FOR IMMEDIATE RELEASE
New York, N.Y. — Today, April 17, 2025, in a harrowing civil rights lawsuit filed in the United States District Court for the Eastern District of New York, Brooklyn resident Keyanna Moody, a Black mother and lawful e-bike operator, alleges she was violently assaulted, unlawfully arrested, racially abused, and denied medical care by members of the New York City Police Department (NYPD) on June 11, 2024. The federal complaint, filed under 42 U.S.C. § 1983 and the New York City Human Rights Law (NYCHRL), details a traumatic encounter that began with a routine family outing and ended in physical and psychological trauma.
The lawsuit names as defendants Lieutenant Daniel Lacalamita, Sergeant Stanislav Zubyk, Police Officers Michael R. Moran, Alvin M. Nieves, Jared W. Cordero, and John Does 1 through 5, as well as the City of New York. The Complaint asserts claims under the First, Fourth, and Fourteenth Amendments, including excessive force, false arrest, racial profiling, retaliation, denial of medical care, and Monell liability.
What Began as a Family Ride Ends in Brutality
According to the complaint, Moody and her husband began their evening ride at Canarsie Pier, each operating a street-legal electric bicycle. Moody rode a Z6 Fly E-Bike, while her husband rode a Venom Fly E-Bike—neither of which requires registration, licensing, or insurance under New York law. While at the pier, they encountered two other individuals on motorcycles, and the group decided to head to Coney Island together. The plan was simple: Moody wanted to buy cotton candy for their five-year-old daughter, while the others planned to stop at Nathan’s Famous.
As they traveled, Moody and her husband followed the designated bike paths, while the motorcyclists took the highway route. By approximately 9:05 P.M., after retrieving the cotton candy, the group reunited near Surf Avenue and West 15th Street in Coney Island, chatting and exchanging contact information before preparing to leave.
At that moment, multiple NYPD officers—some in an unmarked vehicle and others on a police scooter—suddenly surrounded them. As indicated in the complaint, the officers aggressively approached without warning or legal justification. Officer Nieves allegedly snatched the e-bike keys from Moody’s ignition and demanded her license and registration. The complaint asserts that Moody had violated no law, and she calmly explained that her vehicle did not require documentation. Nevertheless, Lieutenant Lacalamita, the highest-ranking officer present, ordered her arrest without probable cause.
Tackled, Tased, and Thrown Face-First into a Police Vehicle
The complaint paints a harrowing picture of escalating brutality. After allegedly ordering Moody’s arrest without probable cause, Lacalamita watched as Officers Moran and Cordero tackled her to the ground. Officer Nieves attempted to tase her multiple times; when unsuccessful, he joined in physically restraining her. As Moody lay prone and handcuffed on the pavement, Moran stepped on her back and legs, while Nieves dug his knee and hands into her spine.
The officers then allegedly forced her face-first into the backseat of a patrol vehicle. During this, her foot became trapped in the doorframe. She screamed in pain, but officers ignored her cries for help before finally releasing her foot.
Adding to the trauma, Lieutenant Lacalamita allegedly berated Moody with racial slurs—calling her a “Black bitch,” attempting to slap and kick her, and ordering officers to “put that bitch in a cage.” She was then placed into another patrol car equipped with a prisoner partition and transported to the 60th Precinct, where the abuse continued.
Still handcuffed, Moody was brought before an unidentified desk officer. There, Lieutenant Lacalamita allegedly kicked her to the floor and stood over her yelling, “Get the f* up**,” while none of the officers present intervened. Despite the presence of a female officer, male officers conducted a full-body search, allegedly making inappropriate contact with Moody’s breasts, buttocks, thighs, and vaginal area. Her repeated demands to know the charges against her were met with silence.
Denied Medical Care, Misled at the Hospital, and Deprived of Property
Despite visible injuries—bleeding knees, torn clothing, and a dirt-covered body—Moody was allegedly denied medical attention for over five hours while detained at the 60th Precinct. Her repeated pleas to Officers Nieves and Cordero were ignored. Only after she refused to provide fingerprints were paramedics finally summoned.
Moody was transported to South Shore Brooklyn Hospital, where EMTs performed only a cursory evaluation. While in the resuscitation area, Lieutenant Lacalamita allegedly reappeared, lied about his identity, stating “I’m not him. I wasn’t there,” and fled when confronted. According to the complaint, Dr. Spencer Doblin Kim, the attending physician, refused to examine her, withheld discharge paperwork, and handed the documents to the NYPD escort instead of giving them to Moody herself. She only discovered the doctor’s identity later via a MyChart notification.
After her release from the hospital, Moody was returned to the 60th Precinct and later transferred to Brooklyn Central Booking, where the District Attorney declined to prosecute her case. However, the ordeal did not end there. Despite her charges being dropped, NYPD officers refused to return her property—including her Z6 Fly e-bike, phone, jewelry, ID, keys, and cash—even after she presented a DA-issued property release form. Instead, she was allegedly told the form was “meaningless” and was threatened with arrest if she did not leave the precinct.
A Pattern of Institutional Failure
The federal complaint does not isolate misconduct to a few rogue actors—it exposes systemic failures within the New York City Police Department in training, supervising, and disciplining officers with well-documented records of abuse. Each of the named officers in the lawsuit—Lieutenant Lacalamita, Sergeant Zubyk, and Officers Moran, Nieves, and Cordero—has been previously implicated in allegations of misconduct. Yet, the City of New York has continued to employ and promote them, emboldening unconstitutional policing.
Lieutenant Daniel Lacalamita, who allegedly directed and physically participated in the violent arrest of Keyanna Moody, has faced multiple CCRB complaints in past years, including allegations of abuse of authority and excessive force. The complaint states that Lacalamita’s use of racial slurs, physical violence, and retaliatory threats against Moody highlights a longstanding pattern of misconduct, exacerbated by the NYPD’s refusal to hold him accountable.
Sergeant Stanislav Zubyk allegedly stood by as a supervisor, watching the illegal arrest and use of force unfold without taking action. According to the lawsuit, Zubyk’s inaction reflects not only personal indifference but also a broader NYPD failure to empower supervisors to prevent or report unlawful conduct.
Officer Alvin M. Nieves, accused of initiating the stop by allegedly seizing Moody’s e-bike keys illegally, has a documented history of civil rights complaints, including alleged unlawful stops and unreasonable searches. The lawsuit states that Nieves attempted to tase Moody multiple times and later participated in violently restraining her, even as she screamed in pain with her foot caught in the patrol car door.
Officer Michael R. Moran is alleged to have stepped on Moody’s legs and shoved her into a police vehicle, later participating in a full-body search by male officers despite the presence of a female colleague. Past CCRB records cite Moran for use of force and discourtesy, and the complaint argues that his behavior toward Moody is part of a pattern of racial and gender-based abuse.
Officer Jared W. Cordero is accused of violently tackling Moody to the ground, ignoring her requests for medical care, and refusing to return her property even after she obtained a DA-issued release form. The lawsuit contends that Cordero’s conduct shows deliberate indifference to both constitutional rights and human dignity.
Despite these officers’ disciplinary histories and prior complaints, the City of New York continues to place them in active field roles, with supervisory backing. The lawsuit alleges that the NYPD has repeatedly ignored red flags, failed to remove problem officers, and allowed racial and gender bias to flourish unchecked.
This institutional failure, the complaint contends, is what made the violent and baseless arrest of Keyanna Moody not only possible but predictable.
A Pattern of Abuse: NYPD’s Troubling History of Civil Rights Violations
The misconduct alleged in Moody’s federal complaint is not an aberration—it reflects a deeply entrenched pattern of unconstitutional policing long associated with the New York City Police Department (NYPD). For decades, civil rights attorneys, independent monitors, and oversight bodies have documented pervasive problems involving racial profiling, excessive force, retaliatory arrests, denial of medical care, and unlawful stops, particularly targeting communities of color.
Ms. Moody’s experience—being tackled to the ground, called a racial slur, handcuffed, physically abused, denied medical care, and detained without cause—is emblematic of the broader institutional culture that the lawsuit seeks to expose. Her case follows a well-documented history in which Black and Latino New Yorkers are disproportionately targeted, with little to no accountability for officers who engage in misconduct.
This complaint does not merely assert individual wrongdoing. It highlights a systemic failure of supervision, training, and accountability, alleging that the City of New York has knowingly allowed officers with documented misconduct histories to continue policing without intervention, discipline, or retraining.
Notable Parallel Cases of NYPD Misconduct
The experiences described in Moody’s lawsuit mirror other high-profile NYPD misconduct cases that have drawn national attention:
Eric Garner (2014): Died after being placed in a banned chokehold by Officer Daniel Pantaleo while under arrest for allegedly selling untaxed cigarettes. The incident, captured on video as Garner repeatedly said “I can’t breathe,” triggered national protests. The City paid $5.9 million in a wrongful death settlement.
Delrawn Small (2016): Shot and killed in a Brooklyn road rage incident by off-duty Officer Wayne Isaacs within seconds of approaching Isaacs’ vehicle. Video evidence contradicted Isaacs’ self-defense claims. Although acquitted at trial, the case raised questions about internal NYPD discipline and prosecutorial accountability.
Kawaski Trawick (2019): Shot inside his own Bronx apartment by officers who entered without a warrant. Trawick was not a threat, and yet no meaningful discipline was imposed, raising concerns about NYPD responses to mental health crises and officer accountability.
Dounya Zayer (2020): Thrown to the ground by an NYPD officer during a protest in Brooklyn, suffering a traumatic brain injury. The incident was recorded and widely shared, prompting over 60 disciplinary findings against NYPD personnel for misconduct related to protests.
These incidents—like Moody’s—are not outliers. They are part of a systemic failure to uphold constitutional protections. In each case, officers acted outside department policy or legal limits, and supervisory failures allowed the misconduct to go unchecked.
NYPD Oversight Data Corroborates Systemic Abuse
The lawsuit draws on the findings of the Floyd Monitor’s 23rd Report—published as part of ongoing federal oversight under the Floyd v. City of New York litigation—to contextualize Ms. Moody’s experience. Among the report’s key findings:
Black New Yorkers accounted for 29.8% of all NYPD vehicle stops in Q4 2024, despite comprising only 22.7% of the City’s population;
White residents, who make up 35.9% of the population, were stopped only 17.8% of the time;
Neighborhood Safety Teams (NSTs) engaged in unconstitutional stops more than 25% of the time;
Supervisors approved 99.1% of all stop reports, regardless of their legality.
Moody’s encounter—initiated over an e-bike that did not legally require documentation—fits this pattern precisely. Her stop was not supported by probable cause, and her attempts to calmly assert her rights were met with retaliation, racial hostility, and force. The failure to discipline involved officers, despite clear violations of NYPD policies, reinforces the systemic failures identified in the Floyd Monitor’s review.
Legal Claims and Relief Sought
Moody’s federal lawsuit brings claims under the:
First Amendment (retaliation for asserting legal rights),
Fourth Amendment (unlawful seizure, excessive force),
Fourteenth Amendment (due process, equal protection, denial of medical care),
42 U.S.C. § 1983 (civil rights violations),
New York City Human Rights Law (NYCHRL) § 8-107(17) (racial profiling and discriminatory policing), and
Monell liability against the City of New York for failing to train, supervise, and discipline officers.
She seeks compensatory damages, punitive damages, declaratory relief, and attorneys’ fees and costs.
Eric Sanders: “We Will Not Be Silent”
Eric Sanders, Esq., of The Sanders Firm, P.C., who represents Ms. Moody, issued the following statement:
“What happened to Mrs. Moody is disgraceful. For doing nothing more than purchasing cotton candy for her child, she was dehumanized, brutalized, and unlawfully imprisoned by NYPD officers who acted with impunity. This lawsuit isn’t just about seeking justice for her—it’s about exposing the systemic rot that continues to define policing in communities of color. We demand accountability. We demand change.”
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