FACTS

10.  Lynn was taken to UAMS and admitted to the emergency room on January 13, 2024 at or about 5:13 PM. He had full capacity. He submitted to testing to determine if immediate surgery was necessary. The doctors decided there was not an emergent need for surgery. Lynn asked to leave. Instead of allowing Lynn to use his phone to call Hammett or the woman he lived with, UAMS doctors and nurses poisoned Lynn with Fentanyl. They continued to drug him for two weeks, claiming that the effects of the drugs were “incapacity”, and telling Hammett he might be this “out of it” the rest of his life because of the brain injury from the fall.

11.  No one witnessed the fall that caused Lynn’s need for emergency care. Despite evidence to the contrary, the UAMS Workforce adopted the narrative that Sean Lynn fell from 30 to 35 feet.

12.  Lynn remembered the accident in detail on or about February 8, 2024. He was on a ladder with his head at about 16 feet and his feet about 10 feet above ground. The ladder began to fall away from the house it leaned against. There was a steep slope in the direction of the fall, so Lynn decided to jump. He did not calculate for inertia and flipped backwards, landing on his head. He remembers his thoughts as he fell, primarily, concern for his daughter if he died.

13.  This was unquestionably a severe injury, though survival rates from 10 feet are significantly better than from 30 feet. Miraculously, Sean Lynn was relatively unscathed. There was no damage except to his head.

14.  According to a scanned copy of the handwritten triage notes first produced to Claimants on May 9, 2025, 15 months after they requested a copy of the entire medical record:

15.  Upon entry to the ED, Lynn had blood pressure 120/70, heart rate 60, Glasgow Coma Scale 14 (13 – 15 is a “mild” TBI). GCS evaluates three key responses:

• Eye Opening (E): Spontaneous, to voice, to pain, or none
• Verbal Response (V): Oriented, confused, inappropriate words, incomprehensible sounds, or none
• Motor Response (M): Obeys commands, localizes pain, withdraws, abnormal flexion, extension, or none

16.  The only one of 37 Primary Scene Trauma Level 1, 2 and 3 Activation criteria Lynn met was fall greater than 20 feet, which was an error based on an unattributed statement written by an EMT who was not a witness to the fall. There are no known witnesses to the fall except Lynn himself;

17.  Neither “Emergency Physician Discretion” nor “MD/Charge RN discretion” were checked off;

18.  Lynn was noted on the Behavior & Suicide Screen as saying that over the past 2 weeks he had not felt down, depressed, hopeless, nor had thoughts of killing himself, and never had thoughts of killing himself;

19.  There was no indication that patient Lynn “refused” to answer, was “unable to complete” or “was not assessed due to severity of illness”;

20.  It was noted that Lynn’s sensory, motor, and circulatory systems were intact.

21.  iSTAT blood test results at 17:22 showed

 sodium: 141 mmol/L [Ref Range: 135 – 145];

 potassium: 3.8 mmol/L [Ref Range: 3.5 – 5.0];

chloride: 106 mmol/L [Ref Range: 98 – 109];

CO2: 23 mmol/L [Ref Range: 22 – 31];

BUN: 13 mg/dL [Ref Range: 6 – 20];

Glucose: 155 mg/dL [Ref Range: 70-105];

 Hct: 47 % [Ref Range: 40 – 52];

 Hb: 16.0 g/dL [Ref Range: 14.0 – 18.0];

 pH: 7.34 [Ref Range: 7.31 – 7.41];

 PCO2: 41.2 mmHg [Ref Range: 41.0 – 51.0];

 HCO3: 22.2 mmol/L [Ref Range: 23.0 – 28.0];

 BE: -4 mmol/L [Ref Range: -2 – 3]

22.  These results are unremarkable, except for mild metabolic acidosis, which might indicate trauma or dehydration, and slightly elevated glucose, also a normal sign of trauma. There are over 363,000 people in Arkansas with chronic elevated glucose plus those who have trauma induced elevated glucose. There are only about 1,197 ICU beds in Arkansas. It is a matter that can be concluded by any person of reasonable intelligence that a glucose level of 155 mg/dL does not demand intensive care.

23.  At 17:24-17:25, CT scans were performed on Lynn’s cervical spine, maxillofacial area, head & neck, abdomen and pelvis.

24.  No need for surgical intervention was documented.

25.  Olivia Speed, MD (Resident) commented, “No need to keep admitted from facial fracture standpoint.” Some of the fractures were plausibly pre-existing.

26.  Lynn had a left frontoparietal temporal subdural hematoma, left frontal hemorrhagic contusion, left tentorial subdural hematoma, and scattered subarachnoid hemorrhages. Despite the radiographic presence of intracranial bleeding across multiple compartments, his condition remained neurologically stable, and no surgical or interventional procedures were deemed necessary or administered. The absence of emergent curative treatment further underscores the lack of medical justification for prolonged involuntary restraint and chemical sedation.

27.  Yet, at 7:33, Sarah E. Martin, MD (Resident) placed an order for levETIRAcetam (Keppra) 500 mg/5 mL (injection). No consent to treat was obtained from Lynn.

28. Levetiracetam is a prophylactic.

29.  UAMS documented no Electroencephalogram (EEG) in the ED or at any time during the two-week forced hospitalization.

30.  At 17:48 Nolan R. Bruce, MD was assigned as admitting physician. UAMS is a teaching hospital where the residents and trainees are required to be supervised, and the standard consent form requires the signatory to acknowledge and agree to be treated by trainees. Lynn did not consent and was bothered that the people who were performing intrusive procedures on him looked inexperienced.

31.  At 17:48, Natalie J. Applebaum, MD (Resident) placed an order for fentaNYL (Sublimaze) (injection) 50 mcg. No consent to treat was obtained from Lynn. No consent to allow students, trainees or residents to treat Lynn was obtained.

32.  At 17:51, the fentanyl was started by Nathan Ernst, RN (possibly a Trainee).

33.  At 17:52, the fentanyl was “stopped”.

34.  In answer to Interrogatory No. 11 propounded by claimants, UAMS wrote, after objections: “on page 84 of the UAMS medical record, it indicates that Dr. Applebaum, an Emergency Department physician, ordered a 50 mcg dose of fentanyl via injection into the IV line for Lynn while he was in the Emergency Department, and Emergency Department nurse Nathan Ernst administered the fentanyl per the order.”

35.  UAMS did not explain why an entry on page 69 of the medical record generated 4/29/25 showed “0 mcg Intravenous Stopped 1/13/24 1752.” There was twice the .1 mg = 100 mcg ordered, but no coding on the record to indicate discarding the remaining 50 mcg (JW).  This along with contradictory records on other medication administration make it more probable than not that there was diversion of some expensive medications and controlled substances diverted for the personal use or sale by the staff. UAMS has shown no meaningful investigation into our claim.

36.  A subdural hematoma might put pressure on the language center of Lynn’s brain, which might cause three types of aphasia. The effect of Fentanyl can mimic aphasia or exacerbate it. It can also delay or blunt recovery. Regardless, aphasia is an ADA disability that does not affect reasoning.

37.  There was no objective evidence that Lynn’s ability to reason was affected. Lynn was always an iconoclast. He was and is brilliant. He just had trouble finding the right words after the administration of Fentanyl.

38.  At admission there was specifically “no evidence of ossicular disruption or otic capsule involvement” in Lynn’s right ear. There was no mention of injury to the left ear. By the time Hammett learned that her son was in the hospital, he had been tackled and restrained and struggled with his superhuman strength to escape, and his hearing, which was already a little impaired before the fall, seemed to approach deafness. Post escape medical exams showed ossicular disruption and virtual deafness in the left ear. It is plausible that the disruption occurred while struggling to escape.

39.   At no time during the two-week imprisonment did UAMS file a petition for an order of detention pursuant to AR Code § 20-47-211 (2023). UAMS failed to serve Lynn or his Accommodator with a copy of his statement of rights, including that he has the right to effective assistance of counsel, including the right to a court-appointed attorney, despite Hammett demanding a copy of “the paperwork” several times.

40.  Following his admission to UAMS, claimants were not informed of Lynn’s rights as required, including not being advised of his right to be released upon the expiration of a legal 72-hour-hold and UAMS Patient Rights and Responsibilities (Exhibit A).

41.   An order for detention could not be justified. At no time did Lynn express an intent to hurt himself or anybody else. There are a small number of boiler plate notes that Lynn made a comment to hurt himself or others well into his imprisonment. There was no quotation. There was no report made to security nor to UAMS police department. Neither Hammett nor Lynn remember any such threat. In fact, Lynn specifically remembered not hurting a healthcare worker because of signs he read, and Hammett specifically remembers and documented Lynn being oddly polite to his captors, saying “sir” and holding out his hand to shake theirs.

42.  Lynn did not want to use benzodiazepines, sedatives, opioids, be catheterized, restrained physically, be fed through a tube or defecate in a bed pan. He used none of these substances or techniques after leaving AMA and survived a year and eight months so far. If God decided it was time for Lynn to go to Heaven, he wanted to die at home, with a chance to “num num” his daughter, giving her big funny kisses like Cookie Monster. But he would do nothing to hasten his death, and he would do everything that in his informed opinion would lengthen his life without destroying the quality of that life.

43.  Positive treatments not allowed by UAMS included eating enough and only healthful food, getting any fresh air, sunshine, adequate water, enough gentle exercise, uninterrupted sleep, and the constant company of his loved ones.

44.  Lynn was able to escape four-point restraints by somehow breaking his right foot free, then bringing his right foot to his left hand and using his toes to loosen the restraints. This took flexibility rarely found in 34-year-old men, dexterity and, most importantly, ingenuity.

45.  Soon after leaving UAMS, Hammett asked Lynn why he did not use force against the staff to escape. He said he read a sign that says it is a felony to assault a healthcare worker. During a whirlwind tour of the 4^th floor on July 1, 2025, there were none of the signs posted on the floor. Either UAMS took them down subsequently, or Lynn was cognizant enough to remember reading the sign in his past.

46.  His speech improved dramatically the moment he got home. He said that he knew he was in a hospital, but thought it was “in the middle of nowhere” and initially thought that the doctors were like those “Nazis that did experiments in World War Two.” (Lynn is Catholic, but half his ancestors are Jews who escaped persecution in Eastern Europe. UAMS kept Lynn isolated from family for the first 14 hours, and were “locking” him to the cot, which was extra confusing with aphasia and hearing loss.)

 47.   After leaving the hospital AMA and getting a mile or so away, Lynn knew exactly where he was and pointed out landmarks in relation to his house. (i.e. There is the place we like (for Chinese), and my house is just a few blocks away.)

48.  Lynn was held against his will from January 13-January 27, 2024 despite repeated requests to go home, and numerous attempts to escape, several of which are noted in his medical record using the base word “elope” instead of “escape”.

49.  Lynn was starved. Typical meals served by UAMS included the following:

• 4 ounces of vanilla ice cream (~100 calories)
• 3.5-ounce Kraft chocolate pudding (~110 calories)
• 4-ounce serving of Ardmore Farms cranberry juice cocktail (~60 calories)
• One cup of tomato soup (~90 calories)
• 8-ounce carton of whole milk (~150 calories)
• 8-ounce glass of sweetened tea (~30 calories if sweetened)

50.   This meal, totaling approximately 540 calories, was representative of the hospital’s nutritional offerings—high in sugar and processed ingredients, and lacking in protein, fiber, fresh vegetables, or healthy fats. These foods are inconsistent with dietary standards for any adult, let alone a neurologically compromised patient with increased metabolic needs. Standard clinical guidelines recommend between 2,000 and 2,800 calories per day for adult males, depending on medical condition and activity level. Mr. Lynn was consistently underfed.

51.  UAMS, in response to interrogatory No. 6, claimed it does not routinely document when food or drinks were presented, how Lynn was supposed to eat or drink (whether his hands were restrained), and an ingredient list for the food and drinks he was given. The full response to our inquiry about his diet during the hospitalization was that “Lynn was given only a liquid diet and/or a feeding tube until just a few hours before he left the hospital against medical advice.”

52.  On January 14, 2024, UAMS told Hammett that Lynn could only eat ice chips until the SLP practitioner evaluated his ability to swallow.

53.  On January 15, 2024, Hammett observed Emily Gray, CCC-SLP allow Lynn to brush his teeth. When given a small cup, approximately 2 oz. of water, Lynn swished it around to rinse, then he looked around like a criminal who was going to snatch something from a shop, and he swallowed the water. He was dehydrated and begging for water before Ms. Gray came into the room. Ms. Gray wrote that “Pt was unable to swish and spit water to remove toothpaste from oral cavity; pt swallowed water instead.”

54.  On January 14, 2024, UAMS also told Hammett that Lynn should not eat solid food for approximately six weeks due to a fracture in his jaw. This limitation was not noted by the doctor who diagnosed Lynn’s facial fractures, Dr. Olivia Speed (Resident) or her supervising physician. Regardless, UAMS fed Lynn pudding and ice cream. Hammett was willing to feed Lynn a soft food diet at home, but she would have ground proteins, fresh whole fruits and vegetables, and used soft cheeses. Lynn did not need to eliminate solids, introduced them immediately at home and had no problem with his jaw.

55.  UAMS refused to keep foods for Lynn and Hammett in the refrigerator. UAMS left the healthful foods Hammett brought for Lynn unused.

56.  Hammett was on a strict elimination diet in a successful attempt to manage Hashimoto’s Disease and gastrointestinal problems. Hammett was also living on about a $650 per month pension. She could not afford the few foods offered by the UAMS cafeteria that had none of her eliminated foods, such as black pepper, tomatoes and onions.

57.   UAMS forbid Lynn to have the company of CL, his beloved daughter, based on her age, 8 years old. UAMS told Hammett while Lynn was in ICU that CL could not visit. They did not tell her the restriction does not apply when he moved to F4. Jaliyah Rucker, PCT noted how well Lynn responded when he got to talk to CL on the phone.

58.   UAMS failed to bring in a priest, despite their feigned concern that Lynn was on the verge of death.

59.   UAMS ceased administration of Keppra after six days. If the hospital was truly concerned about the seizure risk, they should have continued Keppra. Their failure to do so indicates that the seizure risk was exaggerated to justify keeping Lynn in the hospital. (Lynn did not consent to the use of Keppra. The claim is not that it should have been continued, but that it was not necessary or emergent.)

60.   Incurring billable charges is a more plausible motivation for the false imprisonment.

61.    Hammett was physically free to leave but was kept at the hospital by the coercive measure of keeping her son there and threatening to have the police come, with the implication that she would be arrested if she helped Lynn leave. Hammett explained to UAMS Workforce that both she and Lynn had a history of traumatic experiences with police who refused to protect them from Lynn’s abusive father. Since there were people in uniform and surveillance cameras all around, claimants’ concern for inaction and worse, improper action against claimants by the police was reasonable. In fact, when Lynn finally agreed to get the police involved, they flat out refused to investigate.

62.   UAMS condoned the denial of Lynn’s rights, denying each and every “material” allegation in the answer to the claim.

 63.    Lynn, on and after January 13, 2024, repeatedly told the UAMS Workforce that he did not consent to be there and wanted to go home but he was not allowed to do so.  UAMS Workforce further participated in a scheme to cover up their violations of Claimants’ rights. Respondent in the furtherance of the conspiracy by coercion, trickery and deceit convinced Hammett that Lynn’s behavior that was similar to when he abused substances in his teens, was caused by the traumatic brain injury instead of by the drugs UAMS administered. On several occasions UAMS Workforce said, verbatim, “we never give opioids to TBIs” and “we never give Benzos to TBIs.” UAMS convinced Hammett it was illegal for her to help Lynn leave. UAMS insisted Lynn consented to treatment and Hammett could not make decisions as next of kin. In defeat and wanting to mitigate the damages done in escape attempts and pulling out the invasive apparatus, Hammett begged Lynn to stay and “cooperate” with his captors. This was a huge breach of trust between mother and son. On January 29^th, when Lynn woke at home, he said to Hammett that he had a bad dream that she was being mean to him. We will prove at trial that UAMS Workforce’s conduct was especially cruel in light of the history Hammett shared with UAMS about Lynn and Hammett’s traumatic past and the trust issues it caused.

64.   UAMS further showed malice by making an inaccurate record and refusing to amend it completely upon claimants’ request.

 65.   UAMS supposedly destroyed the surveillance videos that would show that the imprisonment was not consensual and that it was UAMS that was belligerent and at risk of harming others, not Hammett and Lynn as noted by UAMS in the inaccurate record.

 66.  UAMS was aware of the illegal action taken by UAMS Workforce against Lynn but failed to take any action to secure his discharge and return him to his home.

 67.  UAMS sent a bill to Lynn, upon his release, demanding $42,095.78 plus a separate bill demanding an additional $4,188.40 for a total of $46,284.18.

68.  Hammett asked to speak with a “social worker” or “case manager” about getting Medicaid for Lynn on January 14, 2024 and January 16, 2024 and was told both times that someone would speak to her. But no one ever did. Hammett obtained and paid for other insurance for Lynn that would begin on February 1, 2024, told UAMS that, and UAMS Workforce noted it in the record.

69.  Because UAMS tricked Hammett into thinking the effects of the drugs they forced on him were due to the TBI, Hammett intended to have Lynn live with her for an unspecified length of time, maybe forever. Hammett was able to help Lynn obtain Medicaid to cover the legal charges incurred before February 1, 2024. This was the ambulance and emergency room charges. UAMS convinced Medicaid to pay charges for the non-consensual imprisonment.

70.  UAMS knew of the illegality of detaining Lynn on what they called a “72-hour hold” (even though it was a two-week hold) and a “psych hold” without first

 filing a petition with the court for an order for inpatient detention and

 treatment pursuant.  Nevertheless, UAMS Workforce willfully, intentionally,

 and in utter disregard of Claimants’ legal and human rights refused to allow Lynn to leave UAMS.

71.   The actions UAMS took violated Lynn’s rights under the “UAMS Patient Rights and Responsibilities”  and under AR Code § 20-47-207 et seq., (2023)., and his rights to be discharged upon request, to informed consent and to refuse medication and invasive procedures without force or coercion.

72.   The actions and inactions of Respondent, their agents and employees were in

 direct violation of Claimants’ rights to liberty and freedom from restraint, to be

 released from detention, and to live or die in his own home.  The actions of Respondent in incarcerating Lynn against his will at UAMS were knowingly taken, without legal authority and in direct violation of well settled standards of medical ethics. The action of Respondent, their agents and employees were intentionally taken and not taken in good faith.

 73.   Respondent further denied Lynn his right to counsel to challenge his detention.  UAMS failed to provide an experienced aphasia accommodator. UAMS failed to provide someone with experience communicating with newly deaf patients. UAMS, who claimants were supposed to be able to trust, lied to Hammett about Lynn’s condition and legal rights, who then conveyed those lies to Lynn. (Lynn never believed the lies and asked Hammett why she was being “weird”.)

 74.   UAMS did not have a psychiatrist or therapist speak with Lynn until January 24, 2024.

75.   UAMS did not discuss their treatment plans with Lynn. None of them were

 presented to Lynn, discussed with him, or signed by him.

 76.   UAMS discussed some treatment plans with Hammett but refused to allow Hammett to make decisions for Lynn. UAMS Workforce repeated that Lynn consented. When Hammett pointed out that he did not consent, UAMS Workforce said he does not have capacity. When Hammett said she had capacity, UAMS Workforce said Lynn was a consenting adult.

77.    Hammett tried to play a YouTube video by a doctor about TBIs to Lynn. A nurse demanded Hammett cease informing Lynn, as she claimed it would upset him.

78.   Respondent’s actions and those of UAMS Workforce in illegally holding Lynn against his will not only denied him due process of law, but exposed him to a significant, foreseeable, and unreasonable risk of harm and actual harm and exposed Lynn and Hammett to traumatic emotional distress.

79.  The ordeal was so traumatizing that when Hammett begged her younger son to voluntarily seek hospitalization in the best hospital in Nevada for mental health issues, he refused. Hammett, in writing, had to acknowledge that the experience at UAMS was horrifying, but not all hospitals are that bad and evil. Her efforts were of no avail. Her younger son died of drug toxicity while using methadone prescribed to a housemate, exactly one year after Sean Lynn was allowed to leave UAMS. It is not possible to apply a certain percentage of fault for Hammet’s son, Lynn’s brother on UAMS. But his refusal to seek help at a hospital shows how the public that UAMS is supposed to serve would view the conduct of the medical providers if informed.

80.  In November 2024, Hammett’s husband was diagnosed with stage IV prostate cancer metastasized to his bones, lungs and lymph nodes. His PSA was 1,299 (one-thousand, two hundred and ninety-nine. That was not a typo.) Healthy range is under .5 (point five). His PCP referred him to UAMS for treatment. He refused to go to UAMS. His PCP changed the referral to Carti. Again, the citizens UAMS is supposed to serve would not enter UAMS knowing what they did to Lynn and Hammett.

81.  Hammett was in an early consultation with her husband at Carti. She heard the doctor ask what his pain level was on a scale of one to ten and his reply. “15”. Hammett asked the doctor how long her husband might live without treatment. Without hesitation the doctor said he would be dead in six months. Even as foreboding as his situation was, Carti did not strap him to the chair and inject him with Fentanyl. He gave informed consent and proudly displays his Carti Certificate of Completion on the fireplace mantle.

82.  Respondent’s actions and those of UAMS Workforce made it impossible for Hammett to care for and advocate for her son unless she was also confined in ICU. This caused Hammett to lose sleep. She is treated for insomnia and had to break her sleep protocol. UAMS caused Hammett difficulty in following the diet that helps her manage Hashimoto’s Disease. UAMS caused Hammett severe emotional distress from watching her son be tortured, having to wipe blood and feces off her 34-year-old son’s genitalia and anus, being forbidden to stay with her son at times, such as on January 21, 2024, when UAMS Workforce demanded Hammett wait in the waiting room. Hammett could not be in two places at once. She, her son and CL would all have benefitted greatly by having Sean stay in Hammett’s house while he needed 24/7 care.

 83.   Respondent UAMS has obtained payment from the United States by illegally

 billing Medicaid for treatment during Lynn’s detention in ICU. UAMS has shown an intent to use the charges that were not covered by Medicaid to make fraudulent statements on grant applications and public relations literature, overstating the charity and good UAMS does for the community.

 84.  The actions of Respondent violate the criminal laws of the State of Arkansas

 and the United States.