The viral YouTube video, posted by user "BrownsFan4Life" on July 18, shows a man wearing an
"Everyone who has buried a loved one has the right to believe that their final resting place will be treated with respect," Shellenberger said in the statement. "Bringing charges against this individual should act as a deterrent to others and assure the rest of us that no matter who you are, indecencies will not be committed against your final resting place."
Shellenberger's office declined further comment.
Modell died in 2012, and has long been considered a villain among Cleveland sports fans because of his controversial decision to relocate the team in 1996.