On September 17, 2018, the city of Cleveland agreed to pay $1 million to the families of six women. The sum was divided evenly among the relatives of Nancy Cobbs, Telacia Fortson, Amelda Hunter, Leshanda Long, Diane Turner and Janice Webb, and the city covered the families' legal costs on top of it, Ideastream reported. It was not a verdict. What the families had argued, in a suit that took years to settle, was that a detective had failed to investigate a complaint against a man named Anthony Sowell and that the failure "led to the murder of these six women."
A criminal court punishes the person who did the killing. A civil court can ask different questions, and it asks them of different defendants: the offender himself, who may have money from a book or a movie or a life insurance policy; the police department that had a name and a file; the hospital that gave a night-shift worker the run of a drug cabinet; the ambulance station that had no rules for who could carry a muscle relaxant. Families have brought such suits for as long as there have been serial cases, and the results run from a million-dollar settlement to a statute thrown out as unconstitutional to an award of 50,000 zloty to a widow in Łódź. Nine cases, taken one at a time, show what each suit asked for and what it got.
Anthony Sowell, a registered sex offender, was convicted in July 2011 of the aggravated murder of 11 women whose deaths came to light in Cleveland in October 2009. A Cuyahoga County jury returned guilty verdicts on 81 counts on July 22, 2011, and Judge Dick Ambrose sentenced him to death the following month. The Supreme Court of Ohio affirmed in December 2016. Sowell died in custody on February 8, 2021, at 61, and was never executed.
The civil case turned on an earlier moment. In December 2008 Sowell was arrested in Cleveland on a complaint from a woman and was released without charge. The families of six women who died after that release sued the city, arguing that the detective handling the complaint had not investigated it properly. In September 2018 Cleveland agreed to the $1 million settlement. The other five families were left out of the payment, Ideastream reported, because of when their relatives had died in relation to that release. CBS News reported that the family of Crystal Dozier received $2,500, and that in 2019 the city paid a combined $300,000 to two women who survived Sowell.
CBS News had traced the delay from the first days of the case. After a woman made a complaint in September 2009, police did not act on the complaint for more than a month; an officer obtained arrest and search warrants on October 28, and officers went to serve them the next evening. The family of Tonia Carmichael told CBS News in November 2009 that police had sent them away when they asked about her. Reforms followed. Ideastream described a county panel on sex crimes and missing persons as a success in May 2011, though News 5 Cleveland reported in October 2019, ten years after the case came to light, that promises of reform had not been kept. A settlement does not settle that argument; it only closes one claim.
David Berkowitz killed six people in New York City between July 1976 and July 1977 and wounded seven more. The last of the dead was Stacy Moskowitz, 20, killed in Brooklyn on July 31, 1977. Berkowitz was arrested in Yonkers on August 10, and Time later recounted that detectives reached him through a parking ticket and through Yonkers police files on threatening letters sent to his neighbors.
That second thread is the one the Moskowitz family seized on. United Press International reported that the family filed a $10 million lawsuit against the Yonkers police, alleging the department had failed to follow up leads. The suit surfaced as Berkowitz was being arraigned in Brooklyn on the Moskowitz case, with indictments in the Bronx and Queens to follow. No outcome of the claim was reported. Berkowitz pleaded guilty to all six murders on May 8, 1978, and has been refused parole at every appearance since 2002, most recently in May 2024.
He appeared as a civil plaintiff himself decades later. In January 2006 he sued his former lawyer, Hugo Harmatz, over letters and other items the lawyer had held and used in a book called Dear David, and he took part in a hearing in Manhattan Supreme Court by speakerphone from prison. In May his lawyers said he wanted to use New York’s "Son of Sam" law, the statute named for him, to strip the author of his profits. No outcome was reported.
The law itself belongs to a different story, but one line of it bears on the courtroom. Under the 1977 statute, money owed to an accused or convicted person for an account of the crime was held in escrow for victims who won civil judgments. In 1991, in Simon & Schuster v. Members of the New York State Crime Victims Board, the United States Supreme Court struck it down as an unconstitutional burden on speech based on content. New York wrote a narrower law, and by 2007 more than 40 states had one.
Dennis Rader, a code enforcement officer and church council president in Park City, Kansas, pleaded guilty on June 27, 2005, to 10 counts of first-degree murder in deaths in and around Wichita between January 1974 and January 1991. On August 18 District Judge Gregory Waller imposed ten consecutive life terms. Kansas had no death penalty in force for crimes committed between 1972 and 1994, so the prosecution could not seek one.
Families of the victims filed nine civil lawsuits against him. A week after the sentencing, District Judge Timothy Lahey placed an attachment on Rader’s personal property, including three boxes of writings and photographs from his jail cell, so that nothing could be sold while the cases were pending. The order answered a gap in the law. Kansas statute barred Rader from profiting from telling his story, but in 2005 nothing prevented him from selling memorabilia, and the families feared that photographs tied to the killings would be offered online. His wife had been granted an emergency divorce soon after his arrest and received the family’s retirement savings.
How the nine suits ended was not reported. What is documented is the order itself: a Kansas judge freezing a prisoner’s papers on behalf of the families, a week after the criminal case closed. Rader was held at the El Dorado Correctional Facility as of August 2025, and in 2023 Oklahoma officials who named him a suspect in an unrelated case concluded the evidence did not support a charge.
The Rhode Island case sits at the hard end of the subject, because the defendant was a boy. In September 1989 Craig Price, then 15, admitted in Family Court to the deaths of Joan Heaton, 39, and her daughters Jennifer, 10, and Melissa, 8, on the night of September 4, and of a neighbor, Rebecca Spencer, 27, in July 1987. Under the law of the time the court could hold him only until his 21st birthday. A delinquency adjudication is not a criminal conviction, a point Justice Flanders of the Rhode Island Supreme Court made in the Heaton family’s civil case.
On April 26, 1994, as Price’s 21st birthday approached, Joan Heaton’s siblings, with the administrator and a beneficiary of her estate, sued him in Superior Court on nine counts, among them wrongful death and unjust enrichment. They also asked the court to apply Rhode Island’s Criminal Royalties Distribution Act of 1983 to any money he might earn from telling his story. The trial court dismissed all but the royalties count and, in February 1995, ruled for the family on that one.
The Supreme Court undid it. In Bouchard v. Price, decided on May 5, 1997, the court held the wrongful-death claims barred because they were filed more than three years after the deaths. It then struck down the royalties act entirely as a violation of the First Amendment, concluding that the law reached any expression about a crime and was not narrowly drawn. The majority held that Price counted as a "criminally responsible person" under the act despite his juvenile status; Justice Flanders, concurring, disagreed on that point. The family therefore lost on the damages claim on timing and lost on the royalties claim on principle, and the opinion invalidated the statute for every other family in the state.
Price remained in custody for other reasons. He was convicted of extortion and held in contempt of court in 1994 for refusing court-ordered treatment, and later sentences in Rhode Island and Florida kept him confined. In January 2019 he pleaded guilty in Florida to attempted murder in a prison and was sentenced to 25 years plus 10 years of probation. He was in Florida custody as of that date.
Efren Saldivar, a respiratory care therapist on the night shift at Glendale Adventist Medical Center in Glendale, California, pleaded guilty on March 12, 2002, to the first-degree murder of six elderly patients who died in 1996 and 1997 and to the attempted murder of a seventh. The six were Eleanora Schlegel, 77; Salbi Asatryan, 75; Jose Alfaro, 82; Luina Schidlowski, 87; Balbino Castro, 87; and Myrtle Brower, 84. He admitted the special circumstances of multiple murder and murder by poison, and the district attorney’s office gave up its pursuit of a death sentence. Judge Lance Ito sentenced him on April 17, 2002, to six life terms and 15 years to life for the attempted murder.
The criminal case was only one of the proceedings. Saldivar had told Glendale police in March 1998 that he had caused 40 to 50 deaths since 1989, retracted the statements and went free for lack of proof. The proof arrived in 2001, when tests at Lawrence Livermore National Laboratory confirmed his involvement in six of the deaths. Saldivar was arrested as he arrived at work as an electrician’s apprentice, CBS News reported on January 9, 2001, and charged with six murders.
The families had started to move before that. In January 2001 the family of Jose Alfaro told CBS News that the drug had been detected and that they had hired a lawyer to bring a wrongful death claim; they later settled with the hospital for an undisclosed amount. The family of Salbi Asatryan sued as well and accepted $60,000, according to news reports in 2002. By the time Saldivar pleaded guilty, seven lawsuits had been filed against the hospital and four had been dismissed, and the hospital said in a statement that scrutiny from the case had led it to make "significant improvements" in patient care. The civil cases were mostly settled or dismissed.
The figures show the limit of the form. The number of patients Saldivar harmed has never been settled. He gave police different numbers at different times, and detectives estimated 100 to 200 deaths; the courts dealt with seven patients. A civil claim can be built only on a death a family can name, and the payments here, where they were reported, ran from a sum in the tens of thousands of dollars to nothing disclosed at all.
Clifford Olson was a career criminal on mandatory supervision when he killed 11 children and young people in and around Vancouver between November 1980 and July 1981. The youngest was Simon Partington, 9. He pleaded guilty in January 1982 to 11 counts of first-degree murder and received concurrent life sentences, with no parole eligibility for 25 years. Justice H.C. McKay recommended he never be released. Olson died of cancer on September 30, 2011, at 71, at the federal prison complex in Sainte-Anne-des-Plaines, Quebec.
The suit grew out of the way the case ended. Days after the pleas, Canadians learned that the British Columbia government had placed $100,000 in trust for Olson’s wife and infant son in return for his cooperation in the investigation. The payment set off a national argument. In 1984 the families of seven of the victims sued, asking the courts to declare the trust fraudulent. They argued that it had been set up to defeat their claims for damages against Olson, whom they called the true owner of the money.
At the trial before Justice William Trainor of the British Columbia Supreme Court, Olson’s wife testified that she had met Olson in January 1980 and married him in May 1981, and that he had spent $60,000 in savings from her previous divorce. She said that after Judy Kozma’s death was charged, she went to see him in jail and knew from his eyes that he had killed Simon Partington. The families' lawyer, David Gibbons, pointed to a television interview she gave in February 1982, a month after the pleas, in which she called Olson a "very kind" man who loved his baby. Former attorney general Williams testified that he had been shocked by the idea of paying for information and had agreed only because police told him a conviction was unlikely without it.
Justice Trainor ruled that the families could claim against the trust money. It was a real victory, and it did not last. The British Columbia Court of Appeal reversed his decision in March 1986, and the Supreme Court of Canada refused leave to appeal, according to the Canadian Encyclopedia. The families lost the one asset anyone could point to.
Kang Ho-sun was convicted in 2009 of murdering ten women in South Korea. Two of them were his fourth wife and her mother, who died in a fire in Ansan on October 30, 2005, that the court held he set; the other eight were women he did not know, killed between September 2006 and December 2008 in Jeongseon County and in southwestern Gyeonggi Province. He admitted the eight deaths after his arrest in January 2009 and denied the fire to the end. The Ansan Branch of the Suwon District Court sentenced him to death on April 22, 2009, the Seoul High Court upheld the sentence on July 23, and it became final when no appeal reached the Supreme Court in time.
Six days before the sentence, on April 16, 2009, a civil court in the same Ansan Branch ordered Kang to pay 1.3 billion won in damages to the families of six of the victims. The judgment ran against an individual, not an institution. The insurance claims that followed the 2005 fire were part of the case against him: weeks before it Kang had taken out several life insurance policies on his wife, and in 2007 he received 480 million won in compensation, the Korea JoongAng Daily reported. Prosecutors later said they had a recording of an automated call he made to four insurance companies on November 4, 2005, to file claims. No report said whether any of the 1.3 billion won was collected.
Kang remained on death row at the Seoul Detention Center in Uiwang as of October 2026. South Korea has carried out no execution since December 30, 1997.
Andrzej N. worked as a paramedic for the emergency ambulance service in Łódź, Poland’s third largest city. In January 2007 the Łódź Regional Court convicted him of murdering four patients while they were being carried to hospital, and of helping a fellow paramedic murder a fifth. He was sentenced to life imprisonment and a ten-year ban from his profession. The Łódź Court of Appeal upheld the verdict on June 9, 2008, and it became final on October 27, 2009, when the Supreme Court dismissed the last appeals. The case had begun with a January 2002 exposé by Gazeta Wyborcza and Radio Łódź on ambulance staff selling news of patients' deaths to funeral homes.
One of the four patients was Wiesław S., 72, who died in January 2001. He had drawn a pension and also earned money as a tailor, and he had been his family’s main earner, a civil court later heard. His widow did not sue the paramedic. She sued the regional ambulance station, the service that had carried her husband, for 100,000 zloty.
In December 2006 a district court ruled that the station was not liable for the killing itself but was liable for a poor resuscitation. An expert listed several errors by the ambulance doctor: using air instead of oxygen, failing to give the proper drugs, and riding beside the driver rather than beside the patient. The court set compensation at 38,000 zloty, taking into account that the widow had a small pension and that her husband had been the family’s main earner.
Both sides and the station’s insurer, PZU, appealed. In November 2007 the appeal court raised the award to 50,000 zloty, to be paid by the station and its insurer. Judge Małgorzata Dzięciołowska said the station’s disorganization had given the paramedic unrestricted access to a dangerous drug, because there were no rules governing how the drug was handled, and that the resuscitation had lacked due care. A doctor sitting beside the patient, she said, might have prevented the killing or started resuscitation sooner. The court raised the award after a psychologist’s report showed that the widow had developed severe depression after her husband’s death and had needed help with daily life for months. "Although six years have passed, she still has not returned to normal," the judge said. TVN24 reported that several similar claims were pending.
The ruling drew a line that civil courts draw often: the institution answered for the conditions it had allowed and for its own medical failure, not for the act the criminal court had attributed to the paramedic. The widow won less than she asked, and half of what she won rested on her depression, not on her husband’s death.
Andrzej N. also became a civil plaintiff. Gazeta Wyborcza reported in June 2010, in an account relayed by the legal portal e-prawnik.pl, that he was serving his life sentence and had sued over the judge’s phrase "agentami ciemności", which he considered a public insult to his personal dignity. He first sought 80,000 zloty and reduced the claim to 3,000 zloty at the hearing. The Łódź Regional Court dismissed the suit, holding that the judge had been entitled to use the term because the crime of which he was convicted was exceptionally reprehensible.
Francisco das Chagas Rodrigues de Brito was a bicycle mechanic on the island of São Luís, in the northern Brazilian state of Maranhão. Arrested in 2004, he confessed to killing boys over more than a decade, in Maranhão and earlier in Altamira, in the state of Pará. The number is 42 in most accounts: 30 in Maranhão and 12 in Pará. Maranhão police attributed 30 deaths of children in their state to him. Juries in Maranhão have since convicted him in trial after trial, one or a few boys at a time, on homicide counts with other charges, and prosecutors reported the sentences adding up to 580 years and 10 months by May 2018. The killings in Pará were never tried against him, and other men had been convicted there before he was identified.
The families' claim was not against Chagas. The boys came from poor families in São Luís, São José de Ribamar and Paço do Lumiar, and before his arrest the families and the groups that worked with them had taken Brazil to the Inter-American Commission on Human Rights, arguing that the police had failed to investigate the deaths of poor children. A 2021 study of the mothers' accounts, in the Revista de Direitos Humanos e Efetividade, describes families living in informal settlements.
The petitions ended in a friendly settlement between Brazil, the state of Maranhão and the two petitioning groups; a 2025 paper for the CONPEDI congress cites the settlement report as number 43 of 2006. Under it, Brazil acknowledged international responsibility at a public ceremony in São Luís. The state promised to reopen the criminal investigations and hold the confessed perpetrator to account, to pay the families a monthly pension of 500 reais for 15 years, to include them in income and housing programs, to place a commemorative plaque, and to train police and set up services for children. Band reported that Maranhão, in its submission to the Commission, acknowledged errors and difficulties in the investigations, citing weaknesses in its security system, the complexity of the crimes, their spread across several towns and technical flaws in some police work. A state law of December 15, 2005, recognized 28 boys as victims for the purposes of the settlement, according to the 2021 study; an MPMA release of 2018 gives the same number.
What the settlement delivered is a mixed record. According to the 2021 study, the families received houses, though the property titles were still pending, and the pension was later made lifelong and raised to one minimum wage. It says a specialized police station and a public defender’s office were opened in Paço do Lumiar and a child protection center in São Luís, while promised schools and prevention programs were never fully delivered, and that the Organization of American States considered the case closed in 2010. The Maranhão prosecutors reported in 2018 that Governor Flávio Dino had sent the legislature a proposal to make the pension lifelong, that houses built for the families were being repaired and their ownership formalized, and that a forensic center for children and adolescents was to be built. Sálvio Dino, a former state secretary, said at that event that parts of the government had first viewed the agreement with suspicion and that the arrest of Chagas and political changes had made it possible.
The settlement is still being monitored. On June 27, 2025, the prosecutors held a public hearing in São Luís on six items of the agreement that had not been carried out in practice, O Imparcial reported. The prosecutors' record lists the gaps: only one property title had been handed over, the inclusion of the families in state income programs had not been shown, and the state forensic institute for children had too few staff, an average wait of 120 days and 277 cases pending. Five state departments sent no one to the hearing. A mother whose four-year-old son was killed in 2003 told the hearing that the agreement had not been fully met and that families needed better support.
Several points stay disputed. The figure of 42 comes from his own confession; the 2025 paper gives 41, with 13 in Altamira. The state recognized 28 boys as victims for the settlement, and the number of deaths proven against him in court is smaller than any of these. The reports also disagree on how many trials he has had. Third parties were arrested and convicted for some of the Maranhão deaths before he was identified, according to the 2025 paper, and prosecutors later asked for the acquittal of two men accused in some of the cases, according to Band.
Set side by side, the nine results are uneven in a way no single legal theory explains. Cleveland paid, but only to the six families whose relatives died after a documented police failure, and it paid the family of Crystal Dozier $2,500. The Heaton family lost its wrongful-death claim on a limitations period and lost its royalties claim when the court voided the statute. The Olson families won at trial and lost on appeal. A widow in Łódź won less than half of what she asked for, from the ambulance station and not from the man who gave the drug. A Korean court awarded 1.3 billion won against a man on death row with no report of payment. Maranhão acknowledged responsibility in a ceremony and was still being asked in 2025 to deliver the property titles.
The outcomes of the Moskowitz suit against the Yonkers police, the nine suits against Rader and the Saldivar families' claims against the hospital were mostly settled, dismissed or not reported, and the record is thin where the money was small. In several cases a rule written for the next family, not this one, was what the litigation left behind: a narrower royalties law in New York, an attachment on a prisoner’s papers in Kansas, hospital and police changes that a reporter was still weighing ten years later. The families had asked for something else.
• July 29, 1976 to July 31, 1977: Six people are killed in New York City in the Berkowitz case; Stacy Moskowitz, 20, is the last.
• August 10, 1977: Berkowitz is arrested in Yonkers.
• 1977: The Moskowitz family files a $10 million suit against the Yonkers police.
• May 8, 1978: Berkowitz pleads guilty to six murders.
• January 1982: Olson pleads guilty to 11 murders; the $100,000 trust becomes public.
• 1984: Families of seven of Olson’s victims sue over the trust.
• March 1986: The British Columbia Court of Appeal reverses the ruling for the families.
• December 10, 1991: The Supreme Court strikes down New York’s "Son of Sam" law.
• April 26, 1994: Heaton relatives sue Craig Price.
• May 5, 1997: Rhode Island Supreme Court decides Bouchard v. Price.
• 1998: Saldivar tells Glendale police of dozens of deaths and is released without charge.
• January 2001: Saldivar is arrested; the Alfaro family says it has hired a lawyer.
• March 12, 2002: Saldivar pleads guilty; Judge Lance Ito sentences him April 17.
• June 27, 2005: Rader pleads guilty; sentenced August 18, with nine civil suits filed by families and Judge Lahey’s attachment on his property a week later.
• 2006: Brazil and Maranhão reach a friendly settlement with the boys' families.
• December 2006: A Łódź district court sets the widow’s award at 38,000 zloty.
• January 2007: Andrzej N. is convicted and sentenced to life.
• November 2007: The appeal court raises the award to 50,000 zloty.
• April 16, 2009: A civil court orders Kang Ho-sun to pay 1.3 billion won; he is sentenced to death April 22.
• July 22, 2011: Sowell is convicted of 11 aggravated murders.
• September 17, 2018: Cleveland agrees to pay $1 million to six families.
• June 27, 2025: Maranhão prosecutors hold a public hearing on unmet terms of the 2006 settlement.