This Complaint alleges that police officers employed by the City of Sparks violated McNeely’s First and Fourth Amendment Constitutional rights to privacy and to be free from unlawful searches and seizures.

The evidence will establish that the officers were trained to act in precisely the manner they acted and, thus, were trained to do precisely the wrong thing. If the officers had been properly trained in the fundamental principles of search and seizure and safekeeping private information, this incident would not have happened. In short, the officers’ actions were contrary to proper police practices.

Sparks police engaged in deliberate and wrongful conduct and compromised police protocol violating McNeely’s constitutional rights for the purpose of promoting and engaging in a sensational story with a public figure; to wit, Reno City Mayor Hillary Schieve.

The complaint further alleges that the defendants abused administrative subpoenas to illegally obtain information regarding McNeely’s private investigation and tracking of Mayor Schieve and notes that the defendants could not legally obtain a search warrant without probable cause, yet bypassed the constitutional requirements to obtain and disseminate McNeely’s information.

Despite the fact that the detectives concluded that McNeely acted lawfully during his investigation of Mayor Schieve, the complaint charges that the willful, unlawful dissemination of his identity as a private citizen caused irreparable harm to McNeely’s life and livelihood.