The Complaint alleges that on April 25, 2013, Constable Staley arrived at Mr. Swabey’s house for an old bench warrant. It alleges further that:

Mr. Swabey was taken before Judge Joshua Kanalis at the Washington County Court of Common Pleas. When Mr. Swabey was before Judge Joshua Kanalis, Constable Staley attempted to remove Mr. Swabey’s handcuffs but was unable to using the key assigned to the handcuffs. In an attempt to remove the handcuffs, Constable Staley took Mr. Swabey to Aggregates & Feed, a local store. The owner of Aggregates & Feed, Mr. Nichols, assisted Constable Staley in removing Mr. Swabey’s handcuffs. Constable Staley unsuccessfully tried to remove Mr. Swabey’s handcuffs using a bolt cutter. Mr. Swabey was not physically hurt by this attempt to remove the handcuffs. Constable Staley unsuccessfully tried to remove Mr. Swabey’s handcuffs using a rebar cutter. Constable Staley then proceeded to use a four-inch angle grinder (hereinafter “grinder”) . Mr. Swabey has been an ironworker for 10 years and told the Constable Staley that it was a bad idea to use the grinder. Constable Staley paid no attention to Mr. Swabey’s warning and proceeded to remove the handcuffs using the grinder.  Constable Staley placed a piece of wood underneath Mr. Swabey’s hands and began to grind the handcuffs. The grinder produced a lot of heat causing the metal handcuffs to overheat and burn Mr. Swabey’s wrists. As Constable Staley was using the grinder, Mr. Swabey was yelling “stop, you’re burning me!” Constable Staley continued to grind and instructed Mr. Nichols’ wife to pour cold water onto the handcuffs in an attempt to prevent the metal from overheating. The metal from the handcuffs continued to overheat and eventually fused with Mr. Swabey’s wrists and burnt his skin. Exhibit A.

Read the entire Complaint.