SAN JOSE -- The family of a Santa Clara man who was shot and killed by police last year filed a civil complaint and demand for jury trial Tuesday against the Santa Clara Police Department and the city of Santa Clara, alleging wrongful death and civil rights violations.

Eric Kleemeyer, 22, was killed in the early morning hours of Jan. 4, 2005, when police officers Jeff Vaden, Dawn Marines and Craig Middlekauff shot him multiple times following a two-mile car chase through city streets that began when police noticed him driving erratically.

According to the complaint, the officers fired a total of 29 shots, between seven and nine of which hit an unarmed Kleemeyer, after he turned into a driveway next his mother's house in the 700 block of Clara Vista Avenue.

A Santa Clara police spokesman could not be reached for comment this afternoon, but police have maintained that Kleemeyer rammed an officer's vehicle after pulling into the carport.

Kleemeyer's family alleges in the complaint that police profiled Kleemeyer as a troublemaker and used excessive force against him.

Kleemeyer, who before he was shot worked as a supervisor at Costco in Santa Clara and had just been accepted to the management program, had three prior arrests for driving under the influence and had a blood alcohol level above the legal limit at the time of the shooting. He was also driving on a suspended license and under court probation.

On April 8, 2005, a Santa Clara County criminal grand jury cleared the officers of wrongdoing by deciding not to indict them after hearing testimony from 33 witnesses and examining 59 pieces of evidence. They essentially found that the officers, who, according to Santa Clara police, feared for their lives, deemed the use of deadly force necessary to detain Kleemeyer.

On Aug. 30, 2005, the city of Santa Clara rejected the family's notice of claim filed against the city and the Police Department.

In the federal suit, the family requests that a jury determine the amount of damages they allege the department owes them for Kleemeyer's life, loss of income and funeral services.

In addition to the three officers, the complaint also targets Chief of Police Stephen Lodge, who the plaintiffs allege was in part responsible for ensuring the proper training of officers on the use of lethal force.

The plaintiffs, who include Kleemeyer's mother Susan Reardon and brothers Adam and Daniel Kleemeyer, maintain that the officers alleged excessive use of deadly force resulted from improper policies and customs of the police department and the city.