Vickie Guerra claims the officers who ordered her son Chris Guerra to cross the busy street are responsible for his son's death, reported TMZ.
Vickie is suing both the police and the driver of the car which hit the photographer.
In her documents, Vickie says that police officers ordered her son to stay away and cross the heavy traffic by gesturing with a gun, after the officers noticed that Guerra was taking pictures of the singer's car.
Vickie said that Chris followed the order and was hit by a car which ran at 40-50mph as the result.
Bieber had released a statement after Guerra's death, hoping a legislation would provide adequate security to celebrities and the photographers themselves.