In the jail on the night of Sept. 7, 2009, in response to Downes’ loud complaints about the televisions being turned off in the unit, several deputies began transferring him to an administrative segregation cell. The Sheriff’s Department said Downes had become verbally disruptive and resisted the move.

Geri Green, the attorney for Downes’ family, alleged in the lawsuit that Downes had been complaining he could not breathe as deputies used forceful restraint procedures that involved placing their weight on his back and neck. Downes stood 6 feet tall and weighed more than 300 pounds.

A short time after being placed face-down in the safety cell, Downes was found to have stopped breathing.

"Mr. Downes, while handcuffed and shackled, died as a result of being asphyxiated by Sheriff’s deputies employing excessive force as well as illegal and unconstitutional restraint procedures," the lawsuit alleged.