A Limited Liability Company

April 7, 2022

VIA CERTIFIED MAIL

Mr. Merrick Garland, United States Attorney General
United States Department of Justice
950 Pennsylvania Avenue, NW
Washington, DC 20530-0001

RE: URGENT MATTER- DEATH OF STANLEY DAVIS, III

Dear Mr. Garland,

Benjamin Crump, Esquire with Ben Crump Law, PLLC, Jasmine Rand, Esquire with Rand
Law, L.L.C., and Sue-Ann Robinson, Esquire with Frontline Law have been retained to represent
Shannon Thompson, natural mother and next of kin of Stanley Davis, III, and Stanley Davis, Jr.,
natural father and next of kin of Stanley Davis, III, against the City of Boynton Beach and Officer
Mark Sohn for causing the death of their son Stanley Davis, III, on December 26, 2021. Officer
Sohn, Boynton Beach Police Department, and the City of Boynton Beach violated our client’s
Fourteenth Amendment of the United States Constitution based upon racial discrimination, and
his right to be free of unlawful search and seizure and the use of excessive force pursuant to the
Fourth Amendment of the United States Constitution. To wit, Officer Mark Sohn conducted an
unlawful high-speed police chase that caused the death of our client, 13-year-old Stanley Davis,
III. Our offices seek the intervention of the United States Department of Justice as this is the third
death of an African American citizen caused by Officer Mark Sohn by conducting a high-speed
police chase, the Boynton Beach Police Department made several findings in the past that he
violated the department’s high speed pursuit policy, he also used racial slurs in the past to refer to
persons of African descent, and has been caught on video using excessive force against two fully
restrained African American men. As such, the City of Boynton Beach has consistently ratified
the violations of African American citizens’ constitutional rights. Moreover, in 2017 a Boynton
Beach Police Department officer was convicted criminally for using excessive force during a high-
speed chase and sentenced to jail time. The Boynton Beach Police Department has a long history
of violating the constitutional rights of its African American citizens, engaging in racist policing,
using excessive force on African Americans, and conducting high speed police chases that result
in the death of African American citizens.

Stanley Davis, III was a 13-year-old African American minor child who was unlawfully
chased in a high speed and/or reckless pursuit by a Boynton Beach Police Department officer
Mark Sohn. Officer Sohn caused a fatal crash resulting in the minor child’s death on December
26, 2021. Stanley Davis, III, or “SJ” was the light of his parents’ life and the type of child a
parent dreams about raising. When SJ was only four-years-old he was elected Valedictorian of
his pre-school class “Tiny Tots.” SJ then attended Galaxy Elementary where he earned his way
onto the Honor Roll and received a scholarship from Teamwork USA. He was nominated for
student of the week for eight weeks in a row and then student of the month. SJ was an incredible
mathematician. He was kind and charismatic and received an award for citizenship and received
an honorable character award. SJ’s parents made sure he had a perfect attendance record. He
began attending Congress Middle School where he was currently in 7th grade, continued to excel
in academics, he played football, baseball, and was on the drumline. SJ was selected as an MVP
and Homecoming King twice. SJ should have had so many more opportunities to become
Homecoming King, but instead, his life was cut short on December 26, 2021, and his parents
were left to plan his final homecoming services on January 8, 2022. SJ was destined for
greatness. On December 26, 2021, Boynton Beach police officer Mark Sohn cut his life short
and turned everyone of SJ’s dream into his parents’ nightmare.

On December 26, 2021, the day after Christmas, SJ was riding his dirt bike and went to
the gas station down the street from his house to fill up his gas tank. As SJ began to drive home
the notorious Mark Sohn conducted an unlawful high-speed pursuit of SJ which caused him to
crash and subsequently die. As thirteen-year-old SJ lay on the ground, blood pouring from his
body, and his life slipping away, Officer Mark Sohn did not even attempt to render any life-
saving treatment, CPR, or check his pulse to see if he was alive. Prior to this incident, Officer
Mark Sohn had already caused the death of two other innocent people before SJ, like five-year-
old Jayden Reardon in 2016. Officer Mark Sohn also killed thirty-eight-year-old African
American male Cyrus Deal during an unlawful highspeed pursuit in 2012. Boynton Beach
Police Department sustained a finding that he lied about pursuing Cyrus Deal, that he engaged in
an unlawful high-speed pursuit, he and that he had no justifiable cause to pursue Cyrus Deal.
The investigation into the Cyrus Deal high speed pursuit reveals that when Officer Sohn was
asked what crimes Cyrus Deal committed leading to pursuit he said, “nothing really.” Officer
Sohn’s employment file memorialized his callous disregard for Black life in an email he sent that
revealed that he used his time-off to take a “vacation” and enjoy his birthday. Boynton Beach
Police Department even allowed Officer Sohn to choose his suspension day and use it like a
vacation. Officer Sohn’s email read: “I guess I will take July 5th as my suspension day so I can
spend my birthday at home with my family.” As Officer Sohn celebrated the day he was born,
Cyrus Deal’s family grieved the day their son died.

The City of Boynton Beach police department’s pursuit policy is as follows: “A police
chase is to be initiated only if the person fleeing has committed a forcible felony such as a
murder, manslaughter, sexual battery, carjacking, home-invasion robbery, arson or kidnapping.”
In the instant matter, there is no way Boynton Beach Police Department can justify Officer
Sohn’s unlawful high-speed pursuit of SJ, a 7th grader on a dirt bike. Officer Sohn and the City
of Boynton Beach have a history, a preexisting pattern and practice and/or custom and policy of
conducting unlawful high-speed police chases resulting in death: i.e., violating citizens
constitutional right to be free of unlawful search and seizure and excessive force under the
Fourth Amendment to the Constitution of the United States. Officer Sohn and the City of
Boynton Beach have a history, a preexisting pattern and practice and/or custom and policy of
racially biased policing violating the Fourteenth Amendment of the Constitution of the United
States. The pattern and/or practice and/or custom and policy of the Fourth and Fourteenth
Amendment constitutional violations was the moving force behind the constitutional violations
of SJ. The City of Boynton Beach’s failure to fire Officer Sohn after admitting to conducting a
high-speed chase in 2012 that caused the death of Cyrus deal, its failure to fire Officer Sohn after
conducting a high-speed chase in 2016 that caused the death of Jayden Reardon, and its failure to
fire Officer Sohn for causing the death of a third person, SJ, in 2021 demonstrates that the City
of Boynton Beach ratifies his unlawful misconduct.

Officer Mark Sohn was unqualified to become a law enforcement officer for the Boynton
Beach Police Department from day 1 when he was hired in 2002. Officer Sohn’s training file
reveals that by 2003 while still in training his supervisors informed him that his performance as a
probationary officer has not met the basic required standards to maintain his status as a full-time
police officer, and he had two weeks to bring his deficiencies up to standards and become
proactive in his policing. Officer Sohn’s file reveals a slew of disciplinary actions for
insubordination, 6 unlawful vehicular pursuits (3 of which resulted in death), 5 car crashes, and
an act of overt racism for referring to a street as: “Stone Haitian Drive.” Moreover, our clients
have learned that there is a video of him beating a restrained Black male who has an ongoing
case against Officer Sohn and Boynton Beach Police Department. Our clients have also learned
that there is also a video of Officer Sohn unleashing a dog on a restrained Black male named
Patrick McFadden that caused him permanent injury. In addition, there is the infamous video of
Officer Sohn pulling his supervisor Michael Johnson over for speeding in 2018. Michael
Johnson was driving 97 in a 65 and Officer Sohn failed to give him a citation and the officers
engaged in a verbal altercation on camera. Major Michael Johnson then pulled Officer Sohn
over for a traffic violation in a display of unlawful use of power and unprofessional misconduct
not becoming an officer. The incident came to the attention of the City Manager, and she failed
to terminate the employment of either officer for their misconduct and misuse of power, and
instead assisted in a coverup of unlawful policing.

Officer Sohn’s employment file reflects the following timeline of his misconduct. (Note:
several incidents are notably absent from his file, including but not limited to him beating the
restrained Black male caught on video and the investigation file of Jayden Reardon):

2002-Mark Sohn hired by Boynton Beach PD. Disciplined for neglect of duty.

August 16, 2002- neglect of duty for accidentally discharging his shotgun in police vehicle.

July 16, 2002- Verbal counseling was issued for care of department issued equipment after he
accidentally dropped his lap top computer.

October 25, 2002- A verbal reprimand was issued for neglect of duty; for failing to respond to a
back-up officer after advising he was enroute and arrived twenty-three minutes later.

2003- Several documented deficiencies and disciplinary issues.

January 18, 2003- A verbal counseling was issued for violating Communication Regulations
(Inappropriate Transmission Index Code 1100 # IV A) for using overtly racist language. Officer
Sohn on main channel responded to police dispatch when called upon, that his current location
was "STONE HAITIAN DRIVE."
February 11, 2003- Officer Sohn was counseled in the presence of Lt. Briganti, Sgt. Broberg
and Sgt. Rodriguez, informing him that his performance as a probationary officer has not met the
basic required standards to maintain his status as a full-time police officer. Officer Sohn was
informed that he has two weeks to bring his deficiencies up to standards and become proactive in
his policing. Officer Sohn stated that he understood and would make every effort to become
proficient.

January 20, 2004- Officer Sohn was suspended for 57.5 hours after he and two officers
participated in an illegal pursuit. Police Chief Marshall Gaze stated the officers endangered
other drivers when they ignored orders to stop pursuit of a stolen vehicle.

October 2004- Officer Sohn received a written reprimand for insubordination and an expletive
filled rant when he was approached about missing a training, became so loud one sergeant left a
briefing to assist several others that reported that: “Sohn was getting out of hand.” The report
stated he was still angry about the week-long suspension he received for conducting chase in
January 2004.

March 2007- Officer Sohn rear-ended Palm Beach County Sheriff’s car when distracted.

January 9, 2009- Officer Sohn violated code by having chargeable car crash.

July 19, 2010- Officer Sohn had unsatisfactory performance with a vehicle pursuit and
apprehension in violation of pursuit policy.

September 29, 2010- Officer Sohn had an at fault car crash.

May 4, 2011- Officer Sohn received written warning for unbecoming conduct.

September 29, 2011- Officer Sohn got in trouble for unauthorized lighting he had installed in his
vehicle.

July 1, 2012- Caused Death of Cyrus Deal- 38 Year-Old Black Male. Officer Sohn
conducted high speed police chase at 100 mph. He lied when first interviewed. His supervisor
Sergeant Henry Diehl stated he believed he was lying and engaged in high-speed pursuit.
Eventually Officer Sohn admitted to the high-speed pursuit. When asked during investigation
what crimes Cyrus Deal committed leading to pursuit he said, “nothing really.” The police report
stated the decision to pursue created more of a dangerous situation than if the suspect remained
at large, and the high-speed pursuit charge was sustained. Boynton Beach found a violation of
pursuit policy and he was suspended for 11.5 hours. Officer Sohn sent an email stating, “I guess
I will take July 5th as my suspension day so I can spend my birthday at home with my family.”

October 2014- Officer Sohn received a verbal reprimand after found to be disrespectful in an
email to Maj. Suzanne Gitmo regarding K-9 partner and for not following chain of command.

May 23, 2015- Officer Sohn was engaged in a traffic related crash with a police vehicle.
June 4, 2014- Officer Sohn was suspended for a day for violating policy on vehicular pursuit.

October 2015- Officer Sohn was suspended for insubordination and intentional undermining
during open roll call he was using knife blade to dig into taser around others. He was told to put
it away. He continued to take it out and refused to comply with orders. Officer Sohn was given
a two-day suspension initially; however, Major Thomas Wallace reviewed his file and
recommended a 40-hour suspension without pay referring to 3 other incidents of insubordination.
He was ultimately given two-day suspension and a 90-day improvement plan he had to follow to
remain on the force. Officer Sohn served suspension in November 2015.

February 13, 2016, death of 5-Year-Old Black Boy Jayden Reardon- Officer Sohn conducted
high speed pursuit, the vehicle he was pursing struck Jayden Reardon and killed him. Jayden
was walking to the part with his 2-year-old brother and grandparents. Officer Sohn conducted a
high-speed chase down a narrow two-lane road in residential area with a nearby school. There is
a pending wrongful death lawsuit.

September 2017- Officer Sohn pulled Patrick McFadden over in Broward County and as he was
surrendering Officer Sohn ordered a dog to attack him and he suffered permanent injury. The
incident was not investigated by the Internal Affairs Unit.

October 2017- Officer Sohn crashed patrol vehicle while searching for robbery suspect

December 26, 2021- Officer Sohn conducted an unlawful high-speed pursuit of Stanley Davis,
III causing his death.

The above timeline makes clear that Officer Sohn frequently engaged in unlawful high-
speed pursuits of Black people and in predominately Black communities resulting in death,
violating citizens Constitutional rights pursuant to the Fourth and Fourteenth Amendments,
respectively. The Boynton Beach Police Department and City of Boynton Beach were on actual
notice of the danger her posed to citizens generally, and Black citizens specifically. In 2004
Police Chief Marshall Gaze stated that he, “endangered other drivers when they ignored orders to
stop pursuit of a stolen vehicle,” and suspended him for 57.5 hours. In 2010 Officer Sohn had
unsatisfactory performance with a vehicle pursuit and apprehension in violation of pursuit policy
but did not receive a suspension despite this being his second violation. In 2012, Officer Sohn
conducted an unlawful high-speed pursuit that caused the death of Cyrus Deal; and the
investigation report stated the decision to pursue created more of a dangerous situation than if the
suspect remained at large and the high-speed pursuit charge was sustained. Officer Sohn was
only suspended for 11.5 hours for conducting an unlawful pursuit that caused death, versus his
prior 57.5 hour suspension for unlawful pursuit that did not result in death. In 2014 he engaged
in a fourth documented pursuit and was suspended for one day or only 8 hours. In essence,
Officer Sohn’s punishment for conducting high speed pursuits lessened each time instead of
escalating to harsher disciplinary measures. In 2016 Officer Sohn conducted a high-speed police
chase that caused the death of 5-year-old Jayden Reardon, it is unknown whether he was
disciplined at all. In 2021 Officer Sohn conducted a high-speed police chase that caused the
death of 13-year-old Stanley Davis, III, it is unknown whether he was disciplined at all.
 The Boynton Beach Police Department and City of Boynton Beach police officers have a
pattern and practice and/or custom and policy of conducting high-speed police chases and the use
of excessive force. In 2017 a Boynton Beach police officer Mike Brown was found guilty of
criminal charges for using excessive force on an unarmed Black man Jeffrey Braswell who was a
passenger in a high-speed police chase in 2014. Initially, two current and two former Boynton
Beach police officers were arrested for their involvement in the incident: Philip Antico, Michael
Brown, Ronald Ryan, and Justin Harris. There was a federal investigation into the incident as
well. The incident was captured on Palm Beach County Sheriff’s Office helicopter footage.

In 2011, three Boynton Beach police officers were arrested over a three-day period.
Officer Alex Lindsey lied on a police report about how he recovered evidence. In 2011, two
other officers Michael Mulcahy and Michael Arco were arrested for lying on a police report. As
the case progresses, our offices will request and obtain all prior founded and unfounded cases
wherein officers used excessive force, conducted unlawful vehicular pursuits, engaged in racially
biased policing, and engaged in misconduct.

On behalf of our clients Stanley Davis, Jr. and Shannon Thompson, we implore the United
States Department of Justice to conduct an independent investigation into the actions, omissions,
and civil rights violations of the City of Boynton Beach and Boynton Beach Police Department
Officer Mark Sohn for causing the death of their son Stanley Davis, III, for causing the death of
two other African American citizens by conducting unlawful high-speed pursuits, for using
document racial slurs against persons of African descent, and for using excessive force against
restrained African Americans. If you have any questions please feel free to contact me at
jasminerand@gmail.com or (706) 424-1027.

Respectfully,

/s/ Jasmine Rand______

Jasmine Rand, Esquire
RAND LAW, LLC

/s/ Benjamin Crump_____

Benjamin Crump, Esquire
BEN CRUMP LAW, PLLC

/s/ Sue-Ann Robinson

Sue-Ann N. Robinson, Esq.
Robinson Caddy