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that Wilson assaulted Johnson, violated his constitutional rights, and intentionally and negligently inflicted emotional pain during the encounter, in which Wilson shot Brown to death.

The lawsuit seeks damages, including punitive, of at least $25,000. It also seeks an injunction to prevent the city of Ferguson and its police from engaging in assault, unlawful arrest and excessive use of force.

The city and Jackson were named because they “negligently hired and supervised police officers who violated citizens’ civil rights,� the suit said.

James Knowles III, the mayor of Ferguson, said the city had not yet been served with the suit and had no comment. Jackson, who resigned March 11, also declined, as did Wilson’s attorney, Greg Kloeppel.

Lawyers for Johnson could not be reached. He is represented by lawyers Daniel K. Brown of Clayton and James M. Williams and Inemesit U. O’Boyle of Metairie, La.

The suit repeated several findings from a Department of Justice investigation, released March 4, that described an out-of-control Ferguson police department whose officers targeted African-Americans, stopped and searched people without reasonable suspicion, arrested people without probable cause, abused their authority in quashing protests and routinely ignored civil rights.

The lawsuit claims that Wilson “acted with either deliberate indifference and/or reckless disregard toward Plaintiff’s rights, targeting him without probable cause or any reasonable factual basis to support that Plaintiff had committed any crime or wrong, and using lethal force in an unjustified and unconstitutional manner.�

According to the lawsuit, Johnson is now living in Metairie, La., a suburb of New Orleans.

A ÃÛÑ¿´«Ã½ County grand jury considered evidence against Wilson, including testimony by Johnson, and decided Nov. 24 not to issue an indictment.

The Department of Justice found in a separate investigation that it was reasonable for Wilson to be afraid of Brown after a violent encounter, and said the officer thus could not be prosecuted for fatally shooting the unarmed 18-year-old. Wilson has resigned from the force.

The federal investigation concluded that statements by Johnson spawned the popular protest narrative “Hands up! Don’t shoot!� but that he was not credible when compared with other evidence.

According to the report, Johnson claimed that Wilson had reached out of a police SUV, grabbed Brown by the throat and tried to pull the 289-pound man through the window. He said that “at no point did Brown ever strike, punch or grab any part of Wilson.�

It is undisputed that Brown ran from Wilson.

Johnson alleged that just before being shot, Brown stopped running, put his hands up and said, “I don’t have a gun,� or “I’m unarmed.�

The report said Johnson’s statements were not consistent with physical evidence, changed from one part of his account to the next and did not agree with other credible witnesses whose stories were corroborated by forensics.

Wilson has said he stopped the two men for walking in the street and realized that Brown was wanted for a strong-arm robbery. He said Brown punched him through the vehicle window and was wounded in the hand as the men struggled for the officer’s pistol. Wilson said he fired after Brown, who was running, came back at him.