CHICAGO — The family of an Illinois man killed in a barrage of bullets by Chicago police filed a federal lawsuit Wednesday alleging the officers involved were “outrageously escalatory” in the traffic stop that left motorist Dexter Reed dead and an officer wounded.

The lawsuit against the City of Chicago and the five officers involved in pulling Reed, 26, over on March 21 outlines 17 counts, including three counts of excessive force, wrongful death, and two violations of the Americans With Disabilities Act that hints at a key part of Reed’s past.

The 81-page filing obtained and reviewed by USA TODAY is the latest development in the case that has sparked controversy in the city ever since Chicago’s Civilian Office of Police Accountability released footage of the traffic stop.

"Officers who initially approached Dexter’s vehicle were outrageously escalatory," the lawsuit says, adding they used "wildly disproportionate force against Dexter — repeatedly shooting at him even when he clearly presented no threat."

The city has said Reed had a gun and fired first. Chicago’s Law Department said Wednesday that the "city has not been served with the complaint and does not comment on pending litigation."

96 shots fired in fatal traffic stop.Chicago watchdog agency and bodycam video raise questions.

Seat belt check

The story of Reed’s death begins with five Chicago Police officers pulling over the 26-year-old for a seatbelt violation, according to officials. Reed didn’t comply with officers and the situation escalated, according to bodycam footage reviewed by USA TODAY.

Reed fired first and officers responded with as many as 96 shots in 41 seconds, the police accountability office said. Reed was awaiting trial in a gun case, Cook County court records show, and he had a gun, his lawyers said.

A bullet grazed one of the officers in the shooting, according to the lawsuit. But it does not clearly say Reed fired the bullet, saying the officer was hit "at some point either before or after" the other officers began shooting.

Regardless, how the traffic stop unfolded has caused an uproar. The head of the city’s accountability board questioned the truthfulness of the officers involved; the officers have a history of complaints, according to records USA TODAY obtained via FOIA request; and bodycam footage of the shooting shows officers firing on an apparently unarmed and down Reed.  

2 counts of 'willful and wanton conduct'

The lawsuit, brought by Reed’s mother Nicole Banks, lists 17 counts; 8 are against the city and the rest are against the officers.

The counts against the officers are making an unconstitutional traffic stop; three counts of excessive force; denial of medical care after Reed was shot; two counts of "willful and wanton conduct" for escalatory behavior and wrongful death; assault; battery; and two counts against the Americans With Disabilities Act. 

The ADA charges are based on Reed experiencing PTSD, according to the lawsuit. 

The counts against the city include one for a pattern of “unconstitutional traffic stops,” for a pattern of “excessive and escalatory force” and a violation against the Civil Rights Act for targeting Reed, who was Black.

Who was Dexter Reed?

Two pictures of Reed in the lawsuit illustrate his life before the shooting. One shows him in a basketball uniform holding up an award; the other shows a dresser covered in over a dozen trophies beneath a framed high school basketball jersey.

Reed lived on the West Side of the city where he attended Westinghouse High School, a school known locally for its basketball program. He “led his team” to being regional champions in 2016, according to the lawsuit. After high school, he played at a Chicago-area community college. 

He was a "sweet and respectful young man," the lawsuit says. “Dexter also loved cooking healthy food for his family and aspired to be a sportscaster.”

It also says Reed lived with physical and mental disabilities and was diagnosed with post-traumatic stress disorder. "This condition adversely affected Dexter’s ability to work, to process and remember information, and to communicate."

'Mentally unstable'

The two counts against the city for violating the Americans With Disabilities Act highlight a key part of Reed’s story, though it’s not spelled out in the lawsuit.

The lawsuit says Reed suffered PTSD for years without directly saying how he got it beyond living in a part of the city where many residents have the disorder "due to hyper-policing, harassment and violent encounters initiated and escalated by the CPD during minor traffic stops."

But Cook County court records, first reported on by Chicago media, show a young man struggling in the years leading up to his death.

In an August 2023 court filing alleging medical malpractice, he writes of being shot in August 2021 and winding up in a coma; in another filing from the same period he writes "I’m physically disabled and mentally unstable with PTSD" and lists several physical impairments.

The filing doesn’t explain how he was shot but it began with an apparent mental health episode where he threatened to kill a family member with a knife, according to the Chicago Sun-Times.

"That injury was traumatic, it was really traumatic for him," attorney Andrew M. Stroth told the Chicago Tribune about the shooting. "There were no criminal charges, nothing legal, he just got in an altercation, he was shot, and he never fully recovered. And over the past couple years, the family shared with me, he’s been working to recover, both physically and mentally."

He was also arrested in July 2023 for illegally possessing a gun inside a local music and food festival. 

The series of foul-ups starting with the shooting "caused many problems, setbacks and domino effects in my life," Reed wrote in another filing. "I suffered from depression, anxiety, pain in legs and foot, sickness because of walking in bad air with a open wound and much more."