Direct Examination Sam Smith Questions

How long have you been a police office?

Just about 23 years of my life

Besides basic police training, do you have any additional law enforcement training?

 I went to Control and Arrest Tactics instructor school and eventually became the lead instructor for all the recruit control and arrest tactic classes at the NYPD Academy. 

Officer, what do you do outside of work?

I work with the County’s board of supervisors as an advisor on handling community housing for people with disabilities

Were you on duty on July 20th, 2023?

Yes, I was on duty and in uniform that day

What happened that caused you to have contact with the Plaintiff that day

I responded to a dispatch about a stolen purse, she matched the description of the suspect

Officer, what was the priority level of the call?

Priority level 1

Do you know what a priority level one call is?

Of course I do

Can you tell the jury why it was such a high priority?

The purse contained a knife in it

Can you tell the jury what kind of response is needed for a priory level one call?

It is the highest level of dispatch intended for life threading emergencies. We have to take the utmost precautions when approaching the scene

After you received the dispatch, what did you do?

I drove to Washington Park to investigate the scene

So, when you first arrived at Washington Park, what did you see?

I noticed someone who pretty much perfectly matched the definition of the suspect. 

Can you give the jury a description of the suspect?

They were 20 years old, wearing a grey tee shirt and red shorts. She looked twitchy and disheveled

What was her name?

Addision Grant

Have you dealt with her before?

Yes, I have

In your past encounters with Grant, has anything stuck out to you?

She gets into a lot of trouble. I’ve arrested her multiple different times for a variety of crimes

What did you do when you arrived at the scene with her?

First, I told her that I was a police officer. Then, I asked her to stand up so I could search her because she matched the description of the suspect

When you told the Plaintiff to stand up, was it your intent to place her into custody?

No, I was just patting her down at the time

How did Grant respond to this?

She got up and said something like “Sure, I’ve got nothing to hide, stupid idiot” and she nearly spat on my face

How did this make you feel?

I felt threatened based on the attitude that Grant was giving me

What happened after this?

Because Grant perfectly matched the suspects description, I informed her that she was under arrest and that she was going to be Brough in for questioning

What was Grant’s reaction to this?

Her arms got really stiff, and she said something about a smell. Right after I told her about the questioning, she started yelling at me

Do you know what it was that she was yelling about?

She yelled “I’m going to seize your…” and then said something I couldn't understand

Okay, what happened after the Plaintiff yelled at you?

I took out my handcuffs and I went to handcuff her

When you took out your handcuffs, how did the Plaintiff react?

Grant started flailing her arms all over the place trying to batter or claw at me. I felt her scratch me multiple times and I began to lose my balance

Did that cause you any pain?

I felt a debilitating, shooting pain up my back.

What did you do in response to your concerns at this point in time?

I warned Grant that if she kept resisting arrest I would use my taser. So that’s what I did. I gave her a shock on the lowest setting

Did the Plaintiff become compliant in response to have being tased?

No, she did not. The shock didn't do much to subdue Grant, but I also didn’t want to hurt her so I didn’t shock her again

What was your response to the Plaintiff’s decision to keep resisting?

I figured that it would be best to try to struggle by hand to handcuff her

What happened next?

Bailey Wilson, one of Grant;s friends suddenly intervened and started yelling at me as I was being attacked

How did the presence of Bailey Wilson impact you?

I was concerned that the pestering by Wilson would defer my full attention needed for the arrest, leading to a more unsafe situation

In response to the situation you were in, what did you do?

I was struggling to take physical control of Grant, so I was forced to use my body weight to control her

Did this allow you to get her under control?

yes

After you were finally able to secure the Plaintiff, what did you do?

I noticed she had fallen unconscious, so I called EMS immediately to get her taken care of

Did you have any knowledge of any medical condition that the Plaintiff may have had?

No, definitely not. In fact, when I arrested her in the past, she told me that she did not have any medical conditions at all at the police station