminal
Court convictions for false reports, criminal trespassing, driving on revoked,
possession of cocaine and contraband in a penal institution. He also has
cases pending the Hamilton County Grand Jury.
Hawthorne is a validated Gangster Disciple. He has openly admitted to being
a Gangster Disciple and has tattoos of GD Nation and 4 about his body.
He has had his photo taken with other confirmed gang members and his
brother Jerrico Hawthorne is a Gangster Disciple currently serving a life
sentence in TDOC for first degree murder.
12




g.

Jonathan Lebron Horton

931 East Avenue
Chattanooga, Tennessee
His criminal history includes convictions for possession of controlled
substance and a pending charge of possession of drug paraphernalia.

Horton is a confirmed Gangster Disciple and has been arrested with
fellow Gangster Disciple Lee Clements. Horton admits he is a Gangster
Disciple, wears gang clothing, and is often in the physical presence
of and in photos with confirmed gang members.

h.
Horatio Houston Jr

4203 10th Avenue

Chattanooga, Tennessee


His criminal history includes Hamilton County General Sessions Court

convictions for assaults and he has pending cases in Hamilton Court Criminal

Court to include aggravated burglary, theft, possession of marijuana, carrying
a dangerous weapon and tampering with evidence.


Houston is a self-admitted and validated Gangster Disciple. He proudly

wears gang clothing and flashes GD gang signs throughout Chattanooga.

i.
Jacorey Darnell Owens

3616 Glendon Drive

Chattanooga, Tennessee


His criminal history includes four convictions for possession of controlled

substances and four convictions for possession of firearm with intent to go

armed out of Hamilton County General Sessions Court and has a pending

drug case in Sessions Court. Owens also has a pending indictment in

Hamilton County Criminal Court for attempted first degree murder,

employment of a firearm during commission of a dangerous felony

and one for reckless endangerment.


He has admitted he is a Gangster Disciple on numerous occasions and has

gang tattoos. He is known to commit crimes in the proposed safety zone

and has even been arrested with fellow Gangster Disciple Thaddeus

Pollard.

k.
Thaddeus Pollard Jr

1803 E. 27th Street

13

l.

Chattanooga, Tennessee
His criminal history includes Hamilton County General Sessions Court
convictions for Resisting Arrest, Driving on Revoked, Resisting Arrest,
Simple Possession of Marijuana, Criminal Trespassing, Criminal Trespassing,
Unlawful Carrying of a Weapon, Theft of Property, Failure to Appear,
Criminal Trespassing, Driving on Revoked, Public Intoxication and
Criminal Trespassing. He also has been convicted in Hamilton County
Criminal Court for two counts of driving on a revoked license.

Pollard has self admitted to belonging to the Gangster Disciples. He
is consistently observed with other Gangster Disciples including when
he was present at a homicide scene and the police told all parties to
not seek retribution for the homicide. Also present when fellow
Gangster Disciple Jacorey Owens was arrested.
Demetrius Delaney Buchanan
3301 Pinewood Avenue, Apt 26
Chattanooga, Tennessee
His criminal history includes Hamilton County General Sessions Court
convictions for Driving on Revoked, Resisting Arrest, Possession of a
Controlled Substance, Failure to Appear and Hamilton County Criminal
Court convictions for Possession of Cocaine, Simple Possession of Marihuana,
Resisting Arrest, and Possession of Marihuana for Resale.
Buchanan is a self-admitted Gangster Disciple since age 14 and has gang
tattoos. In addition, Mr. Buchanan name was identified in correspondence
as a member of the Gangster Disciple roster.

m.

Gregory Lamar Gillespie

2101 Vance Avenue
Chattanooga, Tennessee
Gillespie has convictions for Evading Arrest, Failure to Appear, Assault,
Disorderly Conduct out of Hamilton County General Sessions Court and has
a conviction for carrying a weapon on school property out of Hamilton
County Criminal Court. He has pending cases in state court of two counts
possession of controlled substance, possession of a firearm, aggravated
assault, evading arrest, and failure to appear. In addition, he has a hold
by federal authorities.

Gillespie is a self-admitted Gangster Disciples and has a tattoo HPG
which is for Highland Park Gangster a set of the Gangster disciples.
He is frequently seen wearing gang clothing and flashing gang signs
like pitch forks and 7-4 which are common for Gangster Disciples.
14





n.














o.

p.

Dedrick Lamont Lindsey Jr

3401 Campbell Street
Apt 405
Chattanooga, Tennessee
Lindseys criminal history includes a Hamilton County General Sessions
Court conviction for Carrying Weapons on School Property and a
Hamilton County Criminal Court conviction for aggravated assault.
On numerous occasions, Lindsey has admitted to being a Gangster
Disciple and validated as such. He has been frequently seen with other
validated Gangster Disciples.

Thaddius Gerrard Montgomery

2401 Ocoee Street
Chattanooga, Tennessee
Montgomerys criminal history includes Hamilton County General Sessions
Court convictions for criminal impersonation, possession of controlled
Substance, drinking under age, driving on a suspended license, criminal
trespass, aggravated criminal trespass, criminal trespass, and failure to
appear. He has been convicted of two counts of Aggravated Burglary in
Hamilton County Criminal Court. He has pending charges of possession of
a controlled substance and possession of drug paraphernalia.

Montgomery is a self-admitted and validated Gangster Disciple. He
has gang tattoos and is frequently seen in clothing displaying his gang
colors.
Sean Corn Rhodes
2116 E. 12th Street
Chattanooga, Tennessee
His criminal history includes driving without a license, domestic assault,
driving without a license, aggravated criminal trespass, vandalism, unlawful
possession of a weapon, criminal trespassing, driving without a license,
domestic assault and criminal trespass out of Hamilton County General
Sessions Court and pending cases of aggravated assault. Rhodes has
Hamilton County Criminal Court convictions for driving on a revoked license

15

and aggravated domestic assault of which he has a pending probation

violation.

Rhodes is a proud member of the Gangster Disciples and has been validated.
He bears Gangster Disciples tattoos and has been seen throwing gang signs
and making threats via social media.

q.













r.

s.

Alston Toran, III

1806 S. Greenwood Avenue
Chattanooga, Tennessee
Toran has been convicted in Hamilton County General Sessions Court of
possession of marijuana, possession of controlled substance , driving
without a license, failure to appear, evading arrest and another possession
of a controlled substance.
Toran is a validated self-admitted Gangster Disciple. He has been named
In gang correspondence as a gang member, and also has participated in
photos with gang members, and has known contact with validated gang
members.
Orlando Watkins
2210 Bennett Avenue
Chattanooga, Tennessee
Watkins has been a frequent visitor to all Hamilton County criminal courts
and stands with convictions for driving on a suspended license, disorderly
conduct, possession of marijuana, criminal trespassing, failure to appear,
possession of marijuana, attempted criminal simulation, criminal
trespassing, and criminal trespassing. He has been convicted in Criminal
Court for attempted possession of cocaine for resale and simple possession of
marijuana, Watkins has outstanding warrants for aggravated assault,
evading arrest, possession of cocaine, attempted first degree murder,
aggravated assault, employing a firearm during commission of dangerous
felony and reckless endangerment. He has additional outstanding warrants
for possession of marijuana and felonious possession of MDMA.

Watkins is a validated Gangster Disciple and has stated he will be a GD
until he dies. He has various gang tattoos and has been seen in photos
throwing up gang signs.
Norman Eugene Williams, Jr.
4415 Drummond Drive
Chattanooga, Tennessee
His significant criminal history includes convictions out of Hamilton County
16










t.

u.
















v.

General Sessions Court for possession of marijuana, criminal trespassing and

failure to appear. He has multiple pending criminal trespass cases. He has
Criminal Court convictions for robbery, aggravated burglary, theft, burglary,
theft, and aggravated criminal trespass.
He is a validated Gangster Disciple and has admitted to the same. He bears
Gangster Disciple tattoos and has been seen with other validated gang
members.
Ommerieal Dywane Woods
1307 E. 31st Street
Chattanooga Tennessee
His criminal history includes Hamilton County General Sessions Court
convictions for possession of a controlled substance, criminal trespassing,
unlawful possession of a weapon, theft, possession of a controlled substance,
and six other criminal trespasses. He has a pending theft charge in Hamilton
County Criminal Court.

Woods has admitted his status as a Gangster Disciple and has been validated
as such. He has frequently seen with fellow Gangster Disciples and displaying
gang signs.
Oshae Kadaris Smith
2114 E. 12th Street
Chattanooga, TN
His criminal history includes Hamilton County General Sessions Court
convictions for evading arrest, criminal trespassing, underage drinking,
unlawful possession of a firearm, failure to appear, carrying a dangerous
weapon, reckless endangerment and evading arrest. In addition, he was
convicted of aggravated assault in Hamilton County Criminal Court.
Smith is a self-admitted and validated Gangster Disciple. He has
been photographed with black clothing and bandanas indicative
of his allegiance to the Gangster Disciples and has been photographed
with other validated gang members and also with them when some
were arrested and firearms were seized. Also throws gang signs 4th
which is about 4th Avenue.
Antonio Watkins
2004 Curtis Street
Chattanooga, TN
His criminal history includes Hamilton County General Sessions convictions
for Possession of Controlled Substance and Possession of Burglary Tools. He
17

has cases of unlawful possession of a weapon and driving on a revoked

license pending in General Sessions Court. Watkins has Hamilton County
Criminal Court convictions for possession of marijuana for resale and
unlawful possession of weapon and pending cases of cocaine for resale,
possession of marijuana for resale, retaliation for past actions and possession
of drug paraphernalia in Criminal Court.

VIII. GRAPE STREET CRIPS

38. The Grape Street Crips are a violent, drug dealing, organized street gang

which has taken over the Safety Zones for the purpose of committing criminal

acts. This section will outline how the Grape Street Crips are a criminal gang

that has engaged in and continues to perpetuate criminal activity in the Safety

Zones.

39. Petitioners re-allege and incorporate herein each of the preceding

paragraphs as if stated verbatim.

40. As of July 2016, the Grape Street Crips have over 10 members

who, individually and collectively, engage in criminal gang activity in the

Safety Zones.

41. There is no known structure of the Grape Street Crips, but the gang

consists of foot soldiers and a person as the central head of the group

called the OG or the Shot Caller.


42. Detailed information about Grape Street Crips leaders and their criminal

gang activity is as follows:


a. Sherman Shermaine Bowles

2251 E. 25th Street

Chattanooga, Tennessee

18

Bowles has an extensive criminal history in Hamilton County General

Sessions and Criminal Court to include convictions for evading arrest,
Possession of cocaine, criminal trespassing, evading arrest, criminal
trespassing, driving under the influence, possession of marijuana, criminal
impersonation, criminal trespassing, assault possession of drug
paraphernalia, theft of property, possession of marijuana, possession of
cocaine for resale, possession of marijuana, violation of the habitual motor
vehicle offenders act, possession of cocaine for resale, violation of the
habitual motor vehicle offenders act, and tampering with evidence.

He has been validated as a Grape Street Crip by the Tennessee Department
Of Corrections.

b. Clifford Rasheed Hill
714 S. Seminole Drive
Chattanooga, Tennesee

Hill is a self-admitted and validated member of the Grape Street Crips. He
has been known to wear purple bandanas, the color associated with the
Grape Street Crips, and also has thrown gang signs. He has been
photographed with fellow Grape Street Crips.

He has a prior conviction for violation of a seat belt law out of Hamilton
County General Sessions Court.

c. Keyon Denzel Hinton
7809 Opal Drive
Chattanooga, Tennessee

His criminal history includes a conviction in Hamilton County General
Sessions Court for unlawful carrying or possessing a weapon and convictions
in Hamilton County Criminal Court for possession of a controlled substance,
possession of a prohibited weapon, possession of marijuana for resale,
and unlawful possession of a firearm.

Hinton is a validated Grape Street Crip, and has gang tattoos, uses gang
symbols , and wears clothing specific to the Grape Street Crips. He has
also been in possession of gang documents.


d. Dominique Jackson
2300 Wilson Street
Apt 7J
Chattanooga, Tennessee

Jacksons criminal history includes a Hamilton County General Sessions Court

19

Conviction for Possession of a Firearm with Intent to Go Armed and Hamilton

County Criminal Court convictions for Attempted Aggravated Burglary,
Attempted Theft over $1000, and Resisting Arrest.

Jackson is a self-admitted and validated Grape Street Crip. He admitted such
after police investigated a shots fired call near a local school bus. He is known
to wear Grape clothing to show his allegiance to the gang as well as
frequently flashing crip signs and being photographed with other validated
gang members.

e. Keyshawn Jaquan Kidd
4205 10th Avenue
Chattanooga, Tennessee

His criminal history includes a number of pending cases in both Hamilton
County General Sessions Court and Hamilton County Criminal Court to
include Possession of Drug Paraphernalia, Reckless Driving, Resisting Arrest,
Leaving Scene of an Accident, Possession of a Handgun under the Influence,
Carrying a Dangerous Weapon, Possession of Marijuana, Possession of
Tramadol, and Possession of Drug Paraphernalia.

Kidd is a self-admitted and validated Grape Street Crip. He wears
purple clothing common to Grape Street Crips and also various items
symbolizing the Grape Street Crips. In addition, he has been photographed
with other Grape Street Crips and arrested with fellow Grape Street Crips.

f. Perry Thomas
2626 6th Avenue
Chattanooga Tennessee

Thomass criminal history includes pending cases in Hamilton County
General Sessions Court for criminal trespassing, evading arrest, theft, and
Vandalism. Thomas has convictions in Hamilton County Criminal Court for
Possession of a firearm with intent to go armed, robbery, and assault for
which he has an outstanding probationary capias on the robbery and assault
convictions.

Thomas is known to be a validated member of the Grape Street Crips,
wears gang clothing, flashes signs, and is known to commit crimes with
other validated gang members.

g. Patrick Lamar Tory Jr
8457 Hunter Hill Court
Ooltewah Tennessee

20

Tory has Hamilton County General Sessions Court convictions for failure to
appear, multiple criminal trespassing, disorderly conduct, resisting arrest,
and firearms charges. He has two convictions for aggravated burglary in
Hamilton County Criminal Court.

He has been validated as a Grape Street Crip by his own self admission and
in his possession of gang clothing which were purple bandanas.

h. Guy Wilkerson
2001 S Lyerly Street
Apartment 115
Chattanooga, Tenneseee


His significant criminal history includes convictions for firearms charges
in General Sessions Court and Criminal Court convictions for simple
possession of marijuana and robbery.


Wilkerson is another self-admitted and validated Grape Street Crip.
He proudly wears gang clothing, flashes gang signs has grape tattoos
and has been observed with other validated gang members.


i. Commanieakil Williams
3619 6th Avenue
Chattanooga, Tennessee

Williams criminal history includes pending charges in the Hamilton County
Grand Jury for theft, drugs, and firearms charges.

Williams is another self-admitted and validated Grape Street Crip and has
been found in possession of gang clothing to include purple bandanas.

k. Marty Witt
1810 E. 12th Street
Chattanooga, Tennessee


Witts lenghty criminal history includes Hamilton County General Sessions
Court convictions for theft of property, vandalism, assault, theft, possession
of drug paraphernalia, disorderly conduct, and assault. He has Criminal Court
convictions for eight counts of theft of property, eight burglaries, attempted
robbery and evading arrest.

Witt is another validated, self-admitted Grape Street Crips, with accompanying
tattoos and was also validated by Tennessee Department of Corrections as a
Grape Street Crip.

21


IX. SAFETY ZONE

The Gangster Disciples and the Grape Street Crips operate

43.

primarily in the areas described in this Petition as the Safety Zone. They

reside or stay in various areas throughout the Safety Zones. The Safety Zone

include:


(a)
The East Lake Courts which is a public housing complex which

is owned by the Chattanooga Housing Authority with its physical address as 2600

4th Avenue Chattanooga, Tennessee but that the East Lake Courts extends from the

2400 block of 4th Avenue to the 2200 block of E. 28Th Street east to 2800 block of 6th

Avenue north to the 2400 block of 5th Avenue;


(b) From Interstate 24 south on Hickory Street to Clio Avenue south

to E. 34th Street and then from E. 34th Street to south 7th Avenue also extending on

7th Avenue to E. 37th Street over to 15th Avenue and to E. 38th Street over to S Crest

Road and also following Westside Drive to Interstate 24. See Attached Map.


X. ONGOING CRIMINAL ACTIVITY AND CONDUCT

44. Since the inception of this investigation, the Gangster Disciples and the Grape

Street Crips disregard for laws and lack of respect for community members has

continued. Petitioners have been unable to abate the nuisance through traditional

law enforcement means. As recently as the week prior to the filing of this

injunction, law enforcement officers have seen gang members engage in the

nuisance behavior detailed in this Petition.

45. Members of the general public who live and work within the Safety Zone

22

do not have the freedom to enjoy their homes or public facilities. In the weeks

preceding the filing of this Petition, law enforcement officers have spoken with

individuals afraid to leave their homes at night and individuals afraid to walk alone

to their cars after work at night.

46. Without equitable relief from this Court, the Gangster Disciples and the

Grape Street Crips will continue to commit acts of violence and drug sales, and the

communities inside the Safety Zones will continue to suffer. The citizens and

business owners of the East Lake community fully support the relief sought in this

Petition.

XI. RELIEF SOUGHT


Pursuant to Tennessee Code Annotated 29-3-101 et seq, Petitioners pray

that this Court allow the filing of this Petition and service of process to seek a

permanent injunction against the Gangster Disciples and the Grape Street Crips.

Furthermore, Petitioners pray that, upon the hearing of this matter, the Court

declare the Gangster Disciples and the Grape Street Crips a public nuisance under

Tennessee Code Annotated 29-3-101 et seq and the common law, permanently

enjoining its members from the activities stated below:



A. Activities enjoined in Safety Zone


1. Do not Associate: Standing, sitting, walking, driving, gathering or


appearing anywhere in public view or any place accessible to the public,



with any known member of the Gangster Disciples and the Grape Street

Crips, but not including:

23

(a) when all individuals are inside a school attending class or on school
business, or
(b) when all individuals are inside a place of worship; provided however that
this prohibition against associating shall apply to all claims of travel to or
from any of those locations; and
2. No Intimidation: Confronting, intimidating, annoying, harassing,
threatening, challenging, provoking, assaulting or battering any person

known to be a witness to any activity of the Gangster Disciples

or the Grape Street Crips, known to be a victim of any activity of the

Gangster Disciples or the Grape Street Crips, or known to

be a person who has complained about any activity of the Gangster Disciples,

or Grape Street Crips; and

3. No Guns or Dangerous Weapons: Anywhere in public view or any

place accessible to the public, (1) possessing any gun, ammunition, or

otherwise prohibited weapon as defined in Tennessee Code Annotated

39-17-1302, (2) knowingly remaining in the presence of anyone who is in

possession of such gun, ammunition, or otherwise prohibited weapon, or

(3) knowingly remaining in the presence of such gun, ammunition, or

otherwise prohibited weapon; and

4. No Graffiti or Graffiti Tools: Damaging, defacing, or making a public

property or private property of another, or possessing any spray can,


felt tip marker, or other graffiti tool; and


5. Stay Away from Drugs: Without a prescription (1) selling,
possessing,

24

or using any controlled substance or related paraphernalia, including, but

not limited to, rolling papers, pipes, syringes, and hypodermic needles used
for illegal drug use, (2) knowingly remaining in the presence of anyone

selling, possessing or using any controlled substance or related

paraphernalia, or (3) knowingly remaining in the presence of any

controlled substance or such related paraphernalia; and

6. Do Not Act as a Lookout: Acting as a lookout, whistling, yelling,
making

hand signals, using cell phones, or otherwise signaling another person to

warn of the approach or presence of a law enforcement officer; and

7. Stay Away from Alcohol: Anywhere in public view or any place

accessible to the public, (1) possessing an open container of an alcoholic

beverage, (2) knowingly remaining in the presence of anyone possessing

an open container of an alcoholic beverage, or (3) knowingly remaining

in the presence of an open container of an alcoholic beverage; and

8. No Trespassing: Being present on or in any property not open to the

general public, except (1) with the prior written consent of the owner,

owners agent, or the person in lawful possession of the property, or (2)

in the presence of and with the voluntary consent of the owner, owners

agent, or the person in lawful possession of the property; and

9. No Forcible Recruiting: Making any threats, or doing anything

threatening, including striking or battering a person, destroying or

damaging personal property, or disturbing the peace, or causing or

25

encouraging a person to join the Gangster Disciples or the Grape Street Crips;

and

10. No Preventing a Member from Leaving the Gang: Making any

threats, or doing anything threatening, including striking or battering

a person, destroying or damaging personal property, or disturbing the

peace, (1) to prevent a person from leaving the Gangster Disciples or the

Grape Street Crips, or (2) because a person is known to have left the Gangster

Disciples or the Grape Street Crips; and

11. Obey All Laws: Failing to obey all laws that prohibit (1) violence and

threatened violence, including murder, rape, robbery by force or fear, and

assault and battery, (2) interference with the property rights of others,

including trespass, theft, driving, or taking a vehicle without the owners

consent and vandalism, or (3) the commission of acts that create a nuisance,

including the illegal sale of controlled substances and blocking the sidewalk.

Opt Out Provision

Any person served an Order of this Court as a Gangster Disciple or Grape

Street Crip member may move to be dismissed from this action. In the event that a

person is dismissed pursuant to this Opt Out provision, any injunction shall not be

enforceable against him or her. The terms of Petitioners proposed opt-out provision

are as follows:

a. Requirements: Petitioners agree not to object to an individuals motion to be

dismissed from this action, so long as the dismissal is to be without prejudice and

with each side to bear its own costs and fees, and so long as the motions satisfies

26

the following requirements:

1) Proper Notice: A motion under this provision shall be made on 30 days


notice, properly served upon the District Attorney General of Hamilton

County, Tennessee;

2) Not (or No Longer) a Gangster Disciple or Grape Street Crip: An individual

seeking to opt-out of the Courts injunction must declare in writing that he or

she is either a reformed or former Gangster Disciples or Grape Street Crip

member, he or she is not active with the Gangster Disciples, or Grape Street

Crips and has renounced the Gangster Disciples or Grape Street Crips and

gang life. This declaration regarding the Gangster Disciples and Grape Street

Crips and gang life is an essential part of this provision; and

3) Proof Required: An individual included in the injunction by the Court

as a Gangster Disciple or Grape Street Crip who is seeking to be dismissed

from the this action must truthfully declare that he or she (1) has not been

arrested for the past two years, not including any time spent incarcerated;

and (2) has not been in the company or association of any person known as a

Gangster Disciple or Grape Street Crip, other than an immediate family

member for the last two years; and (3) has not obtained any new gang

related tattoos for the last two years.

b. No Third-Party Beneficiaries: It shall not be a defense to any civil or
criminal

charge of any nature whatsoever that any person involved in the facts underlying

that charge, including the person to be charged, was eligible to apply for a

27

dismissal under this opt-out provision.

c. Effect in Other Proceedings: Petitioners shall not be bound by the criteria
of

this opt-out provision in any action, civil or criminal, other than a motion to opt-out

brought in this action.

d. Judgment not Admissible: This gang injunction shall not be admissible in
any

criminal or other civil action related to a successfully opted-out individual, and

cannot be used against any such individual, except in a proceeding brought for the

violation of this injunction.

e. Dismissed Individual Committing New Violation: Successfully
obtaining a

dismissal under this provision (an opt-out) will not permit any individual to rejoin

the Gangster Disciples or the Grape Street Crips.

If a dismissed individual re-associates with the Gangster Disciples or the Grape

Street Crips, who is the named Respondent, is arrested for any crime that is a gang-

related crime, obtains new gang tattoos, or otherwise conducts himself as a member

of the Gangster Disciples or the Grape Street Crips, such person may be added as an

active gang member; subject again to the the gang injunction.





CONCLUSION


Petitioners pray that this Court declare the Gangster Disciples and the Grape

Street Crips a nuisance and permanently enjoin the Gangster Disciples and the

Grape Street Crips from the above acts in the Safety Zone. Petitioners further pray

28

VIOLENCE IN THE EAST LAKE SAFETY ZONE

Homicides 2010-2015
Shootings 2012-2015
*Crimes involving gang members are highlighted

HOMICIDE VICTIMS
4/30/10
5/1/10
9/7/11
9/8/12
3/19/13
1/28/14
7/10/14
7/27/14
9/7/15
10/20/15

Michael Johnson
Jaylen Ramsey
Demetrius Roshelle
Kenyeta Trimble
Eric Fluellen
Rafael White
Dominic Wright
Jeffrey Jackson
Wonsik No
Percy Allen

OTHER SHOOTING VICTIMS

1/2/12
Sean Jones
1/10/12
Joe Houston
3/12/12
Connie Freeman
4/24/12
Guy Wilkerson
5/28/12
Jerry Jones

Karona Cunningham
7/17/12
Jeffrey House
7/22/12
Courtney Birt
7/30/12
Thomas Armstrong
12/16/12
Brian Hall, Jr.
12/20/12
Lawarren Smith
12/30/12
Michael Ford
1/7/13
Alexander Hughlett
1/11/13
Joshua Brewer
3/12/13
William McMillan
5/2/13
LeMario Branham
5/12/13
Trashaunda Green
5/27/13
Shannon Cooley
5/29/13
Juvenile
8/13/13
Juvenile
8/15/13
Michael Hudgins
10/15/13
Robert Allen
1/5/14
Antonio Beavers
4/27/14
Marice Manghanu
7/5/14
Juvenile
9/29/14
Juvenile
10/1/14
Lakita Bowling
1/7/15
Brian Posley, Jr.
3/2/15
Keith Goodwin
3/21/15
Gary Mitchell
3/26/15
Kendre Allen
4/16/15
Bethany Kindred
5/31/15
Javon Clark
7/24/15
Korrielle Redding
8/9/15
Reginald McGruder
9/21/15
Jonathan Joseph Black
10/20/15
Thomas Simmons

Antonio Watkins
12/31/15
Arterrius Bonds

2138 East 27th Street

10th Avenue
3020 13th Avenue
2213 East 25th Street Ct
3200 blk 13th Avenue
2753 6th Avenue
2108 Foust Street
2525 6th Avenue Ct
2500 4th Avenue
2221 East 28th Street

2600
2200
3206
2601
2217
2116
3700
2125
2800
3800
2200
2700
2100
2219
2200
2600
2218
2200
2243
2600
2421
2800
2600
2424
2255
2600
2214
2800
3100
2500
2413
2100
2200
2700
2800
2800
2714

12th Avenue
blk East 26th Street
1st Avenue
4 th Avenue
East 28th Street

Foust Street
blk 7thAvenue
East 25th Street
5th Avenue
blk 9th Avenue
East 27th Street
blk 4th Avenue
blk Foust Street
26 th Street Ct
blk East 27th Street Ct
blk East 24th Street
East 27th Street Ct
blk East 25th Street Ct
East 25th Street
4th Avenue
4th Avenue
Dodds Avenue
4th Avenue
Dodds Avenue
26th Street Ct
4th Avenue
East 26th Street
Dodds Avenue
3rd Avenue
6th Avenue
4th Avenue
East 35th Street
East 26th Street
4th Avenue
3rd Avenue
blk 4th Avenue

6th Avenue