WASHINGTON — Minneapolis resident Aliya Rahman on Thursday filed a complaint against the Department of Homeland Security over federal immigration enforcement officers’ “brutal tactics and conduct” toward her in January, when they inexplicably dragged her out of her car on her way to a doctor’s appointment.

Rahman, whose violent arrest was captured on video and went viral, filed a Federal Tort Claims Act claim, alleging unlawful use of force and detention by DHS agents. It’s essentially an administrative complaint, but it is the first step necessary for bringing a lawsuit against the federal government, which Rahman intends to do.

Here’s a copy of her complaint, first obtained by HuffPost:

“The federal officers’ brutal tactics and conduct during her arrest and detention on January 13th were flagrantly illegal, violating, among other laws, the Constitution, disability law, and agency regulations and policies related to disability accommodations, use of force, arrest practices, detention practices, and provision of medical care,” reads the complaint, submitted on Rahman’s behalf by her legal team at The MacArthur Justice Center and Minnesota-based attorney Al Gerhardstein of Friedman Gilbert + Gerhardstein.

“Moreover, federal officers violated the mandatory duties of care they owed to Aliya under federal and state law,” it reads. “These duties include, but are not limited to, ensuring the health and safety of individuals detained in DHS/ICE/CBP custody, providing essential medical care, and providing necessary disability accommodations. The federal officers’ unlawful conduct caused Aliya damages.”

In a statement, a DHS spokesperson accused Rahman of trying to “smear” federal officers and said she was obstructing their operations in January.

“As officers carried out their law enforcement duties, a significant crowd surrounded them and began impeding law enforcement operations — a federal crime,” the spokesperson said. “One agitator ignored multiple commands by an officer to move her vehicle away from the scene, she was arrested for obstruction. Any claim she was denied medical care is FALSE and just another smear leading to a 1,300% increase in assaults and 3,300% increase in vehicular attacks. Reminder: Obstruction law enforcement is a federal crime and a felony.”

Rahman, a Bangladeshi American software engineer who is autistic and has physical disabilities, was driving to a doctor’s appointment on Jan. 13 when federal agents stopped her car, smashed in the passenger window and cut her out of her seat belt to haul her onto the street. She was taken to a federal detention center notorious for its poor conditions.

Rahman testified to Congress in February about her assault and detention, where her requests for medical care were ignored for hours until she fell unconscious and a cellmate had to beg for help. She believes she almost died that day.

As if that wasn’t enough trauma, while attending the State of the Union address in February as a guest of Rep. Ilhan Omar (D-Minn.), Rahman was inexplicably dragged out and arrested for standing up. The government ultimately opted not to seek charges.

In a Wednesday interview, Rahman told HuffPost it’s “extremely important” to her to take legal action against the federal agents who assaulted her, in part because she wants other people to see that they can also bring such action if necessary.

You can’t sue a federal agent for constitutional violations directly, but you can file an FTCA claim as a workaround that allows you to sue for improper actions by a government employee. State laws are the basis for filing such claims, which then open the door to filing a federal lawsuit.

“At first, I was like, wow, we can’t sue a federal ICE officer,” Rahman said. “But states are fighting back against the federal government. States are standing up and saying, ‘Not in our state.’ It’s extremely important we do anything we can to be a force multiplier.”

“This shows we can hit back,” she said.

DHS has six months to respond to her complaint.

“They may not respond, which is common, or they could offer a response we don’t like or deny our claim,” said Rahman’s attorney, Jessica Gingold of The MacArthur Justice Center. “After that, we get to take this to court, which we have every intention of doing.”

She ultimately expects to file a lawsuit in a Minnesota district court.

Rahman’s assault took place at the height of the Trump administration’s surge of federal immigration enforcement agents in Minnesota, when thousands of officers swarmed the state looking for brown and Black people to detain, regardless of their citizenship or criminal record. Their monthslong occupation traumatized communities, tore families apart and resulted in two Americans being killed by federal agents, Renee Good and Alex Pretti.

Rahman’s FTCA claim is seeking a monetary remedy, though her attorney declined to share the dollar amount. Rahman volunteered that, at a minimum, she’s asking to be compensated for medical bills stemming from her assault and denial of care at the detention center.

She also wants to be paid back for the damage federal agents did to her car, which they left un-drivable after smashing in a window and cutting up a seat belt. That cost Rahman more than $700. She recently went to move the passenger seat and heard crunching sounds in the door, the sound of broken glass still inside.

“This is a city that was littered with glass” as federal agents roamed around like children “playing a video game,” Rahman said. “So far, nobody has told them to go to their room and think about what you did. If that’s the only thing that comes from this [lawsuit], good.”

She added: “For me, it’s a duty to do everything I can, use every tool in my box — I’m not elected, I’m not wealthy — to say we’re not going to do this. This is not the country we’re going to have.”

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