The family of a woman who was shot and killed by a Border Patrol agent near San Diego has filed a wrongful death claim, saying the agent had a history of misconduct in his previous job.

An attorney for the family of Valeria Alvarado’s filed the claim with the Border Patrol on Friday and gave The Associated Press a copy.

The claim, required before a lawsuit, says 34-year-old agent Justin Tackett was suspended four times for misconduct in about four years as a Imperial County deputy, and quit in 2003 before he could be fired.

The Border Patrol declined comment, and Tackett could not immediately be reached.

Authorities say Alvarado deliberately ran into Tackett with her car on Sept. 28, and he shot her fearing for his life.