................................Sam Dehne Files Federal Lawsuit Against Reno Airport
.....

Sam Dehne, a retired Air Force Lieutenant Colonel and model citizen (who has dedicated his life to exposing government in Reno), was feloniously abducted and kidnapped while quietly sitting at a Public Meeting on 14 September, 2000.
Sam Dehne was illegally handcuffed and thrown in jail and then illegally charged with (BOGUS) crimes in 2 different Courts.
Alert! All (BOGUS) charges were dropped 45 days later. (Click)

Kidnap (Websters): "To seize and hold or carry off (a person) against his will, by force or fraud"
."This Changes Everything" Sam Dehne, Lt Col, USAF (ret)

From Complaint (below): "Each of the Defendants is liable to Plaintiff for past and future general and special damages, including emotional distress, mental anguish, physical pain and suffering, future fear of arrest and incarceration, chilling of Plaintiff's exercise of free speech, loss of enjoyment of life, violation of the aforementioned constitutional rights inter se, adverse publicity, exclusion from a public meeting and prior restraint of Plaintiff's right to speak further, attorney's fees, court costs, inconvenience, embarrassment, humiliation, grief, harm to reputation, all in sums to be proved at trial."
Note: After carefully considering the logistics of the situation, it has been decided that the two airport policemen and the airport executive director are to be removed from the lawsuit as defendants.
This certainly does not mean that they were not without sin.
(Further note: The 9th Circuit Court did not allow these Defendants to be removed from culpability.) The Local Court Wants A Settlement Conference
The trial date for the Kidnap (Airport) case is set for Nov 1, 2004.
The local federal judge has scheduled a settlement conference for
May 25 at 9 AM.
Sam Dehne has been told that he is required to "attend and participate in
good faith towards settlement."
Sam's faith is as good as anybody's... especially the "good" part.
Sam is willing to negotiate and accept a reasonable settlement
(of not less than $10,000,000), but acomment about his attitude toward,
and respect for, the Constitution and Justice System is in order.

Here is a rough DRAFT opening statement:
1. This settlement conference flies in the face of what all of the judges at
the 9th Circuit Court ordered when they said, "Generally, questions of
motivation raise issues of fact that must be decided by a jury. This case
is no exception." (emphasis added)
2. Should the local federal courts be allowed to supercede the dictates
of the higher 9th Circuit Court judges... all 25 of the 9th Circuit Judges? The merits
of this Complaint, as poignantly portrayed on the official video tape of the
Defendants' transgressions, were so obvious that not even a single judge
out of all the 9th Circuit Court judges voted to waste their time to hear it "en banc".
3. I am participating under duress because my right to a jury trial is being denied.
4. This forced settlement process will protect crimes committed against me from being
properly exposed and punished. I do not see a forced settlement conference
as due process.
5. The Court must also be reminded that the Defendants premeditatedly let their
bogus charges (IN 2 COURTS) hang over this senior-citizen military-veteran's head
for 45 days. That was 45 days of embarrassment, loss of sleep, depleted appetite,
trepidation, fear of arrest, unhealthily raised blood pressure, harm to reputation,
humiliation, and trauma.
6. Notwithstanding the above, I am willing to discuss all reasonable settlement
suggestions that recognize the extreme and blatant severity of the atrocities committed
by the Defendants against the Plaintiff and the United States Constitution.
Signed,
Sam Dehne, Lt Col, USAF (ret)

............ "Click"Here to see the LOCAL Court's earlier silly attack on this attack on America. (Shame!)
..............WALKING PAPERS!WALKING PAPERS!WALKING PAPERS!

Walking Papers for the Evil Airport Aviation Amateurs

HERE'S THE LAW SUIT
(Filed due to a deluge of demands from the populace.)

JEFFREY A. DICKERSON
Nevada Bar No. 2690
10100 Old Virginia Road
Reno, NV 89511
(775) 786-6664
MARTIN G. CROWLEY
210 S. Sierra St., Ste. B102
Reno, NV 89504
(775) 786-5297
Attorneys for Plaintiff
.......................................................UNITED STATES DISTRICT COURT
..................................................................DISTRICT OF NEVADA
"SAM" DENIS EDWARD DEHNE, .............CASE NO. CV-N-00-0649-ECR-VPC
..............................................................................................Fed Ninth Appeals (02-15886)
Lt Col, USAF (ret) Sam Dehne, click here

Plaintiff, ...............................................................................COMPLAINT AND JURY DEMAND

vs.

RICHARD HILL, an individual, KRYS BART,
an individual, GARY NOTTINGHAM, an
individual, AIRPORT AUTHORITY OF
WASHOE COUNTY, a political
subdivision of the State of Nevada,
Defendants.
_____________________________/

Plaintiff for his complaint against Defendants complains and avers as follows:
1. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §1331 and 1367.

2. On September 14, 2000, Plaintiff was a citizen and attendee at a meeting
regularly scheduled and agendized of the Defendant Airport Authority of Washoe County.

3. Defendant Airport Authority of Washoe County is a political subdivision of the State of Nevada but is not an arm of the state protected by Eleventh Amendment immunity and is a "person" sueable under 42 U.S.C. §1983.

4. Defendant Nottingham was acting as a sergeant with the police department for the Airport Authority of Washoe County and is sued in his individual capacity.

5. Defendant Richard Hill was ostensibly a member of the Board of Trustees of the Airport Authority of Washoe County on September 14, 2000. He is sued in his individual capacity. He does not enjoy quasi judicial immunity because at the time he was acting in an administrative capacity and was without jurisdiction to act as Chairman of the Board. Defendant Bart is sued in her individual capacity. She was Executive Director of the Defendant Airport Authority.

6. On September 14, 2000 at this meeting, Plaintiff rose during public comment to speak against a set of rules that had been issued by Defendant Hill restricting public comment before the Board. These rules violated Plaintiff's right to speak and constitute policy of Defendant Airport Authority.

7. During this exercise of free speech on a matter of public concern which was videotaped and is not disruptive, Plaintiff made critical comments of Defendant Hill.

8. Following these comments, Plaintiff was seated when he was suddenly accused of making a comment from the seats that he "spit upon" the Board.

9. Plaintiff did not make such a comment. Defendant Hill nevertheless accused him publicly of it. Hill failed to exercise reasonable care in making the accusation which was defamatory in nature.

10. Plaintiff demanded a retraction of the false comment and an apology. Defendant Hill refused and instead ordered Plaintiff to be arrested, detained and removed from the meeting.

11. Defendant Nottingham responded with another presently unknown officer, seizing Plaintiff's person with full knowledge that there was no suspicion or cause to believe he had committed any crime nor to believe that he was disrupting the meeting.

12. Nottingham and the unknown officer exercised unreasonable force in executing the seizure and removal of Plaintiff.

13. Defendant Nottingham and the other unknown officer exercised unreasonable force in applying handcuffs to Plaintiff to effectuate the arrest. Defendant Bart had the authority and immediate opportunity to intercede to prevent these constitutional violations and failed to do so intentionally.

14. Some or all of the Defendants caused or participated in the initiation of criminal charges against Plaintiff in municipal court in Reno and in justice court in Washoe County for obstructing and resisting and for disruption of a meeting. Defendants knew that there was no probable cause for these charges and misrepresented facts in initiating said prosecutions.

15. These charges against Plaintiff have been dismissed with prejudice.

16. Plaintiff was detained for several hours including at the Washoe County Detention facility and was required to post bond but was eventually released on his own recognizance.

17. Plaintiff [USAF Lt Col (ret) Sam Dehne, click here] had never been arrested before in his life.

18. Defendants caused adverse publicity of or concerning Plaintiff.

19. Defendants acted intentionally.
FIRST CLAIM FOR RELIEF
Plaintiff incorporates all statements contained herein as if fully set forth herein above.
Defendant Hill caused Plaintiff's arrest and detention without probable cause subjecting him to liability under 42 U.S.C. §1983 for Plaintiff's damages based upon a violation of Plaintiff's Fourth Amendment right to be free from unreasonable seizures.
Defendant Hill caused Plaintiff to be recused in a defamatory fashion and arrested and detained and prosecuted based upon Plaintiff's exercise of his rights to free speech and to petition for redress of grievances under the First Amendment, subjecting Hill to the same liability under §1983. Defendant Hill is also liable for malicious prosecution plus under §1983.
Defendant Nottingham knowingly participated in Plaintiff's arrest and caused his detention and prosecution without probable cause subjecting him to liability under 42 U.S.C. §1983 for unreasonable seizure of Plaintiff's person and for malicious prosecution plus.
Defendant Nottingham also knew that Plaintiff had just exercised his right to free speech and was aware of no facts that would justify his seizure. Defendant Nottingham had an obligation to disobey Hill's command or commands which he knew violated Plaintiff's right under the First and Fourth Amendments. Nottingham's failure to intercede Hill's command subjects Nottingham to an additional basis of liability under §1983.
Defendant Bart failed to intercede to prevent these constitutional violations subjecting her to liability under §1983.
Plaintiff will seek leave to amend this complaint to identify other individuals involved in this series of events including the unknown officer identified above when their true names and identities are discovered.
Each of the Defendants in this regards acted with intent.
Defendant Airport Authority of Washoe County is liable because the aforementioned constitutional violations took place and were caused by a custom or policy promulgated by the Board of Trustees of the Airport Authority of Washoe County as final policymaker for that governmental body with deliberate indifference to the constitutional rights of Plaintiff.
Each of the Defendants is liable to Plaintiff for past and future general and special damages, including emotional distress, mental anguish, physical pain and suffering, future fear of arrest and incarceration, chilling of Plaintiff's exercise of free speech, loss of enjoyment of life, violation of the aforementioned constitutional rights inter se, adverse publicity, exclusion from a public meeting and prior restraint of Plaintiff's right to speak further, attorney's fees, court costs, inconvenience, embarrassment, humiliation, grief, harm to reputation, all in sums to be proved at trial.
Plaintiff is informed and believes and thereon avers that the actions of Defendant Hill were done with evil motive and malice and with deliberate indifference to the constitutional rights of Plaintiff, entitling Plaintiff to an award of punitive damages under 42 U.S.C. §1983 against Defendant Hill in a substantial sum to be proved at trial.
SECOND CLAIM FOR RELIEF
Plaintiff incorporates all statements contained herein as if fully set forth herein above.
The aforementioned conduct subjects the Defendants to liability for the tort of false arrest under Nevada law for the same damages.
THIRD CLAIM FOR RELIEF
Plaintiff incorporates all statements contained herein as if fully set forth herein above.
The aforementioned conduct subjects the Defendants to liability for the aforementioned conduct under the tort of false imprisonment under Nevada state law, for the same damages.
FOURTH CLAIM FOR RELIEF
Plaintiff incorporates all statements contained herein as if fully set forth herein above.
Defendant Airport Authority of Washoe County is liable for negligently supervising the other Defendant employees so as to avoid the above foreseeable harm to Plaintiff, which negligence proximately caused the aforementioned damage to which Plaintiff is entitled under the State tort of negligence.
FIFTH CLAIM FOR RELIEF
Plaintiff incorporates all statements contained herein as if fully set forth herein above.
The conduct of Defendant Hill was intentional or done in reckless disregard for the infliction of severe emotional distress upon Plaintiff.
Defendant Hill's conduct was extreme and outrageous.
As a proximate result, Plaintiff suffered severe emotional distress and is entitled to damages therefor.
SIXTH CLAIM FOR RELIEF
Plaintiff incorporates all statements contained herein as if fully set forth herein above.
Each of the Defendants failed to exercise reasonable care so as to avoid foreseeable harm to Plaintiff in terms of emotional distress and Plaintiff is entitled to damages therefor which were proximately caused thereby.

WHEREFORE, Plaintiff prays for judgment in his favor and against the Defendants jointly and severally as follows:
1. For general damages in sums to be proved at trial;

2. For special damages in sums to be proved at trial;

3. For punitive damages a substantial sum;

4. For declaratory relief in the form of a declaratory judgment that Plaintiff's aforementioned constitutional rights were violated by the foregoing conduct;

5. For injunctive relief enjoining Defendants from engaging in similar constitutional violations in the future for which there is a threat of repetition;

6. Reasonable attorney's fees and costs of suit pursuant to statute, including 42 U.S.C. §1988; and

7. For such other and further relief as the Court deems just and proper.

DATED this _____ day of November, 2000.

LAW OFFICE OF
JEFFREY A. DICKERSON
_______________________________
JEFFREY A. DICKERSON
LAW OFFICE OF
MARTIN G. CROWLEY
________________________________
MARTIN G. CROWLEY


................................................A Little Background:
It is a well-known fact that the scandal-plagued Reno Airport has had a long-standing multi-year documented history of cowardly antagonism against Sam Dehne [Read about USAF Lt Col (ret) Sam Dehne, click here]. Anybody who follows Reno politics knows Sam Dehne as a model citizen who has dedicated his life to monitoring and exposing evil rotten government bureaucrats in northern Nevada.

1. (1st Amend)
The aviation amateurs at the Reno Airport have attempted to suppress the 1st (Freedom of Speech) Amendment whenever Dehne has objected to the airport's crooked activities. Those Appointees even have had 3 armed guards at meetings specifically to (illegally) try to intimidate Dehne.

2. (4th Amend)
It is the 4th Amendment that was most recently mutilated:
"The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized."
Or... worded specific to Dehne's kidnapping:
"The right of Sam Dehne to be secure in his person against unreasonable seizure shall not, but upon probable cause, be violated."

3. (14th Amend)
The 14th (Equal Treatment Under the Law) Amendment is also given short shrift relative to Sam Dehne virtually every time the Airport board thinks it can get away with it.
Friendly fanny kissers are given carte blanche freedom to kiss the airport board's fannies at will and ad nauseam.
On 14 Sept, 2000 the Airport Board stepped over the edge and descended into a whole new level of citizen-molesting when they ordered the criminal abduction of Sam Dehne from their meeting.
With no legal authority to do so, the board chairman with the acquiescence of the rest of the entirely male good 'ol boy board of aviation amateurs, told 3 fully-armed airport policemen (who are ordered by assistant czar, Krys Bart, to be at these meetings to intimidate Dehne) to get him out of there. This was an order reminiscent of 1930's Hitler-led Nazi Germany. You probably remember the scenes; where the stormtroopers would blast into a citizen's home and drag him and his family off to some unpleasant place for no justifiable reason. Those Reno Airport board dictators and the guards who abducted Sam abdicated their rights and authority when they shirked their duties and failed to obey the dictates of the U. S. Constitution... which they had all sworn under oath to defend. Their wrongful actions had no force under law. And Sam had no "duty" to obey their illegal request that he leave the Public Meeting.
Sam Dehne proved once again beyond a scintilla of doubt that posting these guards at Public Meetings is not appropriate. (Most of the guards don't even want to be there! It's a gross embarrassment to what they are supposed to stand for.) Even though everybody would say Dehne had justification for struggling for his rights, he once again proved that he is no physical threat at these Public Meetings. Although he was being shamelessly abused by illegal orders from those cowardly potentates, he just stood his ground steadfastly in passive resistance and took the illegal assaults... choosing not to fight back one iota. He stood his rightful ground until he was finally overpowered and criminally abducted from the Public Meeting.
He was standing up for the constitutional right (and duty) of all citizens to challenge evil rotten government.
If a Watchdog like Sam Dehne can be wrongfully suppressed... then the average citizen has NO CHANCE.
You can like him or not personally, but if you are worth an ounce of salt, you have to respect Dehne's passion for the defending of the Constitution and those things that used to make America great. Washington, Henry, Revere, and the Colonial Revolutionaries would have been at Sam's side.
Anybody who has seen the Public Television playing of the video tape of what happened at the Airport board has to know that what happened was a travesty of justice and abuse of authority beyond even the typical perversions of local government.
Even though critical parts of the illegal Airport Public Meeting were "doctored" from the video tape, it still clearly displays crimes by the cowardly board that led up to the felony abduction of Sam Dehne.

It's as simple as this:
"King" Hill told Sam to sit down (an order he had no authority to give).
Sam stood his ground... he would not give in.
Can you imagine England's King George III telling the Americans at Bunker Hill and Valley Forge; "George, Patrick (Henry), Paul (Revere) Sit Down!". What if they had obeyed?!?
The Reno Airport later tried to embarrass and intimidate Sam with their bogus charges that Sam is a threat. They claim the dire need for "escape routes", "special training", "special code words", "panic buttons". Even though they already had 3 fully armed guards (with 2 more on immediate reserve) at every meeting... JUST FOR SAM!

(By the way, those Airport police are only "bit" players in this travesty against justice. The real culprits are the airport "bosses"... and THEIR "bosses".)

Folks, where does this cowardly insanity end? All of this hysteria because they are afraid of Sam... a 155 pound 60 year old citizen veteran... who has never hurt a flea.
IS Sam "threatening"?
Only Sam's WORDS are threatening because he speaks the TRUTH... and the TRUTH threatens their evil empire. It is time that somebody challenged that evil rotten empire.
"I spent 20 years in the Air Force defending America against enemies... both foreign and domestic. Some of the most diabolical and cowardly have been of the domestic nature."Sam Dehne

......................................................................

..........................................................Cadet Sam Dehne at USAFA, 1962
Updates
I. Some 45 days after he was kidnapped by the Reno Airport, SAM DEHNE,
was found innocent of the bogus charges trumped up against him. On 14 Sept,
2000 Sam was ignominiously hauled off to jail for having the audacity to speak
out against the Reno airport's massive corruption and double-dealing corporate
welfare schemes. He was then charged with bogus offenses in 2 different
courts... an obvious affront to the U. S. Constitution and honorable government.
"Charges" were dropped.
II. The Reno Airport Board was officially served with the Summons to
appear in Federal Court to answer for their violations of the US Constitution.
This was done during my Public Comment at the 12/14/00 Airport Meeting...
in front of an audience of 100... as well as 1,000s who will see it
on Public TV.
IIa. The "server" handed the documents to each defendant while Sam stood at the podium.
Sam made just two very brief comments about the Federal Complaint:
1. Details can be found on the internet at http://www.renocitizen.com
2. There was no choice about the filing of this Federal Complaint. The
ground swell of outrage in the community demanded action to prevent the
Reno airport's ongoing perversions and mutilations of the Constitution.
III. Sam used his last 60 seconds to give a few "Kudos 2000" to various
entities, including:
1. Dedicated Reno and Washoe county workers who do a good job despite
working under rotten evil government.
2. Reno Police and Washoe sheriffs deputies... WHEN they protect lives and
property... and the US Constitution.
3. SNCAT Public TV for televising the sins of the fat cats... except when
critical parts of some tapes are missing.
4. The Air Force Academy... for inspiring Sam to fight rotten evil government
when it raises its ugly head.
5. God, who in all Her wisdom, has helped Sam.
Notably missing was any kudo for the rotten evil Reno Airport.
IV. Depositions under oath were given by Sam and by the Reno airport in June of 2001. Note: Lying under oath is perjury and can be guilty people can be given severe punishment. The airport people should be very worried.
V. Mr Hill, who has been masquerading as the chairman of the scandal-plagued Reno airport, was ignominiously removed from the board by Reno city council. In its typically incestuous manner... city council then appointed former council member and aviation amateur, Bill Newberg.

VI. Depositions and Statements under oath were taken from some of the Reno airport perpetrators of evil. If their high-powered high-priced (hired from outside) attorneys have sense and good judgment, they will tell their clients to Settle for anything Sam asks for. Because if this hideous case goes to trial, some airport people could end up serving hefty prison sentences... not just for the kidnapping... but for the other shameless perversions they admitted to during the 6 hours of questioning by Sam's attorneys. And they could also go to prison for having perjured themselves under oath over and over and over again!
One could almost feel sorry for the airport attorneys. Given a half-way honest judge and a jury of Sam's peers, this is slam-dunk bad news for the scandal-plagued Reno airport kidnappers. Folks, rest assured, the Reno airport does not want their repulsive actions to see the light of day in a court room!
Kidnap (Websters): "To seize and hold or carry off (a person) against his will, by force or fraud"
 ...........................................AMENDMENTS TO THE CONSTITUTION (click)
Article 1: (Freedom of Speech)
Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances.Freedom of speech, religion, press, petition and assembly.

Article 4: (Freedom from Seizure)
The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.
Article 14: (Equal Treatment of All Citizens)
All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the State wherein they reside. No State shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any State deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws.
"Click" for more about this Reno airport atrocity
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