Defendant's Attorney: Claire Barker, Michael Verdier Cory, Jr., Christian Medina, Dana P. Sims,Francis Starr Springer, and Lee Davis Thames

Description: Jackson, Mississippi personal injury lawyer represented the Plaintiffs who sued the Defendants on civil rights violation theories under 42 U.S.C. 1983 claiming $9.99 million in damages.


In the early daylight hours of January 27, 2018, Crystalline Barnes was driving her red Pontiac in Jackson, Mississippi. City of Jackson Police Officer Rakasha Adams says she observed Ms. Barnes run a stop sign, causing another vehicle to run off the road. After checking on the passengers of the other vehicle, Officer Adams began to pursue Ms. Barnes.

Both vehicles traveled at low speeds, under the speed limit. Officer Adams received information from dispatch that the owner of the red Pontiac was Ms. Barnes and that the vehicle was not reported stolen. Other than the traffic violation Officer Adams says she observed, no crime or suspicious activity was associated with either the vehicle or Ms. Barnes. Nevertheless, what happened next resulted in Ms. Barnes’ death.

The events that led up to the fatal shooting are heavily disputed. On top of the disputes between the plaintiffs and the defendants, there are significant evidentiary conflicts among the defendants stemming from their internally inconsistent statements. In addition, no audio or video evidence from vehicle dashboard or body cameras has been provided to this Court.

Here is an early example of the conflicts. In her initial incident report, Officer Adams stated that she initiated her blue lights and siren. But her affidavit submitted in this litigation says otherwise: her siren was not working. We see the same problem in the report of Officer Albert Taylor, who joined the pursuit after Officer Adams radioed him for backup. In his incident report, Officer Taylor stated that he activated his blue lights and siren. In a subsequent affidavit, though, Officer Taylor stated that he did not activate either. Because Ms. Barnes did not appear to be evading and traffic was very light, he deemed the blue lights and siren unnecessary.

Returning to Officer Adams, she states that when she initiated her blue lights and siren, Barnes did not stop. According to the incident report, Ms. Barnes ran other stop signs and traffic lights. Those specific traffic violations are not mentioned in Officer Adams’ affidavit, however.

In any event, while engaged in her pursuit of Ms. Barnes, Officer Adams called Officer Taylor for assistance. The pursuit lasted about four minutes and for a distance of approximately two miles. At some point, Officer Taylor lost sight of Officer Adams and Ms. Barnes. In his affidavit, he states that after losing sight of them, he returned to his "beat."

From Officer Adams’ incident report we learn that Ms. Barnes made a left westbound turn on Fernwood Avenue. Officer Taylor approached in the eastbound direction of the same road. It is unclear whether Officer Taylor had actually returned to his beat at the time he encountered Officer Adams and Ms. Barnes again.

Officer Adams, in her incident report, states that as Ms. Barnes made the left onto Fernwood Avenue, Ms. Barnes lost control of the vehicle and hit the curb. Docket No. 129-2. Officer Adams explained in her affidavit that Officer Taylor was "approaching in his lane from across the street [when

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Ms. Barnes’] Pontiac accelerated and ran into [Officer] Taylor's car head-on." Docket No. 131-1. Officer Adams felt like Barnes had intentionally run into Officer Taylor's vehicle. Id. With respect to the curb, Officer Taylor's incident report states he saw Ms. Barnes hit the curb, but his affidavit describes the turn without any mention of her hitting the curb.

And with respect to the accident itself, the Plaintiffs have a competing narrative. They attribute the contact to the rainy weather conditions.

The Plaintiffs also describe what happened next differently. They state that after Ms. Barnes hit the curb, she attempted to accelerate away from the curb. They say that this is when Officer Taylor crossed from the eastbound lane into the westbound lane, positioning his patrol car against traffic, and collided with Ms. Barnes.

Despite their different versions of the collision, the parties do acknowledge that a collision occurred. Officer Taylor's patrol car sustained traces of red paint and a crack in the bumper.

The Plaintiffs then state that as Ms. Barnes attempted to drive away from the curb, Officer Adams exited her vehicle and began shooting at the driver's side of Ms. Barnes’ vehicle.1 In an attempt to escape the gunfire, they say, Ms. Barnes began to make a U-turn to re-position her vehicle east. The Plaintiffs state that this is when Officer Taylor exited his vehicle and (also) from the driver's side, began shooting at the driver side of Ms. Barnes’ vehicle. The Plaintiffs state that as Ms. Barnes turned her car around, driving east and away from Officers Adams and Taylor, both officers continued shooting. Within seconds, Ms. Barnes hit a utility pole and came to a stop. She had sustained two gunshot wounds and died from a shot to the back of her neck. Twenty-three shots had been fired.

Unsurprisingly, the officers’ affidavits and incident reports present a very different version of these events. Officer Adams says that after Ms. Barnes hit the curb, Ms. Barnes accelerated towards Officer Taylor's patrol car. Then, after her vehicle hit Officer Taylor's patrol car and he exited the vehicle, Ms. Barnes attempted to run him over. Officer Adams began to shoot at Ms. Barnes’ vehicle to defend her colleague. Officer Adams’ incident report also mentions that after Ms. Barnes drove towards Officer Taylor, she placed her vehicle in reverse and accelerated backwards towards Officer Adams. But, if one only reads Officer Adams’ affidavit, you will find no threats on her life.

Officer Taylor stated that after Ms. Barnes’ vehicle collided with his patrol car, he exited his vehicle and ordered Ms. Barnes out of the car. He states that Ms. Barnes instead put her vehicle in reverse before accelerating towards him. He then drew his weapon and fired at her. In his deposition, he stated that he believes he was the first one to fire his weapon. Lastly, Officer Taylor states that Ms. Barnes then accelerated towards Officer Adams. He fired his weapon again in fear for their lives.

The Plaintiffs’ expert report says JPD's investigation found that a total of 23 shots were fired. Of those, 17 were fired by

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Officer Adams and 6 by Officer Taylor. A total of 19 bullets hit Ms. Barnes’ vehicle. Two struck Ms. Barnes. The bullets hit her lower back and the back of her neck. All of the shots were fired at the sides and rear windshield of her vehicle. Not one shot was fired at the front of the vehicle.

The City's version of events cannot be entirely reconciled with that of the Officers’, either. Its brief states that "the driver of the Pontiac made a right turn toward the curb and then reversed its direction, at a high rate of speed, toward Officer Taylor." At this point, the City states that Officers Adams and Taylor began shooting at Ms. Barnes as she "put the vehicle in reverse and accelerated the vehicle toward Officer Adams." This description makes it sound as if Ms. Barnes drove in reverse twice in a row.

Following the incident, both officers were placed on administrative leave pending internal and criminal investigations. Both officers were found in violation of the City's General Order on police pursuits, for (1) failure to inform the communications center that they were involved in a pursuit, and (2) failure to adhere to the policy of pursuing only violent felons.

The Plaintiffs state that Officers Adams and Taylor also failed to comply with Jackson Police Department's policy of notifying dispatch that shots had been fired. And get this: Officers Adams and Taylor instead reported that a vehicle was on fire and requested the Fire Department.

At the time of the incident, Officer Adams had been a police officer for fewer than two years and Officer Taylor for approximately 18 years. Ms. Barnes’ fatal shooting was the second shooting for Officer Adams within a three-month period. As a result of the prior shooting, Officer Adams was placed on administrative leave pending an investigation. Ultimately, the City asserts that Officer Adams’ force in the prior shooting was found to be justified.2 The Plaintiffs state that Officer Adams nevertheless described herself as having emotional numbness, increased arousal, difficulty sleeping and concentrating, feelings of jumpiness, and easy irritability and anger. They argue that at the time Officer Adams returned to work, she was unfit for duty.

The Plaintiffs have also sued an Officer Morris. What was his role? They say that Officer Morris conspired with Officers Adams and Taylor to falsify a police report. They state that after arriving on the scene, Officer Morris agreed to write a police report that was purposefully misleading and included inaccurate allegations.

The Jackson Police Department's Major Investigations Division submitted Officer Adams and Officer Taylor's names to the District Attorney for consideration of murder charges. No charges were ultimately filed.

After discovery, the parties filed motions for summary judgment, a motion for leave to file a sur-reply, and motions in limine.

Outcome: The City of Jackson's motion for summary judgment is granted in part and denied in part. Officer Morris’ motion for summary judgment is granted in its entirety. Officer Adams and Taylors’ joint motion for summary judgment is granted in part and denied in part." K.B. v. Adams, 480 F.Supp.3d 746 (S.D. Miss. 2020)

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