Romulus Police Chief Dickerson lawsuit.pdf - MLive.com

More documents

Recommendations

Info

2:13-cv-10771-JAC-MKM Doc # 1 Filed 02/25/13 Pg 14 of 18 Pg ID 1483. On January 9, 2013, at approximately 1630 hours, Plaintiff was transferred fromthe day shift and ordered to work the January 10, 2013 afternoon road patrol shiftstarting at 1430 hours. Plaintiff’s department issued cell phone was alsoimmediately confiscated. The immediate confiscation of his cell phone alsodeviated from the Department’s past practice.84. Plaintiff was also excluded from meetings with Defendants Chief Dickerson andShelby and had his authority undermined by them.85. Since Plaintiff’s refusal to destroy evidence of suspected criminal activity, hisreports of suspected illegal activity to the City of Romulus Police Department andthe Attorney General’s Office and the exercise of his free speech rights Plaintiffhas suffered the adverse employment actions set forth in paragraphs 81-84 above.COUNT I:VIOLATION OF PLAINTIFF’S FIRST AMENDMENT FREE SPEECH RIGHTSPURSUANT TO 42 USC § 198386. Plaintiff re-alleges word for word the allegations set forth in paragraphs 1 through85 above.87. Plaintiff spoke out as a citizen on matters of substantial public concern when hecontacted the Attorney General’s Office to report his suspicion that Defendantswere engaged in a cover-up of an assault by a police officer of a handcuffed,defenseless prisoner and his concern that Defendants intended to destroy materialevidence of such assault.88. Plaintiff also spoke out as a citizen on matters of substantial concern when hereported to the City of Romulus Human Resources Department that he believedthat Defendant Captain Shelby had received pay for time he did not work.
2:13-cv-10771-JAC-MKM Doc # 1 Filed 02/25/13 Pg 15 of 18 Pg ID 1589. Defendants knew of Plaintiff’s protected speech because he told them of it.90. Upon learning of Plaintiff’s protected speech, Defendants retaliated againstPlaintiff when they eliminated his position in the Detective Bureau and deprivedhim of the benefits commensurate with such position, wrongly disciplined himand created a hostile work environment for him because he exercised his FirstAmendment free speech rights on matters of public concern.91. Defendants’ retaliatory actions were intentional and malicious.92. Defendants’ retaliatory actions were of the kind that would likely chill a personfrom exercising their free speech rights guaranteed by the First Amendment.93. As a direct and proximate result of Defendants’ violation of Plaintiff’s FirstAmendment free speech rights, Plaintiff suffered economic damages as set forthabove and non-economic injuries including, but not limited to, lost wages, loss ofprofessional opportunities, emotional distress, anxiety, depression, fear and othercompensable injuries.ACCORDINGLY, Plaintiff asks this Court to enter a judgment in his favor and againstDefendants, jointly and severally, in an amount in excess of the jurisdictional limit of this Court,as well as compensatory, exemplary and punitive damages, attorney fees, costs and interest andall other legal and equitable relief, including injunctive relief to prohibit any further acts ofretaliations and reinstatement to his former position as well as all other relief as provided under42 USC §§1983, 1985 and 1988.COUNT II:VIOLATION OF THE MICHIGAN WHISTLEBLOWER PROTECTION ACT94. Plaintiff re-alleges word for word paragraphs 1 through 93.
Page 1 and 2: 2:13-cv-10771-JAC-MKM Doc # 1 Filed
Page 13: 2:13-cv-10771-JAC-MKM Doc # 1 Filed

Romulus Police Chief Dickerson lawsuit.pdf - MLive.com

Create successful ePaper yourself

Delete template?

Save as template?