Steinhoff, Ryan V. Malovrh, Matthew, Et Al

Case Background

On October 21, 2021, Ryan Steinhoff filed a civil rights case against law enforcement officers Charles Ramberg, Cody Kowalcyzk, Matthew Malovrh, Clark County, and Taylor County. Taylor County employed Defendant Cody Kowalcyzk, and Clark County employed Defendants Matthew Malovrh and Charles Ramberg. The complaint alleged violations of his Fourth Amendment Rights and use of excessive force against him during a search warrant execution.

The case was filed in the United States District Court, Wisconsin Western (Madison). The case was assigned to District Judge William M. Conley and referred to Magistrate Judge Stephen L. Crocker. [Case number: 3:21cv664]

Cause

On October 26, 2018, Ryan Steinhoff was sleeping in his trailer when a police team arrived and began banging on his door. The officers, part of a multi-jurisdictional task force with a search warrant, started knocking around 5:30 a.m. The officers were dressed in tactical gear, with many carrying assault rifles pointed at Ryan’s door.

What followed was recorded on body camera, though many officers were unaware of the footage. Ryan exited his trailer slowly and calmly, clearly unarmed, and raised his hands to show compliance. Ryan was instructed to “turn around” and put his hands behind his back, which he began to do. However, before he could finish, Officers Kowalcyzk, Malovrh, and Ramberg violently tackled him to the ground.

One officer struck Ryan in the head with an assault rifle, creating a loud “clunk” that was heard on the body camera. Ryan cried out in pain, asking why he had been hit when he was following orders. As he lay on the ground, the officers continued to stomp on him, including his head, before finally handcuffing him.

Ryan was then taken to the hospital to treat a severe head injury, requiring multiple stitches. Despite his clear compliance, the officers later fabricated reports to justify their actions. Kowalcyzk claimed Ryan was walking away, suggesting he was fleeing, while Malovrh and Ramberg falsely stated Ryan had refused to comply or was attempting to escape.

The body camera footage contradicted these reports, showing Ryan obeying commands and showing no signs of resistance. Initially, Taylor County had claimed there was no body camera footage but later admitted that Clark County had recorded the incident.

Injury

The officers placed Ryan in a squad car and took him to a local hospital, where doctors treated him with multiple stitches for the injuries he sustained from the beating by Kowalcyzk, Malovrh, and Ramberg. Doctors treated him for a large gash to his ear, requiring multiple stitches to close the wound.

Damages

Plaintiff sought actual or compensatory damages from Charles Ramberg, Cody Kowalcyzk, and Matthew Malovrh. Because the defendants had acted with malice, wantonness, or oppression, the Plaintiff also requested punitive damages. Additionally, the Plaintiff asked for the costs of the action, attorneys’ fees, and any other relief the Court deemed just and equitable.

Plaintiff further requested that the Court find Taylor County liable for defending the action against Defendant Kowalcyzk and Clark County liable for defending the action against Defendants Ramberg and Malovrh. The Plaintiff also sought a ruling requiring both Clark County and Taylor County to satisfy any judgment rendered against their employees.

Key Arguments and Proceedings

Legal Representation

  • Plaintiff(s): Ryan Steinhoff
    • Counsel for Plaintiff(s): James Odell | John H. Bradley | Randal Richard Resch , Jr | William Edward Grau
  • Defendant(s):  Charles Ramberg | Cody Kowalcyzk |  Matthew Malovrh | Clark County | Taylor County
    • Counsel for Defendant(s): Samuel C. Hall, Jr. | Timothy M. Johnson
    • Experts for Defendant(s): Robert C. Willis

Claims

The Plaintiff filed a claim for excessive force. Defendants Charles Ramberg, Cody Kowalcyzk, and Matthew Malovrh intentionally used excessive force by striking Plaintiff with an assault rifle, violently throwing him to the ground, and stomping on his head and body. These actions were unjustified and unnecessary, violating the Plaintiff’s Fourth Amendment right to be free from unreasonable arrest and seizure. They also infringed on his right to due process under the Fourteenth Amendment, in violation of 42 U.S.C. § 1983.

The actions of Defendants Ramberg, Kowalcyzk, and Malovrh directly caused the constitutional violations and led to the Plaintiff’s injuries. Additionally, their actions caused Plaintiff significant mental suffering, anguish, fear, humiliation, loss of personal freedom, and expenses.

Defense

The Defendants raised several defenses to the Plaintiff’s complaint. They argued that any injuries were caused by the Plaintiff’s own actions or failure to mitigate. They also claimed immunity under common law, statutory immunities, and qualified immunity, including discretionary immunity for state law claims. The Defendants contended that the Plaintiff failed to meet statutory requirements and that intervening causes barred recovery. They asserted their actions were reasonable, in good faith, and not malicious. Additionally, they denied any policy or practice violated the Plaintiff’s rights and argued the counties were not proper parties. Finally, they claimed that Plaintiff’s complaint failed to state valid claims and that punitive damages were improper.

Expert Testimony

The Defendants retained Robert Willis as their expert witness who is a law enforcement instructor, trainer, and consultant. His expert testimony was presented to strengthen the defense’s argument.

Jury Verdict

On January 30, 2024, the jury returned a defense verdict after it found out that Defendant Matthew Malovrh did not use excessive force against Plaintiff on October 28, 2018.

On February 12, 2024, District Judge William M. Conley passed a final judgment. The judgment was entered in favor of Defendants Charles Ramberg, Cody Kowalcyzk, and Taylor County for the Fourth Amendment claims against them in accordance with the court’s summary judgment.

Further, Judge Conley entered the judgment in favor of Defendants Matthew Malovrh and Clark County in accordance with the jury verdict.

Court Documents:

Available upon request