136.

Sample Indictment—18 U.S.C. § 242

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS GALVESTON DIVISION UNITED STATES OF AMERICA v. CRIMINAL CASE NO. BELARMINO SANCHEZ INDICTMENT THE GRAND JURY CHARGES THAT: On or about August 26, 1992, within the Southern District of Texas, BELARMINO SANCHEZ, defendant herein, then an officer with the Galveston Police Department, while acting under color of the laws of the State of Texas, did willfully deprive Lori Cannon Wilson, an inhabitant of the State of Texas, of the rights and privileges which are secured and protected by the constitution and the laws of the United States, namely, the right not to be deprived of liberty without due process of law, which includes the right to be free from an unreasonable seizure, that is, a willful sexual assault by coercing Lori Cannon Wilson to engage in sexual acts with defendant Sanchez. In violation of Title 18, United States Code, Section 242. COUNT TWO On or about September 16, 1992, within the Southern District of Texas, BELARMINO SANCHEZ, defendant herein, then an officer with the Galveston Police Department, while acting under color of the laws of the State of Texas, did willfully deprive Cindy Hegmann, an inhabitant of the State of Texas, of the rights and privileges which are secured and protected by the constitution and the laws of the United States, namely, the right not to be deprived of liberty without due process of law, which includes the right to be free from an unreasonable seizure, that is, a willful sexual assault by coercing Cindy Hegmann to engage in sexual acts with defendant Sanchez. In violation of Title 18, United States Code, Section 242. COUNT THREE On or about September 29, 1992, within the Southern District of Texas, BELARMINO SANCHEZ, defendant herein, then an officer with the Galveston Police Department, while acting under color of the laws of the State of Texas, did willfully deprive Angela Townsend, an inhabitant of the State of Texas, of the rights and privileges which are secured and protected by the constitution and the laws of the United States, namely, the right not to be deprived of liberty without due process of law, which includes the right to be free from an unreasonable seizure, that is, a willful sexual assault by coercing Angela Townsend to engage in sexual acts with defendant Sanchez. In violation of Title 18, United States Code, Section 242. COUNT FOUR In or about the months of September or October, 1992, within the Southern District of Texas, BELARMINO SANCHEZ, defendant herein, then an officer with the Galveston Police Department, while acting under color of the laws of the State of Texas, did willfully deprive Canisius Bickham, an inhabitant of the State of Texas, of the rights and privileges which are secured and protected by the constitution and the laws of the United States, namely, the right not to be deprived of liberty without due process of law, which includes the right to be free from an unreasonable seizure, that is, a willful sexual assault by coercing Canisius Bickham to engage in sexual acts with defendant Sanchez. In violation of Title 18, United States Code, Section 242. COUNT FIVE In or about the month of October, 1992, within the Southern District of Texas, BELARMINO SANCHEZ, defendant herein, then an officer with the Galveston Police Department, while acting under color of the laws of the State of Texas, did willfully deprive Paula Ruiz, an inhabitant of the State of Texas, of the rights and privileges which are secured and protected by the constitution and the laws of the United States, namely, the right not to be deprived of liberty without due process of law, which includes the right to be free from an unreasonable seizure, that is, a willful sexual assault by coercing Paula Ruiz to engage in sexual acts with defendant Sanchez. In violation of Title 18, United States Code, Section 242. COUNT SIX In or about the months of October or November, 1992, within the Southern District of Texas, BELARMINO SANCHEZ, defendant herein, then an officer with the Galveston Police Department, while acting under color of the laws of the State of Texas, did willfully deprive Paula Ruiz, an inhabitant of the State of Texas, of the rights and privileges which are secured and protected by the constitution and the laws of the United States, namely, the right not to be deprived of liberty without due process of law, which includes the right to be free from the use of excessive force by one acting under color of the law, that is, by striking Paula Ruiz in the head with a pistol, resulting in bodily injury to Paula Ruiz. In violation of Title 18, United States Code, Section 242. COUNT SEVEN On or about November 10, 1992, within the Southern District of Texas, BELARMINO SANCHEZ, defendant herein, then an officer with the Galveston Police Department, while acting under color of the laws of the State of Texas, did willfully deprive Irene James, an inhabitant of the State of Texas, of the rights and privileges which are secured and protected by the constitution and the laws of the United States, namely, the right not to be deprived of liberty without due process of law, which includes the right to be free from an unreasonable seizure, that is, a willful sexual assault by coercing Irene James to engage in sexual acts with defendant Sanchez. In violation of Title 18, United States Code, Section 242. COUNT EIGHT On or about April 9, 1993, within the Southern District of Texas, BELARMINO SANCHEZ, defendant herein, then an officer with the Galveston Police Department, while acting under color of the laws of the State of Texas, did willfully deprive Susan Rodgers Cox, an inhabitant of the State of Texas, of the rights and privileges which are secured and protected by the constitution and the laws of the United States, namely, the right not to be deprived of liberty without due process of law, which includes the right to be free from an unreasonable seizure, that is, a willful sexual assault by coercing Susan Rogers Cox to engage in sexual acts with defendant Sanchez. In violation of Title 18, United States Code, Section 242. A TRUE BILL: ____________________________ FOREPERSON GAYNELLE GRIFFIN JONES United Sates Attorney Southern District of Texas _________________________ GERALD DOYLE Assistant United States Attorney _________________________ NANCY HERRERA Assistant United States Attorney DEVAL L. PATRICK Assistant Attorney General Civil Rights Division ________________________ SUZANNE DROUET Attorney, Criminal Section Department of Justice [cited in Civil Rights Resource Manual 60]