Susan Holmes, the mother of Jeremy Holmes, a nineteen-year-old killed by police officers near the CSU campus last year, has filed a lawsuit against the university over the matter. But instead of seeking a big payout for tragic actions she believes were completely avoidable, she wants authorities at the campus to turn over documents related to the investigation, as well as a video that authorities have repeatedly refused to make public.

"The impetus for filing this lawsuit is not monetarily based," says Julian G.G. Wolfson, the namesake for the Law Office of Julian G.G. Wolfson, LLC, who's representing Susan Holmes. "The big, motivating factor behind her pursuit is transparency, and the belief that the decision to deny the records request appears to be arbitrary and capricious."

The complaint is accessible below. When asked about it, CSU spokesperson Mike Hooker noted via email that "CSU does not comment on pending legal matters."

Susan isn't talking about the suit, either, leaving such discussions to Wolfson. But for an October post, she went into detail about Jeremy and the July 1, 2017, incident that took his life.

In the weeks prior to his death, Jeremy, whom Susan described as "an insightful, brilliant person" with a knack for computer-game design, had such a bad reaction to marijuana that she believes he was suffering from an exceedingly rare condition known as cannabis-induced psychosis. Suddenly, this gentle soul was having uncommon mood swings and making violent threats against his older brother, Alex, who lived in an apartment on the CSU campus. And while he'd never previously owned a weapon, Jeremy obtained a knife three days before his death, ostensibly to protect the family following an attempted break-in on the porch of the Fort Collins-area home he shared with Susan.

Susan Holmes shortly before she was escorted out of a November 2017 Fort Collins City Council meeting. YouTube

These issues came to a head on July 1, when Jeremy became upset that Alex had told him not to visit; Susan said her older son had received several "strange" phone calls from Jeremy when he was in the midst of a major project. At that point, an obviously depressed Jeremy, who Susan thinks had smoked more marijuana, picked up the knife, which was covered by a sheath, and headed on foot to Alex's apartment, located about two miles from his residence, after saying he was angry and wanted to kill him.

Immediately thereafter, Susan called Alex, who lived at the apartment with his wife, but didn't get an answer. So she phoned the CSU campus police and asked for an officer to be dispatched to Alex's place to warn him and her daughter-in-law not to answer the door if Jeremy arrived. "I also said Jeremy was mentally ill," she recalled. "I used that term specifically."

CSU police officer Katie Aron was sent to Alex's apartment and spoke to him and his wife there. Her body-camera footage is what Susan wants released, in part because she conveyed the situation in a mental health context.

Also captured in Aron's video — the moment during her conversation with the couple when she heard a scream and ran off to what turned out to be the scene of the shooting.

Police on the scene after the shooting. CBS4 via YouTube

Jeremy was indeed nearby, but he never went to Alex's apartment. Instead, he was walking along Prospect Road, on the far side of a six-foot-tall fence that separated him from his brother's place. At that point, Jeremy had the knife in his hand, but Susan stressed that he hadn't threatened anyone or done anything wrong.

Nonetheless, she said, CSU Police Department Corporal Phil Morris "drove up to Jeremy with his lights on — drove up really quickly, as if it was an emergency. He jumped out of his car with his gun, and when he saw that, Jeremy started to act suicidal. He pulled the knife out of the sheath and started waving it around, saying, 'Kill me. Please kill me. I want to die.' The officer kept barking at him to drop the knife, but Jeremy kept walking toward him. He didn't charge him in the beginning. He was just walking, and the officer was backing up."

Then, she went on, "another police officer, from the city" — Fort Collins Police Services officer Erin Mast — "drove up, did a U-turn and pulled her gun out. She told Jeremy to drop the knife, too, and that's when Jeremy moved more strongly toward the CSU campus officer, and they started shooting him. They both fired. There were six shots."

Here's a portion of Corporal Morris's body-camera video. Warning: The contents may disturb some readers.

Afterward, authorities allowed Susan, at her request, to see unredacted body-camera footage from all three officers, including a clip that, in her view, showed Morris completely losing control as her son lay dying: "All of his blood is flowing out — he's bleeding out right there on camera — and the officer is still pointing his gun at him and screaming at him to drop his knife."

Police eventually issued body-camera videos associated with Morris and Mast, but actions like the ones alluded to above were edited out. Moreover, the Aron video was not released — another indication, in Susan's opinion, of a coverup on the part of 8th Judicial District DA Cliff Riedel, who cleared the assorted law enforcers of any wrongdoing in the incident.

To that end, Susan filed complaints with the Supreme Court of Colorado's attorney regulation counsel and the FBI. Nothing came of these efforts, and her various formal requests for the three unredacted videos were rebuffed, too. So in September, attorney Wolfson, whose services she'd secured, stepped in with a request that went even further.

"In any and all investigations of this type, whether external or internal, a lot of documents are generated: reports, photos, dispatch and communication records, witness interviews, ballistic data," Wolfson says. "I've submitted CORA [Colorado Open Records Act] requests for investigations conducted by other critical response teams in other districts and have not had the kind of issues we're having here. They won't give you anything under the moon, but I got thousands of pages of material in another case I'm dealing with."

As the lawsuit acknowledges, the Colorado Criminal Justice Act, the statute that governs such matters, gives some discretion to custodians of records in regard to what they release. But it also provides a mechanism for an individual like Susan to petition a court for what Wolfson refers to as a "show-cause hearing." In that setting, authorities would have to present an argument as to why they've thus far refused to turn over the documents. If the court determines that the custodian's decision to deny access was improper, as well as arbitrary and capricious — terms Wolfson used earlier — the university would have to release the docs, as well as to pay Susan's attorney fees and other reasonable costs.

Susan has already spent more than a year seeking justice for Jeremy. The lawsuit is the latest step along this path. Click to access Susan Holmes v. Colorado State University.