RALEIGH, N.C. - TelAve -- RALEIGH, N.C. — A Second Amended Complaint filed in the U.S. District Court for the Eastern District of North Carolina outlines a coordinated pattern of misconduct involving the Raleigh Police Department, the Wake County District Attorney's Office, and multiple supervising officials. The filing names the City of Raleigh, Police Chief Rico Boyce, District Attorney Lorrin Freeman, senior police supervisors, SEU officers, prosecutors, and a city attorney for conduct that violated constitutional protections and hindered access to critical evidence.

Filed by Abdul Kareem Hernandez, the complaint describes a fabricated search warrant, a forced entry executed in about three seconds, false statements in official reports, body-camera violations, and long-concealed law-enforcement records until the matter received heightened judicial attention in 2025 after Mr. Hernandez filed an injunction.

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The affidavit included a false criminal-history entry and omitted an active Protective Order barring the state's witness from the residence. Despite no exigency, officers forced entry while two minor children were inside. The City of Raleigh is described as maintaining practices that enabled unconstitutional knock-and-announce violations, defective warrants, and prolonged evidence suppression.

Chief Rico Boyce approved and ratified the Forced Entry Report (FER).
Sgt. David McDonald authorized the breach and signed the defective FER.
Lt. Matthew VanAntwerp approved the FER despite omissions.
Sgt. Kelly Kinney oversaw tactical decisions and supporting reports.

Detective Rishar Monroe authored the defective affidavit, omitted the Protective Order, failed to activate body-camera equipment, and filed contradictory reports.
Officer David Garner performed the mechanical breach and prepared the FER while omitting key details.

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Officer David Mead acted as physical breacher and staged evidence.
Officers Lindsay Faust and Thomas Webb contributed to incomplete records by failing to document facts they observed.

DA Lorrin Freeman, ADA Guadalupe Howell, and ADA Thomas Crosby continued prosecution despite missing discovery. City Attorney Anna Davis drafted an order restricting access to the FER, preventing its use in the federal lawsuit.

"For nearly three years, critical evidence was withheld," said Abdul Kareem Hernandez.

The case is pending before U.S. District Judge Terrence W. Boyle.

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