Lanham

CHARLESTON - A Charleston woman has filed suit against the city of Dunbar alleging she was the victim of repeated harassment by its officers, including one who pled guilty to violating another woman's civil rights last year.

Megan Lanham named the city of Dunbar as a co-defendant in lawsuit filed in Kanawha Circuit Court on July 8. In her suit, Lanham, 26, a Charleston resident, alleges three Dunbar Police officers, including Raymond O. Conley, constantly harassed her for a two-month period in 2008 which ended in her arrest on drug charges when she rebuffed Conley's sexual advances.

The suit comes after Conley was convicted in April on federal civil rights charges for having sex with a woman following her arrest on drug charges.

Threats of arrest, eviction

According to her suit, Lanham alleges she was subjected to a "systematic course of harassment, intimidation, and threats," beginning in April 2008 by Conley and officers Elliott and Moss. Elliott's and Moss' first names are not stated in court records.

The three, she says, would "congregate outside [her] home" on Moore Avenue "and sit and stand around for no apparent reason, other than to harass, intimidate, scare and threaten" her. She alleges they would appear "on a weekly and sometimes daily basis."

All three are named as co-defendants in Lanham's suit.

The harassment escalated when Conley "made numerous warrantless, unlawful and unreasonable searches" of Lanham and her home. Her lawsuit does not specify when these occurred.

Conley, Lanham alleges, on at least one occasion asked to see her " 'identifying marks'" that included tattoos on private parts of her body. She not only refused to show him her tattoos, but also "go out to dinner with him and have a romantic relationship with him."

Angered at being rebuffed, Lanham says Conley threatened to take her son away, and put her jail if she refused to let him into her home when he stopped by or answered his telephone calls. He insinuated the department had evidence of marijuana, and methamphetamines taken from her apartment from prior searches they would use against her.

Conley's efforts also included informing Lanham's landlord, Carol Latiolas, he, Elliott and Moss would seize the apartment if she did not evict Lanham for drug activity. Their communication with Latiolas included a letter sent by the Dunbar Police Department on an unspecified date informing Latiolas of Lanham's suspected drug activity despite no formal charges filed against her.

Tired of the harassment, Lanham says she complained about Conley to DPD on an unspecified date. The complaint, she alleges, resulted in her arrest on June 13, 2008, "in front of neighbors, friends, and her son, on the false pretense of simple possession of marijuana."

According to her lawsuit, the charge was dismissed in Dunbar Municipal Court on July 8, 2008 on the condition she leave Dunbar for six months. Though Latiolas let her out of the rental agreement on the apartment, Lanham alleges due to Conley's, Elliott's and Moss' actions she incurred "considerable cost, inconvenience, humiliation and other expenses involved in moving."

Following her departure from Dunbar, records show Lanham was arrested on two separate occasions on meth-related charges. The first was in April 2009 in Malden where she was charged with operating a meth lab and exposing a child to meth, and the other in August in Charleston where she was charged just with operating a meth lab.

Records show on the former charges she plead guilty in December to a misdemeanor charge of possession of a controlled substance, and on the latter the charges were dismissed at her preliminary hearing on Aug. 17 when the Kanawha County Prosecutor's Office informed Magistrate Ward Harshbarger they were unable to proceed with the case.

In her civil suit, Lanham makes claims against the city, Conley, Elliott and Moss for negligence, negligent infliction of emotional distress, and negligent supervision and training. She alleges their "negligent and/or reckless and wanton substantial disregard of [her] rights" led her to incur, among other things, "pain and suffering, emotional distress, mental anguish, moving and storage expenses, embarrassment, humiliation, damage to her reputation, annoyance and inconvenience [and] loss of enjoyment of her normal pursuits.

Lanham seeks unspecified damages, court costs and attorney fees. She is represented by former Kanawha County Prosecutor William C. Forbes, and his son, W. Jesse Forbes.

The case is assigned to Judge James C. Stucky

Conviction for similar allegations

Lanham's suit comes three months after Conley was convicted on April 21 in U.S. District Court on a misdemeanor charge of depriving someone of rights under the color of law. Conley, who was indicted on a felony charge of information in October, was able to plead to the misdemeanor charge in December after agreeing to resign from DPD, where he obtained the rank of sergeant, and surrender his law enforcement certificate.

The charge stemmed from a stop Conley made on July 19, 2009, on an unidentified woman for suspicion she was carrying a concealed weapon. Though a weapon was not found, he did find a small amount of marijuana on her, and placed her under arrest.

However, instead of taking her to DPD for booking he took her to a remote area, and had sex with her. After their encounter, he released her, and did not press charges.

According to the U.S. Bureau of Prisons, Conley, 40, is currently incarcerated at the Federal Corrections Institution in Elkton, Ohio. He is scheduled for release on May 24, and will serve another year on supervised probation.

Kanawha Circuit Court case number 10-C-1241

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