OF THE
TIMES
"Plaintiff raised his arms in the air and told defendants Vagnini and Martinez that he did not have anything on him," Mukes says in the complaint.
"Defendant Vagnini patted down plaintiff's pants pockets without plaintiff's consent, found approximately $50, and said, 'This is drug money.'
"Defendants Vagnini and Martinez each grabbed one of plaintiff's arms and defendant Martinez said, 'Maybe it's in his adult diaper.'
"Defendant Martinez, who had no probable cause or reasonable suspicion that plaintiff possessed drugs or contraband on or about his person, reached his hand inside plaintiff's adult diaper, and groped plaintiff's genitals.
"Plaintiff did not have any drugs or contraband in his adult diaper or anywhere on his person.
"Defendant Martinez is not a health care professional, and he conducted the invasive and unreasonable search in an unsafe, unhygienic, and intentionally humiliating fashion, in a public thoroughfare, with no privacy."