One agent drew his weapon and pointed it at [their 9 year old U.S. Citizen son] and his mother, causing the boy to fear the agents would kill him and his family. Even after the agents realized they were in the wrong house, the agents remained in the house questioning Chavez and Galindo and they made explicit threats to take the boy away from his parents. When the agents finally left the house one of the agents announced, “We’re going to come back. And next time it will be worse.” The amended complaint alleges that Galindo and her son experienced severe trauma as a result of the raid. They are unable to sleep and fear the agents’ return. Chavez and Galindo have found their son crying and shaking in the night, and he becomes afraid every time the doorbell rings.
