A Salt Lake City woman begged police not to kill her. In a new lawsuit, her family alleges the officers were not properly trained.

Megan Mohn died on Jan. 30, 2022 — 19 days after she became unresponsive during her arrest.

(Bethany Baker | The Salt Lake Tribune) Kseniya Kniazeva, shown here on Wednesday, March 22, 2023, holds a portrait of her friend Megan Mohn at the site where Mohn became unresponsive during her arrest in Salt Lake City, Utah. Mohn died in the hospital 19 days later. Mohn's family has now filed a lawsuit against Salt Lake City and its police department.

The family of a woman who died after she was restrained by Salt Lake City police in January 2022 filed a lawsuit against the city on Friday, alleging officers were not properly trained and violated the woman’s constitutional rights — which led to her death.

The police department said in a Saturday statement they had not yet received a copy of the filing, and the city declined to comment on the lawsuit’s claims.

Megan Joyce Mohn, 40, was taken into custody by Salt Lake City police officers in the early hours of January 11, after authorities received a report of a woman “walking in circles carrying a piece of rebar” at the intersection of 400 West and 900 North. An off-duty Salt Lake City officer who was working a second job at a nearby refinery had ordered Mohn to drop the rebar, and the woman complied, according to a news release from Salt Lake City Police.

But when she was ordered to sit on the ground, she “kept screaming incoherent language,” resisted arrest and tried to run away, the release states. That’s when the off-duty officer took her into custody and called for backup at about 3:30 a.m.

Body camera footage of the altercation shows Mohn begging for help, saying, “They’re going to kill me!” At about 3:39 a.m, Mohn continues to refuse to give authorities her name and an officer begins to cut off the backpack she’s wearing, the body camera footage shows. She starts to kick, and one of the officers forces her onto her stomach, where she remains for the rest of the arrest.

By 3:45 a.m., Mohn became unresponsive, and she was later transported to a hospital. She was pronounced dead nineteen days later, on Jan. 30. Six months later, on July 28, 2022, the state Medical Examiner’s office ruled Mohn’s death a homicide.

The allegations

The suit was filed Dec. 8, and names 10 “John and Jane Does” as defendants — which the suit identifies as the officers who restrained Mohn on Jan. 30, along with “individuals responsible for implementing SLCPD’s unconstitutional customs,” which the suit alleges caused Mohn’s death. Salt Lake City is also named as a defendant.

The suit alleges Salt Lake City police officers, along with the city, violated Mohn’s fourth amendment right against unreasonable search and seizure.

The filing also alleges a Monell liability and a Canton liability against Salt Lake City, which means the city can be held accountable for constitutional violations related to failing to train its employees, according to legal database Justia.

“With deliberate indifference to the rights of citizens, Salt Lake City failed to provide adequate training to its officers on the use of prone and neck restraints,” the filing states. “[Officers] apparently believed that they could hog-tie Megan in the prone position and put their collective weight on her for over 4.5 minutes even though she was intoxicated and in a state of excited delirium, and even though she posed no immediate threat to the public or the Officers’ safety.”

Mohn’s cause of death was “anoxic brain injury” due to cardiac arrest, the medical examiner ruled, which was due to “probable methamphetamine intoxication in the setting of an altercation involving physical restraint.”

The hazards of restraints

Dr. Alon Steinberg, chair of cardiology at Community Memorial Hospital in Ventura, California, has studied the use of prone restraint and cardiac death. In cases where people are placed facedown and restrained — like Mohn was — Steinberg said that there is potential restriction in ventilation and circulation, which can be fatal.

“When you have a cardiac arrest — meaning the heart’s not pumping any blood flow to the whole body — but the most vulnerable area is the brain,” Steinberg said during an interview with The Tribune in August 2022. “So if the brain doesn’t get oxygen for four or five minutes, it could be quite catastrophic.”

The complaint alleges police were also not regularly trained on use of force methods and de-escalation tactics, which caused the adoption of “outdated and deficient training practices.”

The suit seeks an undetermined amount of compensatory and punitive damages, and also seeks to ensure Salt Lake City properly trains its officers on their use of force and restraints.

Salt Lake City Police Chief Mike Brown said in a July 2022 statement that the four officers involved “acted appropriately, quickly and professionally to save” the woman’s life when she was arrested. The four officers were placed on paid leave in late July 2022, after the cause of death was determined and police initiated the “officer-involved critical incident” protocol.

The officers returned to duty in Sept. 2022, according to a police spokesperson.