IN THE DISTRICT COURT OF GRADY COUNTY
STATE OF OKLAHOMA
ERIC CULVER,
ANGEL ARRINGTON, and
KELLY PENNEL,
Plaintiffs,
-v.-
GRADY COUNTY SHERIFF OFFICE,
KENTON BLUMENTHAL,
HAYDEN JARRETT,
MAX RINEHART, and
TYLER HOGAN,
Defendants.
PETITION
COMES NOW, the Plaintiffs, Eric Culver, Angel Arrington, and Kelly Pennel, and for cause of action against the Defendants, and states to the Court as follows, to-wit:
1. That the Plaintiffs are individual residents of Chickasha, Grady County, State of Oklahoma.
2. That the Defendant Grady County Sheriff Office is a governmental entity with a principal place of business in Chickasha, Grady County, State of Oklahoma.
3. That the Defendants, Kenton Blumenthal, Hayden Jarrett, Max Rinehart, and Tyler Hogan, are individual employees of the Grady County Sheriff Office located in Chickasha, Grady County, State of Oklahoma.
4. That the acts which are subject of this matter occurred within Chickasha, Grady County, State of Oklahoma, and therefore this Court has jurisdiction of this matter under 12 Okla. Stat. § 133.
FACTUAL ALLEGATIONS
1. That the acts of which give rise to this action occurred on April 7th, 2026, at 1523 S. 14th Street, Chickasha, Grady County, State of Oklahoma.
2. That the Defendants entered the aforementioned property in an attempt to locate the Plaintiff, Eric Culver.
3. That the Defendants then performed numerous actions against the Plaintiffs giving rise to this lawsuit.
4. That the Plaintiffs are entitled to relief as outlined below for compensatory and punitive damages.
REQUEST FOR RELIEF
COUNT 1: BREAKING AND ENTERING
COMES NOW, the Plaintiffs, and hereby incorporate and restate the above and foregoing statements, and further state to the Court as follows:
1. The Plaintiffs are afforded under the Fourth Amendment of the United States Constitution to be secure in their persons, houses, papers and affects against unreasonable searches and seizures, more specifically, law enforcement is required to obtain certain warrants, and/or consent prior to entering the dwelling of a private individual where a person has a reasonable expectation of privacy.
2. The Plaintiffs, on the 7th day of April, 2026, had their rights under the Fourth Amendment violated by the Defendants.
3. The Plaintiff, Angel Arrington, an individual currently leasing the real property located at 1523 S. 14th Street, Chickasha, Oklahoma, had the Defendants enter, by use of force, the main home without a valid warrant or consent.
4. The Plaintiff, Kelly Pennel, who resides on the real property within a separate dwelling, also had the Defendants enter her residence without a valid warrant, and without consent by use of verbal threats.
5. The Plaintiffs, Angel Arrington and Kelly Pennel, have the right to refuse access into their private residence unless a valid warrant is established, yet, the Defendants entered the home of Arrington by forcefully kicking the door to the residence until the door shattered into multiple pieces.
6. The Plaintiff, Angel Arrington, was then confronted by Defendant Blumental who had drawn his gun upon entering the residence along with Defendant Jarrett.
7. The Plaintiff, Kelly Pennel, was confronted by Defendants Hogan and Rinehart, who threatened to take Pennel to jail as she questioned their entry into her residence in the rear of the main home.
8. The Defendants actions were in violation of the Fourth Amendment of the United States Constitution, and arise to that of Malicious Mischief as the motivation to enter both homes was motivated by malice and falsity, causing damage to the main residence of Arrington.
9. The Defendants have committed the act of breaking and entering, having no valid right to enter the dwelling structures as defined in 21 Okla. Stat. § 1438 (B).
WHEREFORE, the Plaintiffs, Angel Arrington and Kelly Pennel, pray upon hearing of this matter that this Honorable Court, grant the Plaintiffs relief by way of punitive damages, and for any and all such other relief as they may be entitled to receive in equity.
COUNT 2: ASSAULT AND ASSAULT AND BATTERY
COMES NOW, the Plaintiffs, and hereby incorporate and restate the above and foregoing statements, to include those in Count 1, and further state to the Court as follows:
ARRINGTON
1. The Plaintiff, Angel Arrington, was contacted by Defendant Jarrett while outside of her residence located at the aforementioned address in the City of Chickasha, Grady County, State of Oklahoma on April 7th, 2026.
2. The Plaintiff, Arrington, was instructed to enter her home to locate Plaintiff, Eric Culver, in regard to a misdemeanor warrant which had been issued on April 6th, 2026.
3. The Plaintiff, Arrington, entered her residence where she resides with her disabled child.
4. The Plaintiff, Arrington, is the only person who is named on the lease of the real property, and her and her child are the only residents of the properties main home.
5. The Plaintiff, Arrington, informed Defendant Jarrett, that Plaintiff Culver was not in the property.
6. The Plaintiff, Arrington, then re-entered her home and closed herself, her child, and her dogs within the home.
7. The Plaintiff, Arrington, after having locked the door to her home, shortly thereafter began to hear the Defendants banging violently upon her front door.
8. The Plaintiff, Arrington, then heard the Defendants begin to kick her front door to her residence with force and violence.
9. The Plaintiff, Arrington, then observed her front door to shatter into several pieces, and Defendant Blumenthal enter her home with his weapon drawn.
10. The Plaintiff, Arrington, feared harm to herself and her disabled son due to the nature of force and violence utilized by the Defendants to enter her home.
11. The Plaintiff, Arrington, was then removed from her residence and placed into handcuffs.
12. The Plaintiff, Arrington, was then confronted by Defendants who informed her that she was going to jail if she did not pursue action against Plaintiff Culver by way of a protective order.
13. The Plaintiff, Arrington, was willfully and intentionally confronted by Defendants causing her to fear physical harm, and was in fact battered by Defendants who unjustly placed her into handcuffs.
PENNEL
14. The Plaintiff, Pennel, was contacted by Defendant Rinehart and Hogan, in the rear of the main residence, at Pennel’s residence.
15. The Plaintiff, Pennel, was alerted to the presence of the Defendants by her dog barking.
16. The Plaintiff, Pennel, was instructed to put her dog in her residence by Defendants.
17. The Plaintiff, Pennel, was then instructed to remove her dog and that Defendants were going to go inside her residence.
18. The Plaintiff, Pennel, was assaulted by Defendants as they threatened to take her to jail when she questioned why they were going into her residence. Pennel never provided permission for the Defendants to enter into her residence.
19. The Plaintiff, Pennel, was placed in a state of fear due to the threats made by the Defendants to her. The only person whom resides with Pennel is her daughter.
CULVER
20. The Plaintiff, Eric Culver, is a resident of Chickasha, Oklahoma.
21. The Plaintiff, Culver, is not a resident of the above and aforementioned address, which is leased by Plaintiff Arrington.
22. The Plaintiff, Culver, had a misdemeanor warrant which was issued on April 6th, 2026.
23. The Plaintiff, Culver, was alerted to the presence of the Defendants at the time that they began violently banging on the front door, and kicking the front door of the residence of Arrington.
24. The Plaintiff, Culver, began going to the door informing the Defendants that he was exiting the home as they kicked the front door.
25. The Plaintiff, Culver, was not aware of a warrant being issued for his arrest prior to the events taking place.
26. The Plaintiff, Culver, immediately laid on the floor of the residence when the door began to shatter as the Defendants, entered the residence.
27. The Plaintiff, Culver, was placed in fear of bodily harm due to Defendant Blumental entering the home with his gun drawn.
28. The Plaintiff, Culver, was placed into handcuffs by Defendants.
29. The Plaintiff, Culver, after having been placed into handcuffs was struck in the back of the head by Defendant Jarrett, and then struck in the head by Defendant Blumental.
30. The Plaintiff, Culver, was then searched by the Defendants, and while taking items out of Plaintiff Culver’s pockets, Defendants struck him in the area of his head and face with each item that was removed.
31. The Plaintiff, Culver, was struck multiple times by Defendants while he was in handcuffs to the area of his head and face.
32. The Plaintiff, Culver, was willfully and maliciously placed in a state of fear due to the assault and battery at the hands of Defendants.
WHEREFORE, the Plaintiffs, Angel Arrington, Eric Culver, and Kelly Pennel, pray upon hearing of this matter that this Honorable Court, grant the Plaintiffs relief by way of punitive damages, and for any and all such other relief as they may be entitled to receive in equity.
COUNT 3: FALSE IMPRISONMENT
COMES NOW, the Plaintiffs, and hereby incorporate and restate the above and foregoing statements, to include those in Count 1 and 2, and further state to the Court as follows:
1. The Plaintiff, Angel Arrington, and Plaintiff, Kelly Pennel, were unlawfully detained by Defendants against their will.
2. The Plaintiff, Arrington, was placed into handcuffs and removed from her home after having lawfully shut the door to her residence.
3. The Plaintiff, Arrington, was held by Defendants outside her residence and against her will while Defendants informed her that she would be taken to jail if she did not file a frivolous report against the Plaintiff Eric Culver.
4. The Plaintiff, Arrington, had a lawful right to enter her residence and refuse contact with Defendants whom did not have a warrant for her or her residence.
5. The Plaintiff, Arrington, was falsely imprisoned as the Defendants did not have a lawful reason to detain her, and the detainment was against her will.
6. The Plaintiff, Pennel, was unlawfully detained and removed from her residence by Defendants.
7. The Plaintiff, Pennel, was contact shortly after she had returned home from work.
8. The Plaintiff, Pennel, was initially instructed to place her dog inside her residence, and then was informed to remove her dog and that her home was going to be searched.
9. The Plaintiff, Pennel, was then threatened that she would be going to jail and was held outside of her home.
10. The Plaintiff, Pennel, was unlawfully detained as the Defendants did not have a warrant for her or her residence, and the holding outside of her home was against her will.
WHEREFORE, the Plaintiffs, Angel Arrington and Kelly Pennel, pray upon hearing of this matter that this Honorable Court, grant the Plaintiffs relief by way of punitive damages, and for any and all such other relief as they may be entitled to receive in equity.
COUNT 4: INTENTIONAL INFILCTION OF EMOTIONAL DISTRESS
COMES NOW, the Plaintiffs, and hereby incorporate and restate the above and foregoing statements, to include those in Count 1, 2, and 3, and further state to the Court as follows:
1. The Plaintiffs, were subject to extreme and outrageous conduct of the Defendants when contacted on April 7th, 2026.
2. The Plaintiff, Arrington, had spoken with Defendants while outside her residence and was allowed to enter her home.
3. The Plaintiff, Arrington, then later shut her door as she did not wish to communicate with Defendants any longer.
4. The Plaintiff, Arrington, after locking her door was subjected to the Defendants banging violently on her door and cussing for her to "open this fucking door" repeatedly.
5. The Plaintiff, Culver, was altered to the presence of Defendant due to the violent conduct of the Defendants upon the front door of the residence.
6. The Plaintiff, Arrington and Culver, were then subjected to the door of Arrington’s residence being kicked until it shattered and the Defendants entered the residence without a warrant to search the same with a firearm drawn by at least one Defendant.
7. The Plaintiff, Arrington and Culver, were then assaulted, and battered by the Defendants as outlined in Count 2 above.
8. The Plaintiff, Arrington, was then threatened by Defendants that she was going to jail, and then informed that she would need to file a protective order against Plaintiff Culver to avoid going to jail.
9. The Plaintiff, Pennel, was contacted by Defendants in the manner as outlined in Count 1 and 2 above.
10. The Plaintiff, Pennel, was threatened that she was going to jail if she questioned why her residence, separate from the main home of Arrington, was being searched.
11. The conduct of the Defendants towards each and every Plaintiff named herein was extreme and outrageous, as the Defendants acted with reckless disregard in causing emotional distress to the Plaintiffs.
12. The Plaintiff, Arrington and Pennel, each have children whom reside in their home and the threats made by Defendants caused severe distress in regard to them being threatened with jail and the welfare of their children.
WHEREFORE, the Plaintiffs, Angel Arrington, Eric Culver, and Kelly Pennel, pray upon hearing of this matter that this Honorable Court, grant the Plaintiffs relief by way of punitive damages, and for any and all such other relief as they may be entitled to receive in equity.
COUNT 5: NEGLIGENCE
COMES NOW, the Plaintiffs, and hereby incorporate and restate the above and foregoing statements, to include those in Count 1, 2, 3, and 4, and further state to the Court as follows:
1. The Defendants were negligent in their actions against the Plaintiffs of whom they owed a duty to act in a reasonable and prudent manner within the scope of duty of a law enforcement officer.
2. The Defendants breached the duty owed to the Plaintiffs in violently kicking in the door to the residence of Plaintiff Arrington to affect service of a misdemeanor warrant on Eric Culver.
3. The Defendants failed to establish that the Plaintiff Culver did not reside at the residence of Plaintiff Arrington, and failed to act as a reasonable and prudent law enforcement officer in obtaining a warrant to search the premises of Arrington for Culver.
4. The Defendants breached the duty owed to Plaintiff Arrington and Pennel, by threatening both Plaintiffs with jail if they did not file a false report against Culver (Arrington) and did not allow and questioned search of the residence (Pennel).
5. The Defendants acted negligently in battering Plaintiff Culver while he was in handcuffs and restrained.
6. The Defendants breached the duty of care owed to the Plaintiffs in performance of the duties of a law enforcement officer, causing damages to the Plaintiffs.
7. The Defendants caused measurable damages to the home of Plaintiff Arrington due to their negligent acts.
WHEREFORE, the Plaintiffs, Angel Arrington, Eric Culver, and Kelly Pennel, pray upon hearing of this matter that this Honorable Court, grant the Plaintiffs relief by way of punitive and compensatory damages, and for any and all such other relief as they may be entitled to receive in equity.
COUNT 6: DAMAGES
COMES NOW, the Plaintiffs, and hereby incorporate and restate the above and foregoing statements, to include those in Count 1, 2, 3, 4, and 5, and further state to the Court as follows:
1. The Plaintiffs seek damages which are compensatory and punitive against the Defendants.
2. The Plaintiff, Arrington, suffered actual damages to the residence of which she is currently renting or in a lease agreement with a third party to occupy.
3. The Plaintiff, Arrington, is required to repair the damages made to the door which was shattered by the Defendants when they kicked in the door without a valid search warrant for the home.
4. The Plaintiff, Arrington, should be awarded not less than $1,000.00 for the repair of the door and threshold of the residence.
5. The Plaintiffs herein are entitled to compensatory damages for the negligent acts of Defendants causing emotional distress and mental anguish as outlined in Count 4 and 5 above.
6. The Plaintiffs are entitled to punitive damages against the Defendants as outlined in all counts above due to the actions of the Defendants in their lack of complying with the proper duty of care.
WHEREFORE, the Plaintiffs, Angel Arrington, Eric Culver, and Kelly Pennel, pray upon hearing of this matter that this Honorable Court, grant the Plaintiffs relief by way of punitive and compensatory damages, and for any and all such other relief as they may be entitled to receive in equity.
COUNT 7: REQUEST FOR RELIEF
COMES NOW, the Plaintiffs, and hereby incorporate and restate the above and foregoing statements, to include those in Count 1, 2, 3, 4, 5, and 6, and further state to the Court as follows:
1. The Plaintiffs request the following relief:
a) Punitive damages in excess of $50,000.00
b) Compensatory damages in excess of $75,000.00
c) Actual damages not less than $1,000.00
d) And for any and all such other relief as the Court deems just and equitable
e) All award to be jointly and not severally.
Respectfully submitted,
Eric Culver, Angel Arrington, and Kelly Pennel.
__________________________
ANNA K. VAN DYCK, OBA# 35015
VAN DYCK LAW OFFICE, PLLC
P.O. BOX 909
CHICKASHA, OK 73023
(572) 236-3100
(572) 236-3101-Assistant
[email protected]
[email protected]
VERIFICATION
STATE OF OKLAHOMA )
COUNTY OF GRADY ) ss:
ERIC CULVER, being first duly sworn upon oath says:
That he is the Petitioner above named, that he has read the foregoing Petition and knows the contents thereof, and that the facts therein set forth are true and correct as he verily believes.
Eric Culver
Subscribed and sworn to before me this 24th day of April, 2026.
Melissa Tarver
NOTARY PUBLIC
(Seal)
VERIFICATION
STATE OF OKLAHOMA )
) ss:
COUNTY OF GRADY )
Angel Arrington, being first duly sworn upon oath says:
That she is the Petitioner above named, that she has read the foregoing Petition and knows the contents thereof, and that the facts therein set forth are true and correct as she verily believes.
Angel Arrington
Subscribed and sworn to before me this 24th day of April, 2026.
MELISSA TARVER
NOTARY PUBLIC
#23000520
EXP: 1/9/2027
Melissa Tarver
NOTARY PUBLIC
(Seal)
VERIFICATION
STATE OF OKLAHOMA )
COUNTY OF GRADY ) ss:
Kelly Pannel, being first duly sworn upon oath says:
That she is the Petitioner above named, that she has read the foregoing Petition and knows the contents thereof, and that the facts therein set forth are true and correct as she verily believes.
[Signature]
Kelly Pannel
Subscribed and sworn to before me this 24th day of April, 2026.
(SEAL)
Melissa Tarver
NOTARY PUBLIC
