Oxford Lawsuit

Geoffrey Fieger
Press Release
FIEGER FILES $100 MILLION DOLLAR SUITS
AGAINST OXFORD SCHOOL DISTRICT
OFFICIALS
Nationally known attorney Geoffrey Fieger will hold a press conference today at 11:00 a.m. today
at his law offices located at 19390 West Ten Mile Road, Southfield, M 48075. He will discuss the
filing of two $100 Million lawsuits against the Oxford Community School District and various
school employees as a result of the massacre on November 30, 2021. The suits are filed on behalf
of a child who was shot in the neck during the rampage, and her sister who was next to her when
she was shot. Photo ops will be available with the parents.
For further information please contact:

Samantha Teal
Legal Assistant to Geoffrey N. Fieger
E: [email protected] P: 248.355.5555
(30)
{01208980.DOCX}
Case 2:21-cv-12871-MAG-APP ECF No. 1, PageID.1 Filed 12/09/21 Page 1 of 46
UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
_______________________
19390 WEST TEN MILE ROAD • SOUTHFIELD MICHIGAN 48075 • TELEPHONE (248) 355-5555 • FAX (248) 355-5148
JEFFREY FRANZ and BRANDI FRANZ, as

• A PROFESSIONAL CORPORATION
NEXT FRIEND For RILEY FRANZ, a Minor,

and JEFFREY FRANZ and BRANDI FRANZ,
as NEXT FRIEND For BELLA FRANZ, a
Minor,
Case No.:
Plaintiffs, Hon.
Vs.
OXFORD COMMUNITY SCHOOL DISTRICT,

SUPERINTENDENT TIMOTHY THRONE,
PRINCIPAL STEVEN WOLF, DEAN OF
STUDENTS RYAN MOORE, COUNSELOR
FIEGER, FIEGER, KENNEY & HARRINGTON, P.C.
#1, COUNSELOR #2, STAFF MEMBER,

TEACHER #1 and TEACHER #2
In their Individual Capacity,
Defendants.
GEOFFREY N. FIEGER (P30441)
JAMES J. HARRINGTON (P65351)
ROBERT G. KAMENEC (P35283)
NORA Y. HANNA (P80067)
MILICA FILIPOVIC (P80189)
Fieger, Fieger, Kenney & Harrington, P.C.
Attorneys for Plaintiffs
19390 West Ten Mile Road
Southfield, MI 48075
P: (248) 355-5555
F: (248) 355-5148
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
COMPLAINT AND DEMAND FOR JURY TRIAL
NOW COME Plaintiffs, JEFFREY FRANZ and BRANDI FRANZ, as Next
Friends of RILEY FRANZ, a Minor and BELLA FRANZ, a Minor, by and through
their attorneys, FIEGER, FIEGER, KENNEY & HARRINGTON, P.C., and for
Plaintiffs’ Complaint and Jury Demand against the above-named Defendants, state
as follows:
INTRODUCTION
On November 30, 2021, horrific events took place at Oxford High School
which resulted in the slaughter of four (4) high school students and serious gunshot
and psychological injuries to others. The horror of November 30, 2021 was entirely
preventable. Each and every Defendant named herein created and increased the
dangers then-existing at Oxford High School.
The individually named Defendants are each responsible through their actions
for making the student victims less safe. The Oxford High School students, and
Plaintiffs in particular, would have been safer had the Individual Defendants not
taken the actions they did.
The Oxford Community School District is responsible for having a
Constitutionally deficient policy, custom and practice that was a driving force behind
the constitutional violations. Further, said school district ratified the unconstitutional
actions of the individually named Defendants.
2
JURISDICTION AND VENUE

1. This action arises under the United States Constitution and under the
laws of the United States Constitution, particularly under the provisions of the
Fourteenth Amendment to the United States Constitution and under the laws of the
United States, particularly the Civil Rights Act, Title 42 of the United States Code,
Sections 1983 and 1988, and under the statutes and common law of the State of
Michigan.
2. This Court has jurisdiction pursuant to 28 U.S.C. §§ 1331, 1343 (a)(3),
1343(a)(4) and 42 U.S.C § 1983.

3. The actions alleged in this Complaint took place within Oakland
County, State of Michigan, and as such, jurisdiction lies in the United States District
Court for the Eastern District of Michigan (Southern Division).
4. Venue is proper pursuant to 28 U.S.C. §1391(d).
5. The amount in controversy exceeds One Hundred Million
($100,000,000) dollars, excluding interests, costs, and attorneys’ fees.
PARTIES
6. Plaintiffs hereby reincorporate and reassert each and every allegation
set forth in the previous paragraphs of this Complaint as if fully set forth herein.
7. At all times relevant hereto, Plaintiffs’ Minor, RILEY FRANZ, was a
resident of the City of Leonard, County of Oakland, State of Michigan.

3
8. At all times relevant hereto, Plaintiffs’ Minor, BELLA FRANZ, was a
resident of the City of Leonard, County of Oakland, State of Michigan.

9. At all times relevant hereto, JEFFREY FRANZ and BRANDI FRANZ

are the biological parents of RILEY FRANZ, a Minor, and BELLA FRANZ, a
Minor, and are residents of the City of Leonard, County of Oakland, State of
Michigan.
10. At all times relevant Plaintiffs’ Minors RILEY FRANZ and BELLA
FRANZ were students at Oxford High School in 12th and 9th grade respectively.
11. Plaintiffs’ Minor, RILEY FRANZ, was an honor roll student preparing
to enter college. Plaintiffs’ Minor, BELLA FRANZ, was a star athlete getting ready
for driver’s training.
12. At all times relevant hereto, Defendant, OXFORD COMMUNITY
SCHOOL DISTRICT, was and is a municipal corporation, duly organized and
carrying out functions in the Township of Oxford, State of Michigan. Its functions
include: organizing, teaching, operating, staffing, training, and supervising the staff,
counselors, and teachers at Oxford High School.
13. Upon information and belief, at all times relevant hereto, Defendant,
TIMOTHY THRONE, (hereinafter referred to as “THRONE”) is a citizen of the
State of Michigan and was acting under the color of state law within the course and
scope of his employment as Superintendent of the OXFORD COMMUNITY
SCHOOL DISTRICT.
4
STEVEN WOLF, (hereinafter referred to as “WOLF”) is a citizen of the State of

Michigan and was acting under the color of state law within the course and scope of
his employment as a Principal for Oxford High School within the OXFORD
COMMUNITY SCHOOL DISTRICT.
RYAN MOORE, (hereinafter referred to as “MOORE”) is citizen of the State of
Michigan and was acting under the color of state law within the course and scope of
his employment as a Dean of Students for Oxford High School within the OXFORD

COUNSELOR #1, (hereinafter referred to as “COUNSELOR #1”) is a citizen of
the State of Michigan and was acting under the color of state law within the course
and scope of his/her employment as a counselor at Oxford High School located in
the OXFORD COMMUNITY SCHOOL DISTRICT.
COUNSELOR #2, (hereinafter referred to as “COUNSELOR #2”) is a citizen of the
State of Michigan and was acting under the color of state law within the course and
scope of his/her employment as a counselor at Oxford High School located in the
OXFORD COMMUNITY SCHOOL DISTRICT.
5
STAFF MEMBER, (hereinafter referred to as “STAFF MEMBER”) is a citizen of

the State of Michigan and was acting under the color of state law within the course
and scope of his/her employment as a staff member at Oxford High School located
in the OXFORD COMMUNITY SCHOOL DISTRICT.
TEACHER #1, (hereinafter referred to as “TEACHER #1”) is a citizen of the State
of Michigan and was acting under the color of state law within the course and scope
of his/her employment as a teacher at Oxford High School located in the OXFORD

TEACHER #2, (hereinafter referred to as “TEACHER #2”) is a citizen of the State
of Michigan and was acting under the color of state law within the course and scope
of his/her employment as a teacher at Oxford High School located in the OXFORD
FACTUAL STATEMENT
21. Plaintiffs hereby reincorporates by reference and reasserts each and
every allegation set forth in the previous paragraphs of this Complaint as if fully set
forth herein.
22. Plaintiffs’ Minor, RILEY FRANZ, is a 17-year-old female senior at
Oxford High School.

6
23. Plaintiffs’ Minor, BELLA FRANZ, is a 14-year-old female freshman
at Oxford High School.

24. Ethan Crumbley was a 15-year-old male sophomore at Oxford High

School at the time of the incident.
25. On November 30, 2021, Ethan Crumbley brought a Sig Saur 9mm
semi-automatic handgun to Oxford High School and opened fire slaughtering
students, resulting in the death of four (4), and seriously injuring six (6) other
students and a teacher.
26. Upon information and belief, in the days leading up to the November
30, 2021, incident, Ethan Crumbley, acted in such a way that would lead a reasonable
observer to know and/or believe that he was planning to cause great bodily harm to
the students and/or staff at Oxford High School.
27. By way of example, and not limitation, previous to the November 30,
2021 incident, Ethan Crumbley posted countdowns and threats of bodily harm,
including death, on his social media accounts, warning of violent tendencies and
murderous ideology prior to actually coming to school with the handgun and
ammunition to perpetuate the slaughter.
28. For example, a threat on social media included an update to his twitter
account the night before which read, “Now I am become Death, the destroyer of
worlds. See you tomorrow Oxford.”
7
29. On or about November 16, 2021, days prior to the actual incident,
multiple concerned parents provided communications to Defendant WOLF with

concerns about threats to students made on social media.

30. The parents’ communications to WOLF in part stated, “I know it’s been
investigated but my kid doesn’t feel safe at school," "He didn’t even want to go back
to school today."
31. That same day, November 16, 2021, WOLF emailed parents indicating,
"I know I'm being redundant here, but there is absolutely no threat at the HS…large
assumptions were made from a few social media posts, then the assumptions evolved
into exaggerated rumors."

32. Defendants THRONE and WOLF reviewed the social media posts of
Crumbley prior to November 30, 2021, which threated Oxford High School students.
33. Defendants THRONE and WOLF had actual knowledge of concerns
from parents of students at Oxford High School as well as the students at Oxford
High School.
34. Despite the posts and knowledge of threats of violence, Defendant
THRONE sent correspondence and emails to parents at Oxford High School
reassuring them that their children were safe at Oxford High School.
35. Following the November 16, 2021, email exchanges and other
communications from Defendant WOLF to the parents of Oxford High School
students, Superintendent THRONE warned the students, via loudspeaker, to stop

8
spreading information over social media and to stop relying on information on social
media, reiterating that there were no threats that posed any danger to students at
Oxford High School.

36. At all times relevant hereto, Defendant THRONE, while acting as the
Superintendent of OXFORD COMMUNITY SCHOOL DISTRICT, discouraged
students and parents from reporting, sharing, or otherwise discussing the threatening
social media posts.
37. At all times relevant hereto, Ethan Crumbley’s Instagram and other
social media accounts were not set to private and were available to the public,
including Defendants.
38. Defendants THRONE, WOLF, and other employees and/or agents of
OXFORD COMMUNITY SCHOOL DISTRICT had knowledge of threats made to
the students, including Plaintiffs’ Minors RILEY AND BELLA FRANZ.
39. At all times relevant hereto, Plaintiff Minors were safer before
Defendant THRONE took action and advised each and every student, including
Plaintiff Minors, that there was no credible threat. By virtue of Defendant
THRONE’s actions, he substantially increased the harm to Plaintiffs’ Minors.
40. Defendant THRONE knew and/or should have known, that his
announcement to the students at Oxford High School would discourage the students
and/or their parents from reporting credible threats of bodily harm to teachers,
counselors, and staff of Oxford High School.

9
41. At all times relevant, Plaintiffs’ Minors were safer before Defendant
WOLF took the actions described and advised each and every student, and parents,
including Plaintiffs, that there was no credible threat at Oxford High School. By
virtue of Defendant WOLF’s actions, he substantially increased the harm to
Plaintiffs’ Minors.
42. Defendant WOLF knew and/or should have known that his assurances
that social media threats were not credible would discourage the students and/or their
parents from reporting credible threats of bodily harm to teachers, counselors, and
staff of Oxford High School.
43. On November 26, 2021, Ethan Crumbley’s father, James Crumbley,

purchased a Sig Saur 9 mm semi-automatic handgun for his son.
44. On November 26, 2021, Ethan Crumbley posted a picture of the Sig
Saur 9 mm semi-automatic handgun to his social media account with the caption,
“just got my new beauty today” with an emoji with heart eyes, followed by, “Sig
Saur 9 mm. Any questions I will answer.” Emphasis added.
45. At all times relevant hereto, Ethan Crumbley posted to his Instagram
account a post with a picture and caption of the Sig Saur 9 mm semi-automatic
handgun. This post was for public viewing and accessible to all Defendants.
46. On November 27, 2021, Ethan Crumbley’s mother, Jennifer Crumbley,
posted a message on her social media account reading, “mom and son day testing
out his new Christmas present.” Emphasis added.

10
47. At all times relevant hereto, Jennifer Crumbley’s social media account
was not set to private, and the post was available to the public.
48. At all times relevant hereto, Jennifer Crumbley’s social media account
with the picture and caption of the Sig Saur 9 mm semi-automatic handgun was
available for public viewing and accessible to all Defendants prior to Ethan
Crumbley returning to school on Monday, November 29, 2021.
49. On November 29, 2021, Defendant TEACHER #1 at Oxford High
School observed Ethan Crumbley searching for ammunition on his cell phone during
class and reported the incident to COUNSELOR #1 at OXFORD COMMUNITY
SCHOOL DISTRICT.
50. Defendant TEACHER #1 allowed Crumbley to stay in the classroom
despite the threats of violence with the minor children at Oxford High School,
including Plaintiff’ Minors.
51. Defendant TEACHER #1 knowingly and deliberately decided to
exclude the school safety liaison officer from notice of such dangers, despite
knowing that Ethan Crumbley was searching for ammunition during class, and the
aforesaid social media posts regarding his weapon were available to the public,
including Defendant TEACHER #1.
52. Defendant TEACHER #1 had actual knowledge of the violent threats
of bodily harm and further had knowledge of Crumbley’s intent to perpetrate those
acts when he/she found Ethan Crumbley searching for ammunition and then did
11
knowingly and deliberately decided to exclude the school safety liaison officer from
reporting this incident.

53. Following the search for ammunition on Crumbley’s cell phone,

Defendants WOLF and THRONE were notified of the incident, putting them on
further alert of the threat.
54. Upon information and belief, Ethan Crumbley met with Defendants,
COUNSELOR #1 and STAFF MEMBER about the search for ammunition during
class on November 29, 2021.
55. On November 29, 2021, after meeting with Defendants COUNSELOR
#1 and STAFF MEMBER, and as a result of Ethan Crumbley’s search for

ammunition during class, Jennifer Crumbley, was contacted via telephone by
Defendant STAFF MEMBER who left a voicemail regarding Ethan Crumbley’s
inappropriate internet search.
56. On November 29, 2021, Defendant STAFF MEMBER followed up on
the unreturned voicemail to Jennifer Crumbley, with an email to Ethan Crumbley’s
parents regarding the search for ammunition during school hours.
57. Defendants COUNSELOR #1 and STAFF MEMBER, made a knowing
and deliberate decision to exclude involving the school safety liaison officer of Ethan
Crumbley’s behavior and knowingly decided to refrain from informing the school
safety liaison of the meeting with Ethan Crumbley regarding the same.
12
58. Defendants TEACHER #1 and COUNSELOR #1, deliberately and
knowingly sent Ethan Crumbley home after school, without any discipline or follow-
up search regarding his inappropriate search for ammunition during class.

59. At all times relevant, Defendant STAFF MEMBER, knew and/or
should have known that the information regarding Ethan Crumbley’s inappropriate
internet search would likely be relayed to Ethan Crumbley by his parents and would
encourage and/or entice Ethan Crumbley into more affirmative actions.
60. At all times relevant, the students at Oxford High School, including
minor Plaintiffs, were safer before Defendant STAFF MEMBER, affirmatively
contacted Ethan Crumbley’s parents via telephone and email, and afferently chose
to allow Ethan Crumbley to return to school the next day. This action assisted with
an acceleration of plans to effectuate his slaughter of classmates. Defendant, STAFF
MEMBER, made a knowing and deliberate decision to not take any meaningful
corrective action against Ethan Crumbley, increasing the risk that Plaintiffs’ Minors
would be exposed to Ethan Crumbley’s acts of violence.
61. At all times relevant, Plaintiffs were safer before Defendant
COUNSELOR #1, affirmatively contacted Ethan Crumbley’s parents via telephone
and email, and affirmatively chose against certain actions and affirmatively decided
to allow Ethan Crumbley to return to school the next day. This action assisted in the
perpetuation of his plans to effectuate a violent slaughter of classmates, and
13
increased the risk that Plaintiffs’ Minors would be exposed to Ethan Crumbley’s acts
of violence.
62. On November 29, 2021, when Defendants TEACHER #1 and

COUNSELOR #1, knowingly and deliberately released Ethan Crumbley without
further investigation, or discipline. Further, Ethan Crumbley’s public social media
post’s regarding his Sig Saur 9 mm semi-automatic handgun and Jennifer
Crumbley’s public social media post were available to the Dean of Students, school
principal, superintendent, counselors, and teachers, including Defendants, all of
which altered said Defendants to the imminent attack.
63. Upon information and belief, in the evening of November 29, 2021,
after Defendants TEACHER #1, COUNSELOR #1, and STAFF MEMBER,
released Ethan Crumbley from school without discipline and without investigating
his inappropriate internet search, and without notifying the school safety liaison
officer, that Ethan Crumbley had posted to his Twitter account, “Now I am become
Death, the destroyer of worlds. See you tomorrow Oxford.” Although his Twitter
account was set to private, the posting was made to his profile biography, and visible
to anyone who could search his name, including Defendants.
64. Ethan Crumbley returned to school the next day unchained. The
students at Oxford High School, and Plaintiffs’ Minors in particular, were safer
before Defendant TEACHER #1, COUNSELOR #1, and STAFF MEMBER,
knowingly and deliberately allowed the murderous student to return to school the
14
next day, despite the clear and present dangers he posed to students at Oxford High
School.
65. At all times relevant, Defendant TEACHER #1, COUNSELOR #1,

STAFF MEMBER, made a knowing, intentional, and deliberate decision to
intentionally withhold and exclude important and vital information from the school
liaison officer before allowing Ethan Crumbley to return to school the next day,
putting all students in immediate danger, and accelerating Crumbley’s plans to
effectuate his planned slaughter of classmates, thereby increasing the risk that
Plaintiffs’ Minors would be exposed to Ethan Crumbley’s acts of violence.
66. On the morning of November 30, 2021, Defendant TEACHER #2

discovered a note on Ethan Crumbley’s desk which alarmed her, and which she
reported to Defendant MOORE and Defendant COUNSELOR #1, and took a picture
of said note with her cell phone.
67. Upon information and belief, the note contained the following:
▪ A drawing of a semi-automatic handgun pointing the words, “the

thoughts won’t stop help me;”
▪ In another section of the note was the drawing of a bullet with the
following words above the bullet, “blood everywhere;”
▪ Between the drawing of the gun and bullet is a drawing of a person

who appears to have been shot twice and bleeding;
▪ Below that figure is a drawing of laughing emoji;
15
▪ Further down the drawing are the words, “My life is useless” with
the words, “the world is dead” to the right.
68. Upon information and belief, Defendant TEACHER #2, was also aware
of a school policy of excluding backpacks in classroom, and TEACHER #2, made a

knowing and deliberate decision to leave, unsearched, Ethan Crumbley’s backpack,
even after discovering the alarming note authored by Crumbley.
69. At all times relevant hereto, the students at Oxford High School, and in
particular, minor Plaintiffs, were safer before Defendant TEACHER #2 knowingly
and affirmatively allowed Crumbley to continue to maintain control of his backpack,
phone, and other possessions, giving him easy access to store a gun, thereby
increasing the risk that Plaintiff’ Minors would be exposed to Ethan Crumbley’s acts
of violence.
70. At all times relevant, the students of Oxford High School, were safer
before Defendant TEACHER #2 took action and intentionally did not report the
violent note drawn by Ethan Crumbley, containing threats of bodily harm, including
death, to the school liaison officer, causing Ethan Crumbley to have the opportunity
to shoot the classmates, but to do so on an accelerated timeline, thereby increasing
the risk that Plaintiffs’ Minors would be exposed to Ethan Crumbley’s acts of
violence.
71. Upon information and belief, upon discovery of the concerning note,
Ethan Crumbley was removed from the classroom, in front of his classmates, with
16
his backpack, by Defendant COUNSELOR #1 and was made to sit in the office with
Defendants COUNSELOR #1, and COUNSELOR #2 for approximately an hour and

a half while waiting for his parents to arrive at the school.

72. Defendant COUNSELOR #1 knew and/or should have known that by
removing Ethan Crumbley from class, in front of his classmates, with his backpack
and making him sit for an hour and a half while waiting for his parents, after Ethan
Crumbley had drawn violent pictures and notes depicting death and violence against
students at Oxford High School, such actions would further accelerate Ethan
Crumbley’s murderous plans.
73. Upon information and belief, during the period of time that Ethan
Crumbley sat with the counselors, he maintained control of his backpack which then
contained the Sig Saur 9 mm semi-automatic handgun with 30 live bullets to be used
to slaughter classmates.
74. Defendant COUNSELOR #1 and COUNSELOR #2, knowingly and
deliberately decided to exclude the school safety liaison despite from having
knowledge of threats against the school, Ethan Crumbley’s search history the day
before, and the violent drawing which were the reason for his removal from the
classroom.
75. At all times relevant, the students of Oxford High School, were safer
before Defendant COUNSELOR #1 and COUNSELOR #2 took action and
deliberately did not report the violent note drawn by Ethan Crumbley, containing
17
threats of bodily harm, including death, to the school liaison officer allowing Ethan
Crumbley thereby to have the opportunity to carry out his murderous rampage on an
accelerated timeline, thereby increasing the risk that Plaintiffs’ Minors would be
exposed to Ethan Crumbley’s acts of violence.
76. Upon information and belief, Ethan Crumbley’s parents arrived at the
school and a meeting was held with Defendant COUNSELOR #1, Defendant
COUNSELOR #2, Defendant MOORE, Defendant STAFF MEMBER, and
Defendant WOLF, at which Ethan Crumbley was present and at which time they
were shown the aforesaid drawing and advised by Defendants that Ethan was
required to go to counseling within 48-hours.

77. Upon information and belief, Ethan Crumbley’s parents were advised
by Defendants COUNSELOR #1, COUNSELOR #2, MOORE, STAFF MEMBER,
and WOLF, in the presence of Ethan Crumbley, that a failure to attend counseling
within 48 hours would result in the school contacting Child Protective Services.
78. Defendants COUNSELOR #1, COUNSELOR #2, MOORE, STAFF
MEMBER, and WOLF took these actions during school hours, while students were
present at Oxford High School.
79. After the meeting which Defendants COUNSELOR #1, COUNSELOR
#2, STAFF MEMBER, TEACHER #1, TEACHER #2, WOLF and MOORE, Ethan
Crumbley, and his parents, Ethan Crumbley returned to the classroom with his
backpack containing the Sig Saur 9 mm semi-automatic handgun and 30 live bullets.
18
80. At all times relevant, Defendants STAFF MEMBER, COUNSELOR
#1, COUNSELOR #2, TEACHER #2, MOORE, and WOLF, deliberately conducted
this meeting, excluding the School Safety Liaison Officer from the meeting, thereby
preventing him from being present at the meeting.
81. At all times relevant, Plaintiffs were safer before Defendant WOLF
took action and held a meeting with Crumbley and his parents (without the school
safety liaison officer present) and by subsequently allowing Ethan Crumbley to
return to class where he was able to carry out a massacre of classmates. By virtue of
Defendant WOLF’s actions, he substantially increased the harm that Plaintiffs’
Minors would be exposed to Ethan Crumbley’s acts of violence.

82. At all times relevant, Plaintiffs were safer before Defendant MOORE
took action and held a meeting with Ethan Crumbley and his parents (without the
school safety liaison officer present) and by subsequently allowing Crumbley to
return to his classroom where he was able to carry out the murder of fellow students,
fulfilling his aforesaid promises to do so. By virtue of Defendant MOORE’s actions,
he substantially increased the risk that Plaintiffs’ Minors would be exposed to Ethan
Crumbley’s acts of violence.
83. At all times relevant, Plaintiffs were safer before Defendant TEACHER
#2 took action and held a meeting with Crumbley and his parents (without the school
safety liaison officer present) and by subsequently allowing Crumbley to return to
his classroom where he was able to effectuate his planned massacre. By virtue of
19
Defendant TEACHER #2 actions, he/she substantially increased the risk that
Plaintiffs’ Minors would be exposed to Ethan Crumbley’s acts of violence.


COUNSELOR #1 took action and held a meeting with Crumbley and his parents
(without the school safety liaison officer present) and by subsequently allowing
Crumbley to return to his classroom where he was able to carry out a massacre of
students. By virtue of Defendant COUNSELOR #1 actions, he/she substantially
increased the risk that Plaintiffs’ Minors would be exposed to Ethan Crumbley’s acts
of violence.

COUNSELOR #2 took action and held a meeting with Crumbley and his parents
(without the school safety liaison officer present) and by subsequently allowing
Crumbley to return to his classroom where he was able to carry out a slaughter. By
virtue of Defendant COUNSELOR #2 actions, he/she substantially increased the risk
that Plaintiffs’ Minors would be exposed to Ethan Crumbley’s acts of violence.
86. At all times relevant, Plaintiffs were safer before Defendant STAFF
MEMBER took action and held a meeting with Crumbley and his parents (without
the school safety liaison officer present) and by subsequently allowing Crumbley to
return to his classroom where he was able to carry out his plan to murder classmates.
By virtue of Defendant STAFF MEMBER’s actions, he/she substantially increased
20
the risk that Plaintiffs’ Minors would be exposed to Ethan Crumbley’s acts of
violence.
87. Defendants WOLF, MOORE, TEACHER #2, COUNSELOR #1,

COUNSELOR #2, and STAFF MEMBER, knew that threatening to call Child
Protective Services within 48 hours, and threating, without action, to remove Ethan
Crumbley from his home, would create and/or increase the likelihood that Ethan
Crumbley would carry out his plan and slaughter he lost the opportunity given the
prospect of threatened Child Protective Services intervention in the coming days.
88. Upon information and belief, after being allowed to return to his
classroom, Ethan Crumbley took his backpack to a school bathroom, and, sometime
after being returned to his class, loaded ammunition in the Sig Saur 9 mm semi-
automatic handgun and walked out of the bathroom to design the massacre.
89. Defendants WOLF, MOORE, TEACHER #2, COUNSELOR #1,
COUNSELOR #2, and STAFF MEMBER gave Ethan Crumbley the opportunity to
go to the bathroom, with his backpack, to prepare for his planned rampage, thereby
increasing the risk that Plaintiffs’ Minors would be exposed to Ethan Crumbley’s
acts of violence.
90. At approximately 12:52 p.m., authorities were notified of an active
shooter at Oxford High School.
91. Upon information and belief, Ethan Crumbley’s massacre was halted
when he was apprehended by law enforcement.

21
92. On November 30, 2021, RILEY FRANZ was shot in the neck as a direct
result of each and every one of the within enumerated actions of Defendants’,
causing her severe trauma, post-traumatic stress disorder, fright, shock, terror,
anxiety as well as physical and emotional injuries.
93. On November 30, 2021, BELLA FRANZ, narrowly escaped the bullets
discharged towards her, her sister, and her friends. She observed her sister, friends
and classmates being shot and murdered, causing her severe trauma, fright, shock,
terror, anxiety, post-traumatic stress disorder, and emotional injuries
94. On December 1, 2021, Ethan Crumbley was arraigned and charged as
an adult with one count of terrorism causing death, four (4) counts of first-degree
murder, seven (7) counts of assault with intent to murder, and 12 counts of
possession of a firearm in the commission of a felony.
95. The risk that Ethan Crumbley posed a substantial and deadly harm to
other students was obvious and known by the Defendants.
96. That each and every defendant named herein made affirmative actions
that created and increased the risk of harm and danger to Oxford High School
students, and in particular, Plaintiffs’ Minors’ RILEY FRANZ’s and BELLA
FRANZ’s, vulnerability to the extremely violent behavior and murderous ideology
of Ethan Crumbley. Minor Plaintiffs were all safer before the actions of all
Defendants than they were after.
22
97. The “state action” of all Defendants substantially increased the harm to
the minor Plaintiffs, thereby increasing the risk that Plaintiffs’ would be exposed to
Ethan Crumbley’s acts of violence.

98. The “state action” of each and all of the Defendants accelerated the acts
of violence committed by Ethan Crumbley.
99. The “state action” of all Defendants allowed threats of violence to be
carried out towards the students, and allowed Crumbley the opportunity to retrieve
his handgun, by deliberately conducting inflammatory meetings without a police
liaison present, directly causing the students at Oxford High School to be subjected
to great bodily harm.

100. At all times relevant, all Defendants willfully misrepresented the
dangers presented which was an action in and of itself. The students and Plaintiffs’
Minors in particular were safer had the misrepresentations not been said, thereby
increasing the risk that Plaintiffs’ would be exposed to Ethan Crumbley’s acts of
violence.
101. The Defendants affirmative actions were reckless and put the students
at Oxford High School, and in particular Plaintiffs’ Minors, RILEY FRANZ, and
BELLA FRANZ, in a substantial risk of serious and immediate harm.
102. Defendants had a clearly established duty to not create and/or increase
the risk of harm and danger to Oxford High School Students, and in particular,
Plaintiffs’ minors’ RILEY FRANZ and BELLA FRANZ.

23
103. The Defendants affirmative actions placed Oxford High School
students, and in particular Plaintiffs’ minors, RILEY FRANZ and BELLA FRANZ,
at risk of a violent school shooting.

104. The Defendants knew and/or clearly should have known that their
actions would endanger the students at Oxford High School, and in particular,
Plaintiffs’ Minors, RILEY FRANZ and BELLA FRANZ.
105. RILEY FRANZ and BELLA FRANZ were safer before each and every
one of the individual Defendants took the within enumerated actions, which placed
Plaintiffs’ Minors in a substantially more dangerous situation, increasing the risk
that Plaintiffs’ Minors would be exposed to Ethan Crumbley’s acts of violence.

106. At all times relevant the action by each and every individual defendant
created the substantial risk that outside assistance to the Oxford High School
Students and Plaintiff’s in particular would be negated, by willfully representing
they had taken action ensure the safety of all the Oxford High School Students,
including Plaintiffs’ minors.
107. Defendants’ conduct was outrageous and shocks the conscience.
108. Defendants are not entitled to governmental and/or qualified immunity.
24
COUNT I
VIOLATION OF CIVIL RIGHTS PURSUANT TO THE
14TH AMENDMENT TO THE CONSTITUTION
AND 42 U.S.C. §1983, 1988 STATE CREATED DANGER
AS TO DEFENDANTS, COUNSELOR #1, COUNSELOR #2, TEACHER #1,

TEACHER #2, STAFF MEMBER, SUPERINTENDENT TIMOTHY
THRONE, DEAN OF STUDENTS, RYAN MOORE and, PRINCIPAL

STEVEN WOLF
109. Plaintiffs hereby reincorporates and reasserts each and every allegation
set forth in the previous paragraphs of this Complaint as if fully set forth herein.
110. As a citizen of the United States Plaintiffs’ Minors, RILEY FRANZ
and BELLA FRANZ were entitled to all rights, privileges, and immunities accorded
to all citizens of the State of Michigan and of the United States.

111. Pursuant to the Fourteenth Amendment of the United States
Constitution, at all times relevant hereto, Plaintiffs’ Minors, RILEY FRANZ and
BELLA FRANZ, had a clearly established right to be free from danger created
and/or increased by the Defendants.
112. At all times relevant hereto, that the Defendants, COUNSELOR #1,
COUNSELOR #2, TEACHER #1, TEACHER #2, STAFF MEMBER, THRONE,
WOLF, and MOORE, were acting under the color of state law and created and/or
increased a state created danger by substantially increasing the risk of harm to
RILEY FRANZ and BELLA FRANZ and in reckless disregard to Plaintiffs’ Minors
safety, thereby increasing the risk that Plaintiffs’ Minors would be exposed to Ethan
Crumbley’s acts of violence.
25
113. That actions by Defendants, COUNSELOR #1, COUNSELOR #2,
TEACHER #1, TEACHER #2, STAFF MEMBER, THRONE, WOLF, and

MOORE, under the 14th Amendment to the United States Constitution, as well as 42
U.S.C. §1983 and §1988 were all performed under the color of state law and were
objectively unreasonable and performed knowingly, deliberately and indifferently to
Plaintiffs’ Minors RILEY FRANZ and BELLA FRANZ and in reckless disregard to
Plaintiffs’ Minors’ safety.
114. That each and all Defendants, were acting under the color of state law
when they deprived Plaintiffs’ Minors RILEY FRANZ and BELLA FRANZ of their
clearly established rights, privileges, and immunities in violation of the 14 th

Amendment of the Constitution of the United States, and of 42 U.S.C. §1983 and
§1988.
115. That each and every individual Defendant exhibited deliberate
indifference, pursuant to the Fourteenth Amendment to the United States
Constitution, by taking affirmative actions resulting in the students and Plaintiffs’
Minors in particular being less safe than they were before the action of each and
every Individual Defendant. Their actions created the danger and increased the risk
of harm that their students would be exposed to private acts of violence, to wit:
a. Deliberately and intentionally returning Ethan Crumbley to class

with a loaded Sig Saur 9 mm semi-automatic handgun;
26
b. Deliberating deciding not to involve or advise the proper police

authorities of Ethan Crumbley’s conduct and making a decision to
handle the situation without proper authorities being involved;
c. Choosing to return Ethan Crumbley to class with a Sig Saur 9 mm

semi-automatic handgun after he had been actively searching for
ammunition during class on the internet the day before;
d. Deliberately choosing not to search Ethan Crumbley’s backpack;
e. Choosing not to report Ethan Crumbley’s internet search for

ammunition to proper police authorities the day before the shooting;
f. Deliberately returning Ethan Crumbley to his classroom with a Sig

Saur 9 mm semi-automatic handgun and ammunition, after
confiscating a picture drawn by Ethan Crumbley which
demonstrated a high likelihood that Ethan Crumbley would
effectuate a slaughter;
g. Choosing to internally handle the complaints and threat of a school

shooter in the days leading to the November 30, 2021, school

shooting rather than involve the proper police authorities;
h. Deciding not to inspect Ethan Crumbley’s backpack which

maintained the Sig Saur 9 mm semi-automatic handgun and
ammunition used to shoot Plaintiffs’ Minors and/or Ethan
Crumbley’s locker, when Defendants maintained custody and
control over same;
i. Deliberately and intentionally concealing facts from the appropriate

law enforcement authority before returning Ethan Crumbley to class
where he had access to the Sig Saur 9 mm semi-automatic handgun
used to shoot Plaintiffs’ Minors’;
j. Deliberately choosing not to report Ethan Crumbley’s suspicious

behavior to Child Protective Services;
k. Deliberately choosing not to report Ethan Crumbley’s suspicious

behavior to appropriate law enforcement;
l. Interviewing Ethan Crumbley in front of his parents, knowing that

interview would accelerate the violence planned;
27
m. Deliberately choosing not to have appropriate mental health

intervention for Ethan Crumbley prior to returning him to class with
a Sig Saur 9 mm semi-automatic handgun;
n. Demonstrating conduct so reckless that it demonstrates a substantial

lack of concern for whether any injury would result;
o. Wrongfully causing Plaintiffs’ Minors to suffer extreme emotional

distress;
p. Recklessly, or otherwise improperly returning Ethan Crumbley to

class with the Sig Saur 9 mm semi-automatic handgun, so that he
could effectuate his murderous ideology;
q. Any and all other breaches that may become known throughout the
course of this litigation.
116. That all of the above conduct alleged in paragraph 115 a-q substantially
increased the harm to Plaintiffs Minors, who were safer before Defendants took the
affirmative acts described within paragraph 115 a-q.
117. That the above-described conduct of Defendants COUNSELOR #1,
MOORE, and WOLF, as specifically set forth above, were the proximate cause of
Plaintiffs’ Minor, RILEY FRANZ’s injuries and damages, including but not limited
to the following:
a. Gunshot wound to the neck;
b. Fright, shock, and terror leading up to the shooting;
c. Conscious pain and suffering;
d. Need for wound care;
e. Need for therapy;
f. Post-Traumatic Stress Disorder;

28
g. Terrors;
h. Disruption of her life;

i. Pain and suffering;
j. Anxiety;
k. Mental anguish;
l. Emotional Distress;
m. Fright and shock;
n. Humiliation and/or mortification;
o. Past and future reasonable medical and hospital expenses;
p. Past and future wage loss and loss of earnings capacity;
q. Need for household services;

r. Need for attendant care;
s. Punitive damages;
t. Exemplary damages;
u. Any and all compensatory damages, both past and future;
v. Attorneys’ fees and costs pursuant to 42 U.S.C. §1988;
w. Other damages, injuries, and consequences that are found to be

related to the incident that develops during the course of discovery;
and
x. Any other damages allowed by law.
118. That the above-described conduct of Defendants, COUNSELOR #1,
MOORE, and WOLF, as specifically set forth above, were the proximate cause of
29
Plaintiffs’ Minor, BELLA FRANZ’s injuries and damages, including but not limited
to the following:
a. Post-Traumatic Stress Disorder;

c. Pain and suffering;
d. Anxiety;
e. Mental anguish;
f. Emotional Distress;
g. Fright and shock;
h. Humiliation and/or mortification;
i. Past and future reasonable medical and hospital expenses;

j. Past and future wage loss and loss of earnings capacity;
k. Need for household services;
l. Need for attendant care;
m. Punitive damages;
n. Exemplary damages;
o. Any and all compensatory damages, both past and future;
p. Attorneys’ fees and costs pursuant to 42 U.S.C. §1988;
q. Other damages, injuries, and consequences that are found to be

and
r. Any other damages allowed by law.
119. Defendants are not entitled to governmental or qualified immunity.
30
WHEREFORE, Plaintiffs, JEFFREY FRANZ and BRANDI FRANZ, as
Next Friends of RILEY FRANZ, a Minor, and BELLA FRANZ, a Minor, request
that this Honorable Court enter judgment in their favor and against Defendants,
jointly and severally, in an amount in excess of One-Hundred Million Dollars
($100,000,000.00), together with interest, costs and attorneys’ fees, as well as
punitive and/or exemplary damages.
COUNT II
VIOLATION OF CIVIL RIGHTS PURSUANT TO THE
14TH AMENDMENT TO THE CONSTITUTION
AND 42 U.S.C. §1983, 1988 – SUPERVISORY LIABILITY
DEFENDANTS SUPERINTENDENT TIMOTHY THRONE, and
PRINCIPAL STEVEN WOLF
set forth in the previous paragraphs of this Complaint.
121. At all times relevant hereto, Defendant THRONE, was the
Superintendent at OXFORD COMMUNITY SCHOOL DISTRICT, and directly
supervised and oversaw the actions of Defendants WOLF, COUNSELOR #1,
COUNSELOR #2, TEACHER #1, TEACHER #2, STAFF MEMBER, and
MOORE, and encouraged the specific incident of misconduct and/or directly
participated in it by not expelling, disciplining, and providing proper supervision for
Ethan Crumbley, and/or notifying police authorities of Crumbley’s violent plans.
122. At all times relevant hereto, Defendant THRONE, was the
Superintendent at OXFORD COMMUNITY SCHOOL DISTRICT, and directly
31
supervised and oversaw the actions of Defendants WOLF, COUNSELOR #1,
COUNSELOR #2, TEACHER #1, TEACHER #2, STAFF MEMBER, and

MOORE, and encouraged the specific incident of misconduct and/or directly

participated in it by discoursing the reporting, sharing, or mentioning of threats
against Oxford High School.
123. At all times relevant hereto, Defendant WOLF, was the principal at
Oxford High School, who was the direct supervisor and oversaw the actions of
Defendants COUNSELOR #1, COUNSELOR #2, TEACHER #1, TEACHER #2,
STAFF MEMBER, and MOORE, and encouraged the specific incident of
misconduct and/or directly participated in it by not expelling, disciplining, and

providing proper supervision for Ethan Crumbley.
124. By inadequately training and/or supervising their teachers, counselors,
and dean of students, and having a custom or policy of indifference to the
constitutional rights of their citizens, and/or by failing to adequately supervise school
shooter, Ethan Crumbley, Defendants THRONE and WOLF encouraged and
cultivated the conduct which then caused a violation of Plaintiffs’ rights under the
Fourteenth Amendments of the United States Constitution.
125. By not expelling, disciplining, searching, or providing proper
supervision for Ethan Crumbley, Defendants THRONE and WOLF authorized,
approved, or knowingly acquiesced in the unconstitutional conduct of Defendants
COUNSELOR #1 and COUNSELOR #2, TEACHER #1, TEACHER #2, STAFF

32
MEMBER, and MOORE, by allowing Ethan Crumbley to return to his classroom
and carry out his murderous rampage.

126. Pursuant to the Fourteenth Amendment of the United States

Constitution, at all times relevant hereto, each of Plaintiffs’ Minors, RILEY FRANZ
and BELLA FRANZ, had a clearly established right to be free from dangers created
by the Defendants.
127. That actions and omissions by Defendants, THRONE, WOLF,
COUNSELOR #1, and COUNSELOR #2, TEACHER #1, TEACHER #2, and
MOORE, under the 14th Amendment to the United States Constitution, as well as 42
U.S.C. §1983 and §1988 were all performed under the color of state law and were
objectively unreasonable and performed knowingly, deliberately and indifferently to
Plaintiffs’ Minors RILEY FRANZ and BELLA FRANZ and in reckless disregard to
Plaintiffs’ Minors’ safety.
128. That Defendants, THRONE, WOLF, COUNSELOR #1, and
COUNSELOR #2, TEACHER #1, TEACHER #2, and MOORE were acting under
the color of state law when they deprived Plaintiffs’ Minors RILEY FRANZ and
BELLA FRANZ of their clearly established rights, privileges, and immunities in
violation of the 14th Amendment of the Constitution of the United States, and of 42
U.S.C. §1983 and §1988.
129. The Defendants exhibited deliberate indifference, pursuant to the
Fourteenth Amendment to the United States Constitution, to be free from acts that
33
create the risk of harm and/or increase the risk of harm that an individual will be
exposed to private acts of violence, to wit:

a. Deliberately and intentionally returning Ethan Crumbley to his class

with a loaded Sig Saur 9 mm semi-automatic handgun;
b. Choosing not to involve the proper authorities of Ethan Crumbley’s

conduct and make the decision to handle the situation without the
proper authority involvement;
c. Choosing to return Ethan Crumbley to his classroom with a Sig Saur

9 mm semi-automatic handgun after he had been actively searching
for ammunition during class on the internet the day before;
d. Choosing not to report Ethan Crumbley’s internet search for

ammunition to proper authorities the day before the shooting;
e. Returning Ethan Crumbley to his classroom with a Sig Saur 9 mm

semi-automatic handgun after confiscating a picture drawn by Ethan
Crumbley which demonstrated a high likelihood that Ethan

Crumbley would carry out a mass murder;
f. Choosing to handle the complaints and allegations of a threat of a

school shooter in the days leading to the November 30, 2021, school
shooting, rather than involve the proper police authorities;
g. Deciding not to inspect Ethan Crumbley’s backpack which

maintained the Sig Saur 9 mm semi-automatic handgun used to
carry out the rampage, when Defendants otherwise maintained
custody and control, for over an hour, of Ethan Crumbley and his
backpack;
h. Deliberately and intentionally omitting facts to appropriate law

enforcement authorities before returning Ethan Crumbley to class
where he had access to the Sig Saur 9 mm semi-automatic handgun
used to massacre students;
i. Deliberately choosing not to report Ethan Crumbley’s suspicious

behavior to Child Protective Services;
j. Deliberately choosing not to report Ethan Crumbley’s suspicious

behavior to appropriate law enforcement;
34
k. Interviewing Ethan Crumbley in front of his parents, knowing that

such interview would accelerate the violent actions and/or
murderous plans of Ethan Crumbley;
l. Deliberately choosing not to have appropriate mental health

intervention for Ethan Crumbley prior to returning him to his
classroom with a Sig Saur 9 mm semi-automatic handgun;
m. Demonstrating conduct so reckless that it shows a substantial lack

of concern for whether any injury would result;
n. Wrongfully causing Plaintiffs’ Minors to suffer extreme emotional

distress;
o. Recklessly, or otherwise improperly returning Ethan Crumbley to

class with the Sig Saur 9 mm semi-automatic handgun, so that he
could effectuate his planned slaughter;
p. Enforced the deficient and faulty policies, procedures, and practices

set forth in Count III, infra, as well as those previously described in
this Complaint.
q. Any and all other breaches that may become known throughout the
course of this litigation.
130. That the above-described conduct of Defendants, THRONE, WOLF,
COUNSELOR #1, COUNSELOR #2, TEACHER #1, and TEACHER #2, STAFF
MEMBER, and MOORE as specifically set forth above, were the proximate cause
of Plaintiffs’ Minor, RILEY FRANZ’s injuries and damages, including but not
limited to the following:

35
g. Terrors;

j. Anxiety;
k. Mental anguish;


related to the incident that develops during the course of
discovery; and
131. That the above-described conduct of Defendants, THRONE, WOLF,
COUNSELOR #1, COUNSELOR #2, TEACHER #1, and TEACHER #2, STAFF
MEMBER, and MOORE, as specifically set forth above, were the proximate cause
36
of Plaintiffs’ Minor, BELLA FRANZ’s injuries and damages, including but not
limited to the following:


d. Anxiety;
e. Mental anguish;

q. Other damages, injuries, and consequences that are found to be

related to the incident that develops during the course of
discovery; and
37
jointly and severally, in an amount in excess of One Hundred Million Dollars
COUNT III
42 U.S.C. § 1983 – MONELL LIABILITY
DEFENDANT OXFORD COMMUNITY SCHOOL DISTRICT
set forth in the previous paragraphs of this Complaint.
134. At all times relevant, Defendant OXFORD COMMUNITY SCHOOL
DISTRICT failed and failed adequately to train, discipline and supervise
Defendants, THRONE, WOLF, COUNSELOR #1, COUNSELOR #2, TEACHER
#1, and TEACHER #2, STAFF MEMBER, and MOORE, promulgating and
maintaining de facto unconstitutional customs, policies, or practices rendering them
liable for the constitutional violations alleged herein under Monell v. Dept. of Social
Services of the City of New York, 436 U.S. 658 (1978).
DISTRICT knew or should have known that the policies, procedures, training
supervision and discipline of Defendants, THRONE, WOLF, COUNSELOR #1,

38
COUNSELOR #2, TEACHER #1, and TEACHER #2, STAFF MEMBER, and
MOORE, were inadequate for the tasks that each Defendant was required to perform.
136. At all times relevant, Defendant, OXFORD COMMUNITY SCHOOL

DISTRICT failed to establish, implement or execute adequate policies, procedures,
rules and regulations to ensure that their actions did not create or increase the risk
Plaintiffs’ Minors, RILEY FRANZ and BELLA FRANZ, would be exposed to
private acts of violence.
137. At all times relevant, Defendant, OXFORD COMMUNITY SCHOOL
DISTRICT failed to establish, implement or execute adequate policies, procedures,
rules and regulations to ensure that their teachers, counselors and staff do not take
actions that create or increase the risk of harm to district’s students at Oxford High
School, such as Plaintiffs’ Minors RILEY FRANZ, and BELLA FRANZ.
DISTRICT was on notice or should have known, of a history, custom, propensity,
and pattern for Defendants, THRONE, WOLF, COUNSELOR #1, COUNSELOR
#2, TEACHER #1, and TEACHER #2, STAFF MEMBER, and MOORE, and other
employees of Oxford High School, to fail to properly identify a student with violent
tendencies and acted in such a way that created a risk of harm to Oxford High School
students and/or increased a risk of harm to Oxford High School students, such as
Plaintiffs’ Minors’ RILEY FRANZ and BELLA FRANZ.
39
139. Defendant OXFORD COMMUNITY SCHOOL DISTRICT explicitly
and implicitly authorized, approved, or knowingly acquiesced in the deliberate

indifference to the strong likelihood that constitutional violations, such as in the

instant case, would occur, and pursued policies, practices, and customs that were a
direct and proximate cause of the deprivations of Plaintiffs’ Minors’ constitutional
rights.
DISTRICT knew that its policies, procedures, customs, propensity and patterns of
supervising a student with violent tendencies and murderous ideology, would
deprive citizens, such as Plaintiffs’ Minors RILEY FRANZ and BELLA FRANZ,
of their constitutional rights.
DISTRICT knew that its policies, procedures, customs, propensity and patterns
allowed principals, counselors, and teachers to return a student with violent
tendencies back to his classroom such that their actions created a risk of harm and/or
an increased risk of harm to the students at Oxford High School before getting
permission from proper authorities.
142. Upon information and belief, Defendant OXFORD COMMUNITY
SCHOOL DISTRICT maintained a policy that allowed principals, counselors and
teachers to return a fully weaponized violent child with murderous plans, back into
a classroom, such that he could effectuate a massacre.

40
143. By inadequately training and/or supervising their principals and
counselors and having a custom or policy of deliberate indifference to the

constitutional rights of their citizens, Defendant, OXFORD COMMUNITY

SCHOOL DISTRICT, encouraged and cultivated the conduct which violated
Plaintiffs’ Minors’ rights under the Fourteenth Amendments of the United States
Constitution, thereby increasing the risk that Plaintiffs’ Minors would be exposed to
Ethan Crumbley’s acts of violence.
144. That the above-described conduct of Defendant, Oxford Community
School District, was the proximate cause of Plaintiffs’ Minor, RILEY FRANZ’s
injuries and damages, including but not limited to the following:

g. Terrors;
j. Anxiety;
k. Mental anguish;
41



and
145. That the above-described conduct of Defendants was the proximate
cause of Plaintiffs’ Minor, BELLA FRANZ’s injuries and damages, including but
not limited to the following:
d. Anxiety;
e. Mental anguish;
42


q. Other damages, injuries, and consequences that are found to be related

to the incident that develops during the course of discovery; and

jointly and severally, in an amount in excess of One Hundred Million Dollars
43
Respectfully submitted,
/s/Geoffrey N. Fieger

Dated: December 9, 2021 ROBERT G. KAMENEC (P35283)

P: (248) 355-5555
F: (248) 355-5148
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
44
UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
_______________________
JEFFREY FRANZ and BRANDI FRANZ, as

NEXT FRIEND For RILEY FRANZ, a Minor,

and JEFFREY FRANZ and BRANDI FRANZ,
as NEXT FRIEND For BELLA FRANZ, a
Minor,
Case No.:
Plaintiffs, Hon.
Vs.
OXFORD COMMUNITY SCHOOL DISTRICT,

SUPERINTENDENT TIMOTHY THRONE,
PRINCIPAL STEVEN WOLF, DEAN OF
STUDENTS RYAN MOORE, COUNSELOR
#1, COUNSELOR #2, STAFF MEMBER,

TEACHER #1 and TEACHER #2
In their Individual Capacity,
Defendants.
ROBERT G. KAMENEC (P35283)
P: (248) 355-5555
F: (248) 355-5148
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
DEMAND FOR TRIAL BY JURY
45
NOW COME Plaintiffs, JEFFREY FRANZ and BRANDI FRANZ, as
NEXT FRIENDS OF RILEY FRANZ, a MINOR, and BELLA FRANZ, a

MINOR, by and through their attorneys, FIEGER, FIEGER, KENNEY &

HARRINGTON, P.C., hereby demands a trial by jury in the above-captioned
matter.
Respectfully submitted,
/s/Geoffrey N. Fieger
Dated: December 9, 2021 ROBERT G. KAMENEC (P35283)

P: (248) 355-5555
F: (248) 355-5148
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
46

Oxford Lawsuit

Uploaded by

Copyright:

Available Formats

Oxford Lawsuit

Uploaded by

Document Information

Original Description:

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Oxford Lawsuit

Uploaded by

Copyright:

Available Formats

Geoffrey Fieger

For further information please contact:

UNITED STATES DISTRICT COURT

JEFFREY FRANZ and BRANDI FRANZ, as

NEXT FRIEND For RILEY FRANZ, a Minor,

OXFORD COMMUNITY SCHOOL DISTRICT,

#1, COUNSELOR #2, STAFF MEMBER,

NOW COME Plaintiffs, JEFFREY FRANZ and BRANDI FRANZ, as Next

dangers then-existing at Oxford High School.

taken the actions they did.

The Oxford Community School District is responsible for having a

actions of the individually named Defendants.

JURISDICTION AND VENUE

2. This Court has jurisdiction pursuant to 28 U.S.C. §§ 1331, 1343 (a)(3),

1343(a)(4) and 42 U.S.C § 1983.

3. The actions alleged in this Complaint took place within Oakland

Court for the Eastern District of Michigan (Southern Division).

4. Venue is proper pursuant to 28 U.S.C. §1391(d).

5. The amount in controversy exceeds One Hundred Million

($100,000,000) dollars, excluding interests, costs, and attorneys’ fees.

6. Plaintiffs hereby reincorporate and reassert each and every allegation

7. At all times relevant hereto, Plaintiffs’ Minor, RILEY FRANZ, was a

resident of the City of Leonard, County of Oakland, State of Michigan.

8. At all times relevant hereto, Plaintiffs’ Minor, BELLA FRANZ, was a

resident of the City of Leonard, County of Oakland, State of Michigan.

9. At all times relevant hereto, JEFFREY FRANZ and BRANDI FRANZ

for driver’s training.

12. At all times relevant hereto, Defendant, OXFORD COMMUNITY

SCHOOL DISTRICT, was and is a municipal corporation, duly organized and

counselors, and teachers at Oxford High School.

TIMOTHY THRONE, (hereinafter referred to as “THRONE”) is a citizen of the

scope of his employment as Superintendent of the OXFORD COMMUNITY

STEVEN WOLF, (hereinafter referred to as “WOLF”) is a citizen of the State of

COMMUNITY SCHOOL DISTRICT.

RYAN MOORE, (hereinafter referred to as “MOORE”) is citizen of the State of

COMMUNITY SCHOOL DISTRICT.

COUNSELOR #1, (hereinafter referred to as “COUNSELOR #1”) is a citizen of

and scope of his/her employment as a counselor at Oxford High School located in

the OXFORD COMMUNITY SCHOOL DISTRICT.

COUNSELOR #2, (hereinafter referred to as “COUNSELOR #2”) is a citizen of the

scope of his/her employment as a counselor at Oxford High School located in the

OXFORD COMMUNITY SCHOOL DISTRICT.

STAFF MEMBER, (hereinafter referred to as “STAFF MEMBER”) is a citizen of

in the OXFORD COMMUNITY SCHOOL DISTRICT.

TEACHER #1, (hereinafter referred to as “TEACHER #1”) is a citizen of the State

of his/her employment as a teacher at Oxford High School located in the OXFORD

COMMUNITY SCHOOL DISTRICT.

TEACHER #2, (hereinafter referred to as “TEACHER #2”) is a citizen of the State

of his/her employment as a teacher at Oxford High School located in the OXFORD

COMMUNITY SCHOOL DISTRICT.

21. Plaintiffs hereby reincorporates by reference and reasserts each and

22. Plaintiffs’ Minor, RILEY FRANZ, is a 17-year-old female senior at

Oxford High School.

23. Plaintiffs’ Minor, BELLA FRANZ, is a 14-year-old female freshman

at Oxford High School.

24. Ethan Crumbley was a 15-year-old male sophomore at Oxford High

School at the time of the incident.

semi-automatic handgun to Oxford High School and opened fire slaughtering

students and a teacher.