Claims
Robert Lee Clark and Julie Clark allege civil rights violations arising from an October 1, 2023 traffic stop by the Denison Police Department in Grayson County, Texas. Officers escalated the encounter and forcibly removed Robert Clark from his vehicle. Officer Mario Rojas arrived as backup and assisted in restraining Clark, whose head struck the patrol vehicle's exterior frame and an interior metal component during the process. Julie Clark, acting as Robert Clark's disability advocate, verbally objected and recorded the encounter; officers attempted to seize her phone. Robert Clark was transported to Grayson County Jail. In related criminal proceedings, appointed attorney Sholdon Daniels failed to investigate the video evidence, then on June 14, 2024 presented Clark with paperwork described as an "application" for community supervision without disclosing it would resolve the criminal charge. Daniels escorted Clark into a private off-record meeting with prosecutor Benjamin Craig Smith, excluding Julie Clark as disability advocate; Smith stated additional charges could be brought against Julie Clark. Five claims: (1) Fourth Amendment excessive force against Rojas, (2) First Amendment retaliation for recording and questioning police conduct, (3) Fourteenth Amendment due process violations by Daniels and Smith for depriving Clark of informed participation in criminal proceedings, (4) ADA Title II violation for excluding Clark's disability advocate from critical proceedings without reasonable accommodation, and (5) Monell municipal liability against the City of Denison for policies permitting escalation of traffic stops and use of force without accountability, with Chief Mike Gudgel as final policymaker who ratified or failed to discipline the officers involved.