Keystone Kops Complaint Against DEA

     HOUSTON (CN) - DEA agents busted down a family's door, knocking out the homeowner and causing his wife to have an epileptic seizure, then apologized for raiding the wrong house, the couple claims in court.
     Guillermo and Alejandra Ramirez sued the United States of America in Federal Court.
     The Ramirezes say DEA agents showed up at their house in the early morning hours of June 9, 2010.
     "Plaintiffs (spouses) and their children were asleep at their home in Sullivan City, Texas when plaintiffs and their children awoke to a loud noise at the front door of the house," the complaint states.
     "Plaintiff, Guillermo Ramirez, immediately went to the front door to investigate the commotion. He reached to unlock and open the front door to respond to federal agents outside. Federal law enforcement agents, without a valid or lawful arrest or search warrant, without consent to enter or search the home from plaintiffs or any person with authority to consent, and without lawful authorization or justification rammed open the door with such force as caused the door frame to break and the door to blow open.
     "The door struck plaintiff, Guillermo Ramirez, on the head, lacerating his head above the eye and knocking him to the floor for a period of lost consciousness.
     "Federal agents conducted an unlawful search of the home and seized every person in the home, namely plaintiffs and their children, at gunpoint." (Parentheses in complaint.)
     Alejandra Ramirez says the officers refused to let her leave the house even after securing the scene.
     "The raid and the events that occurred during the raid placed plaintiff, Alejandra Ramirez, in imminent fear for her safety and that of her children and husband, to such a degree that the raid induced an epileptic seizure and/or loss of consciousness," the complaint states.
     The couple says their children "were also traumatized and placed in fear for their safety during the raid." (Graph 11)
     After the raid, the couple says, the officers admitted they raided the wrong house and apologized.
     They seek more than $3 million in damages for assault, false imprisonment, bodily injury, negligent investigation and negligent surveillance.
     Guillermo Ramirez says he lost his job due to injuries he suffered during the raid.
     "Plaintiffs lost the financial ability to pay for the home that they lived in at the time of the raid; and plaintiffs no longer live at the residence," the complaint states.
     The Ramirezes are represented by R.W. Armstrong of Brownsville.