Lorenzo Clark vs. Memphis Animal Services, et al

Case Background

On September 22, 2022, Plaintiff Lorenzo Clark filed a Fourth Amendment violation lawsuit for unlawful search and seizure in the United States District Court, Tennessee Western (Case number: 2:22cv2641).  This case was assigned to Judge John Thomas Fowlkes, Jr. and referred to Magistrate Judge Annie T. Christoff

Cause

On September 24, 2021, Lorenzo Clark, the plaintiff, experienced a clear violation of his Fourth Amendment rights when Memphis Animal Services (MAS) and the Memphis Police Department (MPD) unlawfully entered his enclosed backyard without a warrant. This intrusion occurred under the false pretense of conducting an animal welfare check. With support from MPD, MAS employees unlawfully accessed Clark’s property, seizing his eleven dogs, including ten American Pit Bulls and one Exotic Bully Mix. Despite the dogs being healthy and cared for, MAS failed to notify Mr. Clark about the impoundment, as required by their own rules. Moreover, he was not informed of his redemption rights.

Injuries

The unlawful search and seizure, which violated Clark’s Fourth Amendment rights, caused significant emotional distress and financial hardship. The defendants deprived the plaintiff of access to his pets, which held great sentimental value. They reported that three of the dogs were euthanized, while they allegedly adopted out the Exotic Bully, valued at over $10,000, without Clark’s consent. The defendants also caused reputational harm to the plaintiff by pressing criminal charges, though the court eventually dismissed those charges.

Damages

Clark faced severe financial losses, including legal fees, court fines, and a payment of $3,325 to cover food and vaccination costs mandated by MAS. The emotional toll was devastating, compounded by public humiliation following local news reports about his arrest. The stress from the unlawful seizure of his animals caused ongoing physical illness, further exacerbating the anguish over their mistreatment.

Key Arguments and Proceedings

Legal representation

  • Plaintiff(s): Lorenzo Clark
    • Counsel for Plaintiff: Linda Kendall Garner
  • Defendant(s): Memphis Animal Services | City of Memphis
    • Counsel for Defendants: Robert D. Meyers | Danielle N Rassoul| Miriam Greer Bryant

Claims

This case centers on violations of Clark’s constitutional rights under the Fourth and Fourteenth Amendments. The plaintiff claims unlawful search and seizure, deprivation of due process, and malicious prosecution. The defendants, including MAS, the City of Memphis, and unnamed officers, acted recklessly and maliciously, failing to follow proper legal procedures. Clark seeks justice for the violations of his Fourth Amendment rights, which included an unlawful search and seizure of his property and the unjust removal of his dogs.

Defense

The City of Memphis defended itself against Clark’s allegations by asserting several defenses and denying the claims. Defendants argued that the complaint failed to state a valid claim for relief. They requested that the court dismiss the case. The City contended that Memphis Animal Services (MAS) was not a legal entity subject to a lawsuit. They claimed the City of Memphis was the appropriate party to be held accountable. The City further argued that some claims were barred by the statute of limitations. They also asserted that Clark lacked standing to seek damages.

The City claimed that any alleged injuries or damages resulted from Clark’s own intentional or negligent actions. They denied liability under the principle of respondeat superior, which holds employers responsible for the actions of their employees. Further, they argued that Clark failed to mitigate damages. Additionally, they denied all factual allegations of unlawful conduct by City employees.

Further, the City requested that the court dismiss the case with prejudice, deny all relief sought by Clark, and assess the plaintiff with the costs of the case, including attorneys’ fees. The defense also reserved the right to amend its answer or raise additional defenses during discovery.

Jury Verdict

On December 13, 2024, the jury sided with Lorenzo Clark in his claims related to unlawful search and seizure. They found that the City of Memphis had violated Clark’s Fourth Amendment rights in two ways. First, the City unlawfully seized and removed dogs from his property at 1924 Baldwin Road. Second, the City caused Clark’s arrest. The jury found that City policies directly caused these constitutional violations. As a result, they awarded Clark $120,000 in damages. This amount included $45,000 in actual damages and $75,000 in compensatory damages in a Fourth Amendment violation lawsuit

Court Documents:

Documents are available for purchase upon request at jurimatic@exlitem.com