'Your Grandma Sells Crack'

     CHICAGO (CN) - Chicago police terrorized six children in the wrong apartment, demanding at gunpoint that an 11-month-old show his hands, and telling one child, "This is what happens when your grandma sells crack," the family claims in court.
     Lead plaintiffs Charlene and Samuel Holly sued Chicago, police Officer Patrick Kinney and eight John Does in Federal Court, on their own behalves and for their children and children.
     The six children were 11 months to 13 years old at the time. Plaintiffs Connie and Michelle Robinson are Charlene Holly's daughters.
     The complaint states: "On November 29, 2012 in the early evening hours Charlene Holly was in the first floor apartment at 10640 S. Prairie in the front room helping minor Child #1, Child #2, Child #4, and Child #5 rehearse songs for their church choir. Charlene was also caring for Child #3, who was 11 months old. Child #6 was in the upstairs apartment alone.
     "Charlene and the children heard a loud boom outside and a voice cry out 'Across the street!'
     "Defendant Officers John Doe 1-8 burst through the door to the first floor apartment dressed in army fatigues and pointing guns at Charlene and the children. The officers yelled at Charlene and the children to 'Get on the ground!' The officers referred to Charlene and the children as 'm---f---ers' numerous times.
     "Afraid of the guns being pointed at them, Children #1, 2, 4, and 5 ran to a back bedroom in fear of the officers. In response to the defendants' order to 'Get on the ground!,' Charlene got down on the floor. A defendant Officer told Charlene to 'Put the baby down' so Charlene set Child #3 down beside her. The officers yelled at Charlene to get Child #3's hands where they could see them.
     "After attempting to show the officers that the eleven-month-old's hands were empty, Charlene asked the officers 'What is this about?' To which they replied 'Shut the f--- up.'"
     Samuel Holly says he asked the police what they were doing, and called the 111th Street police station asking for a "white shirt" to come explain the situation, but no supervisor ever came to the house.
     "Charlene continually asked what the purpose of the detention was," the complaint states. "Finally, an officer produced a warrant and handed it to Charlene. The warrant was for an individual named 'Sedgwick M. Reavers' and the premises listed was 'The second floor apartment located at 10640 S. Prairie Ave. A yellow brick two flat building with the numbers 10640 on the front of the building.' In other words, the warrant clearly identified the proper location as the second floor apartment. Charlene, Samuel, and the children were in the first floor apartment.
     "As the officers were detaining Charlene, Samuel, and Children #1-5 in the first floor apartment, they also proceeded to the second floor apartment, where Child #6 was home alone. Child #6 was 13 years old at the time of the incident.
     "The officers approached Child #6 in a bedroom and turned out the lights. They began flashing red lights at the child, calling him 'm-f---er,' placing him in plastic handcuffs and telling him 'I started to Tase your grandmother and cousins' and 'This is what happens when your grandma sells crack.' Child #6 begged the police not to hurt his family in the apartment below and stated that his grandmother did not sell crack."
     The man named in the warrant, Sedgwick Reavers, "was sitting in a squad car outside of 10640 S. Prairie throughout the entire incident," according to the complaint.
     The family claims that "the following day Charlene discovered the family dog, Samson, not in the basement where the family kept him, but in an upstairs laundry room. Samson could not have reached the laundry room without human assistance. On information and belief, defendant Officers dragged and choked Samson from the basement with the dog pole and left him in the upstairs laundry room unattended, where he died."
     Samuel Holly also went to the police station the day after the warrantless search to complain, but "despite his numerous calls the night before, was told that he could not make a complaint and he 'should have made a complaint last night," the family says.
     They seek punitive damages for unlawful detention, unreasonable seizure, excessive force, conspiracy, unlawful search, assault and battery, and emotional distress.
     They are represented by Theresa Kleinhaus with the Law Office of Standish Willis.