My name is Celeste (Biggs) Long. As a mother, wife, woman, friend, human being, I am reaching out for help in raising money for our civil rights law suit, case docket number 2:14-cv-00244-LJM-WGH, filed with the United States District Court, Southern District of Indiana with Larry J. McKinney as the presiding judge.



The media is filled with stories of inhumane acts from law enforcement officials and prison/jail employees. Sadly, however, these main stream media stories only represent a small portion of incidents that actually ever receive the proper attention and corrective action. 

 

My husband (Ian Long) and I are trying to make sure that his encounter does not go unnoticed and others do not have to endure the horror we did. No matter what rights or wrongs we commit or are perceived to have committed, we should still feel safe in knowing we are going to be treated humanely and with equality. Often when we are not treated in this manner, our voice is silenced by our position in the hierarchy of life. Therefore, this fundraising campaign is a chance for those silent voices to be heard.

 

My husband is a medically retired veteran of the U.S. Army. Though before he received his retirement, he endured a very difficult transition from his military service to his civilian life. From the start of 2012, he attempted suicide several times and the Veterans Affairs (VA) doctors had a hard time prescribing him the right medicines and treatment for his Post-Traumatic Stress Disorder, Conversion Disorder, Traumatic Brain Injury, and Seizure Disorder. The summer of 2012 proved to be more trying than he could handle which resulted in two different stays in the VA’s psychiatric ward, incarceration, and a stay in Indiana’s Logansport State Mental Hospital (LSH). Things really started to spiral out of control when he flipped a vehicle on May 9, 2012, because he thought an Improvised Explosive Device (IED) was on the side of the road. He was in and out of a flashback and he became combative with the medics as well as the hospital staff. He continually asked how his "guys" (Soldiers) were and asked for the last four of their social security numbers to confirm they were OK (this is common practice for military). Then on May 14, 2012, he started having psycho genetic non epileptic seizures which caused motor skills and speech problems. On June 4, 2012, he had a flashback where he physically assaulted me.

 

Until this point in his 39 years of life, he had not had anything on his record. On July 11, 2012, things went from bad to worse when he attempted suicide again right after having approximately eight seizures in a row. I telephoned the police for assistance due to my husband’s mental state and his use of phrases that appeared to be the onset of a flashback. The police were confrontational from the moment they entered our home and escalated the situation instead of de-escalating it. As my husband was starting to regain control of his body and his mind, he agreed to get psychiatric help through the VA, but would not go to the local general hospital via a medical gurney. When my husband looked away while he was standing on the landing of our stairway “five steps high”, he was tazed, not once but twice. This resulted in him falling from the landing, taking a chunk out of his nose when he hit the corner of a wooden desk, and triggered a seizure.  It was during this seizure that he was handcuffed and he arbitrarily “spit blood”. The blood just happened to spatter onto an officer’s shoe which resulted in a felony charge of assaulting an officer with bodily fluid. Ultimately, my call for my husband’s suicide assistance turned into felony charges for him.

 

On July 26, 2012, my husband was arrested on a warrant for the incident on the night of the suicide call. Upon arrival at the Greene County Jail, the jailers were informed of my husband's medical conditions by the arresting police. I also personally provided the jail my husband’s prescription medicine and a letter from the VA detailing his medical conditions. However; he had such a severe seizure on the concrete floor during booking that the paramedics had to be telephoned. The judge then released him on his own recognizance.

 

On the morning of August 10, 2012, a stand-off ensued between my husband and the police after my husband enacted the Castle Law which makes it legal under certain circumstances for a citizen to use deadly force against a law enforcement officer who “unlawfully” enters the citizen’s home, curtilage, or motor vehicle. Our older children were in our home. My oldest told me via cell phone that they would not leave their dad because they thought the police would kill him if they left him alone in the house. Finally, our kids agreed to leave the house when we told them that the local police were no longer in charge of the operation.

 

After the stand-off, my husband was taken to the Greene County General Hospital for an initial medical evaluation. He was then transported to the Greene County Jail and walked by himself into booking with an Indiana State Trooper. After being placed in an isolation cell, my husband had a seizure at approximately 6:00 p.m. on August 11, 2012. A local emergency medical service was called to the Greene County Jail to evaluate my husband. The medics confirmed that he had a seizure and was unresponsive. The local emergency medical service personal requested to take my husband for additional treatment. A jailer telephoned the sheriff for guidance in the situation. Despite my husband’s seizure and physical condition, the sheriff did not release him to the medics or allow him any additional medical treatment. The sheriff specifically stated, “[U]nder no orders is that piece of shit leaving.” The medics told the sheriff and other jailers to monitor my husband’s condition.  The remainder of the day, my husband was left unattended on the floor of the isolation cell (“H3”) at the Greene County Jail. Then, on August 12, 2012, at approximately 6:00 a.m. he had another seizure. The local emergency medical service was again telephoned for assistance at the Greene County Jail. My husband was found on the floor, still in the same position from the previous seizure with urine soaked and soiled pants. The medics confirmed my husband had had another seizure, could no longer move his legs, and he could not walk. It was also confirmed he was very unresponsive and unable to verbally communicate. The sheriff again denied him to be released to the medics or any additional medical treatment. Therefore, the medics told the sheriff and the jailers to monitor my husband’s condition. Two jailers then placed a mat underneath my husband and threw a urine soaked blanket over him. My husband remained in his urine soaked and soiled pants. Due to my husband’s inability to verbally communicate, he attempted to use sign language for help and to ask for water (which he was not given until morning of August 13, 2012), but he was mocked to the point of a jailer asking him if he was using the ASL standard (American Sign Language).

 

My husband laid there until the morning of August 13, 2012 when the same Indiana State Trooper that helped book him, came to his assistance. The Trooper provided my husband with drinking water (the first since his seizure at approximately 6:00 p.m. on August 11, 2012), a shower, a Kosher meal, and a wheelchair. (As he was still unable to move his legs or walk. This condition triggered by his conversion disorder lasted from August 2012, to approximately February/April 2014.) The Trooper had to physically give my husband a shower and use a scrub brush to remove all the dried feces from his body. My husband also informed the Trooper that he was of Jewish decent and that he did not want to wear the grey/white striped uniform reminiscent of Nazi concentration camp garb. The Trooper then, simply, provided him an orange uniform on the specific day. However, after that day he was forced to wear the grey/white striped uniform.

 

Shortly after incarceration, my husband had his wheelchair taken away for several days after falling out of his wheelchair and “kicking” it during a seizure. During the seizure my husband fell out of his wheelchair and his legs hit the wheelchair as he was falling, resulting in his wheelchair being taken away. Without his wheelchair, he had to use his arms to drag himself across his cell to the toilet. Sometimes he would not make-it in time, thereby messing himself without the ability to clean himself as he did not have running water in his isolation room.  However, on March 22, 2013, Long had another seizure and the Greene County Jailers took his wheelchair away from him again. 

 

Furthermore, his living conditions in his isolation cell were such that he was diagnosed with early stages of frost bite on his feet. Around October 29, 2012, his feet became discolored and his skin was starting to peel and fall off.  The jail nurse requested a further evaluation by a doctor. On November 1, 2012, a physician from the Greene County General Hospital diagnosed him with early frostbite on both feet and toes.  The physician prescribed my husband to keep his feet elevated, he wear socks, have a warm blanket on both feet, and Vaseline be applied twice daily. At no time was he provided socks, a warm blanket, or Vaseline to apply to his feet. Additionally, the midsection of his body become covered in open bed sores that left permanent scaring. His showers were either every three days or twice a week in which he had to work between a small, unstable plastic chair and a bar to hold himself up on to shower in which he would sometimes fall from. My husband had no running water except for the water in the toilet and he did not even have a sink because it had been removed. Because of this, in August 2012, when my husband arrived at the Greene County Jail he was provided hand sanitizer. When his hand sanitizer ran out after approximately one month, my husband requested more hand sanitizer. Instead of providing my husband hand sanitizer, a jailer gave him a cup of soapy water to keep in his isolation cell on the basis that Long was an alcoholic. The soapy water was of no use to my husband because he could not wipe or clean it off as he was without running water. My husband was also not provided the required one hour a day out of his isolation cell for recreation or for non-isolation time. Therefore, he was in continuous isolation. The lights were never turned off in his cell resulting in sensory deprivation.

 

The jailers were aware that my husband had suicidal tendencies and was potentially a danger to himself. However, on a number of occasion he was provided a razor and cup of water to shave while unsupervised in the isolation cell. On one occasion when he was given the razor, a jailer gestured to my husband by sliding his finger across his neck and told my husband not to cut himself.

 

From his arrival in August 2012, at the Greene County Jail for approximately 45 days, my husband did not eat and only drank milk, water, and juice. My husband is of Jewish decent and abided by Jewish law by only eating a kosher diet which prohibits certain things from being eaten and requires strict food preparation standards. The Trooper requested a Kosher meal plan for my husband. At no time was my husband provided Kosher meals. While a prepackaged Kosher meal replacement was sometimes provided to my husband, the jailers deliberate mishandling of the meal replacement would render it no longer Kosher. The jailers knew that my husband was not eating because a log of his daily activity was required due to him being in an isolation cell. The jail nurse even noted the need for a special diet because he had not been eating. After 45 days, my husband was forced to consume a non-Kosher meal by jailers threatening the use of a restraining chair and an intravenous tube. This ended up being out of necessity for his own life too. When my husband originally arrived at the Greene County Jail he weighed approximately 190 pounds but dropped approximately 60 pounds during his incarnation at the Greene County Jail.

 

Prior to the November 6, 2012, presidential election my husband sent a request to vote to Dennis Conaway, the Jail Commander. Conaway stated he would figure out a way to get my husband to vote. Conaway did not follow up with my husband’s request nor was my husband provided an absentee ballot or any other for voting. At that specific time, my husband was not otherwise prohibited from being eligible or capable of voting.

 

On November 27, 2012, a hearing was held at the Greene County Court House on whether my husband was competent to stand trial under Cause No.: 28D01-1207-FD-000152 and Cause No.: 28D01-1208-FC-000033. At the competency hearing, under oath Jail Commander Conaway stated Greene County Jail did not have the manpower or the facility to support my husband’s physical and mental needs. Therefore, Greene County Superior Court 1 determined that my husband was incompetent to stand trial and ordered the Greene County Jail to transport my husband to the Indiana State Mental Hospital for competency restoration services.

 

On January 2, 2013, my husband was transported to the Indiana’s State Mental Hospital (LSH) in Logansport, Indiana. By the time he was transported, he was having multiple seizures per day. While at the LSH, he received medical treatment, counseling services, and his health improved to include significantly less seizures.

 

On February 12, 2013, while at LSH, my husband was hit in the face by another patient which severely injured his face and caused permanent blindness in his left eye. On February 24, 2013, he received facial reconstruction surgery as a result of the injury. He was prescribed medications for pain and recovery.

 

On March 7, 2013, my husband was rebooked into the Greene County Jail after being deemed competent from LSH. My husband was placed in H2 (with concrete not padded floors) and was told to use his chair as a safety rail to keep him from falling out of his bed and on to the concrete floor. Within hours, my husband had a severe seizure and was moved back into the isolation. It was approximately a week after my husband’s return to the Greene County Jail before he received pain medicine for his surgery. He was also on doctor's orders for two kosher Ensure meal replacements every meal and kosher denture soft fiber food due to him not being able to open his mouth much or chew. My husband was only receiving one non-kosher Ensure meal replacement per meal time, which he was refusing to eat due to it being non-kosher. My husband stated that he was told by a jailer the only special meal the jail was required to provide was a diabetic meal and that they (the jail) would try to get some kosher items in the commissary in case my husband would like to purchase something. He was also on doctor's orders to sleep with his head elevated to help alleviate the pain, help with drainage and swelling in order to help the healing process. He was told to use his bed mat or his blanket if he needed his head propped up. He was also told by a jailer that the commissary might be able to get some pillows he could purchase.  The open wound from his surgery became infected by the lack of drainage and the inability to keep it clean.

 

My husband’s time spent at Indiana’s Greene County Jail located in Bloomfield, Indiana opened our eyes to the total lack of humanity some people in positions of authority can have. As soon as we could, we hired Waples & Hanger of Indianapolis, Indiana to file a tort claim for our case.  After doing so, the law firm decided our case would be too tough to win. Therefore, we choose to represent ourselves as Pro Se and first filed our case August 11, 2014. We were just barely able to keep our case going in the federal system, but received a docket number. We realized that we were way over our head and were able to find a law firm that would work on an hourly rate instead of a firm that just takes a percentage of the court payment. A long time Navy buddy of mine loaned us money to hire Alex Beeman, Senior Associate Attorney from Ciobanu Law, P.C. located in Indianapolis, Indiana. Unfortunately, we do not have the funds to keep up with all the legal costs.

 

This whole experience has been extremely humbling. We are thankful, though, that my husband’s paralysis was due to his conversion disorder. According to the Mayo Clinic, conversion disorder, also called functional neurological symptom disorder, is a condition in which you show psychological stress in physical ways. The condition was so named to describe a health problem that starts as a mental or emotional crisis — a scary or stressful incident of some kind — and converts to a physical problem. The signs and symptoms appear with no underlying physical cause, and you cannot control them. Then April 2014, Twenty months after his paralysis started and months after physical therapy, he was able to walk with the assistance of a cane.

 

I understand that my husband made some bad choices. We respect that and we understand there are consequences for those actions. However, it does not mean that he should be treated with any less dignity or human rights as the next individual. Furthermore, being a service member, law enforcement officer, politician, priest, teacher, coach, grandparent, parent, or child does not make us impervious to corruption it is our choice and our integrity that makes us imperious to corruption.

 

So this we request of you, every penny helps get us closer to our goal of paying our attorney. We have exhausted our resources during this entire endeavor to include the selling of everything of value even our wedding rings. We are on a fixed income as I had to resign my federal employment to be the home healthcare aid for my husband as well as take a medical discharge for my military service. Our three children, ages 17, 14, and 6 are extremely understanding to our situation and finances. So much so that our 6 year-old asks if things are on sale or if we have a coupon before he asked to buy something…

 

As this case is already in the federal system, there is not a set deadline for our campaign funds rather a steady need. We are paying our attorney at an hourly rate. We feel this campaign is greater than us. We want to see change in our penal system and accountability for inhumane treatment. We want oversight of the penal systems to be from an outside entity. We want all individuals incarcerated to wear a type of health monitoring wristband which would continually record all vital signs. We should not have to live in fear of inhumane treatment of ourselves or our loved ones if ever incarcerated for even one night. We should not be left to a jailor’s prejudice nor should they be able to act as the judge and executioner.

 

Thank you so very much for taking the time to read this, share this, and any amount that you can donate. For your reference, I have uploaded screenshot photos of the first filing log and the most recent. As soon as something else is filed with the court, I will give an update.

 

Below are the violations that we filed:

 

COUNT 1: §1983—FOURTH AMENDMENT “CRUEL AND UNUSUAL PUNISHMENT”

Defendant’s actions constitute a violation of the Fourth and Fourteenth Amendment of the United States Constitution which is actionable under 42 U.S.C. §1983.

COUNT 2: §1983—EIGHTH AMENDMENT CRUEL AND UNUSUAL PUNISHMENT

Defendant’s actions constitute a violation of the Eighth and Fourteenth Amendment of the United States Constitution which is actionable under 42 U.S.C. §1983.

COUNT 3: §1983—FIRST AMENDMENT FREEDOM OF RELIGION

Defendant’s substantially burdened Long’s exercise of his religion in violation of the First and Fourteenth Amendment of the United States Constitution which is actionable under 42 U.S.C. §1983.

COUNT 4: INDIANA’S RELIGIOUS FREEDOM RESTORATION ACT

Defendant’s substantially burdened Long’s exercise of his religion in violation of Ind. Code § 34-13-9 et seq.