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Updated November 30, 1999, 8:13 p.m. ET Text of the King family's suit against Loyd Jowers and Martin Luther King Jr.'s "unknown" conspirators
PLAINTIFFS
MARTIN LUTHER KING III, BERNICE KING, DEXTER KING, & YOLANDA KING vs. DEFENDANTS
OTHER UNKNOWN CO-CONSPIRATORS DOCKET NO. 9724210 DIVISION 4
COME NOW that the Plaintiffs, CORETTA SCOTT KING, MARTIN LUTHER KING III, BERNICE KING, DEXTER SCOTT KING, AND YOLANDA KING, by and through counsel. They would show this Honorable Court:
2. Only recently have the Plaintiffs had the opportunity to identify Defendant JOWERS as one of the key players in this conspiracy. This, with precision, occurred within the last year, hereof, when confessed Defendant JOWERS confessed his role in the 1968 murder conspiracy and admitted to have been paid a large sum of money to participate in the conspiracy. Defendant JOWERS made these admissions in the presence of his attorney and Plaintiff Dexter Scott King and Plaintiffs's counsel and on another occasion, also within the last year, in front of Plaintiff Dexter Scott King and former United States Ambassador to the United Nations, Andrew Young. 3. On those occasions, Defendant JOWERS said he had owed a "big favor" to the now deceased FRANK C. LIBERTO, a Memphis produce house operator, who was alive in 1968. LIBERTO advanced the money to further the conspiracy to kill Dr. King to JOWERS as part of the plot to shoot Dr. KIng from the back of JOWERS' cafe. This area was then heavily vegetated with large bushes and trees which could conceal a gunman with a clear view of the balcony of the Lorraine Motel. 4. Defendant JOWERS also admitted that the person accused of the crime, James Early Ray, was not the gunman involved and that he, JOWERS, took the still smoking rifle from another person, carried it into the kitchen of his cafe, and concealed it until it was collected the next morning. 5. Defendant JOWERS confirmed the existence and the role of a man he knew as "Raul", who brought him the rifle to be used to kill Dr. King. JOWERS, thereby, confirmed the existence of the person whom James Early Ray had identified more than thirty years ago as the individual who lured him to Memphis on the pretext of participating in a gun-running scheme. 6. Plaintiffs sue Defendant JOWERS for the tortious actions that constitute : 1) outrage; 2) the deprivation of the life, companionship and benefits, tangible and intangible, material and spiritual, emotional and intellectual, all of which were available to the Plaintiffs in life and taken from them with the death of their husband and father which was the direct result of the Defendant's tortious actions. Such tortious actions grew out of an illegal conspiracy that had the common design, concert of action, and overt acts that included the killing of Dr. King and the coverup of that murder and the framing of another — James Earl Ray — for the murder of Dr. King.
7. Memphis, Tennessee, in Shelby County, is the Lex Loci Delictus where the illegal conspiracy culminated and was consummated with the fatal shooting of Dr. Martin Luther King Jr. as he stood on the balcony of the Lorraine Motel at approximately 6:01 p.m., said motel being in the city limits of Memphis. 8. Memphis, Tennessee, in Shelby County, is also the Lex Loc Contractus where Defendant LOYD JOWERS admits he entered into the illegal conspiracy with FRANK C. LIBERTO and others, known and unknown, to kill Dr. King. 9. Memphis, Tennessee, was the Lex Loci Domicilii of LOYD JOWERS at the time the illegal conspiracy was entered into. Defendant JOWERS today has sufficient contacts with the State of Tennessee as well as the City of Memphis and Shelby County, having owned and operated several businesses there and still having family in that city.
10. Plaintiffs are the widow and children of the victim of this illegal conspiracy and tortious actions of the Defendant. 11. Defendant LOYD JOWERS is a resident citizen of Tennessee with sufficient ties to Shelby County. In 1968, Defendant JOWERS was the owner of Jim's Grill, 422 1/2 South Main, Memphis, and Shelby County in which establishment amongst other places in Memphis and Shelby County. Defendant has admitted the conspiracy took place and the murder was planned in the establishment. He has also confirmed that it was behind his establishment, Jim's Grill, where the murder was carried out.
12. In early 1968, Plaintiffs' husband and father the Rev. Dr. Martin Luther King Jr. decided to come to Memphis, Tennessee in order to support striking sanitation workers in that city. 13. In or around the middle of March, Defendant JOWERS was approached by one FRANK C. LIBERTO, a Memphis resident and produce dealer, and asked to participate in a conspiracy to kill Dr. King. LIBERTO told JOWERS that a person — a "patsy" — was in place to take the blame and that no police would be around. Defendant agreed to participate in the conspiracy to kill Dr. King and eventually was provided with a large sum of money, or all of which, he turned over as instructed to a man he knew only as Raul. Their money was delivered to Defendant JOWERS in a vegetable box from another Memphis produce house, and Defendant JOWERS believed that it came from New Orleans. 14. During this time between the middle of March and the date of the murder, Defendant JOWERS observed and participated in a number of acts in furtherance of the conspiracy. These included planning meetings attended by persons known to him which took place in his establishment — Jim's Grill. 15. In addition, in the morning of the day of the assassination, April 4, 1968, Defendant JOWERS received and concealed in Jim's Grill a rifle from the man he had come to know as Raul. 16. Late in the afternoon of that day — April 4, 1968 — Defendant JOWERS gave the rifle to a third party, now deceased and known to him, who took it away. 17. Sometime before 6 p.m. on that same day, April 4, 1968, Defendant JOWERS, as he had been instructed, went out the back door of Jim's Grill into the overgrown brush area at the rear of the building. 18. While waiting in that area sometime just after 6 p.m., he heard a shot and within seconds of that sound, now deceased, the third party, to whom he had earlier given the gun, appeared and gave him the still smoking rifle. The shot he heard was the firing of the single bullet which struck and ultimately killed the victim, Dr. Martin Luther King Jr. 19. Defendant JOWERS then ran carrying the rifle back inside Jim's Grill entering through the rear kitchen door from which he had come out some time earlier. 20. He then proceeded to once again conceal the rifle, eventually placing it on the shelf under a counter in Jim's Grill. 21. The next morning Defendant JOWERS turned the rifle over to Raul or another person who took it away. He never saw it again. 22. Defendant JOWERS and other persons, in furtherance of the conspiracy and the concealment of the tortious actions herein alleged directly and indirectly for approximately 29 years, participated in covering up the said tortious acts to the detriment, harm, injury, and damage to the Plaintiffs.
23. Paragraphs One through 22 are restated and incorporated herein. 24. Defendant LOYD JOWERS and FRANK C. LIBERTO, along with other known and unknown parties living and dead entered into a conspiracy with a common design and illegal purpose, to-wit, to murder Dr. Martin Luther King Jr. after his scheduled arrival in the Memphis on April 3, 1968. 25. Defendant JOWERS, LIBERTO, and other unknown parties living and dead acted in concert by having a rifle with James Earl Ray's fingerprints on it placed on the sidewalk outside the rooming house adjacent to Jim's Grill shortly before or immediately after Dr. King was shot. 26. Defendant JOWERS acted in concert and collusion with the said others by taking the rifle from another person in or near the bushes in the rear of the establishment immediately after the rifle was used to shoot Dr. King, knowing that the rifle had been used to kill Dr. King as he stood on the balcony of the Lorraine Motel across Mulberry Street. 27. By entering into the criminal conspiracy to murder Dr. King, Defendant JOWERS had also entered into a civil conspiracy to deprive Plaintiffs of the life, presence, companionship, and all the benefits resulting therefrom tangible and intangible, material and spiritual, emotional and intellectual, which were available to Plaintiffs while their loved one was alive and taken from them forever with the death of their husband and father, said loss being the direct result of the tortious actions of the Defendant and others.
28. Paragraphs One through 27 are restated and incorporated herein. 29. Defendant JOWERS' actions, as described herein, constitute intentional and outrageous wanton, willful, and malicious conduct that reflect a common design, concert of action, participation in overt acts in furtherance of an illegal conspiracy. said conspiracy culminated with and resulted in injuries &3151; both physical and mental — inflicted upon Plaintiffs for which they now seek redress. WHEREFORE, PREMISES CONSIDERED, PLAINTIFFS PRAY THAT:
2. Plaintiffs be entitled to recover from Defendant JOWERS or any other Defendant whose identity might be learned through the discovery process, who participated in the illegal conspiracy described herein, actual and compensatory damages as well as punitive damages, as a result of the tortious conduct of Defendant JOWERS and his co-conspirators. 3. Plaintiffs be awarded such other further relief to which this Honorable Court may deem them entitled. 4. Plaintiffs demand a jury trial to determine all issues of fact.
WAYNE CHASTAIN, Esquire, #5205
DR. WILLIAM F. PEPPER, Esquire,
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