Civil Complaint Filed for Deadly Mass Shooting at Club Q Nightclub in Colorado Springs

Legal team calls the loss of life and injuries “foreseeable and preventable”

DENVER, CO (November 19, 2024) – Today, Romanucci & Blandin announces the filing of a lawsuit in the United States District Court for the District of Colorado against government officials and Club Q for their respective roles in the preventable mass shooting that occurred on November 19, 2022, at Club Q, an LGBTQIA+ nightclub in Colorado Springs.  The tragic event claimed the lives of five people, injured twenty-five others, and left an indelible scar on the LGBTQIA+ community and the broader public.

The lawsuit seeks justice for the victims and their families, holding those responsible accountable for their failure to protect the community despite clear warning signs and foreseeable risks.

Claims Against Government Actors

The complaint alleges that government officials in El Paso County, including Sheriff Bill Elder and the El Paso County Board of County Commissioners, failed to invoke Colorado’s Red Flag Law—a tool specifically designed to prevent tragedies like this one.  Despite credible and alarming warnings about the shooter’s violent threats, access to firearms, and intent to harm, these officials refused to act, following an unconstitutional and reckless policy of non-enforcement of the law.

“Colorado’s Red Flag Law was enacted to save lives by allowing law enforcement to temporarily remove firearms from individuals who pose a serious risk to themselves or others,” said Romanucci & Blandin Senior Attorney Patrick A. Huber, lead counsel for the plaintiffs.  “By willfully refusing to enforce this law, despite overwhelming evidence of the shooter’s intentions, government officials abandoned their duty to protect the public, enabling this devastating attack.”

Claims Against Club Q

The lawsuit also asserts that Club Q’s management and owners, including Matthew Haynes, failed to take adequate security measures to protect guests from foreseeable harm.  Despite the known risks faced by LGBTQIA+ venues, particularly in light of prior targeted attacks like the Pulse nightclub shooting, Club Q drastically reduced its security staffing and failed to implement basic safety protocols.

“Club Q advertised itself as a ‘safe space’ for the LGBTQIA+ community, but that was a dangerous illusion,” said Romanucci & Blandin Senior Attorney Sarah M. Raisch.  “By cutting back on security staff, failing to provide armed protection, and neglecting to implement industry-standard safety measures, Club Q’s management prioritized profits over people, leaving its patrons vulnerable to this horrific act of violence.”

Preventable Tragedy

The lawsuit underscores that this tragedy was not an unavoidable act of violence but the result of systemic failures by those entrusted with safeguarding the public:

• Government actors failed to act on clear, credible warnings about the shooter’s violent intentions, choosing to prioritize political opposition to the Red Flag Law over public safety.

• Club Q management ignored its duty to provide adequate safety measures despite the well-documented risks of targeted hate crimes against LGBTQIA+ spaces.

“These failures created the perform storm, allowing a dangerous individual to carry out his deadly plans,” said Romanucci & Blandin Founding Partner Antonio M. Romanucci.  “This lawsuit is about accountability—not just for the victims and their families but to ensure that no other community has to suffer from such reckless disregard for human life.”

Call for Change

This case is not just about compensation—it is about systemic reform.

• We demand that government entities enforce existing laws like the Red Flag Law to prevent similar tragedies.

• We call on private entities, including LGBTQIA+ venues, to implement robust security protocols that prioritize patron safety.

Senior Attorney Patrick A. Huber added: “The lives lost and families shattered in this tragedy deserve more than thoughts and prayers—they deserve action, accountability, and justice.  This lawsuit is the first step in ensuring that their voices are heard and that meaningful change occurs.”

About Romanucci & Blandin, LLC

The victims and their families are represented by the Chicago-based national trial law firm Romanucci & Blandin, LLC, including Founding Partner Antonio M. Romanucci, Senior Attorney Patrick A. Huber and Senior Attorney Sarah M. Raisch.  Romanucci & Blandin is honored to advocate for victims of mass shootings, including those at Robb Elementary School in Uvalde, Texas; the Fourth of July Parade in Highland Park, Illinois; the Route 91 Harvest Festival in Las Vegas; the Pulse Nightclub in Orlando; the Old National Bank in Louisville, Kentucky; and other tragedies.

Additionally, Barrett Hudson, who was injured in the shooting, is represented by attorneys Brad Bufkin and Matt Schneider of Bufkin & Schneider Law, LLC, a law firm based in Colorado Springs. A complaint was filed separately on behalf of Mr. Hudson.

Plaintiffs’ Statements on the Shooting and the Filing of the Lawsuit:

Adriana Vance, mother of Raymond Green:

“My grief comes in waves, waves similar to a tsunami and other days waves of calmness but still waves and I have learned to surf them. God has given me the acceptance, the strength to know it was impermanent. My suffering is impermanent, and it will end someday. If I could share anything with another mother, it would be that yes, you’re totally shattered, yes, you’re cracked wide open, and what are you going to do? I believe if you can truly accept that your life does have meaning in all the events of your life have meaning that even the horrific becomes an ability to grow. God never promised that we wouldn’t face loss. God promised us that he would never leave us or forsake us.”

James Slaugh:

“Consistently, one of the hardest things for me to live with now has been the hyper-vigilance and anxiety. In any public place, I’m always checking for exits, assessing where I could go if I needed to, and watching the behaviors of those around me for something that might feel "off". Crowded spaces—places that used to feel normal—are now filled with anxiety. It’s hard to feel fully comfortable or safe, and that feeling changes everything about how I move through the world now.”

Charlene Slaugh:

“There is a profound loneliness that comes with carrying trauma like this - one that's hard to explain and even harder to share. I now face triggers that I never imagined I would have, reminders that bring me back to a time when my autonomy and independence were stripped away. I remember what it felt like to wonder if I'd survive. These memories don't just disappear. They are woven into the fabric of my life now, a part of my story that cannot be erased, and it's a reality that I'm still trying to come to terms with every single day.”

Ashtin Gamblin:

“Our lives changed forever on November 19, 2022. I find myself not only struggling with what happened but everyday life. I can't drive, or cook by myself. I can't even take my dogs for a walk. I struggle with doing things I once found enjoyable. I hope this lawsuit brings the accountability we all deserve.”

***

Romanucci & Blandin is a Chicago-based national trial practice committed to fighting for victims of negligence, abuse and wrongful death. For 25 years, we have secured more than $1 billion million in verdicts and settlements for our clients - many for millions of dollars and others record-setting awards.  Our experience ranges from mass shootings, civil rights and police misconduct to medical malpractice, sexual abuse, motor vehicle accidents or workplace injury cases involving individual or institutional negligence. Romanucci & Blandin is a valuable legal resource to individuals and groups of people who have been injured by others’ wrongdoing. Referring attorneys and clients say several factors differentiate our firm: Our record of success, depth of experience, talented and dedicated legal team, tireless preparation and strategic use of communications to fight for the rights of those whose lives have been changed forever. We are different from other personal injury firms in that our work does not stop when a verdict or settlement is secured.  We are often inspired by our clients’ experiences and commit resources to create change in our communities. For more information about Romanucci & Blandin, please visit www.rblaw.net or call (312) 458-1000.