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On June 17, 2016, at approximately 5:00 p.m. the Plaintiffs, two Apple account holders, entered the Apple Store located at 4860 Bethesda Avenue, Bethesda, Maryland 20814, to purchase two new cellphones. The Plaintiffs followed proper Apple Store protocol and placed their names on a “list” of customers in need of assistance. The Plaintiffs waited in the store until an employee arrived to assist them. While waiting for their names to be called pursuant to Apple’s protocol and procedure, the Plaintiffs were subjected to constant stares and glares by Apple Store employees, though the Plaintiffs did not understand the need for such stares and glares, as the Plaintiffs had done nothing wrong and had committed no criminal act.

“Why they starin at us. Deys Whiteys starin at us”

“Why are those black people staring at us? They are looking shifty call the cops”


At approximately 5:19 pm, the Plaintiffs names were called and they were called to the purchasing counter. While at the counter, the Plaintiff provided their Apple and Verizon Store account information and requested to purchase two iPhone 6s, 64GB model cellphones. The Apple Store employees retrieved two cellphones from their stock. Both Plaintiffs then purchased the cellphones for $793.94 each. Upon information and belief, the Apple Store employees verified the validity of their accounts prior to the Plaintiffs being called to the purchasing counter.


After spending almost $1600 at the Apple Store, the Plaintiffs began walking toward the door of the Apple Store location. Upon opening the store door to exit, the Plaintiffs were accosted by two uniformed Montgomery County Sherriff s Department officers who detained them for almost an hour in front of the Apple Store location. The Plaintiffs were tackled and slammed to the ground by the officers who then required the Plaintiffs to sit on the ground with the heat of the sun pounding upon their bodies, as passers-by looked upon them. The Plaintiffs were humiliated and felt ridiculed and harassed.