Case Background

On June 27, 2020, Eriberto Perez and his wife ate dinner with another couple. They went to a nearby bar. An altercation broke out involving Mrs. Perez, Ms. Morrison, and Mr. Hunter. Perez stepped in to protect his wife. San Bernardino County Sheriff’s Deputies Brandon Jarzombek, Kaelin Chan, and two unidentified officers arrived.

Cause of Legal Dispute

Deputy Jarzombek deployed a Taser on Perez without warning. Perez fell, struck his head on the concrete, and lost consciousness. While he was unconscious, Jarzombek deployed the Taser again and pressed his body weight on Perez’s torso, neck, and upper back. Deputies Chan and DOES 1–2 did not intervene. Jarzombek and Chan slammed Perez onto a patrol car.

Injury

Perez sustained head trauma and a shattered left shoulder. Deputies left him in the patrol car for over an hour without medical care. Two weeks later, he underwent surgery with twenty-six screws placed in his shoulder. He lost full function in the shoulder, suffered constant pain, and experienced sleep problems.

Damages

Perez lost his job, car, and home. He could not return to work as a forklift operator due to permanent loss of shoulder