[1] He encountered the basement tenant, also an African-American man, who indicated that he was locked out of his apartment and asked for help because Floyd's godmother owned the building.

[1] After sitting on the bench for about ten minutes, Ourlicht noticed two male uniformed police officers walking through the housing complex.

[1] Ourlicht viewed a total of four hundred and two photographs and indicated eleven officers who he thought might have been present at the time of the incident.

[1] The plaintiffs also submitted audio recordings on which various precinct commanders issued orders to produce certain numbers of arrests, stops and frisks, and summonses during roll call.

In addition, plaintiffs stated that in May 2004, the Patrolmen's Benevolent Association filed a labor grievance on behalf of six officers and one sergeant who were transferred out of the 75th precinct for allegedly failing to meet a ten summons-per-month quota.

[1] He furthered testified that he had witnessed fellow officers stop civilians without reasonable suspicion and issue summonses without probable cause; and on several occasions, he and his fellow officers were ordered by supervisors to fill out and sign UF250 forms for stops and frisks that they did not conduct or observe and to issue criminal court summonses for incidents they did not observe.

[1] Plaintiffs David Floyd, Lalit Clarkson, Deon Dennis, and David Ourlicht bring this putative class action against the City of New York, Police Commissioner Raymond Kelly, Mayor Michael Bloomberg, and named and unnamed New York City Police Officers ("Defendants"), alleging that defendants have implemented and sanctioned a policy, practice, and/or custom of unconstitutional stops and frisks by the New York Police Department ("NYPD") on the basis of race and/or national origin, in violation of Section 1983.

[1] Aside from their individual claims, the plaintiffs alleged that the NYPD purposefully engaged in a widespread pattern and practice of concentrating its stop and frisk activity on Black and Hispanic neighborhoods based on their racial composition rather than legitimate non-racial factors, with the result that Blacks and Hispanics are unconstitutionally burdened by illegal stops on the basis of their race.

[1] Daniels was resolved through a settlement agreement requiring the City to adopt several remedial measures intended to reduce racial disparities in stops and frisks.

[7] The policy "prohibits the use of race, color, ethnicity or national origin as a determinative factor in taking law enforcement action," though those markers may be used to identify a suspect in the same way that pedigree information (height, weight, and age, etc.)

"[1] On August 31, 2011, the United States District Court for the Southern District of New York held that (1) in Floyd's case, the officers had reasonable suspicion that suspect was engaged in burglary, warranting Terry stop and search; (2) in Ourlicht's case, an issue of material fact existed as to whether individuals who stopped suspect were from police department; and (3) an issue of material fact existed as to whether police department engaged in widespread practice of suspicionless stops and frisks of African-American and Latino suspects.

[1] The court further held that the officers did not impermissibly use race as the determinative factor in deciding to stop and frisk Floyd.

[1] The Honorable Shira A. Scheindlin found that, "there is a triable issue of fact as to whether the NYPD leadership has been deliberately indifferent to the need to train, monitor, supervise, and discipline its officers adequately in order to prevent a widespread pattern of suspicionless and race-based stops.

[9] The remedies opinion also applied to Ligon, et al. v. City of New York, a lawsuit brought by the New York Civil Liberties Union, The Bronx Defenders, LatinoJustice PRLDEF, and the law firm Shearman & Sterling LLP challenging the use of stops and frisks in private buildings through what is known as Operation Clean Halls.