FOR IMMEDIATE RELEASE
NEW YORK, NY — April 16, 2025 — In a sweeping federal civil rights lawsuit filed in the United States District Court for the Southern District of New York, a 21-year-old Black man from the Bronx has accused multiple members of the New York City Police Department (NYPD) of unlawful seizure, racial discrimination, excessive force, and falsification of legal documents—all stemming from a late-night police encounter that ended with a fractured jaw, a false arrest, and a cascade of lasting trauma.
The complaint, filed by New York civil rights attorney Eric Sanders of The Sanders Firm, P.C., on behalf of Mr. Jaylin Ryan, follows the timely service of a Notice of Claim with the New York City Comptroller’s Office and alleges that NYPD officers engaged in a racially motivated and retaliatory use of force, fabricating a criminal summons in an attempt to cover up their misconduct.
At the heart of the case is a disturbing narrative: a young man standing on a Bronx sidewalk is punched in the face by a police sergeant while restained and being handcuffed, then falsely accused of a crime, denied timely medical care, and forced to defend himself in criminal court—only to have the case summarily dismissed weeks later for lack of legal merit.
The Incident: From Routine Concern to Police Violence
On December 28, 2024, at approximately 12:25 AM, Mr. Ryan stood beside his mother’s 2017 Mercedes-Benz GLS SUV, which was briefly double-parked outside 187 East 188th Street in the Bronx. According to the complaint, Mr. Ryan was not driving the vehicle but was standing nearby to ensure that his female friend, Carolyn Martinez, made it safely into her building. His younger sister sat in the front passenger seat.
What began as an act of caution quickly devolved into an alleged act of police aggression. A group of 4 to 6 NYPD officers, including Sergeant Brian P. Mahon, Sergeant Joel K. Ayala, and Police Officer James G. Geberth, approached Ryan and demanded identification. When Ryan calmly asked, “What did I do wrong?”, officers slammed him against the SUV. While he was handcuffed and physically restrained by multiple officers, Sergeant Ayala allegedly punched Ryan in the face with a closed fist, causing immediate and severe pain.
Ryan was placed in Mahon’s police vehicle and transported to the 46th Precinct. During the ride, Mahon allegedly turned and told Ryan:
“This is what happens if you do not give the police what they ask for; you’ll get punched in the face.”
At the precinct, when confronted by Ryan’s mother, Nazima Royster, Mahon allegedly justified the violence with another racially charged remark:
“He’s a Black kid driving a Mercedes-Benz, and the windows are all tinted. Vehicles like that—they [police] search for drugs and guns.”
Fabricated Summons and Legal Misconduct
Despite the absence of probable cause, NYPD officers escalated the misconduct rather than voiding the arrest in accordance with department policy.
Geberth issued Summons No. 4447558422 charging Ryan with Disorderly Conduct under Penal Law § 240.20(7). In the sworn factual section, Geberth alleged that Ryan had refused to provide his driver’s license and stated that he had a license but would not present it. The complaint asserts that this narrative was fabricated, that Ryan never made such statements, and that even if true, such behavior would not meet the statutory elements of Disorderly Conduct, which requires a person to create a “hazardous or physically offensive condition” without a legitimate purpose.
Later that morning, after Ryan had been taken into custody, Officer Patrick Jean issued two additional traffic summonses—one for double parking and one for parking near a fire hydrant. The federal complaint characterizes these charges as retaliatory, written not for public safety, but to lend retroactive legitimacy to an otherwise baseless arrest.
On January 16, 2025, a Bronx Criminal Court judge dismissed the Disorderly Conduct charge outright, finding that the factual allegations—even if accepted as accurate—did not establish a violation of law.
Physical Injuries, Medical Neglect, and Psychological Trauma
After his release from custody, Mr. Ryan sought emergency medical care at Lincoln Hospital, where doctors diagnosed a fractured jaw—a serious injury consistent with blunt force trauma. Despite Ryan’s visible facial injuries and repeated pleas for medical attention while in police custody, officers allegedly delayed summoning an ambulance. When emergency medical personnel eventually arrived, Geberth allegedly discouraged treatment, stating that Ryan would soon be released.
Left to seek care on his own, Ryan was discharged with pain medication, dietary restrictions, and instructions to follow up with a maxillofacial specialist. He continues to suffer from chronic pain, difficulty chewing, facial numbness, and disrupted sleep.
However, the complaint also chronicles emotional and psychological fallout. Ryan, who was once outgoing and social, has become withdrawn and anxious. He describes himself as a “workaholic,” using long hours at his part-time job to distract from intrusive memories of the incident. He avoids public places where police officers may be present and no longer feels safe in his neighborhood.
“I was just trying to make sure my friend got inside safely,” Ryan told his attorney. “They treated me like I didn’t belong in my own skin.”
A Pattern of Institutional Failure
The complaint does not stop at individual misconduct. It details the NYPD’s systemic failure to supervise, discipline, or retrain officers with repeated histories of abuse. All named defendants have been subject to prior civilian complaints and civil rights lawsuits.
Sergeant Brian P. Mahon has at least 12 civilian complaints and 10 lawsuits involving allegations of excessive force, false statements, and racial bias. He is listed on the NYPD’s “Adverse Credibility” list.
Sergeant Joel K. Ayala has 20 civilian complaints, 74 allegations, and over $600,000 in settlements related to misconduct, racial profiling, and excessive force.
Officer James G. Geberth, despite a short tenure, has already been the subject of multiple complaints and lawsuits, including one resolved for $85,000.
Officers Crystal L. Dones, John Michael B. Medina, and Patrick Jean have all been cited in lawsuits or CCRB complaints for abuse of authority, unlawful stops, and constitutional violations.
Despite this extensive history of misconduct, the City of New York employs these officers, often in supervisory roles. The complaint asserts that the NYPD has deliberately ignored red flags, fostering a culture where abuse is tolerated and accountability is elusive.
A Pattern of Abuse: NYPD’s Troubling History of Civil Rights Violations
The misconduct alleged in Mr. Ryan’s federal lawsuit is not an aberration—it echoes a deeply entrenched and well-documented pattern within the New York City Police Department (NYPD). For years, civil rights advocates, legal monitors, and independent oversight bodies have identified widespread issues of excessive force, racial profiling, retaliatory arrests, and falsified documentation, particularly in neighborhoods of color.
Mr. Ryan’s experience—being physically assaulted while handcuffed, falsely charged with disorderly conduct, and denied prompt medical care—fits squarely within a broader institutional context. Over the past decade, the NYPD has repeatedly been at the center of high-profile incidents that mirror the constitutional violations alleged in this case. These incidents have sparked public outrage and led to massive taxpayer-funded settlements and federal court oversight.
Notable Parallel Cases of NYPD Misconduct:
Eric Garner (2014): Garner, a 43-year-old Black man, died after former NYPD Officer Daniel Pantaleo placed him in a banned chokehold during an arrest for allegedly selling untaxed cigarettes. Video footage captured Garner saying, “I can’t breathe” eleven times before losing consciousness. His death ignited national protests and remains one of the most well-known examples of deadly police misconduct. Despite the public outcry, no officer was criminally charged, and the City later paid $5.9 million to settle a wrongful death lawsuit.
Delrawn Small (2016): A 37-year-old Black man was shot and killed by off-duty NYPD Officer Wayne Isaacs in a Brooklyn road rage incident. Surveillance footage showed Small being shot within seconds of approaching Isaacs’ vehicle, contradicting the officer’s self-defense claims. Although Isaacs was prosecuted, he was ultimately acquitted. The case fueled further debate over the NYPD’s culture of impunity and the failure of internal discipline systems to hold officers accountable.
Kawaski Trawick (2019): Trawick, a 32-year-old Black man and aspiring dancer, was shot and killed inside his own Bronx apartment by NYPD officers. Officers forced entry without a warrant, and within two minutes of arrival, fatally shot Trawick—despite clear signs that he was not a threat. The NYPD refused to discipline the officers involved, prompting demands for an independent investigation and raising alarms over mental health-related encounters with police.
Dounya Zayer (2020): During the George Floyd protests in Brooklyn, Zayer, a young woman of Middle Eastern descent, was violently shoved to the ground by an NYPD officer. She suffered a severe head injury and required hospitalization. The attack, captured on viral video, became emblematic of the NYPD’s aggressive response to peaceful demonstrators, with more than 60 officers later found to have committed misconduct during the 2020 protests.
These cases, like Ryan’s, reflect a broader systemic breakdown, where bias, aggression, and retaliation are not aberrations but recurring features of daily policing in marginalized communities. Civil rights experts argue that the absence of meaningful accountability mechanisms, coupled with a culture of silence and institutional protection, has allowed patterns of abuse to persist across multiple precincts and leadership changes.
In Ryan’s case, the officers involved have prior histories of misconduct, ranging from excessive force and racial profiling to untruthful statements and false arrests. Yet, they remain on active duty, illustrating what many advocates describe as the NYPD’s ongoing failure to police itself.
The lawsuit, therefore, does not merely seek redress for one young man’s suffering—it exposes deep-seated structural flaws in law enforcement that continue to place Black and Latino New Yorkers at disproportionate risk of harm.
Legal Framework: Arlington Heights, Floyd, and Monell Liability
The federal complaint draws on established constitutional doctrine to support its claims. It invokes the Supreme Court’s decision in Village of Arlington Heights v. Metropolitan Housing Development Corp., 429 U.S. 252 (1977) to argue that Mahon’s racially charged statements—coupled with procedural deviations and retaliatory actions—demonstrate intentional discriminatory enforcement in violation of the Equal Protection Clause.
Further, it cites Monell v. Department of Social Services, 436 U.S. 658 (1978), to establish municipal liability, alleging that the NYPD’s customs and practices—ranging from unlawful stops to falsification of summonses—were the driving force behind Ryan’s rights violation.
The complaint is also bolstered by findings from the Floyd Monitor’s 23rd Report, which revealed that:
Only 58% of frisks and 54% of NYPD Neighborhood Safety Team searches were lawful.
Over 90% of stops involved Black or Latino individuals;
Supervisors approved 99.1% of all stop reports, even when they were unconstitutional.
These findings align with the experiences of Mr. Ryan and support the lawsuit’s core contention: that his arrest was not an aberration, but a symptom of an institutional culture of racialized over-policing.
Relief, Reckoning, and the Road to Accountability
The federal lawsuit names the City of New York as defendants, along with Sergeant Brian P. Mahon, Sergeant Joel K. Ayala, Officer James G. Geberth, Officer Crystal L. Dones, Officer John Michael B. Medina, Officer Patrick Jean, and five unidentified officers referred to as John Does 1–5. Each is alleged to have participated in, enabled, or failed to prevent the unlawful arrest, excessive use of force, and racially discriminatory treatment inflicted upon Mr. Ryan.
Under federal and municipal civil rights frameworks, the complaint seeks various legal remedies, including compensatory and punitive damages, declaratory relief, and attorneys’ fees. It asserts violations of 42 U.S.C. § 1983 and claims under the New York City Human Rights Law, which prohibits bias-based profiling and unequal treatment by public servants, including law enforcement.
But the case does more than allege civil infractions—it demands criminal accountability. According to Eric Sanders, the conduct described in the complaint—punching a restrained person in the face, lying under oath, fabricating citations, and failing to intervene or report obvious misconduct—crosses the line into criminality. He has formally called on the U.S. Attorney for the Southern District of New York and the Bronx County District Attorney’s Office to investigate the officers involved.
“This is not just a civil rights lawsuit—it’s a criminal matter,” Sanders said. “Punching a handcuffed person in the face, lying under oath, and fabricating citations to cover it up—those are crimes. And the people who committed them should be prosecuted, not protected.”
This lawsuit represents a rare opportunity for Sanders and his client to hold individuals and an entire system accountable. It tells a larger story—one about how unchecked police authority, racial profiling, and institutional silence can intersect to devastate the life of someone who was trying to make sure a friend got home safely.
“Jaylin wasn’t a threat,” Sanders said. “He was a young man with no criminal record, acting out of care and caution. Instead of being protected, he was assaulted, arrested under pretenses, and then abandoned by the very institutions meant to uphold justice.”
The complaint lays out the brutality of the individual encounter and a broader failure of constitutional governance: where suspicion substitutes for probable cause, where race dictates response, and where retaliatory charges are filed to shield officers from scrutiny. As the lawsuit emphasizes, these are not isolated lapses—they are the logical outcome of a system where misconduct goes unchecked, and repeat offenders remain on patrol.
Whether Jaylin Ryan’s case will catalyze broader institutional change remains to be seen. But as Sanders notes, the suit serves as a legal and moral blueprint—a roadmap for how victims of racialized policing can fight back through the courts and the public sphere. It is also a warning: until meaningful accountability is enforced, constitutional rights remain paper promises for far too many Americans.
“This case is about truth,” Sanders said. “It’s about exposing the lie that equal protection applies to everyone. And it’s about making clear—to the public and to the courts—that if justice means anything, it has to mean something for Black and brown people stopped on the street for doing nothing wrong.”
Contact:
For media inquiries, legal commentary, or to support Mr. Ryan’s case, contact:
The Sanders Firm, P.C.
30 Wall Street, 8th Floor
New York, NY 10005
Phone: 212-652-2782
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Read the Federal Complaint