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Hales v. Newport News — pleading opinion, Doc. 17

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4 Although Plaintiff repeatedly ―begged‖ Officer Brig gs to remove or loosen the handcuffs, Officer Briggs ―ign ored her requests, and [Plaintiff] was placed in a holding c ell and left in handcuffs for approximately thirty (30) minutes. ‖ Id. ¶ 12. Thereafter, ―upon appearing before the Magistrate, the handcuffs were removed.‖ Id. Plaintiff was charged in state court with ―assault and batter,‖ was released on bond, and her criminal charge was ultimately dismissed. Id. ¶ 13. As a r esult of plaintiff‘s arrest and Briggs‘ use of excessively t ight handcuffs, Plaintiff ―sustained serious physical in juries and permanent injuries,‖ requ ired and will in the future require doctor and hospital expenses, became ―lame, sick an d disabled,‖ and lost ―time and income from her gainful employme nt.‖ Id. ¶ 32. II. PROCEDURAL HISTORY Plaintiff filed her Complaint in the Circuit Court for the City of Newport News, Virginia, on or around Decemb er 28, 2010, alleging causes of action for: (1) deprivation of c ivil rights under color of state law; (2) intentional inflictio n of emotional distress; (3) assault; (4) battery; (5) f alse imprisonment; (6) negligence and/or gross negligenc e; and (7) violation of constitutional rights pursuant to 42 U .S.C. § 1983. Plaintiff seeks $100,000 in compensatory damages an d $300,000 in
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